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Anti-Money Laundering: The legal and enforcement response to Cryptoassets in the United Kingdom

Chen, A (2021). Anti-Money Laundering: The legal and enforcement response to Cryptoassets in the United Kingdom. (Unpublished Doctoral thesis, City, University of London)


There is a virtual battle incubating at the moment concerning the future of cryptoassets and the stability of the global financial system. Accordingly, crypto money laundering is one of the most significant economic problems of the 21st century, with substantial social and geopolitical implications. It enables criminals to take advantage of this global technology. This poses a huge threat to national sovereignty since there is a potential for massive movements of illicit assets, which could shift national currencies and overthrow the global financial system. It is submitted that crypto money laundering is not a “victimless crime”. The individual or the innocent third parties or the country from which the cryptoasset is stolen are, by definition, the victims, whilst the cryptoasset is used in the host country to support the criminal’s lifestyle or other illicit activities such as drug importation, human trafficking, child sexual exploitation, prostitution, terrorism, tax evasion and fraud.

The purpose of this research is to provide a comprehensive theoretical framework that can be applied to the implementation of the United Kingdom’s (“UK”) Anti-Money Laundering (“AML”) rules within the crypto sector. This research concludes that imposing conventional AML rules and assuming that the crypto community is an arm of law enforcement is counterproductive and could provoke programmers to develop new crypto protocols that are more autonomous, and as a result, are harder to detect and enforce. This thesis examines the crypto money laundering problem both generally and in the UK in particular. More specifically, this research sets out the primary forms and types of crypto money laundering schemes and the devices used; and the crypto AML framework that can be applied to the enforcement of the AML regulations in the UK. Nonetheless, at the start of this research, it is important to note that the crypto sector in the UK as well as abroad was essentially unregulated. For that reason, this research extends beyond existing works that have offered insight into the broad workings of the crypto sector and its legal implications. In short, this thesis offers originality in providing a thorough overview of the crypto laws, regulations, and the relevant case law pertaining to cryptoassets in the UK.

Publication Type: Thesis (Doctoral)
Subjects: K Law > K Law (General)
Departments: Doctoral Theses
The City Law School
[thumbnail of PhD 2021 Final Draft (v3).pdf] Text - Accepted Version
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