Financial Integrity Implications of Retail Central Bank Digital Currencies (rCBDCs)

Fintech Notes, November 17, 2025

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Central question: How should the international anti-money laundering and combating the financing of terrorism (AML/CFT) standards be applied in a retail CBDC (rCBDC) setting?
Scope: Identifies main categories and characteristics of rCBDCs that may have financial integrity implications and analyzes the potential impact that various rCBDC features might have on effective implementation of an issuing jurisdiction’s AML/CFT regime.
Objective: Provides guidance to policymakers and competent authorities through important considerations that should precede an rCBDC launch and inform rCBDC designs, and through suggested good practices on the application of AML/CFT measures in an rCBDC context.
Limitation: Due to the novelty of rCBDCs and limited practice, the chapter highlights where current rCBDC designs pose challenges or raise questions with respect to specific aspects of prevailing international standards.

rCBDC features can have material implications for the effective implementation of AML/CFT regimes.
There are distinct categories and characteristics of rCBDCs relevant to financial integrity that warrant focused analysis prior to launch.
Current rCBDC designs may pose challenges or raise questions with respect to specific aspects of prevailing international AML/CFT standards.

Policymakers and competent authorities should consider a set of important issues that should precede an rCBDC launch and inform rCBDC designs.
Suggested good practices are provided for the application of AML/CFT measures in an rCBDC context.

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