ANALYSIS: Facebook Creating a Global SRO, Not a New AML Paradigm

In Facebook Hints at New AML/CFT Paradigm of Libra, I noted indications from Facebook’s public statements that it intended to create a new paradigm for anti-money laundering/combating the financing of terrorism (AML/CFT) and sanctions compliance for the Libra cryptocurrency and its Calibra subsidiary. Testimony before Congress by Calibra head David Marcus stated otherwise, but it also raised further issues that Facebook and the governing body for Libra, the Libra Association, should address.

One is that a self-regulatory organization (SRO) under U.S. authority may be necessary to enforce U.S. AML/CFT and sanctions requirements. Another is that the structure of the ...