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How Cryptocurrency Affects Current Transnational Anti-Corruption and Related Anti-Money Laundering Enforcement Efforts

American Bar Association Rule of Law Initiative

Miller & Chevalier, in partnership with Forensic Risk Alliance, presented a succinct briefing to the American Bar Association's Rule of Law Initiative highlighting the evolving convergence of anti-corruption enforcement and cryptocurrency. The briefing navigates the complex world of international anti-corruption efforts, starting with the 1977 U.S. Foreign Corrupt Practices Act, and traces the evolution of global anti-corruption initiatives, including a recent resurgence in anti-corruption efforts worldwide supported by revamped legal frameworks and anti-money laundering provisions. With its use of opaque third-party intermediaries and privacy-focused banking systems, cryptocurrency has become a haven for illicit actors. Rather than revising legal frameworks to combat corruption involving cryptocurrency, the authors wrote that the primary hurdle is detecting and recovering ill-gotten gains from cryptocurrency transactions. While cryptocurrency anonymity has been debunked, sophisticated users still exploit the ecosystem for money laundering. This briefing captures the intersection of anti-corruption enforcement and the evolving cryptocurrency landscape.

Miller & Chevalier authors: Daniel Patrick Wendt, Daniel Solomon, James Tillen, and Facundo Galeano

Forensic Risk Alliance authors: Meredith Fitzpatrick and Peter Bott