It also involves an assessment of the effectiveness of a country’s AML/CFT systems with a view to ascertaining whether the country’s “financial systems and the broader economy are protected from the threats of money laundering and the financing of terrorism, thereby strengthening financial sector integrity and contributing to safety and security.” I must say that even before the publication of the Mauritius MER in September 2018, Mauritius had already started bringing legislative amendments to various pieces of legislation—including the Financial Intelligence and Anti-Money Laundering Act and the Banking Laws—to address the deficiencies.
Not only is it not clear whether comparable protections will be in place with Libra, or what recourse consumers will have, but it is not even clear how much price risk consumers will face since they do not appear to have rights to the stablecoin’s underlying assets. Anti-money laundering (AML), counterterrorist financing (CTF), and know-yourcustomer (KYC) requirements are significant concerns.