Anti-Money Laundering Compliance without the Law: Can Blockchain Alone Do the Job?

The LLM thesis explores whether blockchain technologies, through embedded economic incentives and social norms, can achieve regulatory equivalence with global anti-money laundering (AML) standards without relying on traditional legal enforcement. It critically examines the limitations of existing AML frameworks—particularly the FATF regime—and evaluates emerging alternatives enabled by distributed ledger technology. Drawing on Lawrence Lessig’s four modalities of regulation (law, architecture, market, and social norms), the thesis proposes a model of decentralized compliance by design. Through a simulated prototype and theoretical analysis, it assesses blockchain’s potential to align with core AML objectives while addressing legitimacy, accountability, and effectiveness concerns.