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Policymakers who recently gathered in Washington, DC for the Spring Meetings of the IMF and World Bank highlighted the need for global progress on crypto-asset regulations. G20 finance ministers and central bank governors included global regulatory development on their list of priorities, as did the International Monetary and Financial Committee. Crypto regulations were discussed throughout the meetings, including in a session focused on the future of crypto-assets. 

The meetings made two things clear. First, the need for robust, globally coordinated crypto regulations is evident. And, second, policymakers face substantial challenges achieving that goal. Following on discussions held at the Spring Meetings, we used our Cryptocurrency Regulation Tracker to identify several of the major policy dilemmas facing policymakers and regulators.

Consumer protection rules are lagging behind other forms of regulation

Consumers participating in crypto-markets are exposed to considerable risk. Theft is increasingly common. Volatility, often fueled by speculation, is a defining feature of crypto markets. And misinformation and deceptive advertising make informed investing difficult. Despite the risks that consumers face, we found that only one-third of the countries studied had rules in place to protect consumers. Other countries may have legal protections that extend to crypto market participants, though the law is often untested or ambiguous. 

Fortunately, countries that do provide consumer protections are demonstrating a diversity of approaches. India, France, and others have helped consumers make better informed decisions by requiring that advertisers disclose risks associated with crypto-investing. In South Korea, crypto-asset service providers, such as exchanges and wallets, are required to obtain an information security certificate from the Korea Internet and Security Agency, decreasing the likelihood of theft. And many countries, including Australia and Japan, have rules in place to prevent and penalize deceptive conduct and fraud. While these examples demonstrate steps some countries are taking, the safety of crypto markets requires that policymakers redouble efforts to enact consumer protection regulations. 

Regulations to prevent another FTX-style collapse are a long way off

Centralized exchanges like FTX and Binance play a critical role in the crypto ecosystem. By allowing individuals to participate in “off-chain” transactions involving crypto-assets, they dramatically reduce the barriers to entry posed by more technically complex “on-chain” transactions. The substantial gains made in market capitalization and adoption would be unlikely absent centralized exchanges.

But centralized exchanges that perform multiple functions pose risks that regulators must address. Many exchanges are not sufficiently transparent about their operations, finances, or governance, leaving investors in the dark on key matters. Some companies are taking steps to address this problem by disclosing “proof of reserves”, a transparent accounting of a company’s assets and liabilities. While more than half of the countries in the tracker have licensing or registration rules, these do not typically include disclosure requirements. 

Centralized exchanges may misuse customer funds. Unlike in traditional finance, where customer funds are subject to certain protections, centralized exchanges typically face either nonexistent or less stringent regulations. The Cryptocurrency Regulation Tracker includes only two examples of a specific requirement that crypto companies segregate customer funds, placing a firewall between customer money and proprietary trading. The European Union’s Markets in Crypto-assets framework, which became law last month, has specific rules that wall off customer funds from proprietary trading. The US Securities and Exchange Commission is considering a similar move.

In some cases, global exchanges may fall outside national or regulatory borders. This leaves policymakers incapable of performing basic oversight, as was the case with FTX in the United States. Policymakers have yet to achieve coordinated global action and are continually confounded by crypto companies that evade—intentionally or otherwise—traditional regulatory definitions. Bringing crypto activity within the regulatory perimeter remains a key challenge. 

Our research shows that more needs to be done to prevent the next FTX. Fortunately, that debacle has propelled policymakers and regulators to fill this perilous gap. 

Low- and middle-income countries lag advanced economies in regulatory development, but not in rates of crypto adoption 

The Cryptocurrency Regulation Tracker considers four categories of regulation: taxation, anti-money laundering, consumer protection, and licensing. Of the advanced economies we reviewed, 64% have regulations in each of these categories. Only 11% of the middle income countries have rules in all four categories, and none of the low-income countries do. These findings identify a clear trend: low- and middle-income countries are adopting crypto-regulations more slowly. 

Limited regulatory development, however, has not slowed adoption. In fact, our research found virtually no relationship between crypto-regulation and adoption rates. Six of the ten countries with the highest rates of adoption (according to Chainalysis) have in place either a partial or general ban on crypto-assets. It is worrying that some low- and middle-income countries, who may be vulnerable to crypto-induced shocks, have active crypto-markets with few regulations. 

The widening regulatory gap between countries is a critical challenge for international financial institutions and standard-setting bodies. Patchwork, uncoordinated global regulations present opportunities for regulatory arbitrage. Companies may consider issuing new crypto-assets from jurisdictions with few or no guidelines and selling those assets to investors around the world—even in countries where such sales are technically illegal. In the short-term, such activity could hurt consumers and facilitate illicit activity. In the longer-term, it could present a meaningful financial stability risk. 

In recent remarks at the Atlantic Council, World Bank President David Malpass urged regulators to make global standards “accessible” to countries with lower state capacity. Indeed, the International Monetary Fund, Financial Stability Board, and others must do the tough work of both establishing global standards and providing technical assistance where needed. 

Regulators around the world face multiple challenges. They must protect customers and put in place safeguards to prevent the next FTX-style collapse, all while coordinating across diverse jurisdictions. And they have a long way still to go.

To keep up with this rapidly evolving topic, follow the GeoEconomics Center’s Cryptocurrency Regulation Tracker.

Cryptocurrency Regulation Tracker

Cryptocurrencies may significantly alter financial structures and transform the next generation of money and payments. Governments around the world are looking to create regulations to prevent the harms caused by cryptocurrencies while encouraging the innovative capabilities of cryptocurrencies. We analyze how 45 countries have regulated cryptocurrency in their jurisdictions.

Greg Brownstein is a Bretton Woods 2.0 Fellow and research consultant with the GeoEconomics Center.

At the intersection of economics, finance, and foreign policy, the GeoEconomics Center is a translation hub with the goal of helping shape a better global economic future.

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SWIFT was founded in 1973 with 239 original members and over the years has grown to incorporate 11,696 banks sending more than 44 million messages around the world every day. But the core idea has stayed the same: Banks need a uniform and standard way to communicate with each other about transactions, and SWIFT is the answer. Every member gets a unique code—with details about country, location, and even bank branch. When a bank wants to transfer money to another bank, it simply enters the code through the SWIFT network, tells the other bank the amount, and then the actual money changes hands.

But here’s the rub—SWIFT is only a messaging service. It does not provide bank accounts or hold funds for banks in any capacity. The banks actually transfer the funds through a different entity. In order to send money across borders, individuals usually need to use a trusted network of banks, which settle transactions through a series of mutually held accounts. Think of SWIFT like a very elite Gmail, but once you tell your friend you want money, they have to switch over to Venmo to actually pay you. That’s why ‘banning’ a bank from SWIFT does not mean that the institution cannot get money from other banks. It just makes it more complicated and costly to do so.

In 2020, global businesses transferred approximately $23.5 trillion across borders—and it cost them over $120 billion to process the transactions. That’s like paying a tax the size of Morocco’s entire gross domestic product. Plus, these payments often take days to settle. It’s a lot of money for slow service, and that cost gets passed on to consumers.

How banks move money around the world

Interactive graphic by Sophia Busch, Alisha Chhangani, and Nancy Messieh.

What if SWIFT helped build something faster and cheaper? What if you could create a network that could combine both messaging and settlement and become a one-stop shop for international payments? That’s what China has been working on since 2016 with its Cross-Border Interbank Payments System, or CIPS, and most recently with its wholesale central bank digital currency (CBDC) experiment, the mBridge Project.

Both the CIPS and mBridge projects can be utilized for cross-border wholesale (meaning bank-to-bank) purposes. Importantly, the mBridge project is a cross-border CBDC initiative. The idea for both is that large sums of money could be sent between banks internationally, without using SWIFT for messaging or the dollar-based payments clearance hub, the Clearing House Interbank Payments System (CHIPS), for settlement. Already Hong Kong, the United Arab Emirates, and Thailand have partnered with the People’s Bank of China on the mBridge project, and in October 2022, they settled twenty-two million dollars across borders. This was the first successful test of cross-border bank-to-bank digital currency involving real money. As Atlantic Council research on CBDCs has shown, mBridge is just one of more than a dozen wholesale CBDC projects globally, many of which accelerated after Russia’s invasion of Ukraine and the Group of Seven (G7) sanctions response. Over time, if these systems are successful, they could create alternative financial transfer networks and provide a useful conduit for countries aiming to avoid the bite of Western sanctions.

SWIFT is not sitting idly by. The technology teams at its headquarters outside of Brussels are piloting their own cross-border CBDC system, partnering with major private banks and central banks including the Banque de France and the German Bundesbank. They are also experimenting with new, faster types of global transfers between banks. But transforming SWIFT from a messaging system to a new cross-border settlement system that can handle all types of assets (both traditional and digital) is going to take years and millions of dollars. Where to start?

The first step is for the board that governs SWIFT to give it the green light to innovate. As SWIFT members are eager to point out, they are a “private cooperative” and answer to their shareholders. But it’s not so simple. SWIFT is overseen by the National Bank of Belgium and the European Central Bank alongside the central banks of Italy, the Netherlands, Switzerland, Sweden, Canada, Japan, the United Kingdom, and the United States.

These countries have responsibility for providing SWIFT with strategic guidance and helping direct its technology planning. But so far no central bank has publicly come out in support of a major modernization effort. That’s a mistake.

It is understandable for Western central banks to feel sanguine about SWIFT’s current dominance. After all, the vast majority of global transactions currently touch SWIFT at some point. But look closer and you can see the ground shifting. Last month, Bangladesh agreed to pay a Russian company that is helping the country build a nuclear power plant in Rooppur. What’s interesting is how it is paid. Since Russian banks are largely banned from SWIFT, Bangladesh used a bank account at a Chinese bank that transferred yuan to Russia through CIPS. 

Bangladesh is not alone. Transaction volume on CIPS has more than doubled since 2020, and the number of direct and indirect participants in its network has also increased. More and more of these transactions will develop outside of SWIFT, and governments will understand less and less of what’s happening. Part of the motivation is geopolitical, given the way the dollar and euro are being weaponized against Russia. But a large part of it is simply technological: There are faster and cheaper ways to exchange money between countries, and if SWIFT does not figure out how to do it, someone else will.

Even if it is somewhat late to the game, SWIFT has a massive incumbent advantage. With its network of more than eleven thousand banks, SWIFT can build on a system that the world already relies upon instead of creating something new from scratch. China and Russia have to build a rival from the ground up and that takes time. SWIFT’s network is familiar and trusted: Think of it like an individual customer—why switch to a whole new bank if my current one is going to offer all the same features? If there are disputes, or mistakes, they can be settled in European courts.

Plus, SWIFT has something no one else can offer. It is the gateway to interacting with banks in New York, London, Tokyo, Paris, and Frankfurt. The argument for the new SWIFT is simple: If you want to be interoperable with the dollar, the euro, the pound, and the yen—which together are used in more than 85 percent of global transactions—this is the place to do it. If the G7 works in tandem to set technical and regulatory rules of the road for this new network it will, over time, become the de facto global standard, just like the original SWIFT of the 1970s.

The new SWIFT will have to do multiple things at once: communicate and settle between thousands of banks all over the world, find a way to transfer traditional commercial bank money as well as money on a blockchain, and do it all before a network of regional systems springs up to challenge its effectiveness and increase the fragmentation of money and finance.

Doing this right requires a massive investment in innovation from the Western banks that guide SWIFT. The United States is going to have to spend money and bring its own technological solutions to the table. There are major risks involved with faster settlements, including the need for adequate liquidity to complete the transaction, and it will require new regulations to ensure the system is trusted and secure. The recent Silicon Valley Bank crisis, accelerated by a social media–fueled bank run, should provide a lesson on the perils of moving money quickly in the digital age. And while SWIFT rebuilds, it will need to maintain its current operations. Remodeling a house while living in it is a tricky proposition.

But the bigger risk is doing nothing. This year SWIFT will turn fifty. For decades, SWIFT was the pace setter in the race for the future of money. Its technology connected the world’s financial institutions and helped ensure a system with Western protections on rule of law, privacy, and anti-money laundering provisions became the global standard. But all that is changing. If the United States and its allies want to create and promote the technological standard for the decade ahead while ensuring the effectiveness of sanctions, it’s time to start moving, well, more swiftly.

Josh Lipsky is the senior director of the Atlantic Council’s GeoEconomics Center and a former IMF advisor.

Ananya Kumar is the associate director of digital currencies at the Atlantic Council’s GeoEconomics Center.

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In January 2023, a South Korean intelligence service and a team of US private investigators conducted an operation to interdict $100 million worth of stolen cryptocurrency before its hackers could successfully convert the haul into fiat currency. The operation was the culmination of a roughly seven-month hunt to trace and retrieve the funds, stolen in June 2022 from a US-based cryptocurrency company, Harmony. The Federal Bureau of Investigation (FBI) attributed the theft to a team of North Korean state-linked hackers—one in a string of massive cryptocurrency hauls aimed at funding the hermit kingdom’s illicit nuclear and missile programs. According to blockchain analysis firm Chainalysis, North Korean hackers stole roughly $1.7 billion worth of cryptocurrency in 2022—a large percentage of the approximately $3.8 billion stolen globally last year.

North Korea’s operations have brought attention to the risks surrounding cryptocurrencies and how state and non-state groups can leverage hacking operations against cryptocurrency wallets and exchanges to further their geopolitical objectives. We brought together a group of experts to explore cybersecurity implications of cryptocurrencies, and how the United States and its allies should approach this challenge.

#1 What are the cybersecurity risks of decentralized finance (DeFi) and cryptocurrencies? What are the cybersecurity risks to cryptocurrencies?

Eitan Danon, senior cybercrimes investigator, Chainalysis: 

Disclaimer: Any views and opinions expressed are the author’s alone and do not reflect the official position of Chainalysis. 

“DeFi is one of the cryptocurrency ecosystem’s fastest-growing areas, and DeFi protocols accounted for 82.1 percent of all cryptocurrency stolen (totaling $3.1 billion) by hackers in 2022. One important way to mitigate against this trend is for protocols to undergo code audits for smart contracts. This would prevent hackers from exploiting vulnerabilities in protocols’ underlying code, especially for cross-chain bridges, a popular target for hackers that allows users to move funds across blockchains. As far as the risk to cryptocurrencies, the decentralized nature of cryptocurrencies increases their security by making it extraordinarily difficult for a hostile actor to take control of permissionless, public blockchains. Transactions associated with illicit activity continue to represent a minute portion (0.24 percent) of the total crypto[currency] market. On a fundamental level, cryptocurrency is a technology—like data encryption, generative artificial intelligence, and advanced biometrics—and thus a double-edged sword.” 

Kimberly Donovan director, Economic Statecraft Initiative, and Ananya Kumar, associate director of digital currencies, GeoEconomics Center, Atlantic Council: 

“We encourage policymakers to think about cybersecurity vulnerabilities of crypto-assets and services in two ways. The first factor is the threat of cyberattacks for issuers, exchanges, custodians, or wherever user assets are pooled and stored. Major cryptocurrency exchanges like Binance and FTX have had serious security breaches, which has led to millions of dollars being stolen. The second factor to consider is the use of crypto-assets and crypto-services in money-laundering. Often, attackers use cryptocurrencies to receive payments due to the ability to hide or obfuscate financial trails, often seen in the case of ransomware attacks. Certain kinds of crypto-services such as DeFi mixers and aggregators allow for a greater degree of anonymity to launder money for criminals, who are interested in hiding money and moving it quickly across borders.” 

Giulia Fanti, assistant professor of electrical and computer engineering, Carnegie Mellon University: 

“The primary cybersecurity risks (and benefits) posed by DeFi and cryptocurrencies are related to lack of centralized control, which is inherent to blockchain technology and the philosophy underlying it. Without centralized control, it is very difficult to control how these technologies are used, including for nefarious purposes. Ransomware, for example, enables the flow of money to cybercriminial organizations. The primary cybersecurity risks to cryptocurrencies on the other hand can occur at many levels. Cryptocurrencies are built on various layers of technology, ranging from an underlying peer-to-peer network to a distributed consensus mechanism to the applications that run atop the blockchain. Attacks on cryptocurrencies can happen at any of these layers. The most widely documented attacks—and those with the most significant financial repercussions—are happening at the application layer, usually exploiting vulnerabilities in smart contract code (or in some cases, private code supporting cryptocurrency wallets) to steal funds.” 

Zara Perumal, chief technology officer, Overwatch Data: 

“Decentralized means no one person or institution is in control. It also means that no one person can easily step in to enforce. In cases like Glupteba, fraudulent servers or data listed on a blockchain can be hard to take down in comparison to cloud hosted servers where companies can intervene. Cybersecurity risks to cryptocurrencies include endpoint risk, since there is not a centralized party to handle returning accounts as the standard ways of credential theft is a risk to cryptocurrency users. There is a bigger risk in cases like crypto[currency] lending, where one wallet or owner holds a lot of keys and is a large target. In 2022, there were numerous high-profile protocol attacks, including the Wormhole, Ronin, and BitMart attacks. These attacks highlight the risks associated with fundamental protocol vulnerabilities via blockchain, smart contracts or user interface.”

#2 What organizations are most active and capable of cryptocurrency hacking and what, if any, geopolitical impact does this enable for them?

Danon: “North Korea- and Russia-based actors remain on the forefront of crypto[currency] crime. North Korea-linked hackers, such as those in the Lazarus Group cybercrime syndicate, stole an estimated $1.7 billion in 2022 in crypto[currency] hacks that the United Nations and others ­­have assessed the cash-strapped regime uses to fund its weapons of mass destruction and ballistic missiles programs. Press reporting about Federation Tower East—a skyscraper in Moscow’s financial district housing more than a dozen companies that convert crypto[currency] to cash—has highlighted links between some of these companies to money laundering associated with the ransomware industry. Last year’s designations of Russia-based cryptocurrency exchanges Bitzlato and Garantex for laundering hundreds of millions of dollars’ worth of crypto[currency] for Russia-based darknet markets and ransomware actors cast the magnitude of this problem into starker relief and shed light on a diverse constellation of cybercriminals. Although many pundits have correctly noted that Russia cannot ‘flip a switch’ and run its G20 economy on the blockchain, crypto[currency] can enable heavily sanctioned countries, such as Russia, North Korea, and others, to project power abroad while generating sorely needed revenue.” 

Donovan and Kumar: “We see actors from North Korea, Iran, and Russia using both kinds of cybersecurity threats described above to gain access to money and move it around without compliance. Geopolitical implications include sanctioned state actors or state-sponsored actors using the technology to generate revenue and evade sanctions. Hacking and cyber vulnerabilities are not specific to the crypto-industry and exist across digital infrastructures, specifically payments architecture. These threats can lead to national security implications for the private and public entities accessing or relying on this architecture.” 

Perumal: “Generally, there are state-sponsored hacking groups that are targeting cryptocurrencies for financial gain, but also those like the Lazarus Group that are disrupting the cryptocurrency industry. Next, criminal hacking groups may both use cryptocurrency to receive ransom payments or also attack on chain protocols. These groups may or may not be associated with a government or political agenda. Many actors are purely financially motivated, while other government actors may hack to attack adversaries without escalating to kinetic impact.”

#3 How are developments in technology shifting the cryptocurrency hacking landscape?

Danon: “The continued maturation of the blockchain analytics sector has made it harder for hackers and other illicit actors to move their ill-gotten funds undetected. The ability to visualize complex crypto[currency]-based money laundering networks, including across blockchains and smart contract transactions, has been invaluable in enabling financial institutions and crypto[currency] businesses to comply with anti-money laundering and know-your-customer requirements, and empowering governments to investigate suspicious activity. In some instances, hackers have chosen to let stolen funds lie dormant in personal wallets, as sleuths on crypto[currency] Twitter and in industry forums publicly track high-profile hacks and share addresses in real-time, complicating efforts to off-ramp stolen funds. In other instances, this has led some actors to question whether this transparency risks unnecessary scrutiny from authorities. For example, in late April, Hamas’s military wing, the Izz al-Din al-Qassam Brigades, publicly announced that it was ending its longstanding cryptocurrency donation program, citing successful government efforts to identify and prosecute donors.” 

Donovan and Kumar: “Industry is responding and innovating in this space to develop technology to protect and/or trace cyber threats and cryptocurrency hacks. We are also seeing the law enforcement, regulatory, and other government communities develop the capability and expertise to investigate these types of cybercrimes. These communities are taking steps to make public the information gathered from their investigations, which further informs the private sector to safeguard against cyber operations as well as technology innovations to secure this space.” 

Fanti: “They are not really. For the most part, hacks on cryptocurrencies are not increasing in frequency because of sophisticated new hacking techniques, but rather because of relatively mundane vulnerabilities in smart contracts. There has been some research on using cutting-edge tools such as deep reinforcement learning to try to gain funds from smart contracts and other users, particularly in the context of DeFi. However, it is unclear to what extent DeFi users are using such tools; on-chain records do not allow observers to definitively conclude whether such activity is happening.” 

Perumal: “As the rate of ransomware attacks rises, cryptocurrency is more often used as a mechanism to pay ransoms. For both that and stolen cryptocurrency, defenders aim to track actors across the blockchain and threat actors increase their usage mixers and microtransactions to hide their tracks. A second trend is crypto-jacking and using cloud computing from small to large services to fund mining. The last development is not new. Sadly, phishing and social engineering for crypto[currency] logins is still a pervasive threat and there is no technical solution to easily address human error.”

More from the Cyber Statecraft Initiative:

Countering ransomware: Lessons from aircraft hijacking

Untangling the Russian web: Spies, proxies, and spectrums of Russian cyber behavior

Loose cobras: DPRK regime succession and uncertain control over offensive cyber capabilities

#4 What has been the approach of the United States and allied governments toward securing this space? How should they be approaching it?

Danon: “The US approach toward securing the space has centered on law enforcement actions, including asset seizures and takedowns with partners of darknet markets, such as Hydra Market and Genesis Market. Sanctions in the crypto[currency] space, which have dramatically accelerated since Russia’s invasion of Ukraine last February, have generated awareness about crypto[currency] based money laundering. However, as is the case across a range of national security problems, the United States has at times over relied on sanctions, which are unlikely to change actors’ behavior in the absence of a comprehensive strategy. The United States and other governments committed to AML should continue to use available tools and data offered by companies like Chainalysis to disrupt and deter bad actors from abusing the international financial system through the blockchain. Given the blockchain’s borderless and unclassified nature, the United States should also pursue robust collaboration with other jurisdictions and in multilateral institutions.” 

Donovan and Kumar: “The United States and its allies are actively involved in this space to prevent regulatory arbitrage and increase information sharing on cyber risks and threats. They have also increased communication with the public and private sectors to make them aware of cyber risks and threats, and are making information available to the public and industry to protect consumers against cybercrime. Government agencies and allies should continue to approach this issue by increasing public awareness of the threats and enabling industry innovation to protect against them.” 

Fanti: “One area that I think needs more attention from a consumer protection standpoint is smart contract security. For example, there could be more baseline requirements and transparency in the smart contract ecosystem about the practices used to develop and audit smart contracts. Users currently have no standardized way to evaluate whether a smart contract was developed using secure software development practices or tested prior to deployment. Standards bodies could help set up baseline requirements, and marketplaces could be required to report such details. While such practices cannot guarantee that a smart contract is safe, they could help reduce the prevalence of some of the most common vulnerabilities.” 

Perumal: “Two recent developments from the US government are the White House cybersecurity strategy and the Cybersecurity and Infrastructure Security Agency’s (CISA) move to ‘secure by default.’ They both emphasize cooperation with the private sector to move security of this ecosystem to cloud providers. While the system is inherently decentralized, if mining or credential theft is happening on major technology platforms, these platforms have an opportunity to mitigate risk. The White House emphasized better tracing of transactions to “trace and interdict ransomware payments,” and CISA emphasizes designing software and crypto[currency] systems to be secure by default so smaller actors and users bear less of the defensive burden. At a high level, I like that this strategy moves protections to large technology players that can defend against state actors. I also like the focus on flexible frameworks that prioritize economics (e.g., cyber liability) to set the goal, but letting the market be flexible on the solution—as opposed to a prescriptive regulatory approach that cannot adapt to new technologies. In some of these cases, I think cost reduction may be a better lever than liability, which promotes fear on a balance sheet, however, I think the push toward financially motivated goals and flexible solutions is the right direction.”

#5 Has the balance of the threats between non-state vs. state actors against cryptocurrencies changed in the last five years? Should we be worried about the same entities as in 2018?

Danon: “Conventional categories of crypto[currency]-related crime, such as fraud shops, darknet markets, and child abuse material, are on the decline. Similarly, the threat from non-state actors, such as terrorist groups, remains extremely low relative to nation states, with actors such as North Korea and Russia continuing to leverage their technical sophistication to acquire and move cryptocurrency. With great power competition now dominating the policy agenda across many capitals, analysts should not overlook other ways in which states are exercising economic statecraft in the digital realm. For example, despite its crypto[currency] ban, China’s promotion of its permissioned, private blockchain, the Blockchain-based Service Network, and its central bank digital currency, the ‘digital yuan,’ deserve sustained research and analysis. Against the backdrop of China’s rise and the fallout from the war on Ukraine, it will also be instructive to monitor the efforts of Iran, Russia, and others to support non-dollar-pegged stablecoins and other initiatives aimed at eroding the dollar’s role as the international reserve currency.” 

Donovan and Kumar: “More is publicly known now on the range of actors in this space than ever. Agencies such as CISA, FBI, and the Departments of Justice and the Treasury and others have made information available and provided a wide array of resources for people to get help or learn—such as stopransomware.gov. Private blockchain analytics firms have also enabled tracing and forensics, which in partnership with enforcement can prevent and punish cybercrime in the crypto[currency] space. Both the knowledge about ransomware and awareness of ransomware attacks have increased since 2018. As the popularity of Ransomware as a Service rises, both state and non-state actors can cause destruction. We should continue to be worried about cybercrime in general and remain agnostic of the actors.” 

Perumal: “State actors continue to get more involved in this space. As cryptocurrencies and some digital currencies based on the blockchain become more mainstream, attacking it allows a more targeted geopolitical impact. In addition to attacks by governments (like Lazarus Group), a big recent development was China’s ban on cryptocurrency, which moved mining power from China to other parts of the world, especially the United States and Russia. This changed attack patterns and targets. At a high level, we should be worried about both financially-motivated and government-backed groups, but as the crypto[currency] market grows so does the sophistication of attacks and attackers.”

Simon Handler is a fellow at the Atlantic Council’s Cyber Statecraft Initiative within the Digital Forensic Research Lab (DFRLab). He is also the editor-in-chief of The 5×5, a series on trends and themes in cyber policy. Follow him on Twitter @SimonPHandler.

The Atlantic Council’s Cyber Statecraft Initiative, under the Digital Forensic Research Lab (DFRLab), works at the nexus of geopolitics and cybersecurity to craft strategies to help shape the conduct of statecraft and to better inform and secure users of technology.

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Domestic ambitions 

Even with its persistent low adoption rates, the e-CNY is by far the largest CBDC pilot in the world by both the amount of currency in circulation—13.61 billion RMB—and the number of users—260 million wallets. As the pilot regions have expanded to 25 cities, so have the real-world use-cases tested through the pilots. From the start, the PBOC’s objective within its borders has been to not just to compete in China’s domestic payments landscape, which is dominated by two “private” players—AliPay and TencentPay/WePay—but to expand the universe of economic activities that are included the state-enabled payments network. So far, common use-cases being tested include public transportation, public health checkpoints including COVID test centers, integrated identification cards to receive and pay utilities such as retirement benefits and school tuition payments, as well as tax payments and refunds. The pilots have also begun testing technical and programmability functions like smart contracts for B2B and B2C functions, e-commerce and credit provision. Some of these projects are described in the table below..

These domestic test cases are likely to expand this year and cover a broader range of activities and regions. Already, the PBOC is looking to reach the margins of society: e-CNY is being tested amongst elderly populations and in broader rural connectivity schemes initiated to improve digitization. It is also aiming to reach AliPay and TencentPay/WePay customers through integrating their wallet and e-commerce functions for e-CNY distribution. Over the last few years, the PBOC, like the broader Chinese state apparatus, has displayed a tendency toward centralizing regulatory authority when it comes to the two sectors at the intersection of CBDCs —finance and technology. The universe of expanded economic networks enabled by the e-CNY has rightly created concerns regarding the centralization of authority by the PBOC, and the resulting impacts on freedom of choice and from state surveillance for its users. The expanded network of use cases across applications that would collect data on personal identification, health information, and consumption habits and behavior should also raise concerns around the vulnerability of such data to cyber threats domestically and abroad. 

Recent developments on regulation

Interestingly, on the regulatory side, at the National People’s Congress in early March, there were a few changes announced to China’s financial regulators. The PBOC has lost its authority over financial holding companies and financial consumer protection regulation to a new regulator, the State Administration of Financial Supervision, which will also oversee banking and insurance regulation. The PBOC is also opening up 31 new provincial-level branches signaling deeper coordination between the PBOC and provincial level authorities. This reshuffle in authority signals further centralization of power under the party apparatus. Unlike other central banks, the PBOC is not fully independent, and requires the State Council to sign off on decisions relating to money supply and interest rates, and the State Council has been tracking PBOC’s research into e-CNY since approving the initial plan in 2016. 

From a monetary policy perspective, the e-CNY infrastructure could be a handy tool in the hands of the PBOC, with which it can increase or decrease money supply. As China devises a strategy to stimulate consumer spending this year, there is an opportunity to do so by using and expanding the e-CNY network. China has already increased bank’s short term liquidity by $118 billion and long term liquidity by $72 billion through reducing reserve ratio requirements this year.   

PBOC’s ambition for an all-encompassing domestic network of e-CNY infrastructure raises questions about the state’s ability and reach in controlling citizens’ activities. The pilots test real-world scenarios for CBDC use cases, and while adoption has been low, the broad range of applications suggest that testing, not adoption, is the priority for now.

e-CNY around the world

Use of the word “e-CNY” commonly refers to this domestic, retail payments infrastructure. However, much of the discussion in Washington references the cross-border, wholesale capabilities that the PBOC has been testing publicly for a while now. The PBOC participates in a joint experiment with the Hong Kong Monetary Authority, the Bank of Thailand, the Central Bank of the UAE and the Bank for International Settlements named Project mBridge, the purpose of which is to create a common infrastructure across borders to facilitate real-time and cheap transaction settlement. Last October, the project successfully conducted 164 transactions in collaboration with 20 banks across the 4 countries, settling a total of $22 million. Instead of relying on correspondent banking networks, banks were able to link with their foreign counterparts directly to conduct payments, FX settlements, redemptions and issuance across e-HKD, e-AED, e-THB and e-CNY. Interestingly, almost half of all transactions were in e-CNY, which amounted to approximately $1,705,453 issued, $3,410,906 used in payments and FX settlements and $6,811,812 redeemed. Both issuance and redemption transactions were highest in e-CNY, and as stated by the BIS, it was likely because of the automatic integration of the retail e-CNY system and the higher share of RMB in regional trade settlements. 

Analysts have characterized wholesale cross-border arrangements like the mBridge as an effort towards de-dollarization and internationalization of the RMB. The e-CNY, much like its physical counterpart, faces the same liquidity constraints due to capital controls on off-shore transactions and holdings. This was reflected in the mBridge experiment, as one of the main feedback from participants was the need for greater liquidity from FX market makers and other liquidity providers to improve the FX transaction capabilities of the platform. Additionally, even if e-CNY were to become freely traded in the future, it could lead to significant appreciation of RMB and balance of payments issues for the PBOC. This is likely not a desirable outcome for the PBOC, which is why currency arrangements like the mBridge can only have a limited impact on the role of the dollar.

If winning the currency competition is an unlikely short-term objective of the PBOC, what has raised national security concerns regarding the e-CNY? China has long used the rhetoric of international cooperation and “do no harm” principles in its cross-border CBDC engagements. However, these cross-border experiments require months of preparation and coordination between central and commercial banks to ensure that regulatory and jurisdictional requirements are aligned. They highlight the need for legal pathways and standards for data sharing, privacy, and risk frameworks between heretofore unsynchronized jurisdictions. Similarly, experiments rely on technological prototypes that interact with existing domestic e-CNY framework, creating de-facto technical standards for cross-border transactions which are likely to be replicated by other jurisdictions. What can potentially emerge is a set of technical and regulatory standards built in the image of the e-CNY, and with that comes the baggage of surveillance and unauthorized access by the Chinese state. MBridge’s platform, for instance, can be utilized for domestic CBDC infrastructure if required by any jurisdiction. 

Already, Chinese company Red Date Technology—which, along with China Mobile, UnionPay, State Information Center and others—is behind the creation of Blockchain Service Network (BSN) (a blockchain infrastructure service that connects different payment networks) has launched a similar product under the name of Universal Digital Payments Network. At an event at the World Economic Forum in January 2023, it targeted emerging markets experimenting with CBDCs and stablecoins, since the project wants to build an interconnected global architecture in the vein of BSN’s ambitions.

Technological and regulatory replication by country blocs, enabled by Chinese state and private actors, could create a parallel system of financial networks outside of the dollar, especially where there is a high volume of transactions. The United States relies on the dollar’s dominance to establish global anti-money laundering standards and achieve effective and broad implementation of financial sanctions. The emergence of alternate currency-blocs—enabled by e-CNY-like technology—has the potential to chip away at the primacy of the dollar in global finance and trade, as the dollar will not be the only available option. 

Therefore, even though it is unlikely that the development of e-CNY would lead to a broader share of the RMB as a payment or reserve currency, replication of the e-CNY’s technical and regulatory model could further payments infrastructure that is not only inherently unworkable with the dollar, but exacerbates the privacy and surveillance concerns of the retail e-CNY by exporting the problem to the world. China’s domestic motivations of greater control and surveillance, therefore, are intertwined with its global ambitions, and the consequences will be dire in the absence of a competing, privacy preserving, dollar-enabling, payments infrastructure.

Ananya Kumar is the associate director for digital currencies with the GeoEconomics Center.

At the intersection of economics, finance, and foreign policy, the GeoEconomics Center is a translation hub with the goal of helping shape a better global economic future.

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Central Bank Digital Currency Tracker

Our flagship Central Bank Digital Currency (CBDC) Tracker takes you inside the rapid evolution of money all over the world. The interactive database now features 130 countries— triple the number of countries we first identified as being active in CBDC development in 2020.

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Watch the full event

Online Event Tue, April 4, 2023 • 10:00 am ET

Special event with President of the World Bank Group David Malpass

AN #ACFRONTPAGE EVENT – Malpass shared his vision for how the World Bank Group can respond to global challenges and help foster inclusive growth around the world.

Economy & Business Fiscal and Structural Reform Inclusive Growth International Financial Institutions

As World Bank President David Malpass prepares to hand over the reins to his successor, he has one big worry about the global economy: a “reversal in development.” 

“That means poverty is higher… than five years ago, that education and literacy problems are worse than they were five years ago,” he said at an Atlantic Council Front Page event on Tuesday hosted by the GeoEconomics Center. That reversal is unfolding, he explained, because of the COVID-19 pandemic and Russia’s full-scale invasion of Ukraine, which together hit the global economy with a “double whammy.” 

But even if these crises come to an end, development won’t necessarily get right back on track, warned Malpass, who will be succeeded in the coming weeks by former Mastercard Chief Executive Officer Ajay Banga. Next week, the boards of governors of the World Bank and International Monetary Fund (IMF) will meet in Washington to discuss reshaping development for a new era as central banks around the world raise interest rates to fight inflation.  

“The dislocation is huge,” Malpass said, explaining that countries looking to continue their growth strategies from the past decade will now see higher interest rates reflected on their contracts. Thus, instead of looking to return to pre-COVID development economics, Malpass explained, countries should be looking at this moment as “an inflection point into some new [economic] growth model”—and adjusting their strategies accordingly. 

“We don’t want it to be a lost decade for growth,” Malpass said. Preventing one, he added, will require sorting out global debt restructuring and increasing the resources available to the World Bank. 

Below are more highlights from the event, moderated by Bloomberg Surveillance co-host Lisa Abramowicz, as Malpass dove into the World Bank’s role in the world, its relationship with its contributors, and global financial and monetary challenges. 

World Bank, global problems 

• Malpass pointed out how over the past few decades, as countries face increasing costs, the bank’s contributions from shareholders and donors have “been relatively flat.” Given that “there were no more donations from the advanced economies,” the World Bank instead leveraged its balance sheet to expand funding for programs such as its International Development Association, which works to combat extreme poverty. 
• The flat donations are, in part, due to countries allocating spending to their own international development programs, Malpass admitted, but he noted that all bilateral aid hasn’t grown very much.  
• There’s one big exception to this trend. “China has substantially increased its contribution to the World Bank,” he explained. In response to critiques about China’s lending practices, Malpass argued that the country is the “world’s second-biggest economy, so… there needs to be some component of China’s involvement and engagement.” 
• At the same time, Malpass explained, the World Bank is working with Beijing on improving its development practices and avoiding such practices as requiring nondisclosure clauses and asking countries for collateral. “Billions and billions of dollars… are flowing with insufficient transparency,” Malpass warned. “That’s a high priority as the world interacts with China in a global context.” 
• “What we want China to see is that it is strongly in its interest to see the world growing,” Malpass added. “That can be done through a difference in lending practices—also a faster restructuring of debt.” Why hasn’t that debt restructuring happened yet? Beijing is “looking for a way to have a constructive restructuring dialogue with the world,” Malpass explained. 
• In discussing which countries the World Bank prioritizes for its lending programs, Malpass said the question often involves whether to focus on long-term projects or fast disbursements of money. “There’s a lot of pressure on the World Bank to just lend the money to the country, even if they’re not doing well” on governance and corruption. “We still operate in those countries, but we tend to do it more with social safety nets” and “direct assistance to the people of the country” so that they can survive food shortages and economic hardship. 

Currency: Dollar and digital

• Despite today’s high inflation, the dollar is still strong, Malpass said, adding that he isn’t worried about preserving the dollar’s status as the world’s reserve currency. “You earn that by dependability and by how fast you can trade the currency,” he said. “The US still has dominance in that.”  
• In the meantime, China’s renminbi, which is one of a handful of currencies that make up the IMF’s Special Drawing Rights reserves, has the potential to grow as a reserve currency, Malpass argued. But “competition is good for a currency,” he said, adding that it will push the United States to “really have strong financials… so that the dollar can remain the world’s most important currency.” 
• Malpass briefly discussed the risks that cryptocurrencies pose: He noted that, for example, they grant a measure of anonymity, making it easier to lose track of terrorism financing. Central banks will have to “speed up their settlement process,” he said, to offer a digital currency option that competes with cryptocurrencies while avoiding those risks.  

Crises underway—and on the horizon

• Malpass said that the recent string of bank failures starting with Silicon Valley Bank has increased the risk of a recession. As small and regional banks are under increasing stress, he added that the financial system needs to maintain access to the kind of small loans and local community service these banks provide. 
• With members of the OPEC+ oil cartel, which includes the Persian Gulf countries and Russia, announcing a voluntary cut to oil production on Sunday, Malpass had a grim outlook for global growth. He explained that as oil prices go up, the costs of agricultural inputs and healthy food will rise as well, with devastating impacts on food systems and health. 
• The World Bank responded to Russia’s full-scale invasion of Ukraine by offering direct grants to Kyiv and setting up trust funds that the United States has used to send non-military support to Ukraine. The bank has also conducted damage assessments to help international partners understand the amount of money needed to rebuild the country—and it will continue working on reconstruction with the United States and the European Union, Malpass said. 

Katherine Walla is an associate director of editorial at the Atlantic Council.

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Despite only being three months into 2023, these 18 countries have made significant progress on central bank digital currencies.

Country Updates

Australia

Commonwealth Bank and the Australia and New Zealand Banking Group have joined the Reserve Bank of Australia’s pilot program to explore use cases of the eAUD. They will work alongside twelve other financial institutions and payment companies to test their CBDC. 

Brazil

After conducting a closed pilot program with financial institutions in 2023, the Central Bank of Brazil president Roberto Campos Neto says he aims to launch a CBDC in 2024. 

Canada

In 2023, Bank of Canada released an analytical note, highlighting the importance of offline payment functionality in CBDCs. 

China

In January 2023, China included e-CNY in their currency circulation calculations. The e-CNY represented 0.13 percent of cash and reserves held by the central bank.

India

In 2023, India’s largest retail chain, Reliance Retail, will start accepting payments in digital rupee in stores during its pilot stage. In March, India began testing an offline functionality for its CBDC.

Japan

After completing their proof of concept, the Bank of Japan will begin a pilot program in April to test the technical feasibility of “digital yen.” Japan will also establish a CBDC forum, inviting private businesses engaging in retail payments or related technologies to participate in the discussion. Based on the results, the bank will decide whether to launch a digital currency by 2026.

Jordan

In February 2023, The International Monetary Fund released a technical market report on implementing a retail central bank digital currency. The report concluded that a cross-border rCBDC would be especially beneficial to Jordan.  

Kazakhstan

In 2023, the National Bank of Kazakhstan launched a pilot for their CBDC, which is set to run through 2025. 

Laos

In 2023, Laos’s central bank will start testing a prototype, named Digital Lao Kip (DLak).

Montenegro

Prime Minister Dritan Abazović announced that Montenegro is pursuing a digital currency in partnership with Ripple, a payment settlement asset exchange and remittance system.

Phillippines

In January 2023, the central bank of the Philippines announced that its pilot project, which tests wholesale CBDC, will run until 2024 with select financial institutions. 

Russia

The Bank of Russia is preparing to roll out the first consumer pilot for the digital ruble on April 1, 2023.

Saudi Arabia

In January 2023, the Saudi Central Bank announced that it is increasing research into CBDCs, with a focus on domestic wholesale CBDC use cases with local commercial banks and fintech partners. 

Turkey

In December 2022, the  Central Bank of the Republic of Türkiye announced that it had successfully executed its “first payment transactions” using the digital Lira. It intends to launch a central bank digital currency in 2023.

United Arab Emirates

In 2023, as part of its financial infrastructure transformation program, the United Arab Emirates is planning to launch a CBDC in hopes to address inefficiencies in cross-border payments and drive innovation domestically. In March, the United Arab Emirates will explore a development and interoperability CBDC framework with the Reserve Bank of India. 

Ukraine

In January 2023, Ukraine’s deputy prime minister announced that he will take his salary in e-hryvnia. The Ministry of Digital Transformation’s initial plan was to start the pilot phase in 2024 but the government now is pushing to launch the pilot in 2023.

United Kingdom

In February 2023, the Bank of England and HM Treasury released a consultation paper outlining the case for a digital pound. The paper concluded that it is too early to decide whether to introduce the digital pound but that preparation towards that decision is ongoing.

United States

US Treasury Undersecretary for Domestic Finance Nellie Liang announced the creation of an interagency working group to explore the development of a CBDC during a speech at the Atlantic Council. She noted that this group will comprise representatives from the Treasury Department, the Federal Reserve, the National Security Council and other respective government agencies. 

Cross-border Projects

Project Polaris

The Bank for International Settlements Innovation Hub’s Nordic Centre is launching Project Polaris to explore security and resilience in CBDC systems as well as on and offline payments functionality. The project will begin with an analytical report on offline payment possibilities for CBDC systems. This is followed by a “deep-dive” event where invited vendors discuss their solutions to potential risks and scalability options for offline CBDCs. 

Wholesale vs. Retail CBDC

A necessary choice that countries find themselves making is deciding between wholesale CBDC and retail CBDC. 

To summarize, a wholesale CBDC is used by financial institutions for bank-to-bank transactions and settlements. For example, wholesale CBDCs have been used to facilitate efficient cross-border payments among international financial institutions; they reduce costs, improve speed and reliability, and eliminate intermediaries. 

A retail CBDC is more straightforward. This type of CBDC is available to the general public for all transactions relating to the purchase of goods and services. In simpler terms, it can be used in the same way as cash, but in a digital form.

Countries have also chosen to implement both wholesale and retail CBDCs. By building this hybrid infrastructure, central banks can use CBDC to settle transactions among financial institutions, and consumers also have the option to use CBDC for their retail payments. Australia, China, and India are just some countries that are piloting both use cases for their CBDCs. 

The graph below shows how these 18 countries have decided to implement their CBDCs in 2023. Some have tackled both wholesale and retail CBDC projects, while others are still deciding. 

Conclusion

The GeoEconomics Center will continue to track CBDC exploration around the world, as governments and central banks continue to adopt efficient, resilient, and inclusive digital solutions. To stay updated on these developments, follow our CBDC tracker and our Future of Money work. 2023 has just started, but we can expect much more from the digital currency world this year. 

Check out the CBDC Tracker

Central Bank Digital Currency Tracker

Our flagship Central Bank Digital Currency (CBDC) Tracker takes you inside the rapid evolution of money all over the world. The interactive database now features 130 countries— triple the number of countries we first identified as being active in CBDC development in 2020.

Alisha Chhangani is a program assistant with the GeoEconomics Center focusing on digital currencies. Follow her on Twitter @alisha_chh.

At the intersection of economics, finance, and foreign policy, the GeoEconomics Center is a translation hub with the goal of helping shape a better global economic future.

Learn more

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