Published on

Crypto AML Is Broken — and We're Pretending It Isn't

Authors

Crypto AML Is Broken — and We're Pretending It Isn't

Founder working at the intersection of AI & human interaction


Cryptocurrency was designed to move value without intermediaries. But as digital assets moved from the margins into the financial mainstream, one uncomfortable reality became clear: the anti–money laundering frameworks we rely on were never designed for a world of decentralized, programmable money.

Today, crypto AML exists — but largely as a patchwork of adaptations, assumptions, and inherited rules that don't fully match how crypto actually works. And pretending otherwise is becoming increasingly risky.


Why Traditional AML Struggles With Crypto

Classic AML systems were built around banks, accounts, and clearly identifiable institutions. They assume:

  • a known customer
  • a centralized ledger
  • a regulated intermediary
  • jurisdictional clarity

Crypto breaks most of these assumptions.

Wallets are not accounts. Addresses are not identities. Transactions are global by default. Smart contracts execute automatically, without human intervention. And decentralized protocols don't neatly fit into existing compliance categories.

Applying legacy AML logic to crypto is often like trying to regulate the internet using postal-service rules.


The Illusion of "Solved" Compliance

In recent years, the industry has responded with tooling: blockchain analytics, transaction monitoring, wallet screening, and risk scoring. These tools are valuable — but they're often treated as a silver bullet.

In practice, many AML programs in crypto rely heavily on:

  • probabilistic attribution
  • heuristics and clustering
  • historical behavior patterns
  • assumptions about intent

This creates a dangerous illusion of certainty. Risk scores feel precise, but they are still interpretations — not facts. And when these scores are used to freeze funds, deny access, or flag users, the consequences are very real.

AML in crypto is less about detection certainty and more about risk interpretation under uncertainty — a distinction that's often lost in implementation.


The Human Cost of Automated AML

One of the least discussed aspects of crypto AML is its human impact.

False positives can lock users out of funds for weeks or months. Legitimate users may never fully understand why they were flagged. Appeals processes are often opaque or nonexistent. In decentralized systems, responsibility becomes fragmented — and accountability even more so.

As AML becomes more automated, the distance between decision and consequence grows. A model flags a transaction. A system enforces a restriction. A human feels the impact — often without explanation.

This is where AML stops being a purely technical problem and becomes a human-systems problem.


Where AI Can Help — and Where It Can't

AI is frequently positioned as the solution to crypto AML's complexity. And to a degree, it can help:

  • detecting complex laundering patterns
  • correlating cross-chain activity
  • reducing manual review load
  • adapting to evolving behaviors

But AI also amplifies existing risks if deployed carelessly.

Models trained on incomplete or biased data can reinforce false assumptions. Overconfidence in automated decisions can reduce human oversight. And explainability becomes critical when decisions affect access to financial systems.

AI should support investigation and prioritization, not replace judgment entirely — especially in edge cases where context matters.


Toward a More Honest AML Model for Crypto

A more realistic approach to crypto AML starts with acknowledging what we don't know.

That means:

  • treating risk scores as signals, not verdicts
  • designing transparent escalation paths
  • preserving human review for consequential decisions
  • clearly communicating limitations to users
  • aligning enforcement with proportionality

It also means moving away from performative compliance — systems built to satisfy checklists rather than reduce real harm.

Effective AML in crypto won't come from copying the past. It will come from designing systems that accept uncertainty, respect users, and balance enforcement with fairness.


Why This Matters Now

As regulation tightens globally, crypto AML systems will increasingly shape who can participate in digital finance — and on what terms. The decisions encoded today will define access, trust, and legitimacy for years to come.

Getting AML wrong doesn't just expose institutions to regulatory risk. It erodes confidence in the entire ecosystem.

If crypto is going to fulfill its promise, compliance systems must evolve alongside it — not lag behind it.


Final Thought

Crypto AML isn't broken because people aren't trying hard enough. It's broken because we're forcing a fundamentally new system into frameworks that were never designed for it.

The path forward isn't blind automation or stricter controls. It's honest design — systems that reflect how crypto actually works, how people actually behave, and how decisions actually affect real lives.