Mark Warren (Central European University)
The European Central Bank anticipates including a holding limit of about €3,000 per user within the potential design of its retail central bank digital currency for the Eurozone, the digital euro. This is principally motivated by concerns regarding compliance with regulations related to anti-money laundering and countering the financing of terrorism and the disintermediation of banks as credit intermediaries. This paper argues that these concerns are unwarranted and, in any case, the holding limit would not be an effective solution to these concerns. The digital euro could be introduced with unlimited holdings by individual users in conformity with EU law and while maintaining banks as credit intermediaries in the Eurozone financial system.