Closing the Gates on Money Laundering: Big Tech as Gatekeepers in the Metaverse Jenny Zhang

Abstract

The rise of the metaverse has created meaningful growth opportunities for the digital economy and the use of digital assets. The conditions that have facilitated the metaverse’s growth, however, have simultaneously given rise to unchecked money laundering risk. This Note reviews the existing Anti-Money Laundering (“AML”) framework in the United States and argues that the metaverse’s inherent design features disable the efficacy of the regulatory regime. In order to improve the reach of the AML framework, this Note proposes a system of gatekeeper liability that utilizes technology corporations to curb illicit activity in the metaverse.