President Bukele’s radical crypto initiative made headlines around the world. It also made him somewhat of a folk hero in the crypto community. But, in El Salvador, Bukele received little more than cynical glances. After all, since El Salvador dumped the colón and replaced it with the U.S. dollar in 2001, its average annual inflation rate has been only 2.03 percent, the lowest rate in Latin America. And if that’s not enough, even though the greenback is legal tender, all currencies are legal to use in El Salvador. So, Salvadorans ask, “Why change our dollarized competitive exchange-rate regime?” It works like a charm. The World Bank and International Monetary Fund have made the same observation and asked the same question. And rightfully so.
They won’t be the only institutions asking questions. So will the Financial Action Task Force (FATF), the international money-laundering and terrorist-financing policeman. From an FATF regulatory perspective, El Salvador has been as clean as a hound’s tooth. That will change if the Bitcoin Law is implemented on September 7. In a Johns Hopkins Studies in Applied Economics working paper, I identified 27 FATF regulations related to virtual‐asset transactions that will be nearly impossible for Salvadoran banks, businesses, and their customers to comply with under the new law. For example, the FATF mandates that the parties engaging in virtual‐asset transactions provide complete and sufficient know‐your‐customer information. It also requires that senders and recipients of virtual assets obtain accurate knowledge and information about “the transaction, the source of funds, and the relationship with the counterparty.” The chances of Bitcoin transactions meeting such requirements are slim tonone.
If you are wondering whether the FATF and other regulatory bodies will cast their eyes onto the shady side of El Salvador come September 7, the answer is an unambiguous “yes.” Just look at what the U.S. State Department has recently done. On July 1, it released a list of corrupt and/or undemocratic actors from Central America’s Northern Triangle (El Salvador, Guatemala, and Honduras). Of the 55 Central Americans now banned from the United States, 14 are Salvadorans. They include high‐level members of President Bukele’s administration, including his cabinet chief, minister of labor, vice minister of security, and legal adviser. They’ve been nailed for a laundry list of charges such as money laundering, accepting bribes, and undermining democracy.