Response to the Commission consultation on a digital euro

The creation of a digital euro could possibly enable more direct access to different types of market infrastructures. We see many efficiency gains in this respect. However, this raises fundamental questions around conflicts of interest and the need for extended KYC (know your customer) and AML (anti-money laundering) processes to be applied in all layers of the chain. If a decentralised model is introduced, the relevant market integrity and investor protection safeguards should be replicated to intermediaries when performing their due diligence checks.