In the contemporary debate on blockchain and digital finance, decentralization is often presented as (at the very least) a “disruptive factor” when compared to traditional models of intermediation. In financial markets, however, the issue takes on a deeper significance, as it (sadly) affects core safeguards such as supervision, transparency, and anti-money laundering controls.
The NYSE announcement shows that, albeit after several years, many of the economic and systemic advantages of decentralization are now widely acknowledged. Lower intermediation costs, direct access to financial services, and the ability to avoid arbitrary forms of censorship remain central elements of the appeal of decentralized systems. Looking beyond the specific announcement, one may also point to the active participation of users in protocol governance, which introduces dynamics that differ markedly from those of traditional finance. Alongside these benefits, however, structural shortcomings emerge that appear to limit the “real” adoption of decentralization. The absence of an identifiable intermediary makes external supervisory intervention more complex and raises significant questions in the field of anti-money laundering. Traditional AML obligations are built around accountable and controllable entities; in decentralized systems, this architecture comes under strain due to the distribution of decision-making and operational power.
It is precisely at this juncture that an increasing share of legal and regulatory reflection is concentrating. More and more often, including in discussions between market participants and institutions, the need to move beyond a purely oppositional reading of decentralization versus control is being highlighted. Within this perspective fall studies and analyses that propose embedding safeguards directly into protocol architecture, turning code itself into a tool of ex ante prevention.
According to this approach, the protocol is not merely a technical infrastructure, but can function as an impartial mechanism of guarantee, capable of incorporating rules, limits, and filters aligned with anti-money laundering objectives. This line of analysis is increasingly referenced, both in academic and professional contexts, when dealing with high-complexity cases in the DeFi sector and in decentralized systems more broadly.
A preliminary issue nevertheless remains unresolved: the definitional one. The lack of a legally shared notion of decentralization risks generating interpretative uncertainty and opportunistic phenomena, such as the so-called “Decentralization in Name Only” (DINO), where concentrated control structures are masked behind formally decentralized arrangements. A clear definition therefore becomes essential in order to distinguish genuinely decentralized models from merely nominal solutions.
In the financial context, and particularly with regard to anti-money laundering regulation, decentralization should not be understood either as an insurmountable obstacle or as an automatic solution. It is a structural variable that requires a rethinking of regulatory tools. A rethinking that, as shown by the most advanced analyses and by contributions increasingly cited in sector-wide debates, depends on the ability to reconcile technological innovation, governance, and legality in a coherent manner.