"Reform and Innovation" Mu Changchun: The way of the balance between privacy and security -the theoretical research and practice exploration of digital RMB controllable anonymous theoretical research

Mu Changchun: The way of the balance between privacy and security -the theoretical research and practice exploration of digital RMB controllable anonymous theoretical research

Reform and Innovation

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Digital RMB is a legal currency in the form of digital form, which is mainly positioned in cash in circulation. In the era of digital economy, "controllable anonymous", as one of the characteristic design of digital RMB, can meet people's demand for increasing privacy protection. This article sorts out several key designs of digital RMB to achieve "controllable anonymous", including the double -layer operation system, wallet matrix, and information collection based on the principle of user wishes and minimized principles, and explore the relevant laws of the central bank's digital currency controlled anonymous design. frame. Finally, this article looks forward to improving the top -level design and improving the capacity of risk control. Today, when privacy protection has attracted much attention, risk monitoring such as anti -money laundering, counter -terrorism financing and anti -tax evasion should still be used as a prerequisite for exploring controllable anonymous and strictly implemented. At the same time, the People's Bank of China will continue to optimize the controlled anonymous design of digital RMB and continue to provide the public with more secure and efficient payment services.

1. Introduction

Digital RMB is issued by the People's Bank of China. The designated operating institutions participate in operations. Compatible with three methods such as accounts, quasi -accounts and value -based, based on a broad account system, supporting bank account loose coupling functions, equivalent to physical renminbi, and value characteristics with value characteristics And the law. Digital RMB supports controllable anonymous. As an important feature of digital RMB, on the one hand, it reflects the positioning of its M0 to ensure the public's reasonable anonymous transactions and personal information protection. Illegal and criminal acts such as tax evasion to maintain the objective needs of financial security.

Second, digital RMB controlled anonymous design characteristics

(1) Privacy protection design of digital RMB

In the era of big data, consumers attach increasing importance to personal privacy protection. Although electronic payment represented by mobile payment is more convenient than traditional cash payment, consumers still choose cash transactions. One important reason is that cash transactions have anonymity and natural protection for consumers' privacy. Digital RMB is positioned in cash (M0) in circulation. It is a retail central bank digital currency issued to the public. Diverse needs of payment methods.

Therefore, the design of digital RMB should meet the reasonable needs of personal anonymous transactions, and strengthen the protection of consumer privacy: First, it should meet the habit of daily small cash payment and ensure the confidentiality of related payment transactions. The second is to clarify anonymous objects to ensure that when consumers use digital RMB for transactions, their personal information is not obtained by merchants and other third parties without legal authorization. Third, the use and protection of personal information should be strengthened to ensure that the basic information of customers collected by the operating agency, the transaction and consumer behavior information generated by the operating agency will not be leaked. Digital renminbi will be coexisting with the real RMB for a long time and will not be forced to promote. In the future digital retail payment system, digital RMB and electronic account funds of the designated operating institutions are universal, and they together constitute cash payment tools. The real RMB has an irreplaceable advantage of other payment methods. As long as there is a demand for physical renminbi, the People's Bank of China will not stop the supply of real RMB or replace it with administrative orders. (2) The "double -layer operation" system of digital RMB

Digital RMB adopts the "double -layer operation" system. The People's Bank of China exchanges digital RMB to the operating institution, and the operating institution provides the public with exchanged circulation services. Operation agencies collect the personal information necessary for services and operations, and the personal information generated by wallet services is collected and stored by the operating agency. In order to meet the needs of cross -institutional transactions and reconciliation, the People's Bank of China only handle cross -institutional transaction information transferred through the interconnection platform, and does not master other personal information. At the same time, the digital Renminbi wallet is used anonymous technical processing, and the data of the personal information between all wallets is anonymous to the transaction opponent and other commercial institutions. For the public's normal transactions and consumption, none of the above -mentioned subjects cannot obtain complete transaction information and consumer behavior information to protect consumers' personal privacy. In the case of normal transactions, no unit or individual has the right to obtain relevant transaction information.

Only when legal conditions such as suspected transactions are triggered, the operating institution can apply for further analysis of relevant data to ensure the performance of legal obligations such as anti -money laundering and anti -terrorist financing. In addition, when the relevant authorities query and use the user's personal information in accordance with the law, the scope of the use of the user's personal information is strictly controlled and the use of the use of the use of the use of laws and regulations, and security measures are taken.

The People's Bank of China strictly abides by laws and regulations such as the "Network Security Law" and "Personal Information Protection Law", and ensures personal information security through advanced technical means and strict management mechanisms. At the technical level, the People's Bank of China adopts authority access control security technical measures and multiple identity authentication technology and other advanced technical means and other necessary measures to protect data security and prevent data from being unauthorized, publicly disclosed, used, modified, damaged or lost Essence In the management mechanism, the People's Bank of China has set up a "firewall" inside the People's Bank of China to strictly implement information security and privacy protection management through special management, business isolation, classification authorization, job balance, and internal audit. Digital renminbi related information will be encrypted and sealed, all customer information is identified, and it is not legal authorized. Whether it is internal personnel inside the People's Bank of China or any external unit or individual, they must not inquire or use it at will; For information, legal responsibility will be investigated in accordance with the law.

Therefore, whether it is the operation agency and the People's Bank of China, they will strictly follow the requirements of laws and regulations, establish a personal information protection system and internal control management mechanism, fulfill the management process of customer information protection to ensure personal information security. In short, the protection of the privacy of digital RMB to user privacy is the highest level among the current electronic payment tools.

(3) Digital RMB wallet matrix design

Traditional payment tools, whether it is Internet payment or bank card payment, is bound to the bank account system. Because bank account opening is a real -name system, it is impossible to meet the public's anonymous demands of the payment tool. The loosening of digital RMB wallets with bank accounts reduces the dependence of the transaction link to financial intermediaries and achieves a small anonymous technically. Digital Renminbi wallets Form the wallet matrix with different dimensions of different dimensions such as classification, soft wallets and hard wallets, mother wallets, and child wallets. Meet the differentiated needs of users, multi -level, multi -category, and multi -form.

First, the digital RMB wallet is divided into different levels of wallets with different levels according to customer identification intensity, and gives different single -day transactions and balance limits of various wallets according to the degree of strength and weakness of the real name. Digital RMB allows non -real -name wallets. Four types of wallets are anonymous wallets, which can be opened with a mobile phone number. According to relevant laws and regulations such as the "Network Security Law" and "Personal Information Protection Law", telecommunications operators shall not disclose customer information corresponding to the mobile phone number to third parties including the People's Bank of China. Therefore, the mobile phone number is opened with the mobile phone number. The four types of wallets are completely anonymous. The four types of wallets are benchmarking small cash consumption scenarios. According to the statistics of the "General Situation of the Operation System in the Second quarter of 2021" issued by the People's Bank of China, the average consumption amount of bank card pens under non -cash payment business is 603 yuan, while four four, and four four, and four four, and four The single -stroke payment limit is 2,000 yuan, which meets the public's aonymous demand for small small amounts in daily life. Digital RMB categories, two, and three types of wallets are real -name wallets. The single payment limit increases with the enhancement of the real -name intensity. risk. Compared with the opening of the electronic account, the collection of 9 element information, the customer information collected by the digital RMB system is less than the traditional payment model. The second is that the digital RMB wallet is divided into soft wallets and hard wallets according to the carrier. Under the wallet matrix, the four types of soft wallets and their hard wallets belong to anonymous wallet can meet the needs of public online and offline small anonymous transactions. In addition, the hard wallet of the quasi account model does not associate with the user's identity when the release is issued, and gives full play to the positive role of hard wallets in the field of small anonymous payment. During the Winter Olympics, digital RMB launched a hard wallet with a quasi -account model to provide services to foreigners who came to China in the short term.

Third, the digital RMB wallet is divided into mother wallets and child wallets according to authority belonging. Users can open a child wallet and push to the e -commerce platform under the digital RMB wallet to protect personal privacy. Earlier, when the public was shopping on e -commerce platforms, it was necessary to provide relevant user payment information in the payment link. This method would cause e -commerce platforms to obtain all personal information. Digital RMB identifies all user information. Except for the user's mobile phone number used to associate the e -commerce platform account when pushing a child wallet, it will not provide other user information to the e -commerce platform, such as bank card numbers and bank card validity periods, etc. Information, effectively protect the public's personal privacy.

(4) Principles of information collection with user wishes

Based on the design of the double -layer operation system and the wallet matrix, digital RMB only obtains the necessary personal information directly related to the purpose of processing and collects according to the user's wishes, and collects information in accordance with the principles of autonomy, transparency, and minimizing.

First of all, users have the right to close the relevant authority at any time. The Digital RMB APP will immediately stop the processing activities of personal information to fully protect the user's independent management authority. For users who choose to refuse to provide permissions, the Digital RMB APP will be strictly implemented.

Secondly, the Digital RMB APP does not obtain relevant permissions in a way to allow users to authorize. Instead, according to the specific business and scenes, under reasonable and necessary, after clearly informing the user the purpose, it will apply to the user alone to obtain the relevant permissions. The user will obtain the corresponding permissions until the user agrees. Through detailed columns, the authority required to open the service and the corresponding business scenario, the user fully understands the authority of its authority.

Finally, digital RMB only obtains the necessary personal information directly related to the purpose of processing. Digital RMB APP accounts only collect and process necessary personal information to ensure the realization of basic account functions such as registration, login, password modification, and recovery; when operating agencies provide users with digital RMB wallet services, they also collect the necessary identity information and transaction information. Ensure basic business functions such as digital RMB payment. In addition, in order to ensure the safety of user property, digital RMB only collects the information required for risk control, which is used to strengthen the risk identification of user digital RMB wallets, malicious reporting, and cyber fraud.

3. Digital RMB controlled anonymous legal framework

(1) Anonymous exploration on the basis of risk control

"The freedom of no constraint is not true freedom." If you only pay attention to personal privacy protection, the anonymity of the central bank's digital currency does not increase control, ignore the risks of facilitation, large -scale, and cross -regional risks caused by financial products and services in the digital age, the central bank's digital currency will be used by illegal crimes. , Severe consequences. In order to maintain financial security and stability, the central banks and international organizations of various countries and international organizations take prevent risks as an important premise when exploring the anonymity of the central bank's digital currency. Designs that cannot meet the requirements of anti -money laundering, anti -terrorist financing and anti -tax evasion will be voted by one vote. veto.

The anonymous exploration of the central bank's digital currency is a limited anonymous with the premise of risk controlling. The complete anonymous central bank digital currency does not have feasibility. Agustín Carstens, president of the International Clearance Bank, clearly states that the concept of completely anonymity is unrealistic in the "Future of the Digital Currency and the Monetary System", and the completely anonymous system will not exist. He believes that the vast majority of users will accept a trusted institution, such as banks or public service departments to keep basic information, and retain a certain identification is essential for the security, anti -corruption, anti -money laundering, and anti -terrorist financing of the payment system. Convenience and traceability need to seek a balance.

Coincidentally, the International Clenging Bank and 7 central banks including the European Central Bank and the Federal Reserve jointly compiled and published the "Central Bank Digital Currency: Basic Principles and Core Features" report also rejected the possibility of completely anonymity. The main benefit that may bring is the anonymity of electronic payment, but it is unreasonable for complete anonymity. Although the requirements for anti -money laundering and anti -terrorist financing are not the core goals of the central bank, nor will it become the main main goal of issuing central bank digital currencies The motivation, but the design of the central bank's digital currency should meet these requirements. "In addition, the European Central Bank discussed the balance of privacy protection and preventive risks in the report of" Explore the Anonymous of the Central Bank's Digital Currency "report, and pointed out that" digitalization paid ecological ecology The system constitutes a major challenge, and requires a balance between electronic payment to a certain degree of privacy and compliance with anti -money laundering and anti -terrorist financing regulations, including providing privacy protection for users' small transactions to a certain extent. The requirement of anti -terrorist financing. "This description echoed the concept of" a few considerations for the central bank's digital currency "in the article" Several considerations of the central bank's digital currency ".

It can be seen that the entire anonymity is never within the consideration of the digital currency of central banks in various countries. Only limited anonymous anonymous under the premise of meeting the requirements of anti -money laundering and anti -terrorist financing is an international consensus.

(2) Strictly abide by the regulatory regulations such as anti -money laundering and anti -terrorism financing

The anonymous exploration of the central bank's digital currency cannot violate regulatory regulations such as anti -money laundering, anti -terrorist financing and anti -tax evasion. In its "FATF Report", the financial operation group clearly states that "once the central bank's digital currency is established, and the financial institutions with digital currency transactions with the central bank, including designated non -financial institutions and virtual asset providers, they will bear the legal currency or cash with the legal currency or cash. The same obligations of anti -money laundering and anti -terrorist financing. Customer transactions using central bank digital currencies will comply with due diligence obligations of the same customer in electronic transactions with the use of legal currencies. "

In addition, FATF also mentioned in the above report specifically for virtual currencies that "In the future, the compliance of anti -money laundering and anti -terrorist financing of virtual currencies and virtual asset providers will continue to evaluate and supervise virtual currencies and their virtual asset providers, especially 'data transfer rules'' (Travel Rule) Observing the situation, this rule requires important identification information to transmit an important identity identification between virtual asset providers. "In order to ensure that relevant information is transmitted between different institutions, and the corresponding anti -money laundering obligations should be fulfilled. Comply with relevant requirements such as data transfer rules.

Although the International Clearance Bank acknowledges that the central bank's digital currency has the role of cash replacement, it also clearly requires the performance of the "three anti -" obligations. Its "Central Bank Digital Currency" report states that "Although the central bank's digital currency may replace cash in some cases, but the central bank's digital currency may replace the cash, it The issuance of central bank digital currencies must ensure the requirements of anti -money laundering and anti -terrorist financing, as well as other requirements for supervision and taxation. "The Bank of England also holds the same view in the report of the" Central Bank of Digital Currency Opportunities, Challenges, and Design.

It is worth noting that the central bank's digital currency has the characteristics of digitalization, and the anonymity of the same level as the same level as the physical currency will generate great risks. The financial action special working group (hereinafter referred to as "FATF") mentioned in the "FATF report to the so -called stable currency to the Twentan Group Finance Minister and the Governor of the Central Bank" (hereinafter referred to as the "FATF Report") that "compared to cash , The central bank's digital currency may bring greater money laundering and terrorist financing risks. Because the central bank's digital currency can provide the public with retail payment or as an account, and theoretically allows anonymous point -to -point transactions. In this case, the central bank digits The currency can provide the liquidity and anonymity close to cash, and because the user does not need to carry cash with them, it is more portable than cash. Because the central bank's digital currency will be supported by the central bank of its jurisdiction, it may be possible Extensive acceptance and extensive use. The combination of anonymity, portability and extensive use is very attractive for criminals and terrorists who have the purpose of money laundering and terrorist financing. "

As one of the focus of international competition in the digital economy era, the central bank's digital currency will attract international attention. If the digital RMB is only emphasized anonymous, relaxes management in the client due to due diligence, it will be possible to be drilled and utilized by criminals, becoming a tool for money laundering, drug trafficking and even crime of terrorist organizations, and will not meet the requirements of international organizations such as FATF.

(3) Carefully prevent risks such as online fraud

In recent years, new forms of illegal and criminal activities such as the Internet and telecommunications have intensified. Data show that there are more than 1 million criminals engaged in cyber fraud activities nationwide, causing more than 100 billion yuan in direct economic losses each year. Various types of online gambling cases have also emerged endlessly. In 2019, public security organs from various places detected more than 7,200 criminal cases of online gambling, and the freezing funds involved in the freezer were more than 18 billion yuan. The Party Central Committee and the State Council attach great importance to combating the management of telecommunications network fraud crimes, and adopt special operations to combat illegal and criminal activities such as telecommunications network fraud and online gambling. In the investigated telecommunications network fraud and online gambling cases, most of the funds involved were transferred through the false bank accounts and payment accounts.

Under the traditional bank account system, banks need to open Ⅰ, Ⅱ, and III accounts for users to provide real -name verification. During the duration of the business, we will also take continuous customer due diligence measures. , Divide risk levels, regularly review the basic information of user users. However, even if we have adopted strict customer due diligence measures and continuous due diligence, cross -verification and other risk prevention and control methods, criminals still cannot avoid using bank accounts for criminal behaviors such as online gambling and telecommunications fraud. First of all, the cost of using cash for illegal transactions is very high. Large cash transactions need to generate transportation, counting, delivery and other links. At the same time, there are risks such as incorrect inventory errors, damage, loss, and fake coins. With the increase of cash transactions, the increase in cost is non -linear. In the era of digitalization, regardless of the transaction amount, the cost of the transaction is basically the same. It can be seen that the characteristics of cash inconvenience have increased their friction on money laundering and terrorist financing. Therefore, the anonymity of cash is relatively high. The central bank's digital currency is more portable. If it provides the same anonymity as cash, it will be greatly facilitated illegal trading behaviors such as money laundering. Therefore, the central bank's digital currency should not have the same anonymity as cash.

Secondly, with the development of third -party payment institutions and the popularization of network payment, due to the fact that the real -name system of some payment institutions and platforms is not implemented, the criminals have taken advantage of it, which has caused the payment account to be reduced to the telecommunications fraud gang to collect and bleach illegal funds. "Green Channel". Eventually, the funds of illegal crimes of online black -gray products such as telecommunications fraud and online gambling were transferred from the traditional banking system to a third -party payment institution. It can be seen that criminals have always paid close attention to the weak links and loopholes of anti -money laundering, and various illegal crimes have continued to flow towards policy depression. If the central bank's digital currency is too high, it will provide new criminal soil for criminals. A large number of illegal transactions will flow from electronic payment into the central bank's digital currency and become a tool for telecommunications fraud and online gambling.

Therefore, the digital RMB is not fully applicable to the regulatory rules of physical cash circulation. The digital RMB anti -money laundering system shall determine the supervision measures that should be taken in accordance with the essence of its business, follow the principle of "substantial supervision", and use digital RMB for telecommunications fraud and other illegal activities such as telecommunications fraud and other illegal activities. At the time, it can assist the authority to recover losses, protect the public's property security, and maintain social stability.

(4) Clarify the "three anti" responsibilities of each subject and follow the principle of "substantial supervision"

The People's Bank of China attaches great importance to improving the digital RMB anti -money laundering system. It has established a clear management and supervision system with clear division of labor and clear responsibilities for digital RMB, and realizes the closed -loop management of "pre -evaluation, supervision in the event, and post -post supervision".

First of all, the digital RMB business plan needs to be independent of anti -money laundering and anti -terrorist financing functions to ensure that it meets international standards such as FATF, as well as the requirements of domestic anti -money laundering and anti -terrorist financing laws and regulations. Explanation. Digital RMB is mainly positioned in cash in circulation and needs to abide by laws and regulations related to cash management.

Secondly, the operating agency, as the main body of digital RMB services directly to customers, is the subject of the obligation of digital RMB anti -money laundering. It is necessary to fully perform the core obligations of anti -money laundering and anti -terrorist financing of customers' due diligence, large trading and suspicious transaction reports. According to the relevant principles of FATF and my country's anti -money laundering requirements, in terms of due diligence investigations, operating institutions and other commercial institutions can entrust the cooperation agencies to conduct due diligence investigations by signing an agreement with entrusted cooperation agencies, but they should bear the customer themselves by themselves. The final responsibility of due diligence. In terms of suspicious transaction reports, due to the amount of funds involved or asset value, suspicious transactions need to be monitored and identified. Therefore, for the small anonymous transactions of digital RMB, in order to prevent criminals from opening anonymous account in batches, split transactions, small high -frequency transfer to transfer, etc. to evade supervision. Suspicious transaction monitoring and reports under the circumstances.

At present, digital RMB design and use mainly meet the demand for domestic retail payment. Cross -border and international use are relatively complicated, involving anti -money laundering, customer due diligence and other legal issues. In -depth discussions are being discussed internationally, and the People's Bank of China has also participated in related research.

Fourth, the next plan

(1) Strengthen legislation and improve the design of the top -level system

In order to ensure the effective implementation of digital RMB controllable anonymous requirements, four corresponding arrangements need to be made in the design of the top -level system:

The first is to establish an information isolation mechanism. Clarify the independence of operating agencies to carry out digital RMB operation business, and standardize the use of digital RMB customer information by setting up digital RMB customer information isolation mechanisms and use restrictions. Digital RMB operating institutions need to establish and improve customer information protection internal control and customer information protection monitoring working mechanism. Only when illegal crimes such as money laundering, terrorist financing and tax evasion may be applied for obtaining relevant customer information for risk analysis and monitoring to fulfill the performance and performance to fulfill the performance to fulfill the performance and perform to fulfill the performance and perform to fulfill the performance of the performance to fulfill the implementation of the risk analysis and monitoring. "Three anti" obligations. Other non -operating institutions participants, such as other commercial banks and payment institutions, do not have the right to obtain customer transaction information with digital RMB to ensure that customer information is used within the scope of minimizing.

The second is to clarify the legal conditions of digital wallet query, freezing, and deduction. Only legal authorities authorized by law can inquire, freeze, and deduct user digital renminbi wallets based on legal reasons, otherwise the operating institution has the right to refuse. The third is to establish a corresponding punishment mechanism. The regulatory authorities can take penalties to the operating institutions that deal with digital RMB customer information in accordance with their responsibilities to strengthen supervision.

The fourth is to improve the regulations and systems such as anti -money laundering and anti -terrorist financing. Combining the relevant principles of FATF and the characteristics of digital RMB, research and issue regulatory regulations such as digital RMB anti -money laundering and anti -terrorist financing in a timely manner.

(2) Strengthen the application of science and technology and enhance risk prevention and control capabilities

The application of emerging technologies has provided new vitality and innovation points for traditional financial risk management, and enhanced risk management capabilities through scientific and technological means. In order to strengthen the monitoring of digital RMB risk, especially in risk monitoring in anti -money laundering and anti -terrorist financing, more scientific and technological means should be used to improve risk monitoring and prevention and control level.

Digital RMB supervision will strengthen the practice of regulatory science and technology, and actively use technologies such as big data, artificial intelligence, cloud computing and other technologies to enrich financial supervision methods, and improve the ability to identify, prevent and resolve cross -market and cross -market cross -market risks. The risk management and control of digital RMB will make full use of innovative technologies, and is widely used in key links such as due diligence, suspicious transactions and abnormal transactions, and regulatory reporting to enhance the ability to prevent and dispose of digital RMB risk.

5. Conclusion

In summary, digital RMB, as a legal digital currency issued by the People's Bank of China, needs to prevent risk prevention on the basis of respect for privacy protection to prevent criminal use and become criminal tools. Digital RMB provides the same features and fastness as electronic payment tools, but also provides an controllable anonymous design that electronic payment tools do not have. On the one hand, it can meet the public's demand for personal information protection. And reducing the risk of illegal and criminal activities using digital RMB, maintaining financial security, to protect the balance of personal privacy and cracking down on crimes, and in line with the consensus of central banks and international organizations in various countries. It should be emphasized that under the premise of the real currency, the public can still obtain the complete anonymity provided by the physical currency, and it is not deprived by the issuance of the number of the RMB; Instead, risks and cracking down crimes are objective needs to protect public interests and financial security. In short, the controllable anonymity of digital RMB will provide a positive role in providing a better and safer payment service for the public.

Mu Changchun: Members of Chang'an Street Reading Club, Director of the Institute of Digital Currency Research of the People's Bank of China

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