The Financial Action Task Force (FATF)’s recent revision of Recommendation 16 (R.16) highlights a fundamental weakness in the global fight against illicit finance: the lack of transparency across today’s payment systems.

Today, as a single payment might travel through a maze of facilitators, processors, and service providers, each additional layer increases complexity and cost. More critically, each step in the payment chain increases opacity and makes illicit activity harder to detect. Bad actors thrive in these gaps.

This structural opacity is the real barrier to effective oversight. And it’s a barrier that crypto, if used intentionally, has the unique potential to solve.

The Promise and Risk of TradFi-Crypto Bridges

We’re seeing exciting progress in how crypto plugs into everyday life. Crypto cards are already handling millions in transactions, making it possible to buy a coffee with stablecoins.

But there’s a catch: behind every tap or swipe of a crypto card, there can be more than a dozen entities involved. 

While accessible solutions like crypto cards accelerate adoption, they also risk rebuilding the very patchwork of intermediation that makes illicit activity detection so difficult in the first place.

The alternative? True open-loop payments.

Imagine scanning a QR code to send USDC directly to a merchant's provider. Settlement happens in seconds, with only 3–4 parties involved instead of a dozen. Costs fall, risks fall, and transparency increases.

To avoid rebuilding the same opaque payment structures, we must lean into what makes blockchain unique: openness and transparency by design.

Making Open Payment Systems Work

Openness should not mean chaos. It still requires compliance, controls, and oversight. The challenge is enforcing these standards without closing the system back down.

That’s where the Transaction Authorization Protocol (TAP) comes in.

TAP is designed as a neutral, open protocol: no single company, consortium, or jurisdiction controls it. Regulators can engage without sovereignty concerns, and industries can apply regional requirements without fragmenting the ecosystem.

By aligning authorization and settlement in a single transparent flow, TAP ensures that controls and accountability coexist with speed and openness.

Building the Right Future for Payments

The fight against illicit finance requires us to rethink how payments are built, and to prioritize:

• Open, transparent systems by default;
• Fewer intermediaries who add value rather than opacity;
• Embedded compliance that preserves trust without undermining openness.

Blockchains gives us the tools to get there if we choose to lean into openness rather than falling back into consolidation, control and opacity.