Papers claiming that cash-like anonymity is not possible..

https://www.bankofcanada.ca/2020/06/staff-analytical-note-2020-9/

• Techniques to achieve cash-like privacy are immature. They have limited deployments, none of which comply with know-your-customer (KYC) and anti–money laundering (AML) regulations. Their risks include hidden vulnerabilities, a lack of scalability and complicated operations.

https://www.bankofengland.co.uk/-/media/boe/files/paper/2020/central-bank-digital-currency-opportunities-challenges-and-design.pdf

p.32

The appropriate degree of anonymity in a CBDC system is a political and social question, rather than a narrow technical question. As discussed above, CBDC would need to be compliant with AML regulations, which rules out truly anonymous payments.

https://www.riksbank.se/globalassets/media/rapporter/staff-memo/engelska/2021/on-the-possibility-of-a-cash-like-cbdc.pdf

Third, legal regulations require digital payments to be non-anonymous. According to current regulations in the EU, account-based systems must have registers that make it possible to establish the identity of the owner of each account (Sveriges Riksbank, 2018). We suspect that any system where CBDCs are stored remotely will fall under this regulation, regardless of whether they involve tokens or not. In the case of locally stored tokens, anti-money laundering regulations at present allow for the payer to make a payment of up to EUR 150 without needing to identify themselves. 

https://www.riksbank.se/globalassets/media/rapporter/e-krona/2018/the-riksbanks-e-krona-project-report-2.pdf

p.16

 At the other end of the scale, there is something similar to deposits, where there are no limits on amounts and the bearer of the value, krona on a card or in an app, is linked to an individual who is a registered user and thus not anonymous.

Same page: Under the title "Payments with e-krona will be traceable":

An account-based e-krona must therefore, according to current legislation, be based on an owner register to be able to establish who the owner of the account is.

Under the title "Value-based e-krona can allow anonymous payments according to anti-money laundering regulations":

At present, this is when the payment amounts to less 3than EUR 250. (Now lowered to EUR 150)

MiCA Proposal - Two summaries:

https://www.sygna.io/blog/what-is-mica-markets-in-crypto-assets-eu-regulation-guide/

https://www.ashurst.com/en/news-and-insights/legal-updates/10-things-you-need-to-know-about-mica-europes-proposals-for-regulating-crypto-assets/

MiCA Proposal Text

https://eur-lex.europa.eu/resource.html?uri=cellar:f69f89bb-fe54-11ea-b44f-01aa75ed71a1.0001.02/DOC_1&format=PDF

Prohibition of private currencies. Page 93

The operating rules of the trading platform for crypto-assets shall prevent the admission to trading of crypto-assets which have inbuilt anonymisation function unless the holders of the crypto-assets and their transaction history can be identified by the crypto-asset service providers that are authorised for the operation of a trading platform for crypto-assets or by competent authorities. 

FINCEN Proposal

https://decrypt.co/53178/coinbase-square-rally-against-fincens-proposed-crypto-crackdown

A question of civil liberties

The Electronic Frontier Foundation (EFF), a civil liberties organization, has emphasized the perceived impact FinCEN’s proposal would have on privacy. 

“The proposed regulation would undermine the civil liberties of cryptocurrency users,” the EFF said in a prepared statement, adding, “Anonymity is important precisely because financial records can be deeply personal and revealing: they provide an intimate window into a person’s life, revealing familial, political, professional, religious and sexual associations.” 

To underline its point, the EFF pointed to photographs of Hong Kong protests that showed long lines of individuals trying to purchase subway tickets with cash so that electronic purchases would not place them at scenes of protests. “These photos underscore the importance of anonymous transactions for civil liberties,” the EFF said. 

The EFF also urged FinCEN to allow at least 60 days for consultation in order to correct “the serious abnormalities of this rulemaking process.”