The detector that went blind: crypto assets, money laundering, and the Lucas critique
DOI:
https://doi.org/10.1590/SciELOPreprints.18334Keywords:
money laundering, crypto assets, bitcoin, lucas critique, machine learning, financial regulationAbstract
This paper trains a detector of illicit bitcoin transactions on the public Elliptic data set (203,769 transactions over 49 time steps of about two weeks each) and shows that its out-of-sample performance collapses after the shutdown of a major dark web marketplace: the detection rate falls from 86% to 2% from one time step to the next, and retraining on the few post-shock observations does not restore it. The episode, already noted by the authors of the data set, is read through the lens of the Lucas critique (1976): a detector estimated on past data summarizes how agents behaved under a given enforcement regime and breaks down when enforcement itself changes that behavior. The paper discusses the implications for Brazilian anti-money laundering regulation, recently extended to virtual asset service providers: continuous validation of monitoring systems, period-by-period rather than aggregate evaluation, the complementarity between algorithms and investigation, and the cost of false alarms.
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Copyright (c) 2026 Jose Carlos de Souza Santos

This work is licensed under a Creative Commons Attribution 4.0 International License.
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