The following paper was originally produced as a submission of the Organized Crime Observatory, Geneva, to the European Commission.


[The European Commission announced a public consultation on the March 1, 2017 with respect to cash payment limitations (CPLs) following the adoption of the action plan of the February 2, 2016 “against the financing of terrorism”. This action plan suggests that because “payments in cash are widely used in the financing of terrorist activities”, we should explore “the relevance of potential upper limits to cash payments”.

The goal of detecting, monitoring and investigating serious crime is beyond dispute, but there are serious doubts as to whether CPL would advance this cause substantially or that any incremental benefit would be without considerable negative effects. Cash is popular, safer and serves a long list of legitimate social and economic values that CPL would undermine.

Arguments for a “cashless” or “less cash” society are also made for convenience and facilitation of payments, shorter remittance timelines and better control for monetary and tax policies. Cashless is a buzzword for commercial and internet giants such as Amazon, Google and Facebook and telco companies such as Apple and Vodafone[1].

While traceability is a worthwhile goal for law enforcement, one cannot sacrifice economic interests and livelihoods, freedoms, privacy, subsidiarity, proportionality and indeed the cash preferences of the people for what is likely to be incomplete and ill-balanced transparency and, in some respects, more challenging policing work.]

See the full publication here.