We look at the future of cash in the light of the emergence of a global digital currency, and the paper released for discussion by the Reserve Bank of New Zealand.
There is an interesting paper the Reserve Bank NZ has put out, seeking comments by 31 August. The Future of Cash Use. It was issued in June 2019.
The paper describes the transition to digital alternatives, and explains some of the reasons. But what caught my eye was this section. “All members of society will lose the freedom and autonomy that cash provides, be more exposed to cyber threats, and lose the ability to use cash as a back-up form of payment”. And “other activity in the shadow economy is unlikely to be affected by the disappearance of cash as people find other ways to circumvent the law”.
So two points, New Zealand followers you might want to read the paper, and make a submission – not been much publicity so far.
Those following the DFA campaign relating to the War on Cash in Australia, here is more evidence that the proposal to ban cash transactions above $10,000 will not achieve their stated aims – but of course there is a wider monetary policy objective, as we have discussed.
6 Considerations arising from having less cash in society
Given the trends in cash demand and the cost pressures on the
commercial supply of cash in New Zealand, it is possible that cash will
become less widely available or used in the medium to long term. The
effects of less cash in society would be felt more keenly by certain
groups of people who rely on cash and for whom no practicable substitute
exists. The severity of these impacts would be worsened if the
transition to a society with less cash acceptance occured before
mitigating measures could be put in place. Further, the size of the
affected groups might not be large enough to motivate cash providers to
ensure future cash availability, but the size might also not be
negligible.
This section summarises the information in table 1 and Appendix A and
the issues that should be considered if cash use and availability
decline.
Issue 1: People who are financially or digitally excluded could be severely negatively affected.
Cash provides access to the financial system for those who face
barriers to financial inclusion. Further, in a society with less cash,
barriers to digital inclusion could become barriers to financial
inclusion.
Barriers to financial inclusion include limited access to the
banking system due to either a lack of trust in online security, skill
or motivation to use online financial platforms, or banking
restrictions. People who are not banked or have limitations to accessing
the banking system tend to be people without identification and proof
of address, people with convictions, people with poor credit histories,
people with disabilities, illegal immigrants and children.Elderly people
typically rely more than others on cash as a form of payment.
This could be due to low trust in online payments, low ability or
low motivation to learn new payment techniques. People with physical
disabilities, such as sight or intellectual impairments, might also find
cash a useful form of money. Children are also subject to financial
exclusion as banks do not issue debit cards to children under the age of
13. Further, New Zealand banks have full discretion in the customers
they service. This means that some people who do not meet certain bank
policies cannot obtain or keep accounts with those banks. Appendix A
describes additional groups that rely on cash rather than digital money.
Barriers to digital inclusion include insufficient internet
coverage, affordability constraints for technology hardware or data
plans, lack of skills, lack of confidence and low motivation to use
digital platforms. For example, even if people have access to the
internet they might not be motivated to upload personal details to an
online bank account due to privacy concerns.
Issue 2: Tourists, people in some Pacific islands and people who use
cash for cultural customs might be negatively affected if they cannot
use substitutes.
Tourists
Currently most tourists use cash as a reliable and easy-to-use form
of payment. Reserve Bank research has revealed that cash is typically
issued to Auckland and overseas and sent back to the Reserve Bank from
the South Island. This movement is likely due to the movement of
tourists. Many retailers in New Zealand do not accept credit cards (or
contactless payments) due to their higher interchange fees, preferring
instead to accept debit and EFTPOS cards (which require a New Zealand
bank account) that incur much lower costs for the retailers.We
are not aware of the extent to which inbound tourists’ own financial
services’ fees or portability, or their prior understanding of
transacting in New Zealand, influence this behaviour.
As per Appendix A, tourist access to payments in New Zealand could be
met by overseas-issued debit cards if cash were not available. Further,
competition might cause some retailers to accept tourist credit cards
despite higher interchange fees if cash was not available. Bounie et al
(2015) show that higher competitive pressures (the threat of losing
sales) increase the probability that a retailer will accept credit card
payments despite the higher costs.
Even if electronic payment alternatives were reliable, tourists might
be disadvantaged due to language and cultural barriers that create
actual and perceived barriers to payments in New Zealand. Further,
tourists might be particularly vulnerable to risks of robbery or loss
of payment cards if they could not rely on cash as a back-up payment.
Pacific Islands
Niue, the Cook Islands and Tokelau rely on New Zealand banknotes and
coins for their physical currency. The size of these island economies
has been thought to be a contributing factor to their use of New Zealand
currency. In addition, these islands are formally defined as states in
free association within the Realm of New Zealand. New Zealand banknotes
are also used in the Pitcairn Islands.
The Reserve Bank does not have a formal arrangement to supply these
economies with banknotes and coins. The supply of banknotes and coins to
these islands is facilitated by commercial providers, tourists, and
transfers from families. There are no ATMs on Niue and Tokelau. The Cook
Islands has two ATM providers and also issues its own banknotes and
coins. These islands also have access to digital money as in New
Zealand.
Cultural customs
New Zealand’s banknotes have been referred to as the country’s
business card. The designs on the notes represent many of our cultural
icons and contribute to our national cultural identity. Cash is also
used in many cultural customs in New Zealand. Some cultures that use
cash as gifts in traditional ceremonies might find that part of their
cultural identity is lost if they can no longer access cash easily. For
instance:
A Chinese custom is to give cash to junior family members and
friends during celebrations including New Year (Hoong Bouw — giving
money in red envelopes), at funerals, and during tea ceremonies in
traditional Chinese culture.
Some cultures have a wedding money dance where cash is gifted to
the bride and groom as they dance (the Philippines’ Saya ng Pera, and
the Taualuga in Samoa, Tonga and Western Polynesia).
Western cultures give coins to children who lose their baby teeth (Tooth Fairy).
Issue 3: All members of society will lose the freedom and autonomy
that cash provides, be more exposed to cyber threats, and lose the
ability to use cash as a back-up form of payment.
If cash use and availibility were to decline, an issue for all
members of society could be the loss of freedom that cash provides in
terms of autonomous spending and wealth stores, privacy, ability to live
off the grid, and ability to avoid the banking system. This could
result in a significant loss of social freedom in aggregate and
increased cyber security risks (leading to an increase in national
security risks). Lastly, society would lose the benefit of cash as a
‘back-up’ form of payment, although the usefulness of cash in this role
is limited.
Reduced freedom
Cash is anonymous, so provides consumers with autonomy or discretion
in how they choose to spend their money or store their wealth. The
feature of full anonymity creates personal and societal freedom and has
not been replicated in digital currencies. There are three elements in
this freedom; the first relates to the desire for privacy in making
transactions, the second relates to the desire to avoid banks or
government regulation, and the third relates to exposure to cyber-crime.
First, cash payments and balances cannot easily be traced. Central
agents and third parties (such as banks and governments) cannot easily
intervene or stop cash payments outside the banking system. This is a
unique feature of cash and is not fully replicated by any other form of
money. This anonymity gives people full control of and discretion with
their finances. Independent bank accounts could provide personal
freedoms but they are not always available or sufficient. For example,
individuals who are in abusive and controlling circumstances might
benefit from cash as it is easier to obtain and hide when other personal
freedoms are restricted.35
Additionally, people might feel that they benefit from the choice of
using an anonymous form of payment if it were ever needed.
However, the difficulty in tracing cash makes it relatively more
vulnerable to theft, accidental losses and fraudulent payments
(inadvertently accepting counterfeit notes). For this reason, some argue
that people would be better off with a partially anonymous form of
payment, where only the minimum information is given regarding the
identity of the payer and payee in each transaction, but each
transaction is recorded. These payments include, for example, vouchers,
and prepaid gift (debit or scheme) cards.36
Second, the offline and anonymous features of cash enable people to
separate their transactions and stores of wealth from the banking system
and some government interventions. There are legitimate motivations for
this separation.
There is currently no guarantee of the safety of bank deposits in New Zealand.37
Banks take household and business deposits and lend them to borrowers
— there is a risk that borrowers might not be able to service their
debts. Households and businesses could lose their deposits if banks were
engaging in overly-risky lending or if a severe series of events
occurred and many loans were not repaid.
People might also want to remove their savings from the banking
system if the Reserve Bank charged negative interest rates to stimulate
the economy. Cash provides an avenue for people to avoid this form of
government intervention or any other government intervention that might
occur in the future, such as capital controls.
Relatedly, people might want to store wealth outside the banking
system if they have low fundamental trust in banks or the government.
Examples are individuals who have immigrated to New Zealand from
countries where trust in the financial system is low, or where
government appropriations of assets were not uncommon. If there were
less cash in society, individuals would lose their privacy and autonomy
from government in the sense that all their transactions and savings
would be fully traceable if permitted by law.
Third, storing and transacting in cash reduces exposure to
cybercrime, such as financial losses and identity fraud. On a societal
level, New Zealand might be more exposed to cybercrime such as
state-funded cyber threats if it were totally reliant on the banking
system and digital money for all transactions and savings. On a personal
level, some people might prefer to keep their identities and finances
offline due to cyber concerns.
The loss of freedom in society in the above three areas could result
in demand for a form of digital currency issued by the central bank that
replicates some of the autonomy of cash. There are other assets in
which people could store their wealth that are offline and removed from
the financial system, for example, commodity assets and property.
However, these are more difficult to transform into spendable money and
can come with a different set of risks including fluctuating values.
Therefore, people might demand a central bank digital currency that
provides lower traceability than current electronic payments and
accounts and presents an alternative to the banking system. This could
be in the form of accounts with the central bank or tokens issued by the
central bank, which carry a very low risk of default and sit outside
the commercial banking system. A central bank digital currency could
also be designed to provide a low cost form of payment to put downward
pressure on uncompetitive prices in the payment system. Alternatively,
consumers might ask for deposit protection and greater regulation of the
banking system.38
People might also value the freedom and autonomy of cash for
illegitimate reasons. As noted in section 2, cash is used in the shadow
economy to facilitate illegal transactions or as a means to hide income
and reduce tax and other obligations. The International Monetary Fund
estimated New Zealand’s shadow economy at 11.7 percent of GDP in 1991
-2015. 39
It is difficult to assert what might occur in the shadow economy if we
had less cash. At the margin, some shadow economy activities could be
reduced as people consider the additional difficulty of engaging in them
without anonymous payments. For example, some people might be
dissuaded from buying illegal goods and services if they could not avoid
leaving electronic records of their purchases. However, it is also
possible that criminal activity would innovate to other mechanisms or
forms of payment discussed below.
There is debate on whether the anonymity of cash enables crime or
whether illegal transactions would continue without cash. Rogoff (2016)
and McAndrews (2017) agree that, without cash, criminals could use
commodity money (i.e. gold), foreign currency, and inflated invoices.
But they disagree on the extent to which these substitutes would be
used. Rogoff (2016) argues that there is no complete substitute for
cash, so criminal activity would be hindered if there were less cash in
society. McAndrews (2017) argues that inflated invoices would become the
most likely medium of exchange for criminals. He suggests that a
society without cash would likely move towards deeper institutional
corruption of businesses as criminals launder money obtained from
illegal transactions. He also warns that innocent businesses could find
themselves forced into money laundering as criminals look for businesses
to issue inflated invoices.
Issue 4 considers how some tax evasion might be reduced by less cash.
Loss of emergency back up
Cash can be a back-up payment mechanism when electronic payment
systems are not in operation or otherwise unavailable. The Reserve Bank
survey on cash use indicated that 37 percent of people held cash just in
case it was needed (i.e. not for immediate transactions). Cash is
particularly useful in case of ‘personal emergencies’, or localised or
short disruptions in electronic payments systems, and after large-scale
events conditional on the availability of retail stores able to accept
it. Figure 2 shows a spike in CIC as a percent of GDP in 1999 that could
be attributed to the ‘Y2K’ uncertainty.
Cash has several limitations in its usefulness as a back-up payment
in case of large-scale events or natural disasters. Because the supply
of cash and most retail operations are reliant on electricity and
communications, IOUs between small groups or people who are known to
each other might be more effective in periods of long electricity
outages such as those that occur in natural disasters. There might also
not be sufficient cash infrastructure capacity to meet a national
transition to cash in an emergency.
In addition, the National Risk Unit does not recommend including cash
in a civil defence kit or give guidance on the best means of payment in
a national disaster response period. This could be because people
already have their essentials in their civil defence kits, retail stores
might not be operating, and emergency responders will provide
additional supplies. In the weeks following the Christchurch February
2011 earthquake, public demand for cash did not increase substantially.
Commercial banks anticipated an increase in demand for cash and
increased their stores of cash and set up temporary ATMs based on
generators. However, the bulk of these cash stores returned to the
Reserve Bank relatively quickly. Figure 2 shows CIC did not peak as a
share of the population during 2011.
Issue 4: On balance, there would be limited effects on budgeting, financial stability and government revenue.
Transitioning to a society with less cash does not significantly or
negatively affect household budgeting, financial stability and
government revenue.
Budgeting
Cash is widely cited as a budgeting tool. Psychological studies show
that paying in cash incites a higher psychological pain of parting with
funds. This is because the tangible nature of cash results in high
transparency of payments and so generates a greater awareness of
spending.40
This greater ‘pain of paying’ encourages less spending and is useful
for managing discretionary spending, but it could reduce willingness to
pay bills or debt. Shah et al. (2016) suggest that consumers should
automate their essential payments and savings using online banking then
spend disposable (leftover) income using cash. Cash might also be useful
for limiting spending when people need to keep money separate for other
purposes.
People who prefer to use cash for budgeting might benefit from new
electronic budgeting tools such as budgeting applications on mobile
phones. For example, several banks in Dubai provide real time balance
updates or notifications every time money is spent, replicating the
relatively high ‘pain of paying’ that cash provides.
Cash is not the only nor the most important budgeting tool available
for people with low or no disposable incomes, high debts, overspending
habits, or poor mental health. For these groups, commonly cited
budgeting tools include awareness and education, direct credits,
multiple bank accounts, and removing overdrafts and credit. Cash is used
for people who are in full financial management in a Total Money
Management programme as they are allocated their weekly spending in
cash.41
However, the anonymity of cash makes it difficult for budgeting
advisors to identify areas of overspending. Cash also enables people to
default on automatic payments (for bills or debts) as they can withdraw
their full bank account balances into cash. Further, withdrawing money
into cash puts people at a higher risk of robberies than if they did not
withdraw their money. For example, people who withdraw their income
payments from ATMs at night to avoid automatic payments (processed in
the morning) face a risk of robbery, particularly if these habits are
well known in the community.
Financial stability
A society with less cash does not pose a risk to financial stability.
Cash represents a claim on the government and carries low default risk.
In theory, the ability of depositors to convert their savings into cash
represents a form of market discipline on banks that encourages them to
operate prudently. However, there is little empirical evidence to
support this. Engert et al. (2018) evaluate the bank runs during the
2007 – 2008 Global Financial Crisis and determine that cash withdrawals
are a small and unimportant source of market discipline on banks. Shin
(2009) finds that the Northern Rock bank run was triggered predominantly
by wholesale runs, and the in-branch runs to cash were insignificant.
Market discipline is only one form of discipline safeguarding our
financial system. Another form is regulatory discipline. The Reserve
Bank is mandated to use prudential regulation and supervision to
contribute to a stable financial system. The third form is
self-discipline, whereby financial market institutions self-regulate to
ensure their ongoing prudent operation.
The second aspect of stability is payment stability. Migrating from
two payment systems to one payment system would consolidate operational
risk in the single payment system. Greater emphasis would be required
on ensuring the operational reliability of the single payment system if
people could not easily revert to cash if there were a system outage.
Most electronic payments (except cryptocurrencies) rely on the same
back-end payment systems which, exhibit several single points of
failure.42
Increased tax revenue and reduced seignorage
Government revenue could be affected in two ways if cash use and
availability declined. First, removing the availability of notes and
coins might increase tax revenue as businesses would no longer use cash
to reduce their tax bills. The Inland Revenue Department has reported
that the most common ‘hidden economy’ activity is the underreporting of
taxable income, which includes income from cash jobs and transactions.43
Exactly how much tax revenue is lost due to this type of activity is
unknown. A tax working group paper suggests that unincorporated
self-employed individuals under-report approximately 20 percent of their
gross income. This estimate is based on a study commissioned by Inland
Revenue44
and could represent $850 million per annum in lost tax revenue from
unincorporated (non-trust or non-corporation) taxpayers. There is
considerable uncertainty as to the extent to which this number includes
self-employed people who are evading tax by underreporting cash revenue
versus other types of underreporting. It is also not certain that those
reducing their tax burdens by underreporting cash revenue would increase
their tax payments if cash were used less.45
Second, seignorage revenue might decline if the value of CIC declined
significantly. Seignorage revenue is the profit the Reserve Bank makes
from producing and selling cash and investing the profits, as well as
any profit the Reserve Bank makes from financial market trading. 46
The Reserve Bank estimates that it made around $148 million in
seignorage revenue last financial year by issuing cash and investing the
profits.
Other activity in the shadow economy is unlikely to be affected by
the disappearance of cash as people find other ways to circumvent the
law, as described in Appendix A. People who can no longer launder cash
will likely switch to other methods.
The ABC have written a piece on the proposed cash restrictions (even if it was after the closing date for submissions to Treasury relating to the exposure draft). It appears opposition is mounting, given they cite One Nation, CPA Australia, The Institute of Public Affairs and The Australian Chamber of Commerce. However, Chartered Accountants Australia and New Zealand argued the $10,000 cash limit was high, and needed to be lowered.
Australians could face two-year jail sentences and fines of up to $25,200 under proposed laws that limit the use of cash to $10,000 — a move some groups argue would create an Orwellian state by giving authorities greater control over people’s finances.
Key points:
The proposed law would apply to all
payments of more than $10,000 to a business with an ABN, such as buying a
car from a car yard
Private transactions between individuals with no ABN would be exempt from the new rules
One
Nation has indicated it will vote against the bill, as some business
groups argue it is an attack on the basic liberty of free exchange
A number of stakeholders have called on the Federal
Government to withdraw the proposed laws, which were first announced in
the 2018-19 budget as part of measures to fight the so-called black
economy.
The Government’s Black Economy Taskforce had argued a
$10,000 cash limit for transactions between businesses and individuals
would help fight the cash economy by stamping out tax evasion, money
laundering and other crimes.
The
laws would apply to all payments made to businesses with an ABN for
goods or services, affecting major purchases like cars, boats, housing
and building renovations.
The Government has said the measure
would not apply to individual-to-individual transactions, such as
private sales where the seller does not have an ABN, or cash payments to
financial institutions.
The laws, if passed, would take force on January 1, 2020, and for certain AUSTRAC reporting entities from January 1, 2021.
Senator Malcolm Roberts joins John Adams and Martin North on IOTP to discuss the draft cash ban legislation and he outlines One Nation’s policy position.
We extend the conversation into important broader issues including civil liberties, structural reform and media policy. A landmark event on IOTP!
Well, who would have though it. My show with the CEC’s Robbie Barwick has now had 105,000 views in the past week and counting. So this draft bill is really hitting a nerve.
This is the biggest audience we have ever had for any of our shows. Thanks to all those who watched it and shared it.
Still time to get your submission into the Treasury today, when the consultation closes.
The country of origin is also interesting with 50% based in Australia, followed by the USA, Great Britain Canada and New Zealand. So this has significant international interest.
And if I count up the messages I have received from viewers who have posted a response to the treasury, then they will have received not tens but hundreds of submissions. Now, I wonder if they were expecting that. And if they will report the true volumes received.
And if you have submitted a response, remember to also contact your local MP and Senators in your home states. Contact details are easily found on the Parliamentary website.
I have today submitted my comments to Treasury on their proposed bill, as we discussed in our recent post. I sent it to blackeconomy@treasury.gov.au
My overriding concern is that Parliamentarians will only consider the
narrow tax efficiency aspect of the Bill and vote it through without
grasping the true intent and consequences. Civil liberties are being
eroded, and the trap will be set to force households and businesses to
transact within the banking system, thus facilitating experimental
monetary policies, via the back door.
Currency (Restrictions on the Use of Cash) Bill 2019
I have carefully reviewed your exposure draft and wish to
register my strong opposition to the bill as proposed (which I may say includes
a whole blank section – which is surprising!).
Digital Finance Analytics is a boutique research and
analysis firm specialising in financial service sector. We undertake primary
research through our surveys, as well as deep research from the global
literature relating to financial services. We publish regularly via our online
channels at Digital Finance
Analytics as well as preparing reports on a range of related subject
matters for our clients, and we collaborate with a number of academics.
My objections are centred around the following points.
The Drafting of the bill is incomplete, so your review processes is flawed, plus there has been insufficient public discourse on the measures you propose thanks to the very limited time for consultation and the its release late on a Friday night.
Civil Liberties Are Being Eroded. Further public debate on these measures are warranted as they are fundamentally restricting personal freedoms. This is one in a series of measures which have been taken (including media freedoms) which are curtailing the hard-won freedoms Australians use to enjoy. Surveillance of offending transactions would be required if the Bill were passed. This is not explained, nor how it would be policed.
There Is No Cost Benefit. The stated
objective of the bill is to close tax avoidance and money laundering loopholes.
But there is no quantification of the potential “savings” – and this is also
true of the earlier Black Economy Taskforce report. It appears that simply
stating these desired objectives is seen as sufficient to justify the bill.
What is the cost benefit of such a measure, bearing in mind that transactions
which fall outside the exemptions would need to be tracked and examined? Who would police them, at what cost?
There are other more pressing areas of tax
leakage and AML risk. According to the OECD report “Implementing The OECD
Anti-Bribery Convention” released as part of the OECD Working Group on Bribery,
Real Estate is identified as at “significant risk” of being used for money
laundering. Among a raft of recommendations, is one saying Australia should be
“Taking urgent steps to address the risk that the proceeds of foreign bribery
could be laundered through the Australian real estate sector. These should
include specific measures to ensure that, in line with the FATF standards, the
Australian financial system is not the sole gatekeeper for such transactions”. To date these loopholes, remain open, as do
those relating the corporates and big business who, partly thanks to the
assistance of the large international accounting firms are responsible for the
lions share of tax leakage and AML activity. Our research suggests that
Government, under heavy corporate and business lobbying is deliberately letting
this slide, preferring to target in on a relatively inconsequential area of tax
leakage relating to cash transactions.
The Legislation Would Be Ineffective. Beyond
that, it is clear from our wider research of a range of sources that such a
proposed cash ban would have very little impact on hard core tax leakage. For example,
Professor Fredrich Schneider, a research fellow at the Institute of Labor
Economics at the University of Linz, Austria, a leading international expert on
the black economy has stated that there is a lack of empirical evidence that
cash transaction bans will help reduce the black economy. Schneider published a
paper in 2017 titled “Restricting or Abolishing Cash: An Effective Instrument
for Fighting the Shadow Economy, Crime and Terrorism in which he made this
specific point.
There Is Another Agenda. In addition, while
the Bill is silent on the connection to implementing negative interest rates as
part of unconventional policy, the link was made clearly in the 2016 Geneva
Report by the International Centre Monetary and Banking Studies (ICBM) titled:
What else can Central Banks do? This
paper which was drafted by officials from international organisations such as
the IMF/BIS and multiple central banks + commercial banks.
The IMF Shows Why. The same thematic came
through in recent IMF Blogs and working papers.
In April 2019, the IMF published a new working paper on how to deeply
negative interest rates work. In previous papers, the IMF has suggested that
nominal interest rates may have to go deeply negative, for example, -3% – 4%. First, they say “In summary, ten years after
the crisis, it is clear that the zero-lower bound on interest rates has proved
to be a serious obstacle for monetary policy. However, the zero lower bound is
not a law of nature; it is a policy choice. We show that with readily available
tools a central bank can enable deep negative rates whenever needed—thus
maintaining the power of monetary policy in the future.” Next they declare “Our
view is that, when needed, deep negative rates are likely to be worth the
political cost. While the complete abolition of paper currency would indeed
clear the way for deep negative interest rates whenever deep negative rates
were called for, such proposals remain difficult to implement since they
involve a drastic change in the way people transact.”
The Bill Is Connected to Negative Interest
Rates. The connection is obvious in that in a negative interest rate
environment households and businesses will be likely to withdraw funds from the
banking system and transact in cash. If enough cash is extracted, negative
interest rates will simply have no effect. We believe the measures proposed in
the current Bill are truly about enabling negative rates, yet this is not
mentioned within the Bill. This is misleading and deceptive. The true
motivations should be on the record. But it explains the short time frames.
The Structure Allows Change by Regulation
Subsequently. Finally, the structure of the Bill enables parameters to be
changed subsequently by regulation (not via Parliament). This opens the door to
removing some of the concessions contained in the current drafting by agencies
without full scrutiny. It is important
to note that where cash transaction bans have been introduced, the value
ceiling has been lowered. France has
legally prohibited cash transactions above 1,000 euros, Spain has legally
prohibited cash transactions above 2,500 euros, Italy has legally prohibited
cash transactions above 3,000 euros, and the European Central Bank ended the
production and issuance of its 500 euro note at the end of 2018.