By Graham Vanbergen – On the 23rd January 2017 the EU Commission issued the “Commission Initiative Roadmap”
for 2018 regarding the step up fight against the financing of
terrorism, also known as its ‘Payments Restriction Initiative’ or as we
are reading more often, the cashless society. This document is an
extension of the communication document dated February 2016
(COM-2016/50) and updated to include new regulations for member
countries to implement and future intentions by the Commission.
The policy looks to the “Regulation on the controls of cash entering
or leaving the Community and relevance of potential upper limits to
cash payments.” The Action Plan states that “Payments in cash are widely
used in the financing of terrorist activities.” In its conclusions on
the fight against terrorism, the Economic and Financial Affairs Council
of 12 February 2016 called on the Commission “to explore the need for
appropriate restrictions on cash payments exceeding certain thresholds.
In particular the Proposal for an amendment of the Anti-Money Laundering
Directive2 (COM (2016) 450), which introduced stricter transparency
rules and other measures targeted specifically at terrorism financing.
Furthermore, the initiative should be seen in conjunction with the ECB’s
decision of 4 May (20163) to discontinue the production of the EUR 500
banknote and stop the issuance of this denomination by around 2018 to
address concerns that these notes could be used in financing illicit