Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697641607301.pdf (Australia)
Submission: to the Senate Committees Regarding the Currency (Restrictions on the Use of Cash) Bill 2019 Dear Manager, Thank you for giving myself and the public an opportunity to provide feedback on the Currency (Restrictions on the Use of Cash) Bill 2019.

My submission addresses a number of key issues that have not yet been addressed in the bill or discussed publically.
For that reason I strongly oppose the current version of the bill drafted by the Australian Federal Government as the potential negative implications out way any potential benefits.

In my submission I have laid out nine agenda items that I have derived by researching reports, articles and statements from a variety of sources.
As these items have not been addressed, the bill as it currently stands can have harmful impacts on the general public, therefore the bill requires significant discussion, consultation, debate and a thorough cost benefit analyses.
The nine agenda items are listed below; 1) Freedom and Civil Liberties 2) The IMF and the Black Economy Task Force – Linking Ban on Cash to Tackle Negative Interest Rates 3) The Size of the Australian Black Economy 4) Cost Benefit Analysis 5) Banning Cash Transactions Over 10K….For Now 6) Technological risk and limitations 7) Negative Impact on Industries 8) Benefits the Banks – But how about the Australian People?
9) Royal Banking Commission Exposes the Banks Freedom and Civil Liberties I believe introducing a ban on cash limits my freedom to use and spend my money the way I want.

All Australians work hard to earn a wage and make a living, therefore we deserve and earn the right to use and store our money freely.
As a hard working proud Australian, introducing a substantial fine and long term jail time for using a method of payment that has been accepted since the monetary system was born seems harsh, unfair, unfounded and unjustified.

Freedom of speech, freedom of choice and freedom to transact should never be taken away from us, which is occurring in other countries and we are starting to see that happen in Australia.
Many of the riots happening globally are due to a number of reasons, but commonly include; Governments enforcing capital controls, restricting financial freedom, limiting cash transactions & withdrawals and supporting big financial institutions at the expense of the people.
Currency (Restrictions on the Use of Cash) Bill 2019 [Provisions]Submission 75 Therefore based on my research highlighted below, restricting cash transactions has a minor influence on the black economy, supports the big banks at the expense of the Australian people and has a major impact on civil liberties.
The IMF and the Black Economy Task Force – Linking Ban on Cash to Tackle Negative Interest Rates Forcing Australians into the digital banking system removes the safeguard money provides as a counterbalance to experimental monetary policy.
This is highlighted in a recent article published by the International Monetary Fund (IMF) title "Cashing In: How to Make Negative Interest Rates Work", state that in order for low/negative interests rates to be effective in the current monetary system, Governments and banks need to restrict the use of cash.
Source: https://blogs.imf.org/2019/02/05/cashing-in-how-to-make-negative-interest-rates-work/ Source: https://mobile.abc.net.au/news/2019-08-26/cash-ban-so-you-pay-the-bank-to-hold-your- money-what-imf-wants/11443646 The report submitted by the Black Economy Taskforce also referred to a similar statement as per p48 of the report: “Some economists, including Ken Rogoff argue that financial stability and the effectiveness of monetary policy may also benefit.” Source: Task Force – Chapter 3: Moving to a near Non-Cash World, p48.
The Taskforce and the IMF therefore make statements suggesting negative interest rates are likely to occur — a situation where instead of receiving money on deposits, depositors must pay regularly to keep their money with the bank.

Therefore according to the IMF and the Taskforce, they suggest Governments and banks should restrict the use of cash to support low to negative interest rates by ensuring cash stays in the financial system.
Considering these statements linking to low/negative interest rates, this topic therefore requires to be discussed in length during the hearing.

Not discussing this link means the statements made by the IMF and the Australian Black Economy Taskforce is considered by the Government irrelevant and incorrect.

The Size of the Australian Black Economy Multiple and recent research indicates that the Australian Black Economy is actually quite small in size and continues to decline.
If the black economy was much bigger and increasing, then I would agree it is a problem that needs to be addressed in this country, but that isn’t the case based on strong research.

Currency (Restrictions on the Use of Cash) Bill 2019 [Provisions]Submission 75 On top of that, several countries with heavy cash bans in place actually have much larger/growing Black Economies.

Please refer to the research articles below.


Source: Medina and Schneider, Shadow Economies Around the World Source: IMF Working Paper, Shadow Economies Around the World: What Did We Learn Over the Last 20 years?

These papers suggest;    The size of Black Economies increases when cash is restricted.

The size and declining rate of the Australian Black Economy suggest it is NOT a significant problem in this country.

There is a lack of evidence that restricting cash will help reduce the Black Economy.
Cost Benefit Analysis (CBA) After reading the bill and the report made by the Black Economy Taskforce, I can’t see any factual evidence supporting their estimated benefits to the economy.

All significant bills should be supported and grounded by research and strong evidence to support the bill’s objectives.

The savings suggested are purely a potential and estimated figure without justification.

There is no detailed information on how the Ban on Cash will be policed and how much it would cost to enforce.
How much additional tax revenue is required to police and enforce this law?

Will the revenue outweigh the costs?

What research or studies were conducted to come up with these conclusions and figures?

Is it a conflict of interest that the members of the Black Economy Taskforce are involved in the banking system at some capability?

These are the type of questions that should be raised and discussed during the hearing.
As statement by the Australian Government; “A CBA involves a systematic evaluation of the impacts of a regulatory proposal, accounting for all the effects on the community and economy, not just the immediate or direct effects, financial effects or effects on one group.

It emphasises, to the extent possible, valuing the gains and losses from a regulatory proposal in monetary terms”.
Source: https://www.pmc.gov.au/regulation/guidance-policymakers/cost-benefit-analysis Banning Cash Transactions Over 10K….For Now According to the proposed Restrictions on the Use of Cash Bill, the regulations outlined in the bill can be changed without bringing it back to Parliament at any time.
Meaning any new regulations or changes introduced by the Minister require the majority of the senate to make it disallowable, which is unlikely Currency (Restrictions on the Use of Cash) Bill 2019 [Provisions]Submission 75 to occur.

As the bill is very opened ended, it provides the Government the right to reduce the cash limit fairly easily without public and robust discussion and feedback.
The reduction of the cash limit will likely be reduced as envisioned by the Black Economy Taskforce, and a study by the European Commission suggests that the most effective threshold is closer to $1,500 AUD.

Source: https://ec.europa.eu/info/news/economy-finance/security-union-commission-publishes-report- restriction-payments-cash-2018-jun-13 en Many countries since introducing a ban on cash have since lowered the threshold, for example France, Spain, Italy and India just to name a few.
It is therefore suitable to suggest the ban on cash amount will be reduced by the Australian Government.

So I feel the discussion should be around the likely event of a lower threshold.

Technological risk and limitations There are several examples where outages and technical failures in cashless card systems and online payment infrastructures have left Australians unable to pay their bills, get paid, buy necessities or conduct transactional business.
Although these occurrences are inconvenient, the use of cash allows Australians to still transact during these system failures.

My question is, how can Australians transact when online payment systems are down while there is a ban on cash in place?

It seems that the Government will need to introduce many exemptions in varies parts of the country at different times, which I would imagine will be difficult and expensive to manage, enforce and monitor.
Does the effort and costs outweigh the estimated benefits of banning cash?

Does enforcing a ban on cash in an environment where these outages are common, increases the risk of financial hardship and quality of life?

The articles below pant a disturbing picture on the impact outages have had on the general public.
Source: https://www.abc.net.au/news/2019-10-17/commonwealth-bank-customers-hit-by-national- outage/11611814 Source: https://www.nvi.com.au/story/6481581/telstra-customers-affected-by-outage-may-receive- compensation/ Source: https://www.dailymail.co.uk/news/article-6605945/Mother-stranded-37C-heat-cashless- welfare-card-crashes-leaving-thousands-without-cash.html Negative Impact on Industries?
Currency (Restrictions on the Use of Cash) Bill 2019 [Provisions]Submission 75 It is clear the ban on cash benefits the banks as stated by the IMF and the Black Economy Taskforce, but there is evidence that the restriction of cash has a negative impact on multiple industries.
For example, according to the IMF when the restrictions on cash were introduced in India, they stated – “the disruption caused by cash shortages dampened consumer and business sentiments, leading to a decline in high-frequency consumption and production indicators”.

Several articles out of India report that many vibrant industries have suffered due to restrictions on cash.
Source: https://www.imf.org/en/News/Articles/2018/08/06/pr18330-india-imf-executive-board- concludes-2018-article-iv-consultation Source: https://www.entrepreneur.com/article/304303 Source: https://www.deccanherald.com/business/budget-2019/no-study-done-to-assess-impact-of- cash-ban-govt-744492.html A number of industries in Australia transact in cash as it is convenient, fast, cheap and free to do so.
As restricting cash has been negative in varies industries in India, the Australian Government must undertake a robust study to find out the impact of demonetisation in a variety of industries in Australia.

Many submissions sent to Treasury from 26 July 2019 to 12 August 2019 made by industry bodies clearly outline their concern this bill may have on their industry.
Source: https://www.treasury.gov.au/consultation/c2019-t395788?fbclid=IwAR1iZwh- Hln8VN7eCVLQgk03bZ1pM4E8f9HUahHOObq8MoKEsFXdTQydKLE Benefits the Banks – But how about the Australian People?
Forcing the Australian public to keep their cash in the banks clearly benefits the financial institutions, but the points I highlight below make it clear it disadvantages the public;  As the Australian public would be forced to pay using credit and debit transactions, this increases the number of transaction and banking fees paid by the individual.

Cash payments are free.

Banks could introduce additional fees to compensate for negative interest rates.
  Money stored in the bank is no longer your money, it is considered an investment the individual makes to that financial institution, therefore if the bank gets into financial trouble or closes, your money is at risk of been taken away.

This could also occur through the Bail In act (Financial Sector Legislation Amendment (Crisis Resolution Powers and Other Measures) Act 2018).

Exposes your personal information to a possible data breach.
The poor and those without bank accounts will have difficulty paying and receiving payments.

  I therefore think Parliament are required to discuss these implications and determine how these could be addressed.

Currency (Restrictions on the Use of Cash) Bill 2019 [Provisions]Submission 75 Royal Banking Commission Exposes the Banks The Banking Royal Commission was only the tip of the ice berg in exposing the criminal and unethical activity of the banking industry.
The stories reported publically were frightening and shocking.

Yet the Government wants to introduce laws forcing people to adhere to a broken and corrupt system by keeping cash in the banks and in the current financial system.

Would this happen in any other sector?

Shouldn’t we fix the system first before forcing people into it?

Conclusion In summary, I am concern the Australian Government is attempting to pass the bill without considering the key issues I have laid out in my submission.
I personally found it unusual that the public were only given 2 weeks to make their submissions to the Senate, and these +3,000 plus submissions were only made public a few days before the Committee submissions close.

As the bill currently stands, civil liberties are being eroded, it is forcing individuals and businesses to transact within the banking system, and lacks evidential and robust research.
If the bill passes the way it is, the Government is facilitating experimental monetary policy in a private matter.

Currency (Restrictions on the Use of Cash) Bill 2019 [Provisions]Submission 75