POST Cash and compliance

As I always tell everyone, the fastest way to learn is by arguing with smart people. So I particularly enjoyed arguing with old chum Ian Grigg about the relationship between cash use and tax evasion. I decided to take the time to go and research some up-to-date figures.

The average bank spends £40m a year on KYC Compliance, according to a recent Thomson Reuters Survey, which also revealed that some banks spend up to £300M annually on KYC (Know Your Customer) Compliance and Customer Due Diligence (CDD).

[From The spiralling costs of KYC for banks and how FinTech can help | ITProPortal]

So let’s say a £1 billion for the big four and another £1 billion for the rest. So £2 billion in KYC. And that doesn’t include (obviously) the £5 billion that the UK Treasury estimates that UK banks spend on “financial crime compliance” (which I assume means AML, CTF and PEP). So… that’s something like £7 billion on compliance and presumably tax evasion is one of the main crimes that it is supposed to be tackling.

How does that compliance spend compare with the tax gap? The what? Well, the difference between what Her Majesties Revenue and Customs (HMRC) thinks it’s owed in theory and what it actually collects is called the ‘tax gap’. The tax gap is currently estimated to be £34 billion in the UK. 

It includes a number of things as well as evasion and avoidance. HMRC estimates that in 2013/14, differences in legal interpretation cost it £4.9 billion; unregistered paid work cost it £6.2 billion; organised criminal attacks cost it £5.1 billion; non-payment cost it £4.1 billion; the failure of people to take reasonable care with their tax returns cost it £3.9 billion; and honest errors cost it £2.6 billion.

[From Tax: evasion and avoidance in the UK – Full Fact]

By far the single biggest contribution to the tax gap is the underreporting of income by SMEs, especially those who take payments in cash. Everyone from your builder to your taxi driver contributes to this, which is why the scale of the evasion is so vast. Here are the HMRC figures broken down by source rather than type.

  • SMEs £16.5 billion.

  • Large businesses £9.5 billion.

  • Criminals £5.1 billion.

  • Individuals £3 billion.

That’s a lot of schools and hospitals. Everyone goes on about big companies like Apple and Facebook engaging in perfectly legal tax avoidance (blame the government not Google) but that’s not the biggest chunk of cash missing from the books. Now, no-one would be so dumb as to imagine that reducing cash would eradicate the tax gap. But it would raise the costs of tax evasion as well as the risks and therefore, I would think, at least reduce it. And given the dominance of SME cash under-reporting (it’s half of the tax gap) that would seem to be low hanging fruit, as they say. Maybe instead of spending all of this money on compliance, we should spend it on migrating away from cash?

The Privacy Dangers of a Cashless Society Were Clear Over 40 Years Ago

Some people really can seen into the future. 50 years ago this was already clear

In 1968, Paul Armer of the RAND Corporation testified in front of a U.S. Senate subcommittee about his concerns for privacy in the future.

[From

The Privacy Dangers of a Cashless Society Were Clear Over 40 Years Ago

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The first is that computer technology is introducing order-of-magnitude reductions in the cost of collecting, transmitting, and processing information.

[From 

The Privacy Dangers of a Cashless Society Were Clear Over 40 Years Ago

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Second, centralization of data is usually a concomitant of computer use. The payoff to successful snooping is much greater when all the facts are stored in one place. Though most of the data to complete a dossier on every citizen already exists in the hands of the government today, it is normally so dispersed that the cost of collecting it and assembling it would be very high.

[From 

The Privacy Dangers of a Cashless Society Were Clear Over 40 Years Ago

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The third factor is that computer systems with remote terminals can permit, unless proper safeguards are provided, remote browsing through the data with a great deal of anonymity.

[From 

The Privacy Dangers of a Cashless Society Were Clear Over 40 Years Ago

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Yes, I know, no cash does not mean no crime

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Last summer brought Sweden’s first Swish mugging, when two thugs beat up a man and forced him to Swish them. The criminals were rapidly identified by their account.

From Imagining a Cashless World – The New Yorker

This has to be a candidate for the most stupid crime of the year. I realise it is up against some pretty stiff competition – I absolutely love Drew Curtis’ Fark and some of the crimes curated there are jaw-dropping but, I mean… come on.

 

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The commission is on its third day of vetting traffic police officers in Mombasa where most have been found with huge M-Pesa transactions.

From Police officer on Sh45,000 salary moves Sh100m via Mpesa – Politics and policy

Who knew a life in public service could be so rewarding? 

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In other cases, rogue officers open mobile money outlets where an alleged offender is given the agent’s number and told to withdraw bribe money from their accounts — instead of sending. One does not need to be anywhere near the agent’s physical location.

At the end of the day, the rogue officers reconcile their dirty proceeds by making entries in the catalogue, including filling fictitious personal details of those who “withdrew” cash. 

From M-Pesa the bribe, and other tricks traffic police use – Daily Nation

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Junior officers in the police force were being used by senior police officers to get bribes from the public and send the money through specific M-Pesa accounts. It emerged during the vetting process that the senior officers had set a target for their juniors which they were supposed to meet daily.

From M-Pesa Transactions Led To The Sacking of The 63 Police Officers ▷ Tuko.co.ke

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Music Fans Start to Rock Japan’s Cash-Loving Economy – Bloomberg

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Credit and debit cards and e-money make up only 17 percent of the Japan’s retail consumption, versus 85 percent in Korea, 56 percent in Singapore and 35 percent in India, according to a 2015 report by the credit association. Usage in the U.S., which includes data only for credit and debit cards, exceeds 40 percent.

From Music Fans Start to Rock Japan’s Cash-Loving Economy – Bloomberg

I thought about a couple of things on reading this. First, it’s interesting how Japan (like Germany) is very cash dependent. The second is that the US doesn’t have e-money.

Cash on principle

While I was behind enemy lines at Security Printers 2016, I picked a copy of a report from Guillame Lepecq’s Cash Essentials.

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One section of the report talks about the European Commission’s 2010 recommendation on Legal Tender, which I’ve written about before.

A bank person mentioned to me that they think the European Commission’s recommendation on legal tender (22nd March 2010) is, as he put it, “strange and undesirable”.

From Tender moments | Consult Hyperion

After I’d taken the time to read and reflect on the recommendation, I posted a more sober and balanced perspective, explaining why the recommendations are wrong.

the European commission published a bonkers recommendation concerning the legal tender status of the euro

From Electronic legal tender | Consult Hyperion

One of the main reasons that I thought that the recommendations were bonkers is because they have no strategic context and no economic purpose. They are wholly political.

As Norbert Bielefeld of the European Central bank noted in his excellent article “Dare to be bold: electronic legal tender is an option” in the EPC newsletter back in May 2011, the recommendation flatly contradicts the European Union’s strategic objective to switch to electronic payment methods in order to reduce the total social cost of payments across the member states

From Electronic legal tender | Consult Hyperion

So, as you can imagine, after reading Cash Essentials I thought I just had to blog something about these recommendations again! The Cash Essentials report sets out the “guiding principles” of the recommendation. Here are the first four, all of which are, in my opinion, wrong.

  1. Legal tender: mandatory acceptance of banknotes and coins, for full face value with the power to discharge debts. This is wrong because no-one should be forced to accept payment in anything. Legal tender, in English Law at least, does not mean what people think it means. It does not mean that shops have to accept cash: it means that if you incur a debt, you can settle it with central bank cash and have the debt discharged. If a shop wants to accept cowrie shells, Bitcoins and Avois that is up to them: you don’t have to do business with them and they don’t have to accommodate your fivers.

  2. Can can only be refused for “good faith” reasons (e.g., retailer has no change).This is wrong because even if the mandatory acceptance of principal one exists, there is no way to determine what “good faith” means.

  3. The acceptance of high denomination banknotes should be “the rule”. This is wrong because of principle two. Just as “good faith” is meaningless, so “the rule” is meaningless. And that’s is not even taking into account that it is wrong for society to have these high denomination notes in circulation.

  4. No surcharges on cash payments.This is wrong because retailers should be allowed to surcharge for whatever they want. If the Commission wants to single out the payment that has the lower total social cost and make that the benchmark, then it is PIN debit. The rule should be no surcharging for PIN debit but allow surcharging for everything else.

I won’t go on. Except to talk about the later recommendation about coins for a moment. Coins? Yes, the recommendation goes on to insist that retailers accept the 1- and 2-euro cent coins and that governments do not allow “rounding”. To understand why anyone would make such a baffling recommendation, you have to understand that the euro is for some people (e.g., the Commission) a political project. To retailers, and to most other people, the small coins are pointless and a waste of time and effort. But the to Commission they represent an aspect of the European family and to refuse them is a slap in the face to political union. There are people out there who think that producing the smallest denomination coins is a ridiculous affectation and it may be time to stop: if there are none of these coins in circulation then retailers won’t have to accept them so the Commission’s principle is redundant.

Mark Carney, the Governor of the Bank of England, has suggested that the 1,200-year-old British penny could be scrapped.

From After 1,200 years, could it really be time for the penny to be dropped?

Actually, I’ve suggested it more than once and even tried to get a No. 10 petition about it going, but just because he’s the Governor of the Bank of England his plagiarised proposal gets all the attention. Meanwhile, across the Irish Sea, the Commission’s recommendation appears to have fallen on deaf ears.

Some 126 million coins have been taken out of circulation since a scheme was introduced to round shoppers’ bills up or down.

From 126 million coins taken out of circulation

Ireland can do it, why can’t we? Minting one penny and two penny, one cent and one euro cent coins is insane. The European Commission might stand against rounding, but even in that last redoubt of currency conservatism, the United States, the writing is on the wall and rounding is taking root. For one thing, they are a waste of time.

According to a study undertaken by the National Association of Convenience Stores and Walgreens, handling pennies adds 2 to 2.5 seconds to each cash transaction.

[From The Fight Against the Penny | News | Oakland, Berkeley, Bay Area & California | East Bay Express]

Who can blame retailers..

[Ken Martin decided] to stop using the coins in his eleven Bay Area stores in June 2011… Although Mike’s Bikes and Cheeseboard Pizzeria still accept pennies as payment, neither store hands them out in change. Instead, both stores round transactions down in the customer’s favor to the nearest nickel. Although the stores lose a little from the rounding, Adams said it’s ultimately worth it: “For us, it’s a net savings. It’s more convenient, and the time it takes to roll the pennies and deal with them makes it worth it.”

[From The Fight Against the Penny | News | Oakland, Berkeley, Bay Area & California | East Bay Express]

It is clear that, even to those who want to promote the use of cash over electronic alternatives, that the small coins have to go. It is impossible to understand why any most is wasted on their development and manufacture.

The Swedish central bank’s recent release of a new line of bills and coins struck her as foolish. “It’s trying to be more like the E.U.—two-kronor coins and things like that,” she said. “But it’s, like, why? What’s the point? No one uses it anymore.”

From Imagining a Cashless World – The New Yorker

Whatever the European Commission might think,  I don’t think retailers should be forced to accept cash at all, but if they are, there’s no reason why they should accommodate the extremes: the 1- and 2- cent coins, the €200 and €500 notes. Let them wither or, better still, just get rid of them altogether.

Top 10 technology forces that will shape financial services in 2020

The accountants PwC have published a report that lists the ten most important technology-driven forces that will shape competition in the financial services industry by 2020 for financial institutions. They say that these are:

  • FinTech will drive the new business model
  • The sharing economy will be embedded in every part of the financial system bringing together those who have excess capital with those that need financing, leading to the disintermediation of traditional lending models
  • Blockchain will shake things up
  • Digital becomes mainstream
  • ‘Customer intelligence’ will be the most important predictor of revenue growth and profitability
  • Advances in robotics and Artificial Intelligence (AI) will start a wave of ‘re-shoring’ and localisation
  • The public cloud will become the dominant infrastructure model
  • Cyber-security will be one of the top risks facing financial institutions
  • Asia will emerge as a key centre of technology-drive innovation
  • Regulators will turn to technology.

From Top 10 technology forces that will shape financial services in 2020

I really don’t think that blockchain will shake things up by 2020, but that’s just an opinion. Anyway, I want to pick on three of the PwC forces to open up some more discussion.

AI and reshoring. XXX. Many years ago I wrote a piece for a financial services client saying that I thought that call centres and other support services in India would, because of voice recognition and voice authentication, eventually be replaced by a rack in a data centre, not by cheaper call centres in Vietnam of wherever.

Public cloud. XXX.

Regtech. XXX.

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