CEPS Project

EU Initiative on Restrictions on Payments in Cash to Combat the Financing of Terrorism

Evaluation of the Existing National Policies in the Context of the Preparation for an Impact Assessment Regarding Possible Options for a Future EU Initiative


This report presents the assessment of the impacts of a potential EU measure on cash payment restrictions (either a prohibition or a declaration obligation). Impacts are estimated across categories ranging from terrorist financing, money laundering to tax evasion, and distortions in the Internal Market. Even though an effort is made to quantify impacts, obviously not all impacts can be fully quantified because of data limitations. In those cases where this was not possible, the direction of impacts is as much as possible evidenced and made plausible by data, which is available.
In the course of this study, we have consulted a wide range of stakeholders. We would like to thank them for their valuable insights in the matter. It should be noted that the findings in this report represent the analysis and assessment by the team of consultants and does not represent in any form a position of the European Commission. Furthermore, as the report looks at the impacts of a potential EU measure on cash payment restrictions, it does not deal with the legal feasibility of any such measure.


This project was awarded under the Multiple Framework Service Contract in Competition for the provision of evaluation and evaluation related services, including support for impact assessment activities (2016 ECFIN 009/A) with the European Commission, DG ECFIN. The full list of CEPS’ Framework Contracts is available here.

Antonella Zarra

Matthias Busse


+32 (0)2 229 39 45

Willem Pieter De Groen

Associate Senior Research Fellow