Karsten Wenzlaff, Advisor
August 26th, 2025

Do we have a right to anonymous payments? If so, is this right linked to certain payment instruments, such as cash? Does this right apply equally to payers in the analogue and the digital world? For most people, the daily payments initiated as market participants are unavoidable. It has therefore become one of our basic needs, like sleeping and eating. The right to anonymity, which can be regarded as an essential pillar of a modern democratic society, is generally derived from the fundamental rights to freedom of expression and informational self-determination.
This right is by no means limited to the analogue world. For example, we have the right to browse the internet anonymously, using appropriate software and pseudonyms. Does this right also apply to the payment act? In the analogue world, this right is indirectly established by the existence of cash. Cash leaves no traces of data and, due to its special status as legal tender, it is a means of payment
As long as there is still cash as legal tender, we therefore do not only have the option, but also the right to anonymous payments. The interesting question of whether this right can also be enforced anywhere and at any time (e.g. when paying the broadcasting licence fee) has been debated by the German courts for quite some time, at ever higher levels.
As a means of payment, cash, which is still dominant today, is gradually losing in importance (not, however, as a means to store value). The shift in demand in favour of online retailing has contributed to this, as cashless payments are usually the only option in that area. In the future digital world with, for example, the Internet of Things and automotive payment applications (pay per car), the only thing that will remain are cashless digital payments. In Germany, the right to anonymous online payments is only protected by law for the use of telemedia (Sec. 13 No. 6 of the German Telemedia Act – Telemediengesetz).
The German party SPD was the only party who was consistent and future-oriented in its election campaign program in 2017 in this regard as it demanded a general right to anonymous cashless payment. And rightly so, as why should I have to forfeit my elementary rights from the analogue world when entering the digital world, which is inevitable nowadays? The demand of the SPD party was an important step forward, which unfortunately was again deeply buried in the slightly childish games in the sandpit of the grand coalition.
Is this demand even technically feasible? “Cashless + anonymous” is not an inherent contradiction. In contrast to a cash payment, there is always data on the payment process, but not necessarily on the identities of the payer and the payee. This means that digital payments can also be made while maintaining anonymity. You don’t have to surf the Darknet and pay with Bitcoins to achieve this. Digital payments with an anonymous prepaid card (e.g. a gift card) demonstrate how easily this can be done. Since the mid-1990s, analogue cash has been capable of being used digitally 1:1 as an anonymous bearer instrument without any further complications. If technology is not the problem, then what is?
Let us recall the chutzpah of EU Directive 2018/843 (better known as AMLD5), which has to be implemented by 10 January 2020. In its first draft (2016), the Commission wanted to ban anonymous cashless online payments using e-money. Anonymous e-money payments at the physical POS have not yet been banned, but the thresholds have been significantly lowered (from EUR 250 to EUR 150). In this segment, the door should not be slammed shut completely, as prepaid cards currently still make an important contribution to social and financial inclusion according to recital 14. In addition, according to the Commission’s Impact Assessment Analysis on the draft directive, a ban on anonymous payments in this segment would not be very effective as cash can still be used here.
AMLD is obviously intended to prevent money laundering and terrorism financing. There was no evidence of money laundering with anonymous prepaid cards. On the contrary, the current scandals show that money laundering in the billions is mainly carried out via non-anonymous accounts by fully identified bank customers (Danske Bank in Estonia, ING Bank in the Netherlands, Deutsche Bank in Russia, etc.). The only remaining argument is therefore terrorism financing. There was vague evidence, which has not yet been verified, that in the Paris attack (November 2015) the Islamic terrorists used an (anonymous?) prepaid card.
The consequence is to abolish the right to anonymous cashless payment on the internet for half a billion EU citizens. As a passionate cyclist, I am delighted that the terrorists did not use an anonymous bicycle when they fled, for otherwise the Commission would have introduced the same questionable logic of compulsory bicycle registration and the use of number plates throughout Europe.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
![]() | ![]() | ![]() |
|---|---|---|
![]() | ![]() | ![]() |
McKinsey & Co | Olivia White, Anu Madgavkar, Tawanda Sibanda, Zac Townsend, and María Jesús Ramírez | Jan 26, 2021
Governments worldwide reacted to the COVID-19 crisis with an outpouring of financial aid to businesses and individuals that was exceptional for both its size and the speed with which the disbursements were made. According to the IMF, fiscal measures announced globally amounted to $11.7 trillion, or close to 12 percent of global GDP, as of September 2020. As a result, the pandemic has served as a high-stakes, real-life stress test for the financial infrastructure in many countries, bringing into sharp relief critical gaps and opportunities as well as providing valuable lessons about how to improve efficiency and resilience for the future.
What determines how effectively the money is disbursed, for achieving the design ambitions of the program and delivering the funds rapidly to the intended recipients? This question has been drawing the attention of economic researchers, policy makers, fintech innovators and civil society watchdogs alike. Building on our pre-pandemic research on the economic impact of digital identification and digital financial inclusion, we studied a sample of 12 government economic disbursement programs for both individuals and small and medium-size enterprises (SMEs) in seven countries—Brazil, India, Nigeria, Singapore, Togo, the United Kingdom, and the United States.
Several findings stand out. First, we find that effective programs have three critical structural features of financial infrastructure: digital payment channels, the presence of a basic digital identification system with broad population coverage, and simple data on individuals and businesses that are tethered to the ID.
When these features were present in country-level financial infrastructure, these programs could be optimally designed and delivered quickly. When one or more of these infrastructure features was not present, countries had to make trade-offs between the design ambition (the scope, scale, and specificity of beneficiaries targeted) of their programs and their delivery success (the speed, coverage, and fraud levels in rolling them out).
Second, we estimate that the potential economic gain from building robust digital financial infrastructure is about 20 percent greater now than it was before the pandemic. Before the COVID-19 crisis, we estimated the potential economic gain by 2030 from applying basic and advanced digital ID to a wide range of interactions between individuals and government and nongovernmental institutions to be in the range of 3 to 13 percent of GDP. Finally, the crisis has underscored the resilience and flexibility that a robust financial infrastructure for SMEs and individuals provides, and thus its importance as a critical tool for responding to unexpected and potentially catastrophic events.
Beyond the potential economic impact, investing in digital financial infrastructure can help governments protect their populations in other important ways with long-term benefits. Effective government support in times of need helps prevent extreme poverty, hunger, and inequality, among others.
This cannot all be measured in GDP growth. Financial infrastructure is relevant for the effectiveness of broader national government programs in more normal times, as well as interactions between individuals and non-government institutions (Exhibit 4).
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
![]() | ![]() | ![]() |
|---|---|---|
![]() | ![]() | ![]() |