SVA Calls for a Mandated Right to Pay in Cash to stay safe in the digital economy
With Australians losing more per person to scams than the US or UK, Scam Victim Alliance is urging the government to preserve cash access as a basic consumer protection in a broken digital economy.
We urge Treasury to view mandated cash acceptance as a critical measure to preserve consumer rights, limit harm from financial crime and uphold economic fairness
As a national network of scam victims and harm reduction advocates, we are acutely aware of the risks of our digital economy, which continues to fail Australian consumers and expose them to financial crime.
Many of our victims were trying to open a term deposit, buy a home or move or transfer their superannuation savings when they were targeted by criminals operating with impunity across Australia’s banks, digital platforms and telcos.
We urge Treasury to view mandated cash acceptance as a critical measure to preserve consumer rights, limit harm from financial crime and uphold economic fairness.
Australia needs a resilient and inclusive economy that allows cash to be accepted for essential goods and services
Digital fraud risks must be acknowledged as a driver of financial harm, with cash and cheques the only alternative for vulnerable consumers to transact safely Australians are being actively victimised by the lack of consumer protection in the digital economy, suffering higher per capita scam losses compared to the US and UK in 2023 and in 2024.
Banks and digital platforms have shifted accountability for modern fraud on to customers, rewriting their account terms and conditions to push scam liability onto customers.
Given that most of Australia’s fraud protections existed in the Cheques Act – and that cheques are being sunsetted – the right to use cash remains vital for protection from financial harm caused by lax digital and banking controls that have seen cyber-enabled crime flourish.
Many of our community members are so traumatised by their extreme financial losses that they wish to never use digital apps or online banking again.
The ePayments Code further harms consumers by actively blaming them for falling victim to a financial crime and ‘authorising’ their own loss.
Australia’s Banking Code offers more protection for consumers transacting face to face in a bank branch rather than online, which again underlines the need for broad access to cash and cheques.
• Payment misdirection fraud is the fastest growing scam type, according to the ACCC, so access to cash is a vital consumer protection.
Telcos, banks and digital platforms allow impersonation and deception with little consequence – the Scam Prevention Framework still has no codes or rules to hold corporations to account.
Banks charge interest on financial crime losses and the Australian Financial Complaints Authority endorses this . Consumers urgently need government to step up and hold a Royal Commission into the state of financial crime and money laundering across Australia’s digital economy.
Scam Victim Alliance believes the scourge of financial crime can only be addressed when the government realises the true extent of how corrupted Australia's payments system has become.
There are regulatory loopholes, rampant money laundering and profit-seeking from legitimate and illegitimate stakeholders that effectively make authorised push payment frauds legal and highly successful.
MONEY LAUNDERING ON THE STREETS OF MELBOURNE
Hope & Tom Clifford had their $250,715 property settlement money stolen in a sophisticated fraud that was set up on Snapchat with a $5000 offer to a money mule. The mule then drove around the streets of Melbourne, laundering the $250,715 by buying a gold bar, changing it into foreign currency and withdrawing cash.
Dubbo couple Hope and Tom Clifford had their $250,715 property settlement stolen by a mule with a Commonwealth Bank Account. Court documents revealed the mule was paid $5000 by malicious actors to receive the Clifford’s misdirected funds into his personal bank account, which is still operated by the mule today.
The crime gang network had also breached the Clifford’s solicitor’s email to send a forged and misdirected Commbank payment instruction to the Cliffords.
The Cliffords then went into their local NAB branch to do the payment in person. Court documents reveal the money mule was driven around Melbourne withdrawing cash from ATMs, buying foreign currency and a $94,000 gold bar with the $250,715 proceeds, which meant no money was recoverable to the Cliffords or their bank.
The mule received just 150 hours community service, with no conviction recorded. The justice system did not force a recovery or compensation order on to the mule.
No other people were arrested. This level of on-shore money laundering reveals the need for a whole-of-society approach to fighting financial crime.
The initial misdirected payment happened inside a NAB bank branch, while NAB was engaged in an enforceable undertaking with AUSTRAC to prevent money laundering.
• Digital fraud is a daily threat, not a fringe issue In this context, cash is not just a payment method—it's a tool of financial autonomy.
It is the only payment form that cannot be hacked, reversed, profiled, or denied by an algorithm. Mandated cash acceptance is one way for consumers to avoid the cybersecurity risks of online transactions.
APRA’s stakeholder survey reveals 91 per cent of banks, insurers and super funds describe cyber risks as critical or high risk, yet consumers often have no choice but to use it.
The government's own data confirms that scam losses are rising, and digital systems are failing to prevent it.
Maintaining cash access is a practical safeguard for individuals who have been, or may become, financial crime victims.
People victimised by romance and investment fraud often have their digital financial identity compromised and become unwitting money mules — including hacked bank accounts, drained savings, and flagged bank transactions.
In the aftermath of their fraud, their online banking can be locked or put under investigation. Some of these people are also ‘debanked’ and not allowed to operate accounts again. Many are too traumatised to trust digital payment systems again.
Cash becomes romance and investment fraud victims' only safe and immediate way to:
• Regain financial control without relying on compromised accounts
• Pay for essentials like food, transport, and accommodation during recovery
• Avoid re-traumatisation from using the same digital channels where the abuse occurred
• Protect privacy and limit further surveillance or manipulation from perpetrators, especially in cases involving coercive control.
2. The cash mandate must apply to all essential goods and services
Limiting cash acceptance to fuel and groceries will exclude key essentials that people rely on to live, including:
• Medicines and pharmacy items
• Rent and housing costs
• Utilities (electricity, gas, water)
• Public transport and essential travel
• Telecommunications (phones and internet)
This is not a theoretical issue. Many Australians - especially older people, regional residents, people with disabilities, and financially excluded groups - are being left behind in the digital economy.
A narrow cash mandate creates loopholes that accelerate digital coercion and economic control by institutions, who continue to profit by turning a blind eye to financial crime on their platforms.
We urge Treasury to require cash acceptance for all essential transactions to ensure consumer protections.
IAN WILLIAMS: A CASE STUDY AS TO WHY CASH IS VITAL FOR VULNERABLE AUSTRALIANS
Pensioner Ian Williams was scammed $1300 from his Google Pay Ubank account, operated by NAB.
His bank – and the Australian Financial Complaints Authority - blamed him for the fraud, even though he had CCTV footage showing criminals buying gift cards with his card, more than 100km from where he was located at the time of the payment.
Ian has been in a two-year+ fight self-representing himself at court to seek justice. His health has suffered.
As a consequence of the trauma and financial cost, he now refuses to transact digitally. He relies on cash to participate in the economy.
“My money is not safe in the bank, and if there is an issue, I will be blamed. If I have cash on me, I have control of it," he says.
“In the bank I have no control over my transactions, no security, no support.”
Ian contends the bank has still not given an adequate reason as to how his $1300 was taken from his account, only accusing him of being responsible for it.
3. The $500 cash limit is unreasonably low if we want to be prepared for natural disasters or cyber outages
Many essential costs exceed $500, including:
• Rental bond payments
• Quarterly utility bills
• Essential car repairs
• Bulk groceries or fuel purchases for remote travel
A $500 ceiling effectively blocks consumers from using cash in situations where it matters most.
If there is concern about abuse (e.g. large-scale money laundering), exceptions can be carved out — but the default must support high-value essential cash payments, with monitoring.
This is the approach Minister Tony Burke has outlined for monitoring crypto ATMs .
Reserve Bank Governor Michelle Bullock has acknowledged how essential cash is – even though just 10 per cent of economic transactions are done with it – and confirms that it must be available as a back up when digital systems are unavailable (such as in a natural disaster, digital outages or a cyber attack on vital infrastructure).
4. Retailer cash exemption pathways are too wide
The current proposal seems to allow the ACCC to exempt entire retail chains or site classes from holding cash.
It also exempts all businesses under $10 million turnover, including many mid-sized regional retailers. In practice, this means a regional town may have zero cash acceptance points for essentials, even where local demand is strong.
The proposed regulatory design prioritises operational comfort for retailers over the public interest.
We recommend:
• Narrowing the small business exemption to <$1 million turnover
• Requiring transparent public reporting of all exemptions granted by the ACCC.
Cash acceptance cannot become optional based on the subjective operational preferences of corporations.
5. Supermarkets and large chains must maintain meaningful cash capacity
While we welcome the "reasonable opportunity" language in the draft, it is vague and easily undermined in practice.
We already hear from victims who face:
• Long queues at the only staffed register
• "Card-only" signage at self-checkouts
• Staff discouraging cash through misinformation or passive barriers
To avoid these abuses, we recommend:
• Requiring at least 50% of payment terminals at large retailers to accept cash
• Prohibiting signage that discourages or misrepresents cash acceptance
• Mandating staff training to support compliance with money laundering laws
Cash acceptance must be functional and practical, not just technically present.
6. The cash mandate must be monitored and enforced
Regulation without enforcement invites exploitation.
Treasury must ensure:
• Clear reporting obligations for retailers
• A consumer complaint mechanism for breaches
• Published penalties and compliance data to build trust
The proposed 6-month grace period should be shortened or phased with public progress reporting to ensure momentum is not lost.
The right to use cash must not be quietly eroded through neglect, loopholes, or economic exclusion.
If Australians cannot rely on digital systems to protect them — and current scam statistics show they cannot — then the government must protect the option to pay safely with cash.
We urge Treasury to strengthen the draft regulations by:
• Expanding the mandate to all essentials
• Lifting the cash transaction ceiling
• Tightening exemptions
• Enforcing real-world compliance
• Releasing the codes and rules that support the Scam Prevention Framework
We urge the federal government and its regulated agencies to work harder with financial institutions and groups such as ours to stamp out blatant money laundering and financial crime across the Australian system.
Digital dependence does not deliver economic resilience or justice.
Cash is one pathway for consumers to remain protected while transacting in the economy given the appalling lack of consumer protections for people being robbed through their bank accounts in Australia.
The Scam Victim Alliance stands ready to work with government to protect the economic dignity and security of all Australians.