Venezuela is Europe’s wake-up call — but the Netherlands still sticks to yesterday’s payments policy

On 3 January 2026, the United States launched a large-scale strike on Venezuela and announced it had captured President Nicolás Maduro. Whatever one thinks of Maduro, the message to the rest of the world is unmistakable: power politics are back in the open, and legal norms are being bent — or ignored — at speed.

For Europe, this is not just “foreign policy news.” It is a stress-test for everything we quietly assumed would always work: cross-border finance, sanctions compliance, payment infrastructure, and the idea that “the transatlantic arrangement” automatically protects our values.

In this blog post we will explain how – for financial services and supervision – this moment requires a fundamental rethink and shift away from the classic stepwise bureaucratic policy making. We must act decisively when the financial services sovereignty between EU and US is clearly broken.

Estimated reading time: 5 minutes

HRIF.EU is sounding the geopolitical alarm for some time now

At Human Rights in Finance.EU (HRIF.EU), we have been warning for a couple of years that the U.S. is increasingly willing to use financial tools and legal machinery as instruments of raw geopolitical coercion — rule by law, rather than rule of law. Our analysis of U.S. sanctions against the International Criminal Court (ICC) described how targeting the justice system itself risks normalising the weaponisation of financial power against human rights.

With this weekends developments we must now add a second, very practical conclusion:

In a world of escalating conflict pressure, cash is not nostalgia — it is resilience

Cash remains the only widely usable payment mechanism that can keep working when digital systems fail: during outages, cyber incidents, network disruptions, or broader civil-defence scenarios. Central banks and public authorities across Europe increasingly say this out loud:

  • The ECB recently highlighted how crises and blackouts make cash “indispensable” as a fallback and as public reassurance. European Central Bank
  • The Dutch central bank (DNB) explicitly advises people to keep cash in an emergency kit because disruptions can take multiple forms. De Nederlandsche Bank
  • Sweden’s civil-defence ecosystem treats payment preparedness — including cash — as part of crisis readiness, in cooperation with the Riksbank.

This is not theoretical. It is a basic lesson of preparedness: redundancy beats elegance when systems are under stress.

The Dutch Ministry of Finance is still acting as if cash is a “legacy problem

The Netherlands has begun to acknowledge, at least on paper, that cash acceptance matters. In November 2025, the government announced a legal duty to accept cash at the counter — with exceptions — and opened consultation on the implementing rules.

But the deeper policy reflex inside Dutch “finance governance” remains badly outdated:

  1. Cash is still treated as something to manage away, rather than as public infrastructure to protect. Cash acceptance remains patchy across sectors, and “cashless by default” has been tolerated for years.
  2. The Netherlands still runs an unusually surveillance-heavy AML model that goes beyond the EU’s core logic. EU law is built around reporting suspicion to the FIU (Suspicious Transaction Reports). 
    Dutch law, by contrast, obliges institutions to report “unusual transactions,” supported by indicator lists (objective and subjective, leading to 4 million transaction reports per year: more than all the rest of EU suspicious reports together).
    This approach drives high-volume reporting and pushes the financial system toward permanent monitoring “because the pipes exist” — exactly the kind of logic that expands under geopolitical pressure.
  3. Actual policies are too often self regulatory ‘solutions’ to keep large corporates happy, keep compliance engines running, keep data flowing — while fundamental rights, democratic oversight, and resilience become afterthoughts.

That combination — pushing cash away while scaling monitoring up — is simply not fit for the emerging era.

The broader issue: Europe must stop assuming U.S. alignment and start designing for autonomy

When the U.S. sanctions a court like the ICC, Europe should not shrug and “comply harder.”. When the U.S. conducts an operation like Venezuela, Europe should not pretend this is compatible with a stable, rules-based order.

This is where the conversation gets uncomfortable but necessary: if financial and legal infrastructures can be weaponised, then automatic cooperation and information-sharing pipelines become strategic vulnerabilities.

HRIF.EU therefore last week repeated its argument — in its response to a consultation on Dutch payment policy and draft decisions on acceptance of cash, that Europe should seriously reassess its reliance on U.S.-centric frameworks and assumptions — including the way global AML/CFT governance has often tracked U.S. priorities.

HRIF.EU’s coherent six-step course — a policy package for resilience and rights

Understanding the logic is not the hard part. The evidence is piling up. The hard part is whether institutions have the psychological and political capacity to recognise the tipping point before dependency hurts us.

HRIF.EU calls for a decisive shift, anchored in fundamental rights and real-world resilience:

  • Secure cash and a basic payment account as essential public utilities — grounded in fundamental rights, inclusion, and crisis preparedness.
  • Stop monitoring “unusual” transactions at mass scale; align with the EU logic of targeted, proportionate reporting of genuinely suspicious activity (human-scale, not dragnet-scale).
  • Anchor generous cash acceptance by the government itself, using the legal space that already exists (including administrative-law tools). Public services should not be allowed to become quietly cashless.
  • Make cash acceptance effective and publicly enforceable — not symbolic, not optional, not “only if convenient.”
  • Normalise cash and stimulate practical innovation in oversight and market practice, rather than defaulting to ever-expanding monitoring.
  • Consider creating a Sovereign Government Cashier (SOK) to safeguard public values in payments — robustness, accessibility, efficiency, and meaningful privacy — especially under stress.

Further reading — support HRIF.EU

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