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1. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 brill.com/eccl Banknote Counterfeiting Phenomenon in Poland Remigiusz Lewandowski* Assistant Professor of Economics & Security, Faculty of National Defense, War Studies University, Warsaw, Poland R.Lewandowski@akademia.mil.pl Abstract The paper presents the phenomenon of banknote counterfeiting in Poland and a se- lection of methods used against this type of crime. It shows that the number of coun- terfeit banknotes in Poland is much lower than in the eurozone countries. Moreover, a share of counterfeit Polish zloty banknotes significantly dropped in 2011 to the level of 7.6 ppm and between 2015–2018 to the level of 2.6–2.7 ppm. This decline can be associ- ated with increased law enforcement (elimination of a large criminal group of coun- terfeiters in 2001) and the Polish zloty banknotes upgrade in 2014 and 2016, which in- troduced a set of new security features further discussed in this paper. This leads to the conclusion that regular currency modernization, introducing new security features as well as law enforcement activities are an effective anti-counterfeit method. Keywords banknotes – counterfeiting – currency modernization – security features 1 Introduction Currency plays a crucial role in economic and social relations in every state. It serves three fundamental functions: it is a medium of exchange, a store of * Assistant Professor at the Faculty of National Defense, University of War Studies (Poland), specializing in identity, cyber as well as economic security. He obtained his MSc. degree at the Aarhus University (Denmark) and his PhD degree in economics at the Nicolas Coperni- cus University (Poland). He is an author of more than 30 academic papers and a co-author of several books. In his professional career he also worked in the Polish Security Printing Works (a Polish national manufacturer of banknotes and identification documents) as a Chief Strat- egy Officer. © koninklijke brill nv, leiden, 2020 | doi:10.1163/15718174-bja10008 Downloaded from Brill.com08/29/2023 10:47:19AM via free access <UN>

2. 253 Banknote Counterfeiting Phenomenon In Poland value, and a unit of account. As a medium of exchange, currency facilitates transactions. Without currency, the possible way to make a transaction would be barter involving a direct exchange of goods or services. Due to the obvious limitations of barter there was a need of a universal, commonly accepted me- dium in the form of currency which was finally introduced around 3000 BC by the Mesopotamian civilization (Kramer 1981). At the first stage of its develop- ment, money took a form of the so-called shekel, which was a unit of both weight and currency, referring to a specific weight of barley and equivalents of silver, bronze, as well as copper. Later, between the years 700 and 500 BC, first manufactured coins started to appear respectively in India, China, and cities around the Aegean Sea (Graeber 2011). They were made of gold, silver or bronze. Paper money, i.e. banknotes, was introduced in China in the 11th cen- tury. In Europe, notes started to be issued in Sweden in 1661 and replaced cop- perplates used as a means of payment. Nowadays, contemporary economies are based on non-cash money (about 85% of the total value in circulation), banknotes (about 97–98% of the value of cash currency in circulation), and coins (2–3% of cash currency in circu- lation). For instance, the total value of euro banknotes in circulation equals to eur 1.2 trillion, whereas the value of euro coins equals only to eur 28.8 billion, so coins constitute only 2% of the total cash euro in circulation.1 In Poland, the total value of Polish zloty banknotes equals to pln 214.4 billion and the value of coins is pln 4.8 billion, i.e. 2% of the total value of cash money in circulation.2 However, the total value of both cash and non-cash currency in circulation (M3 aggregate) is pln 1.4 trillion.3 Therefore, banknotes and coins constitute only 16% of the total value of money in circulation in Poland. That is why it is not only cash money but also electronic records on bank accounts that lay in the center of interest among criminals. Nonetheless, both types of crimes, i.e. money counterfeiting and electronic thefts from bank accounts, are serious threats to economic security. This paper, however, focuses only on the issue of banknote security and skips coins security because of its relative low importance and weight in the total value of money in circulation and a low face value in comparison to banknotes. The aim of this paper is to provide a thorough analysis of banknote coun- terfeit scale in Poland, patterns used by criminals in terms of currency and 1 https://www.ecb.europa.eu/stats/policy_and_exchange_rates/banknotes+coins/circulation/ html/index.en.html, data for February 2019. Accessed 13 April 2019. 2 https://www.nbp.pl/home.aspx?f=/statystyka/pieniezna_i_bankowa/struktura-obiegu.html, data for December 2018. Accessed 13 April 2019. 3 https://www.nbp.pl/home.aspx?f=/statystyka/pieniezna_i_bankowa/miary.html, data for February 2019. Accessed 13 April 2019. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access <UN>

3. 254 Lewandowski denominations chosen to counterfeit as well as Polish banknote security fea- tures. The security features and banknote modernizations (associated with public campaigns familiarizing the society with genuine banknotes and non- secret security features) are the most significant instrument of central banks of dealing with the counterfeiting problem. Law enforcement is the second possible way of dealing with the discussed issue but it is not a prerogative of central banks. Moreover, there is a strong tendency in the European Union to rely on self-defending banknotes rather than use law enforcement and cooper- ate closely with the secret service. Central banks do not possess the criminal law enforcement prerogatives, as governments do, but they are legally respon- sible for the value of national currencies. For instance, under Article 227(1) of the Polish Constitution the National Bank of Poland has an exclusive right of currency issuing and is responsible for the value of the Polish currency. Simi- larly, according to the Article 127(1) of the Treaty on European Union the pri- mary objective of the European System of Central Banks shall be to maintain price stability. Both the value of currency and price stability are subject to the public’s trust in currency and its genuineness, which depends on the scale of counterfeit banknotes. Thus, an analysis of security features is essential in the context of banknote counterfeiting phenomenon in Poland. Moreover, the paper gives estimations of the magnitude of banknote counterfeiting in Po- land against the situation in other countries. Such a study helps to improve the state’s resistance to this serious crime and facilitates efficient methods of fighting against counterfeiting. It is essential because the phenomenon of banknote modernization and banknote counterfeiting is not widely discussed in academic papers. Some findings concerning the results of modernization and its effects on a scale of counterfeiting are contradictory, which, in turn, im- plies a necessity of more research on this issue and a focus on other countries. This paper also meets this expectation, giving a value added to the discussed issue. 2 Literature Review In order to indicate importance of the analyzed issue, it is worth presenting a review of literature on financial and public security of the state. In addition, studies carried out to date on banknote security features and their impact on the scale of counterfeiting also require attention. An analysis of such academic articles allows the reader to discuss and compare the research results carried out in this paper in a broader context. The aspect of currency protection in the context of the national payment system and the economic security of the state european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access

4. 255 Banknote Counterfeiting Phenomenon In Poland is not widely discussed in literature. According to Lewandowski and Goliński (2015), currency manufacturing is strategic for the state, and many countries keep the production of local money domestic. Consequently, Kitler (2011) re- marks that the lack of state control over strategic economic sectors is one of the threats to the economic security of the state. Stachowiak, Kurek and Kurek (2004) define the economic security of the state as a condition for developing a domestic economic system. Such a system should ensure high efficiency of its functions and an ability to effectively fight against external factors which may lead to development disturbances. In this classic approach, the economic security of the state is related to the security of the payment system and, there- fore, to the security of currency in circulation because, as Iwańczuk (2011) states, an oversight of the payment system by central banks covers, in a broad sense, payment instruments and the technical infrastructure, too. This also involves a secure system of supplying central banks with adequately secured currency. If this element is violated, it may weaken the financial stability, influ- encing financial markets, as Lewandowski (2014) underlines. The research on the scale of counterfeit banknotes in Poland is not com- mon. The last data published by Lewandowski (2016) refer to 2014 and show that the ppm index (counterfeit banknote per million banknotes in circula- tion) was quite stable and not too high, i.e. between 7 and 8, between the years 2011 and 2014. Since 2014, there has been no research published concerning this issue, especially in the context of the 2014 and 2016 banknote modernization. What’s more, the phenomenon of money counterfeiting is also analyzed from a different point of view and takes into account a number of criminal proceed- ings. Nesterowicz (2017) shows that severe criminal penalties for money coun- terfeiting do not completely discourage counterfeiters and the number of criminal proceedings between 2010 and 2014 was stable and equaled to about 7–8 thousand per year. Similar findings are presented by Grabowska (2015). An interesting point of view is given by case-study literature on banknote counterfeit. An analysis of methods and technologies used by criminals is pre- sented by Nesterowicz (2016) as well as Kamiński and Nesterowicz (2012, 2015, 2016) and it shows that criminals use a variety of different methods in order to imitate security features and confirms that they do not replicate the original production process of banknotes. An analysis of security features of Polish and some other banknotes is also discussed by Konarowska (2011). However, the analysis in question does not cover the newest series of Polish zloty (pln) banknotes. More recent analyses are presented by J. Dziemidowicz (2017) as well as Konarowska and Pruszak (2014). They show that security features in the newest series of Polish banknotes belong to the most modern ones and are used by other central banks in developed countries. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access <UN>

5. 256 Lewandowski Centeno et al. (2019), based on their survey concerning euro banknotes, con- cluded that there does not exist a single deterrent feature which is readily rec- ognizable, highly durable, difficult to counterfeit or simulate, affordable and easy to produce. Therefore, the best strategy is to select a combination of secu- rity features, which adds complexity to a counterfeiter’s task and increases the number of counterfeiting steps to the point that a casual counterfeiter would eventually “give up”. This suggests that regular banknote modernization can prevent counterfeiting in the long run. However, according to de Heij (2010), central banks should be cautious with the issuance of new banknote designs because, shortly after issuing a new note model, the number of counterfeits rapidly rises to figures higher than it used to be the case with its predecessor. This conclusion is based on two cases of the Canadian $10 note in 1999 and the British pound gbp 20 note in 2007. Therefore, de Heij’s (2010) conclusions should be confronted with effects of currency modernization in other coun- tries, especially after 2010, when a group of innovative security features were developed and introduced in a few new banknote series. This conclusion is contradictory to Moxley, Meubus and Brown’s (2007) and Ball’s (2019) findings based on modernization of all Canadian dollar denominations between 2001 and 2004. Central banks have a duty to safeguard the integrity of their currency secu- rity. Thus, banknotes must definitely incorporate effective security features. This applies both to the European Central Bank responsible for euro issuance and domestic central banks in countries beyond the European Monetary Union. In order to protect euro banknotes EU legislation aims to ensure coor- dination of anti-counterfeiting measures between national authorities and adequate penalties for counterfeiters under national criminal law. EU legisla- tion on currency counterfeiting (banknotes and coins) refers to: 1) law enforcement legislation:4 – minimum standard for maximum penalties of imprisonment in Mem- ber States (penalty of at least eight years for manufacturing and at least five years for distribution of counterfeit banknotes and coins), – possibility to use special investigative tools for organized crime cases related to counterfeiting, – possibility to analyze seized counterfeits during judicial proceedings, – obligatory data collection by Member States on the number of coun- terfeiting offences, persons prosecuted and convicted, 4 Directive 2014/62/EU on the protection of the euro and other currencies against counterfeit- ing by criminal law; Framework decision 2000/383/jha on penalties for counterfeiting. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access

6. 257 Banknote Counterfeiting Phenomenon In Poland 2) multidisciplinary cooperation between national authorities in EU coun- tries, the Commission, the European Central Bank, non-EU countries and international organizations in the fight against counterfeiting,5 analysis, identification and withdrawal of counterfeits,6 authenticity checks by banks and other credit institutions,7 ban on sales, manufacturing, imports or distribution of medals and to- kens having visual characteristics, size or metal properties which are similar to euro coins,8 exchange, assistance and training programs in order to protect the euro against counterfeiting.9 3) 4) 5) 6) 3 Methods The research is based on an analysis of both quantitative and qualitative data. The quantitative data includes the volume and value of genuine and counter- feit banknotes in circulation in Poland as well as the volume of criminal pro- ceedings related to money counterfeiting taken by the Polish Police. In order to 5 Council Regulation (EC) No 974/98 of 3 May 1998 on the introduction of the euro; Decision 2001/887/jha on protecting the euro against counterfeiting; 2003/861/EC: Council Decision of 8 December 2003 concerning analysis and cooperation with regard to counterfeit euro coins; 2003/862/EC: Council Decision of 8 December 2003 extending the effects of Decision 2003/861/EC concerning analysis and cooperation with regard to counterfeit euro coins to those Member States which have not adopted the euro as their single currency; 2005/37/EC: Commission Decision of 29 October 2004 establishing the European Technical and Scientific Centre (etsc) and providing for coordination of technical actions to protect euro coins against counterfeiting; 2005/511/jha: Council Decision of 12 July 2005 on protecting the euro against counterfeiting, by designating Europol as the Central Office for combating euro counterfeiting. 6 Regulation 1338/2001 protecting the euro from counterfeiting in the euro area and Amending regulation 44/2009; Regulation 1339/2001 protecting the euro from counterfeiting outside the euro area and Amending regulation 45/2009. 7 2010/597/EU: Decision of the European Central Bank of 16 September 2010 on the authentic- ity and fitness checking and recirculation of euro banknotes (ecb/2010/14); Authentication regulation 1210/2010 on euro-coin authentication & handling of coins unfit for circulation. 8 Council Regulation (EC) No 2182/2004 concerning medals and tokens similar to euro coins (6/12/2004); Council Regulation (EC) No 2183/2004 extending to the non-participating Mem- ber States the application of Regulation (EC) No 2182/2004 concerning medals and tokens similar to euro coins (6/12/2004). 9 Regulation (EU) No 331/2014 of the European Parliament and of the Council of 11 March 2014 establishing an exchange, assistance and training programme for the protection of the euro against counterfeiting (the ‘Pericles 2020’ programme) and repealing Council Decisions 2001/923/EC, 2001/924/EC, 2006/75/EC, 2006/76/EC, 2006/849/EC and 2006/850/EC. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access <UN>

7. 258 Lewandowski give a clear view of the counterfeiting phenomenon it is necessary to present and discuss the scale and structure of Polish banknotes in circulation. The data on the volume and value of given denominations of Polish banknotes in circu- lation (pln 10, 20, 50, 100, 200 and 500) in 2018 comes from official statistics of the National Bank of Poland (the central bank of Poland).10 It is presented in the section: 4. Genuine vs. counterfeit banknotes in Poland The data on the volume of counterfeit banknotes, delivered to the author on his request by the National Bank of Poland, refers to the period of 2008–2018. The National Bank of Poland presents this information in a form of Parts Per Million (ppm), i.e. the number of counterfeits per million genuine banknotes in circulation, which is a commonly accepted method of showing a scale of banknote counterfeiting. The data on the criminal proceedings comes from annual statistics of the Polish Police for the period of 1999–2016. It refers to proceedings taken under Article 310 of the Polish Penalty Code. This data is confronted with the statistics of genuine banknotes in circulation in order to assess the magnitude of the banknote counterfeit problem in Poland. The data on counterfeiting banknotes in Poland (ppm) is compared with Canadian and Namibian ppm. ppm for Canadian banknotes is computed by the author based on a number of counterfeits and a total number of banknotes in circulation, both officially published by the Bank of Canada. Namibian ppm comes from other research. This analysis is also presented in the section: 4. Genuine vs. counterfeit banknotes in Poland. The qualitative data used in the paper refers to a selection of non-secret security features applied in modern banknotes on the example of pln 500 note. Security features and currency modernization are the most important instruments in dealing with the counterfeiting problem by central banks in Europe. Designing and manufacturing of secure banknotes has always been challenging but, given the rapidly developing technology available to counter- feiters and a relatively high share of cash in circulation (about 15%), it is more serious than ever. Consequently, an effective fight against banknote counter- feiting requires security features which are difficult to imitate and at the same time easily recognized by the public. They are presented and discussed in sec- tion 5. Modern security features. The paper also discusses general patterns of money counterfeiting in a his- torical perspective as well as two case studies of money counterfeiting (both euro and Polish zloty) by Polish criminal groups in the period of 2009–2010. 10 https://www.nbp.pl/home.aspx?f=/statystyka/pieniezna_i_bankowa/struktura-obiegu. html. Accessed 15 March 2020. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access

8. 259 Banknote Counterfeiting Phenomenon In Poland They are presented in section 6. Examples of banknote counterfeiting. Conclu- sions are discussed in section 7. 4 Genuine vs. Counterfeit Banknotes in Poland The first two functions of money, i.e. a medium of exchange and a store of value, make currency very attractive from a point of view of criminals. It refers both to coins made of gold or silver (holding the intrinsic value of precious metal itself) and to banknotes (with the face value only and a promise or guar- antee of the issuing bank). With a relatively low cost of counterfeiting, crimi- nals have a possibility of a multiple rate of return on their crime. This high rate of return concerns both old gold-coins times (coins counterfeited with the use of non-precious metal) and the present, when banknotes are still a store of significant value and mass production techniques bring the effect of econo- mies of scale that was impossible to be reached 100 years ago or earlier. Of course, the higher the face value of counterfeited money, the greater the rate of return on a crime. In Poland, there are 6 denominations of banknotes: pln 10, 20, 50, 100, 200 and 500. The number of these banknotes in circulation is shown in Figure 1. 1,400.0 1,302.1 1,200.0 1,000.0 800.0 600.0 400.0 316.9 190.2 173.3 200.0 123.2 14.2 0.0 500 pln 200 pln 100 pln 50 pln 20 pln 10 pln Figure 1 The number of Polish banknotes in circulation in millions; data as at 31/12/2018. Source: https://www.nbp.pl/home.aspx?f=/statystyka/pieniezna_i _bankowa/struktura-obiegu.html. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access <UN>

9. 260 Lewandowski The most common banknote in Poland is pln 100, whose number in circula- tion is 1.3 billion. It constitutes 61% of total Polish banknotes in circulation. The second most popular banknote is pln 200 (15%), and the third one is pln 50 (9%). With an exception of pln 500, these three banknotes represent the highest denomination and the greatest popularity in terms of usage. The pln 500 banknote is an exception as it was introduced quite recently and its de- nomination may be perceived as relatively high in relation to the value of cash transactions in Poland, resulting in some reluctance to use it due to the threat of counterfeiting. The banknote denomination related to their volume in circulation provides information on which denominations are the most important in the Polish economy. It is presented in Figure 2. According to Figure 2, the highest value of banknotes in circulation refers to pln 100 banknotes, and it amounts to pln 130.2 billion (61%). The second highest value refers to pln 200 banknotes and equals to pln 63.4 billion (30%). Finally, the third highest value covers pln 50 banknotes with the value of pln 9.5 billion (4%). The pln 500 banknote represents 3% of the total value of banknotes in circulation. These observations might lead to a conclusion that pln 100, pln 200 and pln 50 banknotes provide the highest rate of return to criminals because: 1,40,000.0 1,30,209.0 1,20,000.0 1,00,000.0 80,000.0 63,376.8 60,000.0 40,000.0 20,000.0 9,508.4 7,111.1 2,464.3 1,733.5 - 500 pln 200 pln 100 pln 50 pln 20 pln 10 pln Figure 2 The value of Polish banknotes in circulation in pln, in millions. Source: https://www.nbp.pl/home.aspx?f=/statystyka/pieniezna_i _bankowa/struktura-obiegu.html. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access

10. 261 Banknote Counterfeiting Phenomenon In Poland 1) their denominations are higher than the minimum (pln 20 and pln 10 notes) which leads to a higher profit, their denominations are lower than the maximum (pln 500 notes) which reduces the risk of detecting counterfeit banknotes (lower at- tention of the public when accepting the banknotes and checking their genuineness); they have a high share in circulation, provided that, in case of these banknotes, counterfeiting does not require ultra-difficult, time-consum- ing and costly activities. As de Heij [2010] remarks, this pattern was also true for the euro banknotes (counterfeiters target mainly eur 20 and 50, and leave aside the low and the high denominations). 2) 3) Money counterfeiting is a serious crime in Poland. According to Article 310 § 1 of the Criminal Code, it carries a maximum of 25 years and not less than 5 years in prison. Also, accepting, storing, transferring and bringing counterfeited money in circulation as well as assisting in such practices brings the penalty of a maximum 10 and not less than 1 year in prison (Article 310 § 2). Despite these heavy legal consequences, the level of money counterfeiting still remains sta- ble. Figure 3 presents the number of criminal proceedings concerning money counterfeiting in Poland taken by Police under Article 310 of the Penalty Code. 18,000 15,808 15,403 16,000 14,000 13,087 13,087 12,409 12,000 10,093 10,056 10,000 8,556 8,414 7,5278,3248,375 7,804 7,720 8,000 7,248 7,163 6,4036,897 6,000 4,000 2,000 - 2011 2013 2012 2015 2001 2010 2014 2016 1999 2003 2002 2005 2007 2000 2004 2008 2009 2006 Figure 3 The number of criminal proceedings by Police concerning money counterfeiting in Poland (under Article 310 of the Polish Penalty Code). Source: http://www.statystyka.policja.pl/st/kodeks-karny/ przestepstwa-przeciwko-18/63904,Falszowanie-pieniedzy-i-pa pierow-wartosciowych-art-310.html. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access <UN>

11. 262 Lewandowski Figure 3 shows that the number of money counterfeiting proceedings in re- cent years varies between 6 and 8 thousand per annum. This level may be ob- served since 2006. Before 2006, the number of proceedings had been much higher and amounted to almost 16 thousand in 2002. It is hard to identify rea- sons for the visible drop in the number of proceedings in 2006. It is not con- nected with modernization of Polish banknotes (with introduction of new se- curity features) because this took place much later, i.e. in 2014 (pln 10, 20, 50 and 100) and 2016 (pln 200). Therefore, a possible reason might be lower ef- fectiveness of the police or lower activity of criminals counterfeiting banknotes. Activities of banknote counterfeiters are also visible through ppm index for Poland, which is presented in Figure 4. As figure 4 shows, the ppm index in Poland fell down dramatically in two periods: in 2011, when it dropped from around 14–16 to 7–8, and in 2015, when it dropped to 4.6 and then gradually to 2.7 in 2018. The 2011 change is not cor- related with any changes in security features but can be linked with the elimi- nation of a large criminal group counterfeiting banknotes in 2010 (see: section 6. Examples of money counterfeiting). However, a drop to 4.6 in 2015 and fur- ther to 3.6 in 2016, 2.6 in 2017 and 2.7 in 2018, may suggest the effect of a banknote modernization process, as anticipated by [Lewandowski 2016]. Similar effects of a lower ppm index following banknote modernization have been observed in many countries. For example, in Namibia, in 2012, the ppm index of old-series banknotes equaled to 2.53 and was reduced to 0.04 for 18.0 16.1 16.0 14.3 13.9 14.0 12.0 10.0 8.3 7.6 7.5 8.0 6.6 6.0 4.6 3.6 4.0 2.7 2.6 2.0 0.0 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 Figure 4 The ppm index in Poland. Source: National Bank of Poland, data presented to the author. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access

12. 263 Banknote Counterfeiting Phenomenon In Poland 500 470 450 377 400 326 350 300 250 221 178 200 131 150 119 118 117 110 105 76 100 59 45 35 34 29 28 50 0 1996 2011 2013 2012 2001 2010 1997 1998 1999 2003 2005 2002 2007 2004 2008 2009 2006 2000 Figure 5 The ppm index in Canada. Source: Own compilation on the basis of Annual Reports of the Bank of Canada 1996–2013; https://www.bankofcanada.ca/publica tions/. new series banknotes [Lewandowski 2016]. In Canada in 2014 the ppm index amounted to an extreme level of 470. Nevertheless, following banknote mod- ernization, trainings for cashiers, a public campaign and law enforcement it was significantly lowered to 76 in 2008, 29 in 2013 and 9.1 in 2018. Figure 5 shows ppm for Canadian dollars in the period 1996–2013. The decision to introduce a new banknote series was made by the Bank of Canada in 1997 as a reaction to increased counterfeiting activities. Initially, three additional security features (a hidden number, fluorescent elements and iridescent ink) were applied in new banknotes, although, due to the bank’s budgetary restraints they did not prove sufficient to protect $5 and $ 10 notes against counterfeiting. The first banknotes of a new series ($10) were issued into circulation in 2001 and the last in 2004 ($50). In 2002, due to a remaining high level of ppm, the bank decided to introduce a new strategy designed to meet both the challenges posed by counterfeiters and the needs of the public. This strategy covered increasing the banknote intrinsic security (a metallic holographic strip, a ghost image, a see- through number and a security thread), building awareness of security features through education, promoting deterrence of counterfeiting by law- enforcement agencies and Crown prosecutors as well as removing older series banknotes from circulation (Moxley, Meubus and Brown 2007). According to Ball (2019), Lewandowski (2016) as well as Moxley, Meubus and Brown (2007) european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access <UN>

13. 264 Lewandowski these changes finally led to a significant drop in counterfeiting of Canadian banknotes. The observed effects of lowered ppm in Poland, Namibia and Canada fol- lowing banknote modernization and application of new security features sug- gest that there is a cause-effect relationship between the two phenomena. Of course, it is not a direct proof that a banknote upgrade limits criminal activities of counterfeiters. Such a direct proof would require research on counterfeiters themselves and their reactions to banknote modernizations applied by cen- tral banks. Unfortunately, there is no such research carried out, which, by the way, creates very interesting directions of new academic investigations. Theo- retically, the lowered ppm could be an effect of factors other than banknote modernization, such as elimination of a large criminal group counterfeiting banknotes or switching to other forms of crime, alternative to counterfeiting. Still, Studies on the Canadian case (Ball 2019; Moxley, Meubus and Brown 2007; Bank of Canada Annual Reports 2004–2013) do not support such an explana- tion and do not confirm any presence of factors other than banknote modern- ization. On the contrary, the Bank of Canada stated that the initial impact of its efforts to enhance banknote security became evident in 2005 when coun- terfeiting levels remained high but the number of counterfeit notes detected in circulation dropped significantly and the value of counterfeit notes found in circulation decreased substantially (Bank of Canada Annual Report 2005). Slightly different conclusions can be drawn in the case of Poland. A signifi- cant drop in ppm is visible in 2011 when there were no changes in security fea- tures but a large criminal group specializing in banknote counterfeiting was discovered by the Police. In this instance the factor of law enforcement can be responsible for the discussed positive change. Nonetheless, around the periods of introducing modernized Polish banknotes (2014 and 2016) there was no spectacular success in detecting large criminal groups of counterfeiters and no significant change in targets of criminal activities was observed by the Police according to their annual Reports on State’s Security in Poland (2014, 2015, 2016). This suggests that the drop of ppm following 2016 was caused by new security features applied in Polish banknotes. The technological development and availability of printing equipment, including 3D printing, gives criminals possibilities of better quality of their counterfeit banknotes and superior imitation of even relatively new securi- ty features. Therefore, central banks decide to release modernized banknote series periodically. The frequency of such actions depends on resistance to counterfeiting of existing banknotes and the scale of counterfeiting. For in- stance, the Bank of Canada, until an upgrade of 2001/2004, developed a new series approximately every 15 years. However, the discussed developments in european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access

14. 265 Banknote Counterfeiting Phenomenon In Poland technology available to criminals led to more frequent modernization, ap- proximately every 10 years. As for euro banknotes, the first series was issued in 2002 and the second series (with enhanced security features) 11 years later, i.e. in 2013. ppm across countries is affected by a number of factors including the secu- rity of a currency’s banknotes, the broader crime rate, how cash is used, and the cost of equipment used to counterfeit banknotes (Quercioli and Smith 2015, van der Horst et al. 2016). Effective prevention of money counterfeiting clearly requires an instant upgrade of banknotes and the introduction of new security features which make counterfeiters’ work harder and more costly. This is a never-ending process. It takes some time for counterfeiters to find methods how to efficiently imitate security features. Then the central bank develops a new series with more innovative features which, as discussed on examples of Poland, Canada and Namibia, should lead to a decrease in the counterfeit rate. What is important, counterfeiters do not use original manufacturing process- es, original technologies, or security features (Jakielaszek 2016). They are either too expensive or impossible to reach by non-official banknote producers. A relatively small number of counterfeit Polish banknotes also results from limited liquidity of Polish zloty and a low face value in relation to some stron- ger currencies such as euro or US dollar. Euro and US dollar are international currencies with the currency-to-Polish-zloty exchange ratio of about 0.2 and 0.3 respectively. Therefore, they are more attractive to counterfeiters. First of 70 64 60 53 48 47 50 41 41 40 34 33 32 30 26 20 10 0 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 Figure 6 The ppm index in the euro-zone. Source: https://www.ecb.europa.eu/pub/annual/html/ar2018 ~d08cb4c623.pl.html#toc43. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access <UN>

15. 266 Lewandowski all, manufacturing one counterfeit euro or dollar banknote brings a 3–4 times higher return than counterfeiting a Polish zloty banknote (because of the cur- rency exchange ratio and similar counterfeiting costs). Secondly, it is easier to circulate euro or dollar banknotes as they are recognized internationally (Ball 2019). This attractiveness of dollar or euro banknotes implies a number of counterfeit banknotes, much higher than in Poland’s case. Figure 6 presents the ppm index in the euro-zone. In recent years, the ppm index in the euro-zone has stabilized at a level be- tween 20 and 30. It is still about 10 times higher than in Poland despite the rela- tively modern security features adopted in euro banknotes. However, this is the price which euro pays for being an international currency. 5 Modern Security Features There is not a single security feature which protects banknotes against coun- terfeiting completely. Therefore, it is important to apply a set of different secu- rity features and to modernize them or add new ones approximately every 10 years. Polish banknotes were modernized in 2014 (pln 10, pln 20, pln50 and pln 100 notes) and 2016 (pln 200 notes). A new pln 500 banknote was intro- duced in 2017. Security features applied in Polish banknotes are advanced and similar to those which are present in banknotes of other developed economies. Figures 7 and 8 present selected security features of Polish modernized banknotes on the example of the pln 500 note. Figure 7 The face of the pln500 banknote. Source: Polish Security Printing Works, data presented to the author. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access

16. 267 Banknote Counterfeiting Phenomenon In Poland Figure 8 The back of the pln500 banknote. Source: Polish Security Printing Works, data presented to the author. One of the most common security features is a watermark. The watermark field is free from print. When the banknote is held against the light, a multitone watermark with a repeat of the image of King John iii Sobieski from the face side of the banknote and a light monotone value numeral “500” (filigree) are visible. Figure 9 shows the watermark against the light. The banknote paper together with the watermark is produced by the Polish Security Printing Works (Polska Wytwórnia Papierów Wartościowych), i.e. the manufacturer of Polish banknotes. When the banknote is held against the light, a security thread, i.e. a line with a microprint including the value numeral of the denomination “500” and “500 ZŁ” is visible. Fragments of the so-called windowed security thread are visible on the face of the banknote, and the whole security thread is visible when checked against the light. The windowed security thread also combines a color- shift effect (when moving a banknote horizontally and vertically the col- or smoothly changes from green to blue) and a motion effect (two crossing lines appear to move). The Polish Security Printing Works purchases it from foreign suppliers. It is presented in Figure 10. Another important security feature is a latent image. The value numeral “500” on the right side of the portrait of the king becomes light or dark depend- ing on the angle at which it is viewed. On the left side of the portrait, in the escutcheon, there are rectangular fields visible depending on the angle at which the banknote is viewed. A latent image is an effect of the intaglio print- ing technique. This technique also involves raising the printed image, which european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access <UN>

17. 268 Lewandowski Figure 9 The watermark on the pln500 banknote. Source: Polish Security Printing Works, data presented to the author. Figure 10 The windowed security thread of the pln500 banknote. Source: Polish Security Printing Works, data presented to the author. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access

18. 269 Banknote Counterfeiting Phenomenon In Poland can be felt by running a finger over it or scratching it gently with a fingernail. In pln 500 banknote intaglio printing is used in a portrait, value numeral, the name of the issuing bank (National Bank of Poland) as well as a mark for blind people (in the bottom left corner of the front). The effect of a latent image is shown in Figure 11. The banknote also takes advantage of the color-shifting ink. When the banknote is tilted, the ornamental graphic element to the right of the portrait (lobster-tailed pot helmet) smoothly changes color from green to blue, and the Figure 11 The latent image on the pln500 banknote. Source: Polish Security Printing Works, data presented to the author. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access <UN>

19. 270 Lewandowski pattern of a wavy line placed on it appears to move in the vertical plane. The ink is supplied to the Polish Security Printing Works by an external company. The feature is shown in Figure 12. Microlettering is a very popular way of protecting banknotes and docu- ments. Tiny inscriptions are made with high precision in offset or intaglio printing techniques. The smallest inscription on the banknote should be sharp and readable when magnified. There are two microletterings on the back of the banknote, i.e. intaglio microlettering – “RZECZPOSPOLITA POLSKA”; and offset microlettering – “NARODOWY BANK POLSKI”; “nbp 500 NARODOWY BANK POLSKI.” They are presented in Figure 13. Figure 12 The color-shifting ink on the pln 500 banknote. Source: Polish Security Printing Works, data presented to the author. Figure 13 Microlettering on the pln500 banknote. Source: Polish Security Printing Works, data presented to the author. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access

20. 271 Banknote Counterfeiting Phenomenon In Poland Figure 14 The see-through register on the pln500 banknote. Source: Polish Security Printing Works, data presented to the author. The see-through register (or recto-verso) is another popular method of secur- ing banknotes. Elements of the graphic design on the face and back of the banknote are visible in transmitted light and align perfectly to form a complete image. This is presented in Figure 14. Iridescent ink is often used by security-printing producers as it is eye- catching for users and compliant with the “look-and-tilt” method of authen- tication. The ornament on the back of the banknote is printed with gold iridescent ink. The ornament is visible or almost invisible depending on the angle at which the banknote is viewed. The ink is supplied to the Polish Secu- rity Printing Works by an external producer. The effect is shown in Figure 15. Security features also concern wavelengths other than daylight. There are security features of banknotes that are also visible in UV and IR light. Certain graphic elements appear in UV light: a square with a value numeral “500” and an abbreviation “ZŁ” to the left of the portrait; the serial number on the left side of the banknote; a stripe on the top right-hand side of the king’s portrait; and some other graphic elements on the front and back of the banknote. These are presented in Figure 16. Some graphic elements on the front and back of the banknote appear in infrared light. They are shown in Figure 17. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access <UN>

21. 272 Lewandowski Figure 15 The iridescent ink on pln500 banknote. Source: Polish Security Printing Works, data presented to the author. On the example of the pln 500 banknote, the above analysis presents the most popular, contemporary, non-confidential security features applied by many central banks worldwide. Generally, there are four characteristics of them: 1) they should be eye-catching and easily recognized by the public in order to authenticate a banknote; they should be difficult to imitate; they should include a set of different security features with different au- thentication effects recognized by the public; introduction of upgraded currency should be accompanied by an educa- tion process among the public. 2) 3) 4) Apart from the non-confidential security features, there are also confidential security features which are not disclosed to the public. An example of such qulities is the Counterfeit Deterrence System (cds), which consists of anti- counterfeiting technologies that prevent personal computers and digital imag- ing tools from capturing or reproducing an image of a protected banknote. It prevents unauthorized reproduction of banknotes. Polish banknotes are cov- ered by the cds as well. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access

22. 273 Banknote Counterfeiting Phenomenon In Poland Figure 16 UV-visible images of the pln 500 banknote. Source: Polish Security Printing Works, data presented to the author. Banknote designing and upgrading constitute a complex, long and difficult process which should include 4 main factors (Dziemidowcz 2014): 1) the aims of upgrading or designing new series (e.g. making banknotes more secure against counterfeiting, expanding banknotes’ life span in cir- culation or political reasons); the analysis of counterfeiting methods; the design of machine-readable features (sorting machines, atms); the conditions in which banknotes will be used (e.g. climate, habits of users). 2) 3) 4) european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access <UN>

23. 274 Lewandowski Figure 17 IR-visible images of the pln 500 banknote. Source: Polish Security Printing Works, data presented to the author. 6 Examples of Money Counterfeiting There are two general types of money counterfeiting (Nestorowicz 2017): – counterfeiting by states; – counterfeiting by criminal groups or individual criminals. Both have a long history. Counterfeiting by states is mainly used for politi- cal reasons, whereas criminal groups or individual criminals are motivated by profit from a crime. State counterfeiters have an access to professional european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access

24. 275 Banknote Counterfeiting Phenomenon In Poland equipment, materials and know-how, so that they can organize a production process very similar to the original one. The so-called “Bernhard operation” performed by Nazi Germany during World War ii was one of the greatest coun- terfeiting operations. It enabled the Germans to manufacture almost 9 million British sterling (gbp) banknotes whose value amounted to 10% of the total value in the British circulation (Lewandowski and Goliński 2015). “Private” counterfeiters have much poorer conditions of work and that is why they imitate security features and do not replicate the manufacturing pro- cess. Among them, there are both professional counterfeiters who invest in equipment and pay the highest attention to quality as well as amateur counter- feiters who often use only photocopier machines or simple ink-jet printers. Counterfeiting in Poland is organized by domestic criminal groups and ap- plies to Polish zloty and other international currencies such as euro. However, foreign currency (mostly euro) is generally transferred to Poland from abroad by couriers. In recent years, there have been a few cases of discovering large, professional counterfeit-money production sites. In 2009 and 2010, the Central Investigation Office of the Police Headquarters (Centralne Biuro Śledcze kgp) and Europol carried out the “MOST” operation against distributors of counter- feit euro banknotes. The operation led to arresting more than 100 persons in Italy, Germany, Spain, Austria, Norway, Finland, and Poland, including the leaders and active members. The criminal group specialized in introducing eur 100 and eur 50 banknotes in shops and shopping malls in European Union (Kamiński and Nesterowicz 2012). The counterfeit banknotes were of good quality; they were made by applying the offset technique and had well- imitated security features (such as the hologram, security thread, and see- through register). The original technology (e.g. intaglio printing technique) was not applied during their manufacture; the manufacturing process was based on the imitation of the final outcomes of the original production process. In 2010, the Central Investigation Office also discovered in Skarżysko- Kamienna the largest manufacturing site of counterfeited money in Poland. The criminals had a complete production line of counterfeit pln 100 banknotes and some equipment for counterfeiting eur50 banknotes. The manufacturing site had been active since 1998. The losses of the Polish Treasury resulting from this criminal group were estimated to amount to pln 30–50 million. Each counterfeit banknote was composed of two layers of paper of a low basis weight (40–50 g/m2) which were glued after imitating the watermark and the security thread. The counterfeited banknotes were produced in the offset tech- nique (no intaglio printing). The quality of counterfeited banknotes was poor. However, the cor scheme similar to genuine banknotes and precise imitations european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access <UN>

25. 276 Lewandowski Figure 18 Counterfeit banknotes in the production process (drying stage). Source: Kamiński, M., and R. Nesterowicz. “Walka z fałszerstwami pieniędzy w Polsce.” Człowiek i Dokumenty, no. 25/2012, p. 15. of UV security features were enough to introduce them successfully into circu- lation (Nesterowicz 2016). Interestingly, the counterfeiter had no education in printing technologies. He was a baker. Figure 18 presents counterfeit banknotes in the production process (drying). 7 Conclusions Money counterfeiting remains a serious issue of contemporary economies. Despite the fact that propensity to counterfeit is significantly greater in the euro-zone countries and the United States, Poland is still prone to this type of threat. This is confirmed by a large number of criminal proceedings that concern money counterfeiting. Due to the critical role of currency in the pay- ment system and the economic security of the state, money counterfeiting, and banknote counterfeiting in particular, central banks and governments must strongly fight this phenomenon. Therefore, severe criminal penalties and efficient police investigation activities seem to be crucial elements here. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access

26. 277 Banknote Counterfeiting Phenomenon In Poland Additionally, regular upgrading of currency security features is also necessary. The case of Polish zloty banknotes modernization in 2014 and 2016 as well as the case of Canadian dollar modernization of 2001/2004 show that there is a time correspondence between implementing new security features and reducing the number of counterfeit banknotes in circulation. This correspon- dence, due to the lack of other potential causes of lowering the ppm index, suggests that banknote modernization leads to a positive effect of reduc- ing the volume of counterfeits in circulation. However, the study also identi- fied the second factor possibly responsible for lowering ppm index in Poland in 2011, i.e. law enforcement and elimination of a large criminal group. Never- theless, both of the identified potential factors, banknote modernization and law enforcement should be handled with necessary caution. Further research in this respect should be continued, e.g. focusing on counterfeiters’ propensity to commit the analyzed crime, their propensity to cease the crime and, finally, on counterfeiting cases in other countries. Banknote modernization requires applying innovative security features. Polish banknotes of the 2014/2016 series meet this requirement and the ppm rate is low. Nonetheless, in approximately 5 years a new upgrade will be neces- sary. Every new series should take into consideration four fundamental rules of efficient banknote modernization: 1) 2) 3) 4) easy recognition of genuine banknotes by the public; difficulty of imitation; creating a set of different security features; education of the public on banknote security features. Bibliography Altig, D. E. 2002. “Why Is Stable Money Such a Big Deal?” Economic Commentary, May. Ball, M. 2019. “Recent Trends in Banknote Counterfeiting” Reserve Bank of Australia Bulletin, March. Centeno, A. B., Terrades, O. R., Canet, J. L., & Morales, C. C. 2019. “Identity Document and banknote security forensics: a survey”. ArXiv, abs/1910.08993. Bank of Canada, Annual Report 1996, https://www.bankofcanada.ca/publications/. Bank of Canada, Annual Report 1997, https://www.bankofcanada.ca/publications/. Bank of Canada, Annual Report 1998, https://www.bankofcanada.ca/publications/. Bank of Canada, Annual Report 1999, https://www.bankofcanada.ca/publications/. Bank of Canada, Annual Report 2000, https://www.bankofcanada.ca/publications/. Bank of Canada, Annual Report 2001, https://www.bankofcanada.ca/publications/. european journal of crime, criminal law and criminal justice 28 (2020) 252-279 Downloaded from Brill.com08/29/2023 10:47:19AM via free access <UN>

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