According to an opinion piece published in the Wall Street Journal by Markos Kounalakis (sorry, it’s behind a paywall), the sanctions on Russia are not reaching their people. Kounalakis believes that the United States should stop circulating the $100 bill to reach the people.
The United States dollar is the world’s reserve currency, and it is used as a safe store of wealth by people and companies. The Euro may represent an easily transactional currency, but the dollar is where the world turns for a store of wealth. In Russia, where the banks are not trusted, average citizens keep their savings in dollars.
According to the Federal Reserve, more than 661,500 pounds of $100 bills are in Russia as of 2019. Russians are stuffing them in a mattress and not using them for commerce.
Removing large-denomination currency from circulation is not new. In 1969, the Treasury withdrew the $500 and $1000 notes from circulation to make it more challenging for drug traffickers to move large amounts of cash.
In 2016, some economists made a case to stop circulating the $100 bill and the €500 banknote, even claiming the €500 note was nicknamed the “Bin Laden.” Eventually, the European Central Bank (ECB) stopped circulating the €500 banknote in 2018. But that has not stopped their use by criminals since the ECB has not demonetized the notes.
Even if the United States wanted to stop the circulation of $100 notes in Russia, it would not be an easy process. First, who would have the authority to make this determination? According to the Federal Reserve Act of 1918, it is the Federal Reserve’s job to manage circulating currency independently. The law that created the Office of the Comptroller of the Currency (OCC) allows this Treasury bureau to oversee the mechanisms that go into currency movement.
The government has more latitude over managing currency than coins. The law requires the U.S. Mint to strike cents, 5-cents, dimes, quarter dollars, half-dollars, and dollar coins (31 U.S. Code § 5111). On the other hand, the law (12 U.S. Code § 418) sets the denomination types, but it does not require the Federal Reserve to circulate all denominations.
If the President decides that it is in the best interest of U.S. foreign policy to stop the circulation of $100 notes, the Federal Reserve must decide if it is in the best interest of the Federal Reserve System to do so. However, the law complicates the matter by having the OCC oversee the institutions managing the currency. The blurry line between the authority of the Treasury Department and the independence of the Federal Reserve could create tension.
Should the policy regarding issuing $100 Federal Reserve Notes change, currency collectors may find opportunities to collect $100 notes.