List of Successful PMI IMPACT Applicants

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PMI IMPACT-funded projects around the world have predominantly focused on areas that are beneficial to PMI’s reputation and commercial objectives. Most notably, the projects promote:

  • Enhancing public-private cooperation – a concept which has been used by transnational tobacco companies as a way to undermine tobacco control1 and in conflict with article 5.3 of the Framework Convention on Tobacco Control (FCTC), which states that there is a “fundamental and irreconcilable conflict between the tobacco industry’s interests and public health policy interests.”2;
  • decreasing taxation levels to address illicit trade – in line with transnational tobacco companies’ objectives – and despite extensive evidence that increasing cigarette taxes constitutes one of the most effective ways to reduce smoking prevalence and thus related morbidity and mortality3 and that countries with higher taxation levels tend to have lower levels of illicit trade4;
  • free market and limited government through the type of organisations that are funded, including libertarian think tanks that push for reduced regulation (e.g. Lithuanian Free Market Institute, Institute for Market Economics);
  • and technology solutions including track and trace programs, with one executive of a grantee organisation accused of promoting Codentify (an industry owned system to authenticate tobacco products) across West Africa.5


Funding round Organisation & country Information678
1 ADIT, France Project name: “Rogue trade project”
Project description: “Development of a pan-European awareness platform, based on digital communication tools, to inform European businesses about the illegal trade of tobacco products and other mass consumption goods.”
Dates: July 2017 – April 2019
Additional information: The project notably led to the creation of Eurobsit (European Observatory on Illicit Trade), a website dedicated to illicit trade.9
2 Apar, University of the Thai Chamber of Commerce, Thailand Project description: “Research to identify situations and problems of illegal trade of drugs, alcohol and counterfeit products at Thailand’s borders. Project will develop an action plan for ASEAN cooperation against illegal trade.”
Additional information: This project is not listed in the PMI IMPACT progress report.10
2 Bahcesehir University, Turkey Project name: “Analysis of Illegal Trade of Alcoholic Beverages, Cigarettes and Tobacco, Fuel and Mobile Phones in Turkey”
Project description: “Analysis of illegal trade in alcohol, tobacco, fuel and mobile phones in Turkey to understand supply and demand factors. Project to develop proposals to fight these crimes through better utilisation of existing penal legislation and taxation rules.”
Additional information: A website on illicit trade in Turkey was created as part of the project: SAM Research and Consulting, Inc. and Ernst & Young – Turkey partnered on the project. A report published in May 2022 focuses on taxation as the primary driver of illicit tobacco trade: “Almost everybody agrees that taxes on alcoholic beverages, tobacco products, fuel and mobile phones are unreasonably high.” (…) “price is still the primary factor in illegal product consumption”,11 a central tobacco industry argument debunked by academic evidence.12 A presentation to an event hosted by the Center for the Study of Democracy (CSD) (another PMI IMPACT grantee – see below) noted that many of the cigarettes smuggled into Turkey in 2014 were manufactured by Bulgartabac, acquired by BAT in 2017, and some were produced by BAT in Turkey, legally exported and smuggled back (a scheme known as ‘round-tripping’).13
2 Basel Institute on Governance, Switzerland Project name: “Stop corruption from fuelling illicit wildlife trafficking (IWT) along the East Africa – Southeast Asian trading chain”
Project description: “Promote systematic, intelligence-led action against illegal wildlife trafficking networks across East Africa, Southeast Asia trading chain. Project focus on uncovering and targeting illicit financial flows, strengthening the ability of law enforcement agencies to investigate and prosecute transnational related crimes, and improving coordination across public, private and non-governmental sector actors.”
Additional information: The project engaged with numerous government officials, including from the Uganda Wildlife Authority, Uganda Revenue Authority, the Criminal Investigation Division of the Uganda Police, and other “wildlife crime agencies across East Africa”.14. In an interview with PMI, Juhani Grossmann, team leader of the IWT project stressed the importance of public-private cooperation: “Cooperation is tremendously important because illicit wildlife trade is a multifaceted issue that we need to tackle from all angles. From our perspective, the funding we received from PMI IMPACT was invaluable in getting our cross-sectoral work off the ground.”15
1 Belbrand, Belarus Project name: “Legal trade – Secure world”
Project description: “Sociological research and comparative analysis of legislation, combined with awareness activities and training programs on intellectual property protection, to combat illegal trade and counterfeiting, with a focus on Belarus, the Eurasian Economic Union, and the EU.”
Dates: September 2017 – March 2020
Additional information: The project centred on counterfeiting and intellectual property. It involved creating the “Legal Trade – Secure World” website, which highlighted examples of anti-illicit trade initiatives in the region; opening the “Economic Security and Intellectual Property” office; and opening a museum displaying counterfeited items at the Customs Department of the Belarusian State University. Despite sanctions imposed against Grodno Tobacco Factory Neman (GTFN) by the US on 9 August 2021 and the EU on 7 June 2022, the company was still listed as a member of Belbrand on 13 June 2022.161718
1 BOTEC Analysis, US Project name: “Impact of e-cigarette regulation on illegal trade in tobacco products in the European Union”
Project description: “Research on the interaction between illegal tobacco trade and e-cigarette policies in the EU.”
Dates: June 2017 – December 2019
Additional information: As part of this project, a paper found that “the more available e-cigarettes become, the less ITTP [illicit trade in tobacco products] market share rises in response to tax-driven price increases for conventional cigarettes”,19, an argument beneficial to PMI’s business strategy of pushing heated tobacco products, not as an alternative but a supplement to its cigarette business. (A PMI announcement on the company’s 2022 first quarter results included the following note on its increase in cigarette sales: “our combustible business performed robustly, exceeding our objective of stable category share and delivering positive volume and organic net revenue growth. In addition to supporting strong financial performance, this also enhances our ability to maximize the switching of adult smokers to smoke-free alternatives.”)20
1 California State University, Long Beach Research Foundation, US Project name: “The Darknet of the illegal tobacco trade”
Project description: “Research examining illegal tobacco trade on the dark net, and how the market is facilitated by both single vendor shops and crypto markets.”
Dates: September 2017 – July 2020
Amount: US$299,00021
Additional information: Research published as part of this project suggested that illicit tobacco trade on the dark net was insignificant, with sales estimated at US$6,304 in 2016 and US$16,245 in 2017, and a decrease in the number of relevant listings which the authors believe could be explained by the fact that “There are already established offline distribution channels for smuggled tobacco.”22
1 Center for the Study of Democracy (CSD), Bulgaria Project name: “The illegal trade of tobacco products along the Balkan route: addressing institutional gaps and corruption”.
Project description: “Research into the drivers of illegal tobacco trade in Bulgaria, Italy, Greece, and Romania. Development of tools for performance evaluation and corruption risk assessment of law enforcement and revenue authorities with regards to illegal tobacco trade.”
Dates: July 2017 – January 2020
Additional information: The project website states that “The research team involves experts from Bulgaria (CSD), Italy (Intellegit), Romania (SCE), as well as three independent criminology researchers from Greece. Over the next two years, the project will elaborate tools for performance evaluation and corruption risk assessment of law enforcement and revenue authorities with regards to illegal tobacco trade.”23 As part of this project, the CSD organised a round table discussion in March 2018 on “The illicit tobacco market: limits to institutional enforcement”, which involved representatives of Bulgarian revenue, customs, and law enforcement agencies and tobacco industry officials.24. In January 2020, an event entitled “Use of Corruption and The Illicit Market of Tobacco Products: Driving Factors and Trends” was held, again featuring tobacco industry representatives and government officials.25 Reports released by CSD on October 2019 and November 2019 as part of this project focus on three factors behind illicit trade: police effectiveness in seizing illicit cigarettes, size of police workforce, economic development, and tourism, ignoring potential industry complicity or lack of control over their own supply chain.2627 A policy brief published in March 2018 acknowledges that one of the illicit trade models underway in Bulgaria is one which involves “local production through legal cigarette manufacturers with significant market share in the legal cigarette markets of Bulgaria and Greece.” The companies with the highest cigarette market share in the two countries were, in order, BAT, PMI, Karelia Tobacco Company, and JTI in 2021.28 The authors describe a well-known tobacco industry strategy known as round-tripping: “the manufacturer declares the cigarettes are intended for export in non-EU countries and part of the production may actually be exported only to be returned to the country through organised criminal networks.”29
2 Center of Business Excellence of the Faculty of Economics, University of Ljubljana, Slovenia Project name: “Broader impacts of illicit cigarette trade in Europe: Key drivers, main trafficking routes and capacity building”
Project description: “Research to identify key drivers of tobacco trafficking routes between Asia and Europe as part of existing organised crime networks. The findings will be used to identify best practice recommendations and train specialists in countries of the Balkan region.”
2 Centre for Liberal Strategies (CLS), Bulgaria Project name: IT for Illicit Trade Risk Management (IT2RM).
Project description: “Development of a database with analytical capabilities to identify key trends and main drivers of illegal trade at a regional level, with a focus on Eastern Europe and the Middle East”
Additional information: The project aims to “serve strategic decisions and focus PMI and law enforcement’s efforts towards eliminating the root causes of illegal cigarette trade.”30 Interestingly, the project found an overall decrease in rates of illicit trade across the countries studied.31
2 Centre for Policy and Governance, Bosnia and Herzegovina Project name: “Shadow Economy in Western Balkans Region”
Project description: “Research on the shadow economy in the Western Balkans region focusing on informal labour and illegal trade of high-tariff goods.”
Additional information: The project’s research methodology “was developed in cooperation with the Lithuanian Free Market Institute”, a libertarian think tank who also received funding from PMI IMPACT.32 The project found that cigarettes “are the most frequently purchased items” in the shadow economy of the Western Balkans, with an estimated 25% of total cigarette consumption coming from “illicit purchases” (up to 40% in Montenegro).32 Project director Adis Muhović notably pointed to “overregulation” as a driving factor “pushing entrepreneurs into the shadow economy”.33 A project report recommends decreasing taxation to address shadow economies, noting that “tax policy toward excise goods contributes to its illicit production and trade”.32 Decreasing taxes and other types of regulation is a well-known tobacco industry argument on illicit trade.
1 Civitta, Lithuania Project name: “Insight into CEE border-town smuggling economics”
Project description: “Research exploring the size of and attitudes towards shadow economy generated in part by cigarette smuggling in border-towns within Eastern Europe. Development of policy recommendations to reduce the incentives for illegal trade by strengthening local economies.”
Dates: July 2017-March 2018
Additional information: The project included interviews with revenue, customs, and law enforcement officials, in addition to “organizations fighting illicit trade” (it is unclear whether these included tobacco industry representatives).34
1 Cross-border Research Association (CBRA), Switzerland Project title: “Precursors of Illicit Cigarette Trade (PRECISE)”
Project description: “Research project to study the sourcing and supply chains of raw materials and secondhand production machinery used for the manufacturing of illicit cigarettes. The project provided recommendations for a new joint monitoring system and improved enforcement mechanisms and tools.”
Dates: August 2017 – November 2019 (though the final report notes research was conducted between May 2017 and April 2021)
Additional information:
In the project’s final report, the authors “thank the numerous industry and government experts who contributed to this study by providing interviews and reviewing drafts of this study”, without specifying the role played by PMI. The report’s recommendations include voluntary implementation by the industry of anti-illicit trade practices, increased intra-industry cooperation, and closer collaboration between industry and government.35
2 Euromonitor International, UK Project name: “Tackling Illicit Trade: From Accurate Data and Intelligence to Action”
Project description: “Develop cross-sectoral policies to counter illegal trade, and explore and assess the issue in up to 80 countries in Africa, Latin American and Asia. In 10 selected countries, quantify and qualify the market size, trends and drivers. The project will also assess the robustness and effectiveness of regulatory frameworks, and draw correlations across categories and regions.”
Additional information: Euromonitor International has been criticized for receiving PMI funding and thereby jeopardizing its claims of independence from the tobacco industry, Euromonitor International responded that it “remains a privately owned and autonomous business which has merely entered into two quite separate and distinct project contracts with FSFW and PMI Impact to provide market research services to those bodies.”36
2 Faculty of Business Economics and Entrepreneurship, Serbia Project title: “Combating Illegal Trade Through Research, Education and Awareness”
Project description: “Research, modern education techniques and awareness activities to address illegal trade in the Balkans including Serbia, Albania, Kosovo, Montenegro, Bosnia and Herzegovina. Project to focus on the illegal trade of tobacco, alcohol and drugs, analysing the links between illegal trade, corruption and money laundering.”
Dates: June 2019 – ?
Additional information: One of the stated objectives of the project is “developing and conducting training courses in the field of combating illegal trade for police and customs officers, tax authorities, etc.”37
2 Fraunhofer FKIE, Germany Project name: “FIFI Fraud Information Fusion Intelligence”
Project description: “Development of a digital platform to identify and track critical processes and produce intelligence in the context of illicit trade. The intelligence processes have been developed, tested and proven by governmental security services. The creation and development of the platform will take the knowledge about these processes to adjust them to private sector’s needs so that the project develops and makes available a platform intended to support companies affected by illegal trade.”
Additional information: Other partners on the project are DITS, Analytical Semantics AG, and Traversals Analytics and Intelligence GmbH.38 In 2019, project representatives attended police trainings on illicit trade organized by a police trade union (Gewerkschaft der Polizei – GdP or Trade Union of the Police) and sponsored by PMI.39
2 Freeland USA, US Project name: “ACE (Analytical Center of Excellence): Converging Governance to Address Convergence of Crime”
Project description: “Development of a data fusion and analytics hub that will harness insights from open source data regarding illicit trafficking in general to inform and improve laws, policies, training, enforcement strategies, and behaviour change campaigns, in Asia, with connectivity to Africa and Latin America.”
Additional information: The project is also referred to as “Analytical Center of Excellence on Trafficking” or ACET, described as “the first civil society/for-profit joint venture made up of NGOs, tech companies, and law enforcement partners that share the goal of ridding the world of human slavery and the illicit endangered species trade.”40 Mekong, another recipient of PMI IMPACT funding, is also a partner on the project.40
2 Gendarmería Nacional Argentina, Argentina Project name: “Triple Frontier Impact”
Project description: “Creation of a Center for the Analysis and Investigation, Command and Control in the fight against organised crime and illegal activities in the Brazil, Paraguay, Argentina Tri-Border Area. The focus will be on combating and investigating crimes, including human trafficking and exploitation, drug trafficking, organised crime, money laundering, and other economic crimes.”
Amount: US$1.5 million
Additional information: The Center will be located in the town of Iguazú in the Misiones Province, at the border with Paraguay and Brazil.41 According to the Gendarmerie, it will “allow strengthening and deepening” of institutional capacity to tackle organized crime and other illegal activities, including trafficking of minors and child prostitution, and will feature approximately 30 staff.42 The letter also noted “the award received by the National Gendarmerie does not generate any type of interaction outside the legal norms with the PMI organization.”42 The Global Tobacco Industry Interference Index ranks Argentina second to last in Latin America in guarding against tobacco industry interference, and 71 out of 80 countries reviewed worldwide.43 An analysis of internal tobacco industry documents (1966-2005) found that “Transnational tobacco companies have been highly influential in Argentina. Using similar strategies as elsewhere in the world, the tobacco industry successfully blocked, delayed, and diluted meaningful federal tobacco control bills.”44
1 GLOBSEC, Slovakia Project name: “From criminals to terrorists and back?”
Project description: “Research into the links between criminality and terrorism among individuals arrested for terrorism-related offences in 11 EU Member States in 2015, and related information campaigns to raise awareness on the modalities of the crime-terror nexus.”
Dates: September 2017 – December 2019
Additional information: In June 2019, GLOBSEC hosted a PMI IMPACT Conference entitled “It takes a Network to Combat Illicit Trade: Achievements, Challenges, Opportunities, and Solutions” to “bring together two rounds of the PMI Impact grantees and external stakeholders and provide a platform for the exchange of experiences and joint discussions.”45. GLOBSEC President Robert Vass argued that PMI IMPACT heralded “A new form of public-private partnership, in which BOTH private entities and governments come together to work towards common good, means: a world with less or far less illicit trade.”46 The final report challenged the links between organized crime and terrorism – often stressed by PMI executives,474849 concluding “the crime-terror nexus in Europe truly is a “poor man’s crime-terror nexus” as its representatives are former, and relatively unsuccessful, criminals whose jobs do not amount to bringing in a sizeable skillset to their new terrorist patrons.”50
2 Group-IB, Russia Project name: “Cybericeberg”
Project description: “Research and in-depth analysis of the international online criminal community to deliver actionable information for the prevention of crimes. The research will examine the most dangerous types of hi-tech crimes such as illegal trade in rare species of animals, counterfeiting of alcohol and tobacco, intellectual property infringements, and technology crimes.”
Additional information: Founded in 2003 by Ilya Sachkov, the company’s customers have included Interpol, Russian banks, and defence companies.51 In 2018, Group-IB moved its headquarters to Singapore as part of the “company’s efforts to grow its business and remain independent”51 yet continued to work in Russia52 and Sachkov received an award from Russian President Vladimir Putin in 2019.53 On September 2021, Russian authorities arrested Sachkov on treason charges for the “transfer of classified information to foreign agencies which allegedly “employed” the executive”.54 He is alleged to have provided the US with information on Operation “Fancy Bear” that sought to undermine the US election.55 In May 2022, the Italian National Cybersecurity Agency banned the company from working in the government sector.52
1 GTD, France Project name: “SMITE’2: Smart Illicit Trade Evidence Engine”
Project description: “Development of a system to prevent, detect, and reveal illegal trafficking networks and street crimes, including the illegal tobacco trade, using smart city sensors data.”
Dates: January 2018 – December 2019
Additional information: Information included in a PMI report suggests close cooperation with French law enforcement: “Developed for French cities and security
forces, the project is based on the practices and knowledge of local police and city services. SMITE’2 aims to provide each strand of the French security forces with functionalities and added value through automatic camera analysis.”56
1 Hellenic Coast Guard, Greece Project: “Contraband Sea Shield (CSS)”
Project description: “The project funded the procurement of five RIB vessels for the HCG to help it improve its surveillance and enforcement of Greek sea trafficking routes. The illegal tobacco trade poses a significant threat to the Greek economy and has grown in the country in recent years. In contrast to elsewhere in Europe, most illegal tobacco trafficking in Greece takes place by sea. While most trafficked goods are exported from Greece by land, the majority of imports are trafficked into the country by sea at remote coastal locations. Increased enforcement capability for the HCG is designed to tackle this illegal activity.”
Dates: February 2018 – February 2021
Additional information: An agreement was signed in January 2018 for the procurement of five high-speed boats worth US$2.4 million to the Greek Coast Guard fleet patrol the country’s waters and prevent illegal trade, which according to PMI, “highlights the importance of cooperation between the private and public sectors in combating the illicit tobacco trade.”5758 Greece is a key market for PMI, who announced the same year it would invest €300 million in the country to build an IQOS factory.59 In 2016, in the presence of Prime Minister Alexis Tsipras, PMI CEO André Calantzopoulos and Minister of Agriculture Vaggelis Apostolou signed an agreement for PMI to commit “to continuing to purchase in the next three years significant volumes of the Greek oriental tobacco” and the ministry to implement policies to make tobacco production “competitive and of high quality”. Apostolou described the agreement as “a clear case of private and public sector cooperation that will bring about significant benefits to all parties”.60
2 InSight Crime, Colombia Project name: “Mapping and Containing Criminal Economies, Homicides, and Corruption in the Northern Triangle and the Tri-border Area”
Project description: “Map and analyse criminal dynamics in the border provinces of Guatemala, Honduras, El Salvador, Paraguay, Brazil and Argentina. The project will look at relationships between different types of transnational organised crime, violence, corruption and criminal actors.”
Amount: Unclear but available annual reports and financial statements include the following donations from PMI and Philip Morris Products SA:
2021: COP259,811,374 or US$66,600 (, 16 June 2022)61
2020: COP1,521,543,151 or US$390,473 (, 16 June 2022) – largest donation to the foundation in 202062
2019: COP913,478,920 or US$234,258 (, 16 June 2022) – – largest donation to the foundation in 201962
2018: COP35,947,323 or US$9,225 (, 16 June 2022)63
2017: COP307,811,180 or US$78,922 (, 16 June 2022)
Additional information: PMI IMPACT funding is not mentioned on the Insight Crime website itself (beyond the aforementioned annual financial reports). Stories on the illicit tobacco trade published by InSight Crime often rely on industry sources and fail to mention the organisation’s own funding from PMI.65666768697071727374757677
1 Intelligence Culture and Strategic Analysis (ICSA) Foundation, Italy Project name: “Fighting terrorism on the Tobacco Road”
Project description: “A combination of research, educational, and dissemination activities exploring the connection between cigarette smuggling, related crimes, and the financing of international terrorism. The aim is to increase public awareness on global security risks associated with illicit trade.”
Dates: September 2017 – December 2019
Additional information: The project produced a report and training manual on the links between terrorism, the illicit tobacco trade, and other criminal activities, and later held four training seminars for approximately 500 law enforcement officials, seven training seminars for journalists, and one for high school students.787980818283 In October 2019, the ICSA Foundation celebrated its ten-year anniversary with a cocktail party attended by journalists and government, military, and law enforcement officials. The event featured a session with ICSA president General Leonardo Tricarico, and Alvise Giustiniani, vice president of illicit trade prevention at PMI, during which Giustiniani thanked ICSA for the project “which explains the connection between terrorism and smuggling very well”. Giustiniani praised “An excellent job with a remarkable result”, stressing that “public-private cooperation is the only viable solution to tackle the problem in a systemic way.”848586
1 Information Technologies Application (INTA). Lithuania Project name: “Cargo scanners image analysis and threat object recognition training”
Project description: “Image analysis and threat objects recognition training program for the operators of x-ray cargo scanners to enable a faster and more efficient screening process and the identification of a range of potential threats.”
Dates: August 2017 – June 2018
Additional information: The project involved training law enforcement officials from fifteen European countries on how to operate X-ray scanners and analyze the images they produce.8788
1 Institute for Market Economics (IME), Bulgaria Project name: “Law and economics of illegal trade of tobacco products in Bulgaria”
Project description: “Analysis of the institutional framework in Bulgaria and its effects on the illegal market in order to explore the links between economic issues and the legal and institutional framework, such as criminal prosecution and the performance of investigative bodies.”
Dates: June 2017 – June 2019
Additional information: The project notably focused on the effects of regulation – particularly excise duty policy – on the illegal market.89 A 2019 IME Policy Note notably describes “the initiative against illegal trade by the big tobacco companies in the market” as the number one factor behind Bulgaria’s record low levels of illicit trade.90 Independent academic research indicates transnational tobacco companies “have been involved in cigarette smuggling to and through Bulgaria since at least 1975 and used smuggling as a market-entry strategy”, while lobbying the government to “influence the Bulgarian tobacco excise tax regime, import duties and pricing mechanism”.91
1 Institute of Law Studies of the Polish Academy of Sciences, Poland Project name: “Controlling the illegal trade of tobacco in an era of fast change”
Project description: “Identifies trends and required modifications in the control of illegal trade in tobacco products and e-cigarettes in the EU, taking into account a number of recent political, legal, and technological changes. These include the Brexit referendum, the decision not to prolong EU-tobacco industry agreements, and the emergence of new tobacco products.”
Dates: September 2017 – July 2020
Additional information: In 2019, the Institute of Law Studies organised a conference entitled “Combatting Illegal Tobacco Trade in the Era of Fast Change”. According to conference documents, the event was “organized by the ILS PAS presenting the outcome of research supported under the PMI Impact”.92 In a statement the organisation said: “The Institute has been established over 60 years ago, we value our academic freedom and we would never allow or endorse any publications which do not comply with the standards commonly accepted in the academic world.”93 The project led to the publication of a book with Springer.94 It notably states: “The negative impact of tobacco products on human health is indisputable. As researchers in the field of criminal law, we focused our research on states’ (criminal) tobacco policies, which constitute at the same time an important part of national criminal policies and a part of the national tobacco control policy. The clear health hazards related to tobacco were not subject of this research and are very competently covered by researchers in other disciplines of sciences, in their publications.”94
2 International Organisation of Employers (IOE), Switzerland Project name: “Business and Migration: strengthening the dialogue between the private sector and governments”
Project description: “Enhancing the dialogue between the public and private sectors on how to strengthen regular frameworks for migration. The project will examine the barriers to recruit foreign workforce, and also look at the existing legal pathways that need to be carefully crafted to prevent the risks related to irregular migration.”
Additional information: The project is described in an IOE annual report as supporting “the work of the GFMD [Global Forum for Migration and Development] Business Mechanism in enhancing dialogue between the private sector and governments on migration and advocating for a regulatory environment that maximises the benefits of migration, while reducing the risks of trafficking, irregular migration, unethical recruitment practices and forced labour.” Planned deliverables include extensive meetings between private sector and government officials: “four business-government workshops in Latin America, South Asia, Africa and the Middle East; four short research projects on best practices in the four regions (…); and eight informal meetings to foster dialogue with governments via the Ambassadors of Permanent Missions in Geneva and New York”.95 IOE has also received funding from JTI.95
2 JHM Pesquisa e Consultoria em Seguranca, Brazil Project name: “Census of Illicit Markets – Public platform of spatial data about crime problems which involves illicit trade, related crimes and socioeconomic data for the formulation and assessment of public policies between the Brazil-Paraguay-Argentina triple border”
Project description: “Development of public platform to analyse illegal trade and related crimes around the Brazil, Paraguay, Argentina Tri-Border Area and the main regions of consumption up to the metropolitan region of São Paulo, using socioeconomic data to support the formulation and assessment of public policies.”
Additional information: JHM Pesquisa also organized events in Brazil with TRACIT, which has received PMI IMPACT funding and is closely aligned with the tobacco industry. In November 2019, one of those events featured representatives from the Brazilian Parliament, the National Gendarmerie of Argentina (another PMI IMPACT grantee), and David Luna, chairman of the OECD Task Force to Combat Illicit trade and of the Business at OECD taskforce on illicit trade, which is co-chaired by Alvise Giustiniani, vice president of illicit trade prevention at PMI IMPACT.9697
1 Kazazi Consulting, Albania Project name: “Correlation between tax burden, illegal tobacco trade, and corruption on Albanian borders”
“Project description: “Research on illegal tobacco trade in Albania and bordering countries, exploring the correlation between tax policies, penal legislation against illicit trade, and state policies. Monitoring of the growing, processing, and trade of raw tobacco, as well as the illicit tobacco trade and corruption.”
Dates: July 2017 – October 2019
Additional information: The project notably focused on the correlation between taxation and illicit trade, a well-known tobacco industry point of focus.98
1 Kiel University, Germany Project name: “Asset recovery in the German legal system – an instrument to fight tobacco trafficking?”
Project description: “Research on asset recovery as a legal instrument to discourage illegal tobacco trade in Germany and other jurisdictions.”
Dates: October 2017 – November 2019
Additional information: This project led to the publication of a thesis on non-conviction based confiscation.99
1 KPMG, UK Project name: “Analysis of seizures to inform policy and Law Enforcement Predictive Analysis Tool”
Project description: “Research project to collate intelligence related to tobacco products seizures within the EU, Norway, and Switzerland. The collated intelligence will be used to identify key trends in illicit tobacco trade activity across the countries within the study, presented in a way that helps law enforcement to act on trends identified and reduce illicit tobacco trade.”
Dates: October 2017 – March 2019
Additional information: The close ties between KPMG and the tobacco industry are well established. Interestingly, data compiled as part of this project shows that out of 4,855 identified seizures, only 148 were recorded as counterfeited products. Though this may be an underestimation, this clearly clashes with tobacco industry messaging on counterfeiting.100. When brands could be identified in seizures, 27 of the top 30 brands were illicit whites. The report also notes that “The overall volume of Illicit Whites seized was proportionately higher than the share of consumption identified”. Though this is not a hypothesis put forward in the report, this may suggest greater law enforcement focus on illicit whites at the expense of smuggling of genuine TTC brands.101 It is also worth pointing out that 70% of seizure reports did not include brands. The project does not provide details on brand names either. When brand name could be identified, 80% of cigarettes seized in France were classified as contraband.102 A recent lawsuit filed by MSI against PMI claims that PMI has been overproducing Marlboro cigarettes in its factory in Algeria, which have then been smuggled across Europe, notably France where Marlboro is the number one smuggled cigarette on the illegal market.103
1 Lithuanian Free Market Institute (LFMI). Lithuania Project name: “Unfolding drivers of illegal trade through Baltic and Nordic cross-country microanalysis”
Project description: “Research and awareness activities, exploring the scope and drivers of illegal trade in Lithuania, Latvia, Estonia, Poland, Sweden, and Czech Republic.”
Dates: September 2017 – October 2019
Additional information: The project engaged with “policy and decision-makers in the legislative and executive sphere” from Lithuania, the Czech Republic, and Estonia.104 The reports focused on the links between taxation and illicit trade, arguing that “Taxes and regulations are (…) the primary causes of the shadow economy.”105106
2 Mykolas Romeris University, Lithuania Project name: “Interdependence between illegal trade in tobacco and corruption money laundering and organized crime”
Project description: “Research into the impact of illegal tobacco trade in Ukraine, Armenia, Serbia, Georgia, Moldova, and Albania. The project will explore aspects related to corruption, money laundering, and organised crime, and aims to strengthen cooperation between the public and private sectors, and academic communities.”
Additional information: A report published as part of the project curiously notes that “governments should ensure that tobacco industry would have no interventions in the introduction and implementation of tobacco control measures.”107
2 National Tax and Customs Administration of Hungary Project name: “Tackling cigarette smuggling in passenger traffic at the Serbian and Ukrainian borders”
Project description: “Procurement of X-ray scanners and training of staff at the crossing points of the Ukrainian and Serbian borders for passengers’ baggage to prevent smuggling.”
2 No Peace Without Justice, Belgium Project name: “The Human Rights Impact of Illicit Trade in conflict: the case of Syria and Iraq”
Project description: “Expose and address the impact of illegal trade on current and future human rights. The project aims to increase awareness, understanding and commitment among relevant stakeholders, including policy and decision-makers, as well as to secure potential new allies within the human rights community.”
Additional information: On 8 March 2022, the project held a side event as part of the 49th regular session of the UN Human Rights Council.108 Another event, held on 24 February 2022, featured Fabio Massimo Castaldo, Member of the European Parliament Committee on Foreign Affairs.109
1 Oxford Economics, UK Project name: “Combating Illicit Trade – understanding perspectives and strategies”
Project description: “Research and analysis of the motivations of consumers to buy illegal goods, and the anti-illicit trade strategies of businesses and policy makers.”
Dates: July 2017 – July 2019
Additional information: Oxford Economics has long-held ties with the tobacco industry. This specific project involved a consumer survey (37,000 purchasers across 37 European countries), a stakeholder survey (interviews with 150 business executives and 75 government officials – though none from public health authorities), and qualitative analysis including guidance from an advisory panel – which included individuals with links to the tobacco industry, namely Peggy Chaudhry, Stefano Betti of TRACIT, Elizabeth Allen, who has worked with the International Tax and Investment Center (ITIC) and the Kangaroo Group, and Allen Bruford, advisor at ITIC.110111 The report also quotes other individuals and entities linked to the tobacco industry, including Ernesto Savona of Transcrime and Jeff Hardy of TRACIT.112 A panel event organized as part of the project on 27 June 2018 featured officials from Ireland’s Health Products Regulatory Authority and the UK’s Intellectual Property Office.113
1 Panta Rhei Research Limited Company, UK Project name: “The Crime-Terror Nexus”
Project description: “A combination of research, education and training to map illicit trade activities in Europe and investigate evidence of the terrorism-crime nexus, explain its nature and dynamics, and spell out its implications to create the framework for continued, sustainable, and effective collaboration both across and within sectors and countries.”
Dates: October 2017-October 2019
Additional information: Panta Rhei Research Ltd114 was created by former PMI employee Zora Hauser and Peter Neumann, Professor at King’s College London (KCL), founder of the KCL-based International Centre for the Study of Radicalization (ICSR), and director of the centre between 2008 and 2018. The ICSR website now has a page dedicated to the Crime-Terror Nexus under ‘Our Work’ section, despite the project being funded through Panta Rhei Research Ltd, not ICSR.115 The page does not mention PMI IMPACT funding. King’s College London prohibits tobacco industry donations. A King’s College London ‘Policy for the Solicitation and Acceptance of Donations’ issued in March 2018 stated: “The fundraising partners will not solicit or accept donations of funds that they judge to be unethically or illegally obtained. Under this guiding principle, the fundraising partners will not accept gifts from tobacco companies.”116 Fifteen country/regional working papers were published and presented to government officials and other stakeholders in Greece, Spain, the UK, Portugal,
Italy, and Germany.117
1 Personeels- en Management Opleidingen voor Retail (PMO CVBA), Belgium Project name: “Impact of illegal trade in Belgium”
Project description: “Campaign in Belgium to raise awareness among local business owners, policy makers, and consumers about the negative consequences of illegal trade and counterfeiting.”
Dates: September 2017 – December 2019
Additional information: Featured a “Hansel and Gretel gingerbread house” displayed on a shopping street in Antwerp in December 2017, which passers-by could enter to learn about illicit trade and counterfeiting.118
2 Portcullis International Business Consulting (S) Pte. Ltd., Singapore Project name: “To improve awareness and enforcement of Intellectual Property Rights F(IPR) Crimes on Pharmaceutical consumer products in Indonesia, Malaysia and Singapore”
Project description: “Identify the gaps, misconducts and failures in supporting and protecting intellectual property rights for pharmaceutical consumer products in Indonesia, Malaysia and Singapore. The study will focus on the causes of illicit trade, the impact of corruption and the success factors for effective enforcement.”
Additional information: The project’s final report focuses on counterfeiting and the need for a collaborative approach to tackle the problem.119
2 Rangsit University Project description: “Research to identify, map out, describe and analyse the illegal network of activities closely related to the illegal trade of cigarettes in selected countries of continental Southeast Asia. Findings will be used to propose solutions to taming and mitigating such activities, while raising public awareness.”
Additional information: The project was removed from the PMI IMPACT website, though it is unclear whether the work carried on. On 6 March 2019, a seminar entitled “Illicit Economy, Law, and ENDS” was held at Rangsit University.120
1 Research Centre of Security and Crime (RISSC), Italy Project name: “Project DNT: Improving knowledge on the trafficking in drugs, NPS, and tobacco”
Project description: “Research combined with educational and awareness activities focused on the illegal trafficking of drugs, New Psychoactive Substances (NPS), and tobacco products, both offline and online – particularly on the dark web.”
Dates: October 2017 – November 2019
Additional information: Events held in December 2018 and May 2019 as part of the project notably featured representatives from INTERPOL, the Council of Europe Pompidou Group, and Italian customs and law enforcement agencies, and stressed the importance of public-private sector cooperation.121122
1 Romanian Police Project name: “DETECT – Enhanced capabilities for detecting and investigating tobacco smuggling at EU border”
Project description: “Procurement of patrolling and tobacco detection equipment, coupled with training and coordination activities in Romania to disrupt criminal smuggling networks in the country and at the borders with Ukraine, Moldova and Serbia.”
Dates: October 2018 – September 2020
Amount: US$1.2 million
Additional information: The funding was dedicated to purchasing vehicles, high-tech cameras, protective equipment and sniffer dogs.123
1 & 2 Royal United Services Institute (RUSI), UK Round 1:
Project name: “Rethinking counter-terror finance: Assessing the effectiveness of current policy responses”
Project description: “Research exploring key components of contemporary terrorist financing, in particular illegal trade and transnational organized crime, in order to identify inconsistences and implementation shortcomings in counter-terror finance.”
Dates: July 2017 – March 2020
Additional information: The project involved meetings with “key policy-makers, international governmental organizations and the private sector”, including presentations to the United Nations Counter-Terrorism Committee, the ISIL/(Da’esh)/al-Qaida Sanctions Committee, 1988 Sanctions Committee, the Global Counter-Terrorism Forum (GCTF), the European Parliament, the World Bank, the IMF, UN Member States France and Peru on their Security Council Resolutions (2462 and 2482), the French Treasury leading up to the 2018 “No Money for Terror” Summit, and the UK Joint Money Laundering Intelligence Task Force (JMLIT) terrorist financing expert working group.124
Round 2:
Project name: “Assessing Free-Trade Zone Integrity”
Project description: “Bridge the gap between general recognition that Free Trade Zones (FTZs) pose a range of criminal risks and limited understanding of the scale and nature of those risks to date. The project will provide a mechanism to enable authorities and business partners to assess overall risk levels in individual FTZs.”
Additional information:
The project examined four country case studies: Morocco, Panama, Singapore and the UAE. Dissemination of findings included a parliamentary testimony in the UK and other contributions to government consultations.125 The project also developed a FTZ Risk Assessment Tool “that helps private-sector companies ensure they do not unwittingly facilitate crime when operating in [FTZs]”.126The project does not elaborate on how transnational tobacco companies may wittingly rely on FTZs to smuggle their own products.127 On 18 May 2021, RUSI organized a launch event in Singapore, which featured Jeremy Rabani, the head of external affairs at PMI in Singapore.128
2 São Paulo University Support Foundation, Brazil Project name: “Illicit Markets and Organized Crime at the Triple Frontier: The Challenge of Police Cooperation”
Project description: “The Institute of International Relations from this university will develop a course for police officers from the Brazil, Paraguay, Argentina Tri-Border Area incorporating different analytical models to explore issues such as the organisation of crime, transnationalisation of illicit markets and crime, and operational structure of the main illicit markets.”
Additional information: In October 2020, the Institute signed a cooperation agreement with the Brazilian Ministry of Justice and Public Security to provide training to law enforcement officials in the Tri-Border Area (Brazil, Paraguay, and Argentina) and “raise awareness about the operational structure of criminal organizations profiting from illicit trade in this region.”129130 Two papers published in Globalization and Health found that from the 1960s onwards, PMI and BAT used Paraguay as a transit hub to smuggle cigarettes to Argentina and Brazil, creating the conditions for the illicit tobacco trade to flourish in the region, with Paraguayan company Tabacalera del Este (Tabesa) mimicking many of the same tactics, including a heavy reliance on smuggling, from the mid-1990s onwards. Paraguay is now one of only three countries in Latin America whose cigarette market share is not dominated by either PMI or BAT.131132
1 Siracusa International Institute (SII) Project name: “Strengthening the Fight Against Illicit Trade in South Eastern Europe (SEE-IMPACT)”
Project description: “Comprehensive national and regional assessment of practical challenges for the fight against illicit trade in South Eastern Europe, in order to: identify innovative cross-sectoral solutions; strengthen the capacity of national judges, prosecutors, law enforcement and customs officers; and promote regional harmonisation.”
Dates: September 2017 – April 2020
Additional information: The project’s final report emphasized the need for greater public-private cooperation, deemed of “fundamental importance”: “there is growing consensus that efforts are needed to make both criminal justice actors and business representatives cognizant of the mutual benefits of their reinforced cooperation. This presents an opportunity that countries across the region should seize with both hands.”133 In December 2018, the Institute convened a Regional Strategic Dialogue, which involved over 100 national politicians, policy-makers and senior criminal justice officials (including Renata Deskoska, Minister of Justice of the former Yugoslav Republic of Macedonia, Besfort Lamallari, Albanian Deputy Minister of Interior, Milko Berner, Bulgarian Deputy Minister of Interior, Augustin Lazar, Romanian General Prosecutor, and Jean-Claude Brunet, French Ambassador-at-Large and Special Envoy for Transnational Criminal Threats), as well as directors of international agencies such as Tim Morris, Executive Director of INTERPOL, and senior executives from Europol, the World Customs Organization, and the UN Office on Drugs and Crime.134135 In June 2019, the National Strategic Dialogue on Illicit Trade featured Piero Cristoforo Sardi, Italian Ambassador to Kosovo, Fatmir Gashi, Deputy Minister of the Ministry of Finance of Kosovo, Afrim Kasolli, Advisor of the Ministry of Justice, Bahri Berisha, Director General of the Kosovo Customs, Fatos Rushiti, Advisor at the Minister of Interior, Colonel Fahredin Verbovci, Representative of Kosovo Police, and Valon Jupa, Director of the Prosecution Performance Review Unit at the Kosovo Prosecutorial Council.136
1 Southeast European Law Enforcement Center (SELEC) Project name: “FAIT – Fight Against Illegal Trade”
Project description: “Increasing the operational capacity of SELEC and its Member States through training programs, procurement of equipment, infrastructure improvements, and awareness activities to efficiently respond to smuggling into EU via the SELEC region.”
Dates: November 2017 – September 2020
Additional information: SELEC is a law enforcement international organization involving police and customs authorities across 11 Southeast European countries and focusing on transborder organized crime. As part of the PMI IMPACT-funded project, SELEC notably organized the 19th meeting of the Anti-Fraud and Anti-Smuggling Task Forced in May 2019, featuring representatives from the EU Border Assistance Mission (EUBAM), the European Anti-Fraud Office (OLAF), the Spanish government, Kazazi Consulting (another PMI IMPACT awardee), and PMI.137 The project also involved the creation of a consumer-facing awareness campaign in three countries focusing on the risks of cigarette smuggling, and the purchase of three vehicles to support operations and investigations.138 More recently, in February 2022, SELEC took part in a conference on the illicit tobacco trade organized by Romania NGO ACTIV which featured representatives from PMI, JTI, BAT, EU institutions FRONTEX, EUBAM, the EU Advisory Mission Ukraine, and the EU Delegation to the Republic of Moldova, and government and law enforcement representatives from Ukraine, Republic of Moldova, Bulgaria, and Romania.139
2 The Foundation for International Human Rights Reporting Standards (FIHRRST) Project name: “Combating Illegal, Unreported and Unregulated Fishing and Its Related Crimes in South-East Asia”
Project description: “Raise awareness and help combat illegal, unreported and unregulated fishing in Southeast Asia. Project to examine the issue and its commonly associated crimes such as illegal trade and human rights abuses.”
1 The Institute of Economics, Zagreb Project name: “Illegal trade of tobacco products: smuggling as experienced along the Balkan route – BalkanSmugg”
Project description: “Academic research and awareness activities focused on the attitudes and experiences of citizens in the Balkan countries related to illegal tobacco trade.”
Dates: July 2017 – October 2019
Additional information: “Along our research path, PMI IMPACT has provided us with constant support not just financially, but also with their flexible approach and full cooperation”, notes EIZ researcher Jelena Budak, suggesting extensive PMI involvement beyond the mere selection and funding process.140 In an interview with PMI, Budak argued: “Only through coordinated cooperation between the state authorities of all countries located on the so-called Balkan route, including increased controls and considerably higher penalties, can the gray market be reduced. Such actions should involve all interested sectors—internal affairs, customs administration, tax administration, the judiciary, border police, as well as the legal tobacco industry.”141 Philip Morris Zagreb controls 70% of the distribution of tobacco products in Croatia (with JT International Zagreb, Imperial Tobacco Zagreb, and BAT Hrvatska sharing the rest of the market) while TDR (owned by BAT) manufactures 87% of the country’s tobacco products.142
2 The Mekong Club Project name: “Leveraging Private Sector Engagement to Reduce Trafficking in Persons in Target Sectors”
Project description: “Engage the banking, manufacturing, retail and hospitality sectors in tackling the issue of modern slavery by developing tools, data collection techniques, and training.”
Additional information: The project is described by PMI as focusing “on collaboration, working with companies in a positive, supportive way. It does this by identifying and developing practical, innovative, relevant tools to help corporations understand the potential vulnerabilities applicable to their businesses.”143
2 The Soufan Group LLC Project name: “North Africa: The Nexus Between Organized Criminal Groups, Terrorist Organizations and Illicit Trade”
Project description: “Research to explore how terrorist organisations and organised criminal groups use transnational smuggling networks in North Africa. The project will explore linkages between terrorism, organised crime and the illegal trade, and highlight the transnational crimes of human smuggling, drugs and arms trafficking.”
Additional information: The Soufan Group website does not mention PMI IMPACT funding. Intelligence services listed instead include the following: “Investigated and mapped the organized crime/terrorism nexus in North Africa and the Sahel for a multinational organization.”144
1 & 2 Transcrime Round 1:
Project name: “ITTP Nexus in Europe and beyond”
Project description: “Research project to identify the flows of illegal cigarette trade through the EU and selected EEMA countries, focusing on how these are connected to the social, political, and legislative frameworks. Assessment of the related risk factors and development of preventive measures to tackle the issue.”
Dates: December 2017 – April 2019
Additional information: Transcrime has well-established ties with the tobacco industry. In this project’s final report, none of the factors listed as “driving illicit flows of cigarettes” include supply chain control or tobacco industry complicity in illicit trade.145. The report’s booklet on the ‘Maghreb route’ mentions that “France is the main destination for illicit cigarettes outflowing from the Maghreb region”, failing to note that a vast majority of those are reportedly Marlboro cigarettes, produced legally in the PMI factory in Algeria and diverted to the illicit market. The word ‘Marlboro’ appears only once in the 36-page booklet, to mention that: “Legally produced cigarettes from well-known international brands are also smuggled in the area and to the EU, especially Marlboro and L&M.” – without questioning any potential issue of complicity or lack of supply chain control from manufacturer PMI.146 Perhaps aware of the criticisms from the tobacco control community against Transcrime for its close links with the tobacco industry, Ernesto Savona, Director of Transcrime, notes:
“A crucial element is that the formula fully respects the independence of the research conducted and leaves academics the freedom to conduct their research how they see fit. What I really appreciated most is the fact that we were completely free to develop our research and our results in the manner that we thought was most appropriate and more interesting from an academic point of view.”147
Round 2:
Project name: “DC-iFlows – Displacement and Convergence of Illicit Flows (humans and goods)”
Project description: “Research on the displacement and convergence of human smuggling and drug trafficking in North Africa. The project will enhance the knowledge among policy makers, experts in the field, regulators, students, civil society and the public.”
Additional information: The project led to the publication of a book entitled ‘The Evolution of Illicit Flows: Displacement and Convergence among Transnational Crime’, part of Springer Nature Sustainable Development Goals Series. The editors thanked PMI “for providing funding for the original project which led to the development of this book. We appreciate their professional assistance and belief in the importance of this research topic. We should conclude by noting that this publication solely reflects the views of the authors and editors, and not those of others.”148
2 Transnational Alliance to Combat Illicit Trade Project name: “From Assessment to Action – Global Business Report and Advocacy Initiative on Combating Illicit Trade”
Project description: “Development of a Global Illicit Trade Business Report, drawing upon private sector experiences and identifying solutions to supply chain vulnerabilities common to all forms of illicit trade. It examines transportations modalities, customs, FTZs, human trafficking, criminal activity, financial fraud, and regulatory gaps. Findings will be shared with stakeholders in response to their calls to significantly upgrade the availability and exchange of information.”
Additional information: Visit the TRACIT page for more information.
2 Transparency International Turkey Project name: “Initiative Against Illicit Trade: Strengthening Integrity Systems and Raising Public Awareness for the fight against Illicit Trade and Informal Economy in Turkey”
Project description: “Strengthen integrity systems and raise awareness to tackle illegal trade and the ‘informal economy’ in Turkey. Project will focus on research, advocacy, awareness raising and capacity building activities.”
Additional information: A report launch event was organized in June 2022, which featured a Legal Counsel from Total.149
1 Turtle Group Consulting Project name: “The impact of illegal activities inside Italian ports”
Project description: “Research into the complex dynamics of criminal activities related to narcotics, weapons, people smuggling, cigarette smuggling, and terrorism inside Italian ports.”
Dates: September 2017 – November 2019
Additional information: Turtle Group’s director Lorenzo Vidino is also Director of the Program on Extremism at George Washington University.150 The project’s recommendations focused on the need to increase public-private cooperation, with heavier reliance on the private sector for intelligence gathering and sharing.151 Project events featured senior officials from law enforcement, customs, justice, and port authorities across the country.152153
2 Ukrainian Institute for the Future Project name: “Combating Smuggling in Ukraine and Bordering Countries through Monitoring, Research, Advocacy and Changing of Public Policy”
Project description: “Combating smuggling and illegal trade in Ukraine through monitoring (including the state border), sociological research, advocacy and raising public awareness.”
Additional information: One of the project’s main findings is that smuggling has become routine in Ukraine because the population condones smuggling, having benefited from it, and is overall accepting of it.154 The main report on tobacco smuggling also focuses on taxation being the number one cause for illicit trade155, despite independent academic evidence pointing to a range of other more important factors.4. It also heavily relies on data funded by the tobacco industry, including KPMG and Kantar.155
2 Université de Montréal Project name: “Disrupting The Darknet: Law Enforcement Operations And Their Impact On Darknet Offenders”
Project description: “Research to assess offline and online law enforcement interventions and their impact on dark net offenders. Based on online data collection and interviews with law enforcement officers, the project aims to better understand their perceptions of the interventions. Research findings will be broadcasted at an international workshop.”
Dates: January 2019 – December 2022
Amount: C$707,391 (US$545,740)
Additional information: A workshop organized as part of the project brought together “practitioners, law enforcement agents and academics [to] share in a conversation their experiences.”156 In 2018, project PI David Décary-Hétu had already co-authored a paper funded by Philip Morris France on online tobacco trafficking. Though the paper is entitled “The Shift to Online Tobacco Trafficking”, the authors estimated the total revenues generated by tobacco trafficking on crypto-markets at approximately $7,880 per month in the Fall of 2016 or to $94,560 on an annualized basis” (for context, PMI’s annual revenue in 2016 was US$26.7 billion157, also noting: “There is no denying that tobacco trafficking is still marginal on crypto-markets.”158 Similarly, a paper published as part of this project found that tobacco trafficking on cryptomarkets is insignificant: “We found 14 vendors among a population of 3511 (0.4%) were involved in the illicit trade of tobacco on cryptomarkets as of the Summer of 2018. These vendors traded cigarettes, cigars and rolling tobacco generating monthly revenues of $8952 from the sales of these items. These revenues pale in comparison to these vendors’ revenues from non-tobacco product listings ($22,177) and the monthly revenues generated by other cryptomarkets vendors (over $37 million US dollars).”159
1 University of National and World Economy Project name: “Contraband and counterfeit risk identification – business process analysis and spatial aspect”
Project description: “A combination of research, training programs, and awareness activities focused on the modus operandi of illegal tobacco trade and its links to organized crime, corruption, and drug trafficking.”
Dates: August 2017 – July 2019
Additional information: A workshop organized as part of the project in June 2018 involved “experts from national and international public, private and academic sectors”.160 The event notably featured Bulgaria’s Deputy Minister of Agriculture. The project, focusing on the links between the illicit tobacco trade and organized crime, corruption, and drug trafficking, created “teaching materials and training courses for decision-makers and law enforcement officers.”161
1 University of Palermo Project name: “The new era of smuggling in the Mediterranean Sea” (NESMeS Project)
Project description: “Research and educational activities with a cross-sectoral approach to explore the extent to which the smuggling of goods and the trafficking of human beings are being committed by the same criminal organizations and realized through the same Mediterranean routes.”
Dates: November 2017 – February 2020
Additional information: The project focused on the smuggling of migrants, people, drugs, and cigarettes across the Mediterranean Sea, with a particular focus on Italy, Spain, Portugal, Germany, and Greece. The main report characterizes the smuggling of transnational tobacco companies’ brands as a thing of the past: “Until thirty years ago, the main type of illicit trade in Europe was the large-scale smuggling of well-known brands of cigarettes that were legally produced for export but stolen. In recent years, other types of illicit trade have emerged such as illegal manufacturing, counterfeiting and new cigarette brands.”162 Though it is true that the illicit tobacco trade has evolved since the 1990s, with new modus operandi and actors emerging, the report does not mention extensive evidence of continued industry complicity in the illicit trade.162 It relies heavily on sources funded by the tobacco industry, including KPMG, Transcrime, Euromonitor International, and RUSI. Workshops organized as part of the project in 2019 included representatives from Frontex, the German Customs Office, the Italian Permanent Representative to the UN, and other Italian authorities including the Financial Police, the Customs and Border Protection Office, and judges.163.
2 West Sands Advisory Ltd Project name: “Illicit Trade & Corruption: Reconsidering the Role of State-Affiliated Actors in Organized Crime”
Project description: “Address the involvement of state-affiliated actors in illegal trade by developing a typology and testable models, covering different types of involvement, from complacency to complicity. The project seeks to better inform and engage policy makers and the public through media engagement, events and public initiatives.”
Additional information: In September 2018, West Sands Advisory – a business intelligence and political risk consultancy, was acquired by Sibylline Ltd, operating in the same sector.164

TobaccoTactics Resources

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