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PMI IMPACT is a US$100 million funding initiative launched by Philip Morris International (PMI) in 2016.1 It describes itself as “a global initiative to support public, private, and nongovernmental organizations to develop and implement projects against illegal trade and related crimes”.2


Funding Process

PMI IMPACT funding allocation is split into several funding rounds, each with a distinct theme.1

The selection of successful projects involves a three stage process. First, applicants submit an expression of interest which PMI conducts “initial due diligence checks” on.3 Second, selected applicants submit full proposals for review and approval. The final stage involves successful applicants signing a grant agreement with PMI, which includes the following requirement:

“When making public its Project’s work product or any deliverables, to be transparent about PMI’s financial support of the Project, Grantee shall disclose the fact that the Project was funded by PMI IMPACT. Before Grantee makes any of its work product or deliverables public, PMI and Grantee shall agree on the precise language of disclosing PMI’s financial support, ensuring that such language complies with applicable laws, PMI transparency and disclosure policies, and other applicable ethics rules.”4

Expert Council

The funding applications are judged by an Expert Council of individuals with close links to United Nations (UN) agencies and INTERPOL.5 The Council members are financially compensated for their time, 6 and in May 2021 included:

Carlos Moreira

Moreira consulted for several international government organizations including the International Labour Organization (ILO), United Nations Conference on Trade and Development (UNCTAD), the World Trade Organization (WTO), the World Bank, the United Nations Development Programme (UNDP) and the United Nations Economic and Social Commission for Asia and the Pacific (ESCAP), before founding WISeKey, a cybersecurity company in 1999 – where he is currently Chairman and CEO.7 He was also a Member of the UN Global Compact and a Vice-Chair of the World Economic Forum’s Global Agenda Council on Illicit Trade.8

Suzanne Hayden

Hayden worked as a PMI consultant on “law enforcement matters”, and is the former Senior Advisor to the UN Office on Drugs and Crime (UNODC) and the International Anti-Corruption Academy (IACA). She also established the UN’s first financial investigation unit.5 Hayden was also involved in an Anti-Contraband Tobacco Working Group meeting, partly-funded by Dawson Strategic,9 a consultancy registered under the Senate Office of Public Records as a PMI lobbying firm.10

Alain Juillet

Juillet served as Intelligence Director for the General Directorate for External Security (DGSE) of the French Ministry of Defence, and later took the role of Senior Official in charge of economic intelligence to the Prime Minister’s office, holding this position until 2009.5 In 2009 he became President of the Académie de l’Intelligence Economique, and in 2011, President of the Club des Directeurs de Sécurité des Entreprises (CDSE). From 2016, he worked with INTERPOL as chair to the International Forum of Security Technologies (FITS).11

Luis Moreno Ocampo

Moreno Ocampo was the first Chief Prosecutor for the International Criminal Court (ICC) from 2003-2012, and he also served as Chairman of the World Bank Expert Panel on the Padma Bridge project.5 On 11 June 2015, he hosted a workshop for the Global Order Project on the Philip Morris vs. Uruguay lawsuit, though its content is unknown.12 In 2017, Mediapart revealed that while serving as Chief Prosecutor of the ICC, Moreno Campo managed offshore companies in tax havens (later arguing that his ICC salary “was not enough”)13, “undermined the confidentiality of cases” and used the ICC “as private property”.14

Navi Pillay

Pillay was elected by the UN General Assembly to be a judge on the International Criminal Tribunal for Rwanda serving from 1995-2003, and was UN High Commissioner for Human Rights from September 2008 to August 2014. Pillay was added to the expert council in 2017.15

Former expert council members

Cherif Bassiouni (deceased).16.(deceased)

Bassiouni was Emeritus Professor of Law at DePaul University. He also held several positions with the UN and consulted for the US Department of State and Department of Justice, including on drug trafficking and terrorism.17. Regarded as the “father of international criminal law”,18 his work notably led to the creation of the International Criminal Tribunal for the former Yugoslavia and the International Criminal Court19. He was one of the founders of the International Institute of Higher Studies in Criminal Sciences (ISISC) located in Siracusa, Italy, and later became Honorary President of the Siracusa International Institute from (2015-September 2017)20, who received funding from PMI IMPACT’s first round on September 2017.

Paul Makin

Makin worked at the UN Industrial Development Organization (UNIDO) where he was Director, Operational Support Services and Director of the organization’s Egypt and Regional Office.5

Jürgen Storbeck

Storbeck is a former head of the Central Bureau of INTERPOL and was the first Director of Europol between 1999 and 2004. More recently he has been consulting for governments, public authorities as well as private organisations, including PMI, in the field of crime prevention and enforcement.5

Catherine Volz (deceased)15

Volz worked in the United Nations Office on Drugs and Crime (UNODC) for more than 18 years, where she notably served as Chief of the Human Security Branch of the Division for Operations, Chief of the Treaty and Legal Affairs Branch from 1988 onwards. She previously was at the U.S. Department of Justice, including in its Criminal Division Narcotics and Dangerous drug section.2117

Who Is Funded?

For a full list of projects and events funded through PMI IMPACT and further information on each project, see the List of Successful PMI IMPACT Applicants.

For other significant organisations that have either partnered with PMI IMPACT on projects, or produced PMI IMPACT sponsored content, see the Organisations linked to PMI IMPACT page.

First Funding Call (2016)

To date, PMI IMPACT has had three funding calls. The first funding call focused on projects with an impact in the European Union (EU). PMI announced that it would spend $28 million over two years to fund 32 approved projects (Image 1).2223242526

Image 1. Snippet from PMI IMPACT website, as seen 11 September 2017.22

Second Funding Call (2017)

The second round was opened on 29 September 2017 and called for initiatives that addressed “converging forms of illegal trade and related crimes, such as corruption, money laundering, and organized criminal networks”, and had to have an impact in one or more of these geographic areas: Eastern Europe, Middle East, North Africa, Tri-Border Area in South America, Central America, South and Southeast Asia.27 The funding call received 157 expressions of interests, and PMI awarded 31 projects in 23 countries, for a grant total of US$21 million.282930 PMI announced the results at a meeting of the OECD Task Force on Countering Illicit Trade, itself vice-chaired by senior PMI executive Alvise Giustiniani.3031

Third Funding Call (2021)

The third funding call was opened on 16 June 2021 and once again invited applications on the theme of illicit trade.3233 Within this theme, projects were asked to address: border control; capacity building; restorative justice and victims’ protection; network engagements, awareness building and international cooperation; COVID-19 and the threat of illicit trade.33. The “capacity building” topic includes funding “training for police and judges”, giving the company an opportunity to influence law enforcement and policy.3334 The topic of COVID-19 welcomes proposals “that can address the threat of illicit COVID-19 vaccines, medical equipment and PPE.” Representing attempts to gain credibility by investing in pharmaceuticals, COVID-19 vaccines and Corporate Social Responsibility, actions that challenge the WHO Framework Convention on Tobacco Control.35

Controversy: Funding Of Science

One of the successful recipients of the first PMI IMPACT funding round was Professor John Vervaele, an academic at Utrecht University School of Law in the Netherlands. Vervaele was awarded €360,000 to examine how enforcement could be improved to combat illicit tobacco trade in the EU, particularly ‘cheap whites’ from Belarus, Russia and Ukraine.36

The funding attracted widespread criticism from health organisations including the Dutch Cancer Society (KWF), which said that “the tobacco industry is not a normal industry, and that’s why they should not be funding scientific research”.37

Following the criticism and subsequent pressure in the media, the university decided to no longer accept PMI’s funding and fund the project themselves.37

TobaccoTactics Resources

TCRG Research

For a comprehensive list of all TCRG publications, including TCRG research that evaluates the impact of public health policy, go to the Bath TCRG’s list of publications.

Relevant Link

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  3. PMI IMPACT, Application Terms and Funding Rules, Second Funding Round, 2017, accessed October 2017
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