TRACIT
The Transnational Alliance to Combat Illicit Trade (TRACIT) is a non-governmental organisation consisting of corporations and select trade associations within a range of sectors including tobacco, alcohol, agri-foods, petroleum and pharmaceuticals. TRACIT aims to build co-operation between business and government regarding regulatory responses to illicit trade. It has extensive tobacco industry connections and its reports ignore any industry involvement in smuggling activity. The organisation has been successful in accessing international meetings to insert its agenda.
Contents
Background
TRACIT was established in April 2017 and formally launched in New York in September 2017. It received endorsements from representatives of the American Department of Homeland Security, the UN Office of Drugs and Crime and the OECD.[1] Its first public event appears to have been a two-day conference in London on combatting illicit trade sponsored by the Financial Times and the Philip Morris campaign on illegal trade Impact.[2] As well as Tracit Director General Jeffery Hardy, the were several members of the PMI Impact panel: Suzanne Hayden, Alain Juillet, Paul Makin, Luis Moreno Ocompo, Navi Pillay and Jurgen Storbeck. PMI CEO Andre Calantzopoulos was also a guest speaker.
Membership
The TRACIT organisation does not say on its website who its members are, but in support of an application to the World Intellectual Property Organization it disclosed that Philip Morris International is one and that British American Tobacco and Japan Tobacco International are project partners.[3] Also listed as a project partner is Crime Stoppers International which has tobacco company support.
Partners
TRACIT is partnered with several other similar organisations including the Anti-Counterfeiting Group and is part of the UN Global Compact.[4]
Activities
Overview and tobacco funding
The organisation breaks its focus down into 12 sectors, of which one is tobacco. It says:
“Overall, for the tobacco industry the illicit trade in cigarettes results in lost revenue, reputational damage and loss of consumer trust, and increased costs in supply chain monitoring and the implementation of technologies that enable companies to track and trace their products.”[5]
TRACIT accepts sponsorship from tobacco companies to help in the production of reports and quotes uncritically from industry documents as part of its analysis. In its lobbying it will often share platforms with industry officials and their allies. For instance, in its introductory analysis of the the tobacco sector, TRACIT quotes from a KPMG report called Project Sun which was produced in 2015 and looks at the illicit cigarette market in the European Union, Norway and Switzerland. The report was produced on behalf of BAT, Imperial, JTI and PMI.[6] Nowhere does TRACIT reference the multiple reports, supported by evidence, of the involvement of tobacco companies in the illicit trade.
In March 2019 TRACIT was awarded funding from PMI IMPACT - a $100 million initiative from Philip Morris International to support projects against smuggling. The award, one of 31 in a second round of funding worth $21 million in total, was for the:
"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 transportation modalities, customs, free trade zones, human trafficking, criminal activity, financial fraud, and regulatory gaps. Findings will be shared with all stakeholders in response to their calls to significantly upgrade the availability and exchange of information."[7][8]
Work programmes
Global Illicit Trade Environment Index
The Global Illicit Trade Environment Index, released in June 2018, was produced by the Economist Intelligence Unit and evaluates 84 countries on their “structural capability to guard against illicit trade, highlighting specific strengths and weaknesses”. The objective is “to improve the knowledge and understanding of the regulatory environment and economic circumstances that enable illicit trade.[9] It is a key report which, with its regional and country subsets and recommendations, is the foundation for TRACIT policy proposals and lobbying. The report’s sponsors include Philip Morris International (platinum sponsor), British American Tobacco, Japan Tobacco International and Crime Stoppers International (bronze sponsors).
Mapping impact of illicit trade and sustainable development goals
In an area which has seen increasing interest by tobacco companies, TRACIT maps the impact of illicit trade against the UN sustainable development goals. It released a report in July 2019. The report has chapters for each of its sectors and how illicit trade has a negative impact on specific goals. For tobacco it lists the goals of good health and well-being; decent work and economic growth; peace, justice and strong institutions and partnerships for goals as being affected. Again, no mention is made in the chapter on any culpability that tobacco companies have for the illicit trade.[10]
Involvement with UNCTAD
In July 2019, as part of its launch on the report, TRACIT co-hosted a meeting on illicit trade and the UN’s Sustainable Development Goals (SDG) in partnership with the United Nations Conference on Trade and Development (UNCTAD).[11] TRACIT Director General Jeffrey Hardy addressed the meeting with contributions from UN officials.[12] TRACIT’sengagement with the UN organisation reflects the attempts of tobacco companies to use third parties to ingratiate themselves with governments as partners in reducing illicit trade. Other UN organisations have been targeted by groups with close tobacco company affiliations such as Concordia and the International Chamber of Commerce.[13]
Regional and Country Activities
TRACIT has been active in a number of countries representing industry interests at governmental level backed by its own reports. The principal report is the Illicit Trade Environment Index from which various regional versions have been produced.
Asia
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Myanmar |
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Latin America
Latin America |
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Argentina: |
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Colombia |
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Costa Rica |
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Dominican Republic |
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Ecuador |
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Panama: |
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Europe
Europe |
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Serbia, Bosnia and Montenegro |
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Middle East
Israel |
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United Arab Emirates |
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Africa
Tunisia |
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South Africa |
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Staff
Senior Management
The senior management team is made up of the following people:[57]
- Jeffrey P Hardy – Director-General. Hardy previously served as the Director of the International Chamber of Commerce’s Business Action to Stop Counterfeiting and Piracy. The group has consistently produced reports sympathetic to its tobacco industry members and lobbied against Plain Packaging measures. Hardy is founder and managing director of IDA Consulting, a management consultancy.[58] Hardy is listed in the EU lobbying register.[59]
- Stefano Betti – Deputy Director General
- Louis Bonnier – Director of Programs. Co-author of the report on illicit trade and SDGs
- Ulrika Bonnier – Director of Programs. Co-author of the report on illicit trade and SDGs
- Suriya Padmanaabhan – Director of Programs
- Cynthia H Braddon – Head of Communications and Public Policy
- Esteban Giudici - Senior Policy Advisor
Directors
Directors TRACIT gives its mailing address as One Penn Plaza in New York City, but it is registered in Fort Myers, Florida, as not-for-profit organisation under US tax code 501(c)(6). Its corporate filing on 19 April 2019 listed three directors: [60]
- Jeffrey Hardy
- David Benjamin
- Shelley Duggan. UK-based trademark lawyer who is a director at Proctor & Gamble. Duggan is chair of the Anti-Counterfeiting Group (ACG), a not-for-profit global trade association which tackles counterfeiting and is partner of TRACIT.[61] One of the founders of the ACG was British American Tobacco. It is no longer listed as a member but Philip Morris, Japan Tobacco International, Imperial Tobacco and the Tobacco Manufacturers' Association all are.[62]
Advisory Council
The organisation’s Advisory Council is made up of independent experts providing advice in a personal capacity.[63] Among its members are:
- Karl Lallerstedt, from the Confederation of Swedish Enterprise, contributed a chapter to a book on organised crime which grew out of a BAT-funded project.[64].
- Leonard McCarthy, founder of integrity and risk management firm LFMcCarthy Associates, prior to that an investigator at the World Bank.[65] McCarthy came to prominence as the head of South Africa’s Directorate of Special Operations, or so-called Scorpions, which investigated organised crime, including tobacco smuggling. The unit was disbanded in 2009.[66]
Notes
- ↑ Tracit,Tracit launch, Tracit website, 6 September 2017, accessed October 2019
- ↑ Financial Times, Combatting Illicit Trade, FT Website, date unknown, accessed October 2019
- ↑ World Intellectual Property Organization, Advisory Council on Enforcement, WIPO website, 8 August 2019, accessed October 2019
- ↑ Tracit, Partners, Tracit website, date unknown, accessed October 2019
- ↑ Tracit, Tobacco, Tracit website, undated, accessed October 2019
- ↑ KPMG, Project Sun report, KPMG website, 2015, accessed October 2019
- ↑ PMI IMPACT, Second Round Funding, PMI IMPACT website, undated, accessed October 2019
- ↑ See here for a full list of PMI IMPACT projects in the first and second round
- ↑ Tracit, Global Illicit Trade Index, Tracit website, date unknown, accessed October 2019
- ↑ Tracit, Illicit Trade and the UN sustainable development goals, Tracit website, July 2019, accessed October 2019
- ↑ Tracit, Event dialogue on illicit trade and the SDGs, Tracit website, undated, accessed October 2019
- ↑ UNCTAD, Meeting Details, UNCTAD website, unknown date, accessed October 2019
- ↑ Expose Tobacco, UNGA briefing, Expose Tobacco website, 1 September 2019, accessed October 2019
- ↑ 14.0 14.1 14.2 TRACIT, Policy Recommendations to Combat Illicit Trade Inspired by the Global Illicit Trade Environment Index Asia Region, 2018, accessed October 2019
- ↑ International Trademark Association, Board, ITA website, undated, accessed October 2019
- ↑ TRACIT, Policy Recommendations Myanmar, TRACIT website, 2018, accessed October 2019
- ↑ TRACIT, Myanmar Illicit trade paper, TRACIT website, 2018, accessed October 2019
- ↑ 18.0 18.1 TRACIT, Latin America Recommendations, TRACIT website, 2018, accessed October 2019
- ↑ TRACIT, INTERPOL global conference, 11 September 2019, accessed October 2019
- ↑ TRACIT, Latin American regional summit, 14 June 2019, accessed October 2019
- ↑ Latin America’s head on fight against illicit trade, Stop: Illegal website, 23 June 2019, accessed October 2019
- ↑ TRACIT, Latin America scores low on illicit trade index, 13 June 2019, accessed October 2019
- ↑ 23.0 23.1 TRACIT, Policy recommendations Colombia, 2018, accessed October 2019
- ↑ Ministry of Health of Brazil and CONICQ, 5 July 2019, accessed October 2019
- ↑ TRACIT, Media Release, 18 October 2018, accessed October 2019
- ↑ TRACIT, Policy recommendations Costa Rica, 2018, accessed October 2019
- ↑ Ministry of Home Affairs Costa Rica, Bill to improve the fight against illicit trade, 17 November 2014, accessed October 2019
- ↑ Adiario Costa Rica, Conflicts of Interest in Costa Rica, 8 June 2018, accessed October 2019
- ↑ AmCham, Directory, AmCham website, 2018, accessed October 2019
- ↑ TRACIT, Costa Rica shown vulnerable to illicit trade, 16 August 2018, accessed October 2019
- ↑ TRACIT, Policy recommendations Cost Rica, 2018, accessed October 2019
- ↑ M.Cabral, M.Cabral profile LinkedIn, accessed October 2019
- ↑ TRACIT, Policy recommendations Dominican Republic, 2018, accessed October 2019
- ↑ BritCham, Membership Directory, BritCham website, undated, accessed October 2019
- ↑ TRACIT, Dominican Republic is on the right path to fight illicit trade, 8 May 2019, accessed October 2019
- ↑ TRACIT, Policy recommendations Ecuador, 2018, accessed October 2019
- ↑ Carla Muirragi, Linkedin profile, undated, accessed October 2019
- ↑ TRACIT, Ecuador must do more to tackle illicit trade, 27 November 2018, accessed October 2019
- ↑ TRACIT, Crime Stoppers International conference, 18 October 2017, accessed October 2019
- ↑ CSI, Conference Guide, CSI website, accessed October 2019
- ↑ TRACIT, Europe, 2018, accessed October 2019
- ↑ TRACIT, Policy recommendations Europe, 2018, accessed October 2019
- ↑ TRACIT, Serbia, Bosnia and Montenegro, 2018, accessed October 2019
- ↑ TRACIT, Policy recommendations Serbia, Bosnia and Montenegro, 2018, accessed October 2019
- ↑ TRACIT, Israel, 2018, accessed October 2019
- ↑ EBR, Tobacco illicit trade in Europe, Israel and Middle East, European Business Review, 27 February 2018, accessed October 2019
- ↑ TRACIT, Policy recommendations Israel, 2018, accessed October 2019
- ↑ TRACIT, UAE, 2018, accessed October 2019
- ↑ TRACIT, UAE, 2018, accessed October 2019
- ↑ TRACIT, Tunisia, 2018, accessed October 2019
- ↑ TRACIT, Tunisia, 2018, accessed October 2019
- ↑ Vellios, N., van Walbeek, C. & Ross, H. Illicit cigarette trade in South Africa: 2002-2017, 2019, Tobacco Control, quoted in the TRACIT report
- ↑ TRACIT, Press release South Africa, TRACIT website, 23 October 2019, accessed October 2019
- ↑ TRACIT, South Africa report and recommendations, TRACIT website, 2019, accessed October 2019
- ↑ Members, AmCham website, undated, accessed October 2019
- ↑ board members, CGCSA website, undated, accessed October 2019
- ↑ TRACIT,Team TRACIT website, date unknown, accessed October 2019
- ↑ IDA Consulting, About, website, date unknown, accessed October 2019
- ↑ Lobby Facts EU, Transnational Alliance to Combat Illicit Trade, undated, accessed October 2019
- ↑ State of Florida, 2019 corporate filing May 2019, acccessed October 2019
- ↑ Website, Who We Are, ACC website, date unknown, accessed October 2019
- ↑ Website, A Complete List of ACG Members, date unknown, accessed October 2019
- ↑ Tracit website, Advisory Council, date unknown, accessed October 2019
- ↑ Comolli, V (ed). Organized Crime and Illicit Trade: How to Respond to This Strategic Challenge in Old and New Domains, Palgrave Macmillan 2018 https://www.palgrave.com/gp/book/9783319729671
- ↑ LFMcCarthy Associates, website, date unknown, accessed October 2019
- ↑ Staff reporter, Former Scorpions boss lands big job monitoring Russian telecoms firm, City Press, 23 August 2019, accessed October 2019
- Transnational Lobby Networks
- Third Party Techniques
- Smuggling
- British American Tobacco
- Philip Morris International
- Japan Tobacco International
- South Asia
- Myanmar
- Latin America and Caribbean
- Argentina
- Colombia
- Costa Rica
- Dominican Republic
- Ecuador
- Panama
- Europe
- Serbia
- Bosnia
- Montenegro
- Israel
- United Arab Emirates
- South Africa
- Tunisia