The illicit tobacco trade is prone to money laundering. Trade is considered to be cash intensive and profitable whilst being accompanied by low levels of risk posed to the criminal groupings (in terms of detection, seizures, penalties, criminal procedure) contributing towards the manifestation of the related illicit activities. Key areas of concern include:

a) Loss of revenue to the fiscal authorities.

b) The use of the illicitly generated proceeds (i.e., to fund other crimes or the financing of terror).

c) The ability to distinguish between illicit activities as undertaken by licit and illicit players in the tobacco sector.

d) To identify the extent that governments enforcement agencies prioritise the addressing of illicit trade in tobacco when compared to other crimes.

This document provides a synopsis of the nature and extent of the ML/TF risks currently associated with the illicit trade in tobacco. It contains an overview of the problem statement and the data provided, as well as an analysis of the predicate offences, extent of associated money laundering and terror financing activities coupled lastly to the various jurisdictional enforcement responses to the curbing of this specific phenomenon.