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GLOBAL CRIME

GLOBAL CRIME-ORGANIZED CRIME-ILLICIT TRADE-DRUGS

Posts in Financial Crimes
Internet Organised Crime Threat Assessment (IOCTA) 2024

Europol; European Union. Publications Office

From the document: "This edition marks 10 years since the release of Europol's first IOCTA [Internet Organised Crime Threat Assessment]. Throughout this time, the threats posed by cybercrime have evolved dynamically in terms of volume, intensity and harm potential. The number of cybercriminals entering the market continued to grow steadily, thanks to the adoption of new technologies as well as the increasing complexity of digital infrastructures, which expands the potential attack surface. In 2023, millions of victims across the EU were attacked and exploited online on a daily basis. Small and medium businesses were increasingly popular targets for cyber-attacks, while e-merchants experienced the most digital skimming attacks. Adults were victimised through phishing, investment and romance frauds, and more and more minors were targeted by child sexual exploitation offenders and online sexual extorters. In parallel, a number of worldwide law enforcement actions shook the cybercriminal underground through continued arrests of ransomware affiliates and operators. Law enforcement also carried out coordinated disruption operations against cybercriminals' digital infrastructures. Notwithstanding the growing presence of law enforcement in the dark web, this environment continues to function as an enabler for cybercrime, allowing offenders to share knowledge, tools and services in a more concealed way. In addition, the use of cryptocurrencies in a wider variety of crime areas has become more noticeable in 2023, alongside the growing number of requests for investigative support in cryptocurrency tracing received by Europol. Cybercriminals are keen to leverage Artificial Intelligence, which is already becoming a common component in their toolbox and is very likely to see even wider application. Law enforcement agencies are expected to build a robust capacity to counter the growing threats stemming from this, both in terms of human resources and technical skills."

Europol; European Union. Publications Office . 2024. 38p.

Global Catastrophic Risk Assessment

RAND CORPORATION

From the document: "Global catastrophic and existential risks hold the potential to threaten human civilization. Addressing these risks is crucial for ensuring the long-term survival and flourishing of humanity. Motivated by the gravity of these risks, Congress passed the Global Catastrophic Risk Management Act in 2022, which requires the Secretary of Homeland Security and the administrator of the Federal Emergency Management Agency to coordinate an assessment of global catastrophic risk related to a set of threats and hazards. The U.S. Department of Homeland Security Science and Technology Directorate and the Federal Emergency Management Agency requested the Homeland Security Operational Analysis Center's support in meeting this requirement. This report documents findings from our analysis." Authors include: Henry H. Willis, Anu Narayanan, Benjamin Boudreaux, Bianca Espinosa, Edward Geist, Daniel M. Gerstein, Dahlia Anne Goldfeld, Nidhi Kalra, Tom LaTourrette, Emily Lathrop, Alvin Moon, Jan Osburg, Benjamin Lee Preston, Kristin Van Abel, Emmi Yonekura, Robert J. Lempert, Sunny D. Bhatt, Chandra Garber, and Emily Lawson.

RAND CORPORATION. HOMELAND SECURITY OPERATIONAL ANALYSIS CENTER. 30 OCT, 2024.237p.

Gangsters at War: Russia's Use of Organized Crime as an Instrument of Statecraft

By GALEOTTI, MARK

From the webpage description: "'Since 2012, Russia has strategically used criminal networks to evade sanctions, conduct intelligence, and destabilize the West. Under Putin's 'mobilization state,' illegal activities--from smuggling to cyberattacks--are seen as essential tools of warfare. This report delves into the Kremlin's alarming integration of organized crime into statecraft.' Russia's transition from a 'conscription state' to a full 'mobilization state', after the 2022 invasion of Ukraine, has intensified the involvement of criminal groups in operations tied to sanctions-busting, cyber warfare, and intelligence. Organized crime networks provide Russia with access to restricted goods, such as advanced electronics for its military, and facilitate money laundering and illegal financial flows. Notably, Russian intelligence services have relied on criminal syndicates to supplement their espionage activities, including sabotage, cyberattacks, and assassinations. The report also highlights Russia's weaponization of migration, using smuggling networks to create political instability across Europe. Meanwhile, Putin's regime has blurred the lines between state and criminal actors, using them as tools to evade international sanctions and expand Russian influence globally. 'Gangsters at War' reveals how Russian-based organized crime operates as a tool of Kremlin foreign policy, focusing not just on profits but on weakening geopolitical rivals. From sanctions evasion to destabilizing societies, criminal networks have become a key element in Russia's geopolitical arsenal. The report calls for increased vigilance, international cooperation, and stronger countermeasures to address this growing threat to global stability."

GLOBAL INITIATIVE AGAINST TRANSNATIONAL ORGANIZED CRIME. November. 2024. 82p.

World Drug Report 2024

UNITED NATIONS OFFICE ON DRUGS AND CRIME

From the webpage description: "A global reference on drug markets, trends and policy developments, the World Drug Report offers a wealth of data and analysis and in 2024 comprises several elements tailored to different audiences. The web-based Drug market patterns and trends [hyperlink] module contains the latest analysis of global, regional and subregional estimates of and trends in drug demand and supply in a user-friendly, interactive format supported by graphs, infographics and maps. The Key findings and conclusions booklet [hyperlink] provides an overview of selected findings from the analysis presented in the Drug market patterns and trends module and the thematic Contemporary issues on drugs booklet, while the Special points of interest [hyperlink] fascicle offers a framework for the main takeaways and policy implications that can be drawn from those findings. As well as providing an in-depth analysis of key developments and emerging trends in selected drug markets, the Contemporary issues on drugs booklet [hyperlink] looks at several other developments of policy relevance. [...] The World Drug Report 2024 is aimed not only at fostering greater international cooperation to counter the impact of the world drug problem on health, governance and security, but also at assisting Member States in anticipating and addressing threats posed by drug markets and mitigating their consequences."

UNITED NATIONS OFFICE ON DRUGS AND CRIME. 2024

CCP's Role in the Fentanyl Crisis

UNITED STATES. CONGRESS. HOUSE. SELECT COMMITTEE ON THE STRATEGIC COMPETITION BETWEEN THE UNITED STATES AND THE CHINESE COMMUNIST PARTY

From the document: "The fentanyl crisis is one of the most horrific disasters that America has ever faced. On average, fentanyl kills over 200 Americans daily, the equivalent of a packed Boeing 737 crashing every single day. Fentanyl is the leading cause of death for Americans aged 18-45 and a leading cause in the historic drop in American life expectancy. It has led to millions more suffering from addiction and the destruction of countless families and communities. Beyond the United States, fentanyl and other mass-produced synthetic narcotics from the People's Republic of China (PRC) are devastating nations around the world. It is truly a global crisis. The PRC, under the leadership of the Chinese Communist Party (CCP), is the ultimate geographic source of the fentanyl crisis. Companies in China produce nearly all of illicit fentanyl precursors, the key ingredients that drive the global illicit fentanyl trade. The House Select Committee on the Strategic Competition between the United States and the Chinese Communist Party (Select Committee) launched an investigation to better understand the role of the CCP in the fentanyl crisis. This investigation involved delving deep into public PRC websites, analyzing PRC government documents, acquiring over 37,000 unique data points of PRC companies selling narcotics online through web scraping and data analytics, undercover communications with PRC drug trafficking companies, and consultations with experts in the public and private sectors, among other steps. [...] [T]he Select Committee found thousands of PRC companies openly selling [...] illicit materials on the Chinese internet--the most heavily surveilled country-wide network in the world. The CCP runs the most advanced techno-totalitarian state in human history that 'leave[s] criminals with nowhere to hide' and has the means to stop illicit fentanyl materials manufacturers, yet it has failed to pursue flagrant violations of its own laws."

UNITED STATES. CONGRESS. HOUSE. SELECT COMMITTEE. 16 APR, 2024. 64p.

Illegal synthetic opioids: Can Europe prevent a crisis?

By Mafalda Pardal, Elle Wadsworth, Beau Kilmer

Potent synthetic opioids, illegally produced, are starting to emerge in Europe. Considering the damaging harms caused by the opioid crisis in North America, which has led to a substantial surge in overdose deaths, it is crucial that European leaders understand the challenges associated with synthetic opioids. In this Perspective, we present and discuss the current situation in Europe concerning synthetic opioids, and draw on earlier and ongoing crises involving this group of substances to reflect on likely challenges ahead and ways to improve preparedness.

Santa Monica, CA: RAND, 2024. 20p.

The political economy of illicit drug crops: forum introduction

By Frances Thomson, Patrick Meehan & Jonathan Goodhand (02 Apr 2024):

his article and the forum it introduces examine illicit drug crop (IDC) economies from agrarian perspectives. Examining IDCs as a group implies analysing how prohibition distinguishes them from other (licit) crops. We identify seven mechanisms through which prohibition shapes the agrarian political economy of IDCs and explore how these mechanisms and their effects generate distinctive patterns of development and political action amongst ‘illicit peasantries’. We also examine connections between illicit and licit crops, including how licit crop crises and illicit crop booms intertwine. We argue that IDC economies provide a bulwark for smallholders but are by no means peasant idylls.

The Journal of Peasant Studies. 2024. 39p.

EU Drug Markets Analysis 2024: Key insights for policy and practice

European Monitoring Centre for Drugs and Drug Addiction (EMCDDA)

Availability remains high across the main drugs used in Europe, evidenced by the large and in some cases increasing quantities that continue to be seized in the European Union. In addition, the market for illicit drugs is characterised by the diversification of consumer products and the widespread availability of a broader range of drugs, including new psychoactive substances, often of high potency or purity. Specialised equipment may be required to meet the detection and monitoring challenges posed by this diversification.

The recent emergence of highly potent opioids, particularly benzimidazoles (nitazenes), poses a particularly complex threat to public health due to their increased risk of life-threatening poisoning. The potential emergence of new patterns of consumption in Europe is also a key threat, due to the availability of cheap and highly potent or pure drugs. This is particularly the case for cocaine, which has seen unprecedented levels of availability

European Monitoring Centre for Drugs and Drug Addiction (EMCDDA), 2024. 39p.

Colombia: Drug smuggling prevention report 2024

By A&A Multiprime

As part of our commitment to contribute to loss prevention in Colombia and across the region, our team regularly engages in meetings with representatives of the Colombian Highest Maritime Authority (DIMAR) and the officers in charge of anti-narcotic policies in the ports. We gather updated informa tion about new practices and precautions to be aware of, as well as relevant recommendations and measures to adopt while visiting any of our ports. This ongoing engagement has culminated in our 2024 report, which reflects the latest insights and strategies in combating the challenges faced by the maritime industry

Recent events highlight the ongoing challenges in countering cocaine trafficking. For example, on February 8, 2024, British authorities announced a historic seizure of over 12,500 pounds of cocaine concealed in a banana shipment from the Port of Turbo, Colombia, to Southampton. This incident, marking the largest single drug seizure in UK history, emphasizes the advanced techniques used by cartels to transport substantial drug quantities into Europe and the UK, thereby confirming the global impact of Colombian narcotics. This report results from our efforts and experience over the last years, successfully assisting in several drug smuggling-related incidents and administrative investigations for breaches of shipping regulations, including the ISPS Code. We trust that this report will serve as a valuable resource for all P&I Clubs, their Members, the Masters and crews, and, in general, the entire marine industry with an interest in Colombian ports to mitigate incidents associated with drug smuggling activities

Bogota: A&A Multiprime. 2024. 18p.

Drug Trafficking on the High Seas: A Primer on the Maritime Drug Law Enforcement Act Brendan McDonald Trial Attorney Criminal Division Narcotic and Dangerous Drug Section

By Colleen King

In December 2023, the United States Coast Guard (USCG) offloaded approximately 18,219 pounds of cocaine from the USCG Cutter Waesche. The estimated street value of the cocaine was more than $239 million. The offload occurred as a result of six separate maritime interdictions, performed by separate cutters, taking place over a 17-day period off the coasts of Mexico and Central and South America. The interdictions were performed as part of the USCG’s counternarcotics mission. While interdictions of this size may seem out of the ordinary, the USCG routinely interdicts a variety of vessels, including Go-Fast Vessels and semi submersibles, with massive amounts of drugs (usually cocaine), moving from the Pacific and Caribbean coasts of South America northward to Mexico, the Caribbean, and eventually the United States. One can imagine that prosecuting interdictions like these may raise a variety of questions: could the United States assert jurisdiction over the suspected traffickers; would the maritime location of the interdiction matter; and would it make a difference if the ship carrying the contraband was flagged—registered—by another country? What about the transit time to a U.S. court for an initial appearance where the interdiction occurred over a thousand miles from the United States? The dizzying array of issues confronting a federal prosecutor following a high seas interdiction may not be typical of land-based legal challenges. Fortunately, a body of both federal law and international authorities is instructive on these questions. The Maritime Drug Law Enforcement Act (MDLEA) is the United States’ principal statute addressing high seas drug trafficking and has supported thousands of prosecutions for decades. The MDLEA, as it re lates to controlled substances,5 prohibits the distribution, manufacture, or possession with intent to distribute or manufacture, controlled sub stances aboard a “covered vessel.” Its prohibitions apply “outside the territorial jurisdiction of the United States,” and include both attempt and conspiracy liability. And, where an interdiction occurs outside of the United States, venue may be appropriate in your district. This article is intended to serve as an MDLEA primer. It will provide a brief his tory of the MDLEA, identify the MDLEA’s core definitional provisions, discuss its key criminal prohibition, detail its jurisdiction and venue pro vision, describe the MDLEA’s position on the use of international law as a defense, and finally, address its sentencing provisions.

March 2024 DOJ Journal of Federal Law and Practice

A Framework for Countering Organised Crime: Strategy, Planning, and the Lessons of Irregular Warfare

By David H. Ucko and Thomas A. Marks

Organised crime is not going well. According to the 2021 Global Organized Crime index, ‘the global illicit economy simply continue[s] along the upward trajectory it has followed over the past 20 years, posing an ever-increasing threat to security, development and justice – the pillars of democracy’ (Global Initiative, 2021, p. 8). Wherever governments seek to draw the line, criminal actors find profitable ways of crossing it; wherever governments fail to deliver on human need, criminal actors capitalise on citizens’ desire or despair. As of now, more than three-quarters of the world’s population ‘live in countries with high levels of criminality, and in countries with low resilience to organized crime’ (Global Initiative, 2021, p. 12). On aggregate, the associated activity amounts to an illicit form of governance, furnishing alternative services to a wide range of clients, be they the vulnerable and weak or a covetous elite. The breadth of organised crime, its clandestine nature, and its blending of creative and destructive effects make it difficult to counter. In past SOC ACE research, we argued that the response to organised crime often shares certain pitfalls with counterterrorism, at least since 9/11 (Ucko & Marks, 2022c). Both efforts have been stymied by 1) conceptual uncertainty of the problem at hand; 2) an urge to address the scourge head on (be it violence or crime), without acknowledging its socioeconomic-political context; and, therefore, 3) unquestioned pursuit of strategies that miss the point, whose progress is difficult to measure, and which may even be counterproductive. This convergence is based on the common features of the two phenomena, which are both concerned with i) collective actors, who ii) use violence and coercion among other methods; and who have iii) corrupting, or outright destructive effects on society. Though organised crime is not consciously political in its ideological motivation, it is – like terrorism – deeply political in its origins, activities, and effects. Given the conceptual overlap, and the common pathologies that undermine response, the lessons from countering terrorism are relevant also to the countering of organised crime. Focusing on the concept of ‘irregular warfare’, our past research identified six key lessons, touching upon 1) the socio-political embeddedness of the problem, 2) the tendency to militarise the response, 3) the mirror-imaging of state assistance programmes, 4) the invaluable role of community mobilisation, 5) the dearth of strategy, and 6) the need to engage more closely with questions of political will. As argued elsewhere, these challenges point to a need for greater strategic competence both in assessing the problem of organised crime and in designing a response (Ucko & Marks, 2022c).

To generate this strategic competence, this follow-on report sets out an analytical toolkit to assist planners and policymakers with the crafting of strategy. This ‘Framework of Analysis and Action’ builds upon lessons – negative and positive – learned via years of experience with irregular warfare, defined by the Department of Defense as ‘a violent struggle among state and non-state actors for legitimacy and influence over the relevant population(s)’ (U.S. Department of Defense, 2007, p. 1).1 It is a framework that finds its origins within the U.S. National Defense University’s College of International Security Affairs (CISA), where for two decades it has been used to teach strategic planning for complex and intensely political challenges (Ucko & Marks, 2022a). The framework consists of two parts: the Strategic Estimate of the Situation (which maps the problem, explores its drivers, frames, and methods, and critiques the current response) and the Course of Action (which uses the strategic estimate to design an appropriate strategy, guided by a theory of success). The framework is in this report adapted for organised crime, to enable the mapping of relevant actors and the crafting, thereby, of a viable response. By design, the framework responds to the six key lessons identified in our earlier work. This report goes through the framework and explains its adaptation to organised crime. Appendix A provides a summation of the toolkit, a ‘user’s guide’, that will facilitate application of the framework. Testing to date suggests great potential and we look forward to sustaining a dialogue with those engaged with countering organised crime to further evolve this toolkit. Indeed, since the beginning, this framework has been a living product, enriched by theoretical application in the classroom and practical use in the field.

SOC ACE Research Paper No. 19. Birmingham, UK: University of Birmingham, 2023. 45p.

Observatory of Illicit Economies in South Eastern Europe

By Global Initiative Against Transnational Organized Crime’s Observatory of Illicit Economies in South Eastern Europe.

In this issue, we focus on three cases where criminal groups from the region have been active in recent years: the Netherlands, Ecuador and parts of Africa.

These examples illustrate the growing involvement of Balkan criminal groups in some of the world’s hotspots for illicit activity. Research for these articles is facilitated by the Global Initiative’s network of contacts with local investigative journalists, as well as close cooperation between regional observatories of illicit economies, namely South Eastern Europe, West Africa and Latin America.

As part of the GI-TOC’s analysis of the risks of firearms trafficking from Ukraine, in this issue we show that the Western Balkans remain the main source of illegal weapons in Europe. At present, weapons are still cheap and plentiful in the region, and stockpiles have been augmented by inflows from Turkey via Bulgaria, particularly of gas and alarm guns. More on this topic can be found in a forthcoming GI-TOC report on trends in arms trafficking from the Ukraine conflict.

In this issue, we also report on a major crackdown by Serbian authorities in late 2023 on increasingly violent smugglers operating along the border between Serbia and Hungary, and examine how this has displaced migration flows towards Bosnia and Herzegovina.

Risk Bulletin No. 18. Geneva, SWIT: Global Initiative Against Transnational Organized Crime, 2024. 25p.

The Swedish Crime Paradox. A Brief on Challenges Posed by Organised Crime in Sweden

By Amir Rotami

In this policy brief, based on published and forthcoming studies, author Amir Rostami outlines the changing nature of crime in Sweden, with a focus on organised crime, specifically lethal violence and fraud. What are the lessons learned from the Swedish crime paradox, namely the rise in organised crime, but not an equivalent rise in general crime, and what needs to be implemented to counter organised crime? The reaction to the question can be divided into two components: local and global/

European Liberal Forum Policy Paper . Brussels: European Liberal Forum, 2021. 19p.

Oil Theft, Energy Security and Energy Transition in Mexico

By Vlado Vivoda, Ghaleb Krame and Martin Spraggon

Oil theft refers to the exploitation of crude oil or refined petroleum products for criminal purposes. In Mexico, oil theft—referred to as huachicolero—is endemic and widespread. By framing it within the energy security and transition context, this paper offers a new perspective on the problem of oil theft in Mexico. Focusing on crude oil and refined petroleum, the paper demonstrates that Mexico’s energy security—as framed around the 4As (availability, accessibility, affordability, and acceptance)—has deteriorated over the past decade. Application of the 4As framework in the Mexican context shows that the increasing frequency of oil theft has contributed to this deterioration. The proposed solution to the energy security and oil theft problems is centred on Mexico moving from gasoline and diesel to electrification in the transportation sector. The paper demonstrates that, while transport electrification in Mexico has been lagging behind other countries, recent developments in the country point to growing momentum among the country’s political and business elites, in tandem with US partners, in support for the energy transition. Areas where further emphasis should be placed to accelerate Mexico’s energy transition in the transportation sector are identified. Finally, the feasibility of and potential limitations associated with implementing the transition are evaluated.

Resources 202312(2), 30; https://doi.org/10.3390/resources12020030

Money Laundering Risks in Commercial Real Estate: An Analysis of 25 Case Studies

By Global Financial Integrity, FACT Coalition, and the Anti-Corruption Data Collective

Today Global Financial Integrity, in conjunction with the FACT Coalition and the Anti-Corruption Data Collective, is releasing a report with identifies 25 cases in which illegal, allegedly illicit or suspicious funds were funneled into commercial property in the United States over approximately the last 20 years. With a total value of property exceeding $2.6 billion, California, Florida and New York are some of the most favored locations for these illegal investments, but criminals stashed money across some 20 different states. This money originated from around the globe and includes suspicious funds from 14 countries, including Iran, North Korea, Kazakhstan, Russia and Mexico. As varied as the sources of funds were, so too were the types of properties involved. Hotels, shopping malls, supermarkets, a music studio and an equestrian facility in addition to more pedestrian office high-rise

It should be noted that our research represents only known cases involving U.S. commercial real estate: the actual number is likely much higher. Our data definitively shows, however, that commercial property in the U.S. offers criminal syndicates, cartels, kleptocrats and fraudsters an easy path to hide and launder their ill-gotten gains. Russian oligarchs facing international sanctions have also invested in U.S. commercial real estate. Shockingly, eight of the 25 cases involve foreign government officials or their relatives, yet the links to these Politically Exposed Persons were only uncovered long after the purchases.In recent years it has become increasingly clear that the combination of complex financing schemes and a lack of transparency mean commercial real estate provides a unique opportunity for laundering huge amounts of cash with a relatively low risk of detection. Identifying who is behind the purchase of commercial property often presents a significant challenge given large financial flows from real estate investment trusts and private investment groups, in addition to funds from shell companies formed and operated by registered agents, proxies and/or attorneys. Key Findings – More than $2.6 billion in suspicious funds were invested in commercial real estate in 22 U.S. states over approximately the last 20 years. The actual figure is likely much higher.– Funds used to buy commercial real estate in the United States originated in 14 different countries including Russia (4 cases), Mexico (4 cases), China, Malaysia, Iran and Kazakhstan (see Map 2). – Of the 25 cases reviewed for this study, 14 involved either politically exposed persons or oligarchs who typically have especially close relationships with foreign government officials. – The types of properties appearing in cases fall into four broad categories: land/buildings, business facilities (e.g. music studios, health facilities), retail spaces (e.g. supermarkets, hotels) and industrial sites (e.g. steel plants). – Weak or non-existent reporting requirements by professions involved in the purchase of commercial real estate contributed to the ease with which illicit funds were laundered.Recommendations 1.FinCEN should adopt a reporting obligation for multiple real estate professionals in a cascading order to ensure the requirement falls on at least one U.S.-based entity involved in the transaction, from both the buyer and the seller. As attorneys are legally required to be part of the closing process in almost 20 states, attorneys should be included with specific reference to the function they perform in the transaction.The rule should cover transfers of ownership that do not constitute a sale. Current rules only refer to purchases of real property by a legal entity. However, numerous cases of real estate money laundering simply involve the transfer of ownership or creation of equitable interest in the property without an actual sale. FinCEN should expand the types of transactions covered to include direct/indirect transfers of ownership or creation of equitable interest in the property.The rule should cover transactions by trusts: An increasing proportion of housing is now owned by legal entities and arrangements, including trusts. In Los Angeles, for example, 23% of rental units are owned by trusts. Both foreign and some domestic trusts are excluded from the purview of the Corporate Transparency Act. We recommend that transactions by all different classes of legal entities and legal arrangements be included in any prospective rule.

Washington, DC: Global Financial Integrity, 2024. 21p.

Illicit Financial Flows in the Mekong

By Kristina Amerhauser

Illicit financial flows (IFFs) are a serious concern in the Mekong region, which includes Cambodia, Lao People’s Democratic Republic (PDR), Myanmar, Thailand and Vietnam. Facilitated by state-embedded actors, each year vast amounts of illicit proceeds are generated, moved and laundered across the region and beyond in offshore tax havens. This distorts the local economies; deprives the state of income needed for health, education and infrastructure; and deepens inequality. This paper is part of a comparative research project that tests and applies the ‘IFFs pyramid’, a new framework of analysis of IFFs proposed by Reitano (2022), in the context of the Mekong region. Based on a review of secondary literature, it provides an overview of financial flows, trade flows and informality – the three main means by which IFFs are enabled, moved and held according to the ‘IFFs pyramid’ – and discusses how IFFs manifest across the Mekong. It finds that: • There is widespread evidence that each flow is significant in the Mekong and that flows converge and intersect. Nevertheless, current responses to IFFs almost entirely focus on the formal financial system. • Porous borders and strong trade relationships, including with neighbouring China, offer abundant and diverse opportunities for trade-based money laundering (TBML). Lack of capacity to identify misclassified goods and low cross-border collaboration are key impediments to its response. • There are a large number of special economic zones (SEZs), some of which are treated as ‘lawless zones’ where national governments have no authority. This creates widespread opportunities for value to be extracted, under-reported and comingled with legitimate flows. They have also been linked to other illicit markets, such as drug trafficking, the illegal wildlife trade (IWT), human trafficking and financial crimes, and provide the space to generate and launder illicit proceeds in a multitude of ways. • The big informal economy, coupled with the large number of people who remain outside the formal financial system, limits the efficiency of regulatory and oversight instruments. • Political will to tackle IFFs in the Mekong appears to be limited, in large part due to the involvement of Chinese actors. In fact, some actors in charge of the response to IFFs seem to have created loopholes to their own benefit. State-embedded actors are part of the problem, both as a source of IFFs as well as by further enabling them. This research shows that the IFFs pyramid proposed by Reitano (2022) is a helpful tool for organising information related to IFFs in the Mekong and for improving understanding of the major negative impact and harms that IFFs exert on societies and economies of the region  

SOC ACE Research Paper No. 30. University of Birmingham. 2023, 32pg