- 1 Background
- 2 PMI IMPACT Expert Council
- 3 First Funding Round (2016)
- 4 Second Funding Round (2017)
- 5 Hosted Illicit Trade Conference
- 6 Promoted Via United Nations Global Compact
- 7 TobaccoTactics Resources
- 8 TCRG Research
- 9 Relevant Link
- 10 Notes
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”.
PMI IMPACT funding is split into several funding rounds, each with a distinct theme. Through its website, “Public organisations, law enforcement, private entities, and non-governmental organisations from around the world” are encouraged to submit project proposals.
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. At the second stage, selected applicants submit full proposals for review by an expert council. The final stage involves successful applicants being asked to sign 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.”
PMI IMPACT Expert Council
Funding applications are judged by an expert council of, originally seven, individuals with close links to United Nations (UN) agencies and INTERPOL. INTERPOL accepted a €15 million donation from PMI in 2011 and have promoted access to the tobacco industry’s ‘track and trace’ system Codentify through the INTERPOL Global Register.
In December 2017, the Expert Council included:
Suzanne 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. Hayden was also involved in an Anti-Contraband Tobacco Working Group meeting, partly-funded by Dawson Strategic, a consultancy registered under the Senate Office of Public Records as a PMI lobbying firm.
Alain Julliet 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. 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).
Paul Makin served in the UN Industrial Development Organization (UNIDO) and is a former Director of the UNIDO Regional Office in Egypt.
Luis Moreno Ocampo
Luis 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. 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.
Navi 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.
Jürgen Storbeck is a former head of the Central Bureau of INTERPOL and was the first Director of Europol between 1999 & 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.
Former Expert Council members:
Mahmoud Cherif Bassiouni (deceased)
On 25 September 2017, Mahmoud Cherif Bassiouni died, bringing the number of expert council members down to six. Cherif Bassiouni had previously held 22 UN positions, including Chair of the Drafting Committee of the Diplomatic Conference on the Establishment of an International Criminal Court in 1998. In 1973, he served as a consultant to the U.S. Department of State and Department of Justice on projects relating to the international traffic of drugs.
First Funding Round (2016)
PMI IMPACT's first funding round called for “projects that have an impact on illegal trade and related crimes in the European Union (EU), even if they are implemented elsewhere” (Image 1).
The initiative put forward three focus areas, with each funding proposal required to address at least one of them and demonstrate how it was “likely to have a clear impact on the illegal tobacco trade”. The areas were:
- Education & awareness; and
On 7 September 2017 PMI announced that it would spent $28 million over the next two years to fund 32 approved projects from organisations in the public, private, and academic sectors, representing 18 countries (Image 2).
Some of the successful applicants had pre-existing tobacco industry links, including: 
Produced several reports funded by Cornerstone Research “under contract to Altria Client Services”, including Unintended Consequences of Cigarette Prohibition, Regulation, and Taxation (2015), Cigarette Taxes and Illicit Trade in Europe (2016), and Empty Discarded Pack Data and the Prevalence of Illicit Trade in Cigarettes (2017), co-authored by Alberto Aziani of Transcrime.The company's chairman, Mark Kleiman, was a speaker at the Global Tobacco and Nicotine Forum 2017, a tobacco industry event.
The Center for the Study of Democracy (CSD)
The CSD and the Balkans’ Customs Agency held an international conference in 2011 named “Counteracting Cigarette Smuggling in the Balkans”, attended by representatives of PMI, Japan Tobacco International (JTI), British American Tobacco (BAT), Imperial Tobacco, and Bulgartabac Holding. In 2010, the CSD hosted a round table on the Bulgarian cigarette market, with the Center's website later stating that:
”In the presentations delivered at the meeting it became clear that representatives of the cigarette producing companies (Philip Morris international, British American Tobacco, Japan tobacco International and Bulgartabac) along with the law enforcement and financial agencies… embrace the idea of establishing better cooperation among themselves, as well as developing a common strategy to efficiently counteract cigarette smuggling”.
GLOBSEC’s website, accessed in September 2017, listed Philip Morris Slovakia as one of its partners. PMI’s Vice President of Illicit Trade Strategy & Prevention, Alvise Giustiniani, was a panellist at a May 2017 GLOBSEC event titled ‘Threat-financing: money, illicit trade and (in)security’, which was part of the GLOBSEC 2017 Bratislava Forum.
An Albanian tax, financial, accounting and legal services consulting firm, which according to its website, has Philip Morris Albania as one of its main clients.
Has a history of undertaking research on the illicit tobacco trade on behalf of the tobacco industry. For more information on this relationship see KPMG.
Lithuanian Free Market Institute (LMFI)
The LFMI is a member of the European Policy Information Center (EPICENTER), a group of eight think tanks, spanning multiple countries within the EU. EPICENTER is entirely funded by the Institute of Economic Affairs (IEA) which has a history of close collaboration with the tobacco industry. See: Institute of Economic Affairs.
Oxford Economics has produced multiple tobacco industry-commissioned reports on illicit tobacco trade in Asian markets. Click here for more information on these reports and the company's relationship with tobacco companies.
Panta Rhei Research Limited Company
In December 2017, Zora Hauser was one of the Directors of Panta Rhei Research Limited Company. Hauser worked in corporate affairs for PMI between 2014-2017. Panta Rhei Research Limited Company should not be mistaken for Pantarhei, an Austrian public relations company.
Royal United Services Institute for Defence and Security Studies (RUSI)
In July 2017 KPMG released the first report from its annual Project SUN series on EU illicit tobacco that was not directly commissioned by tobacco companies, but instead commissioned by RUSI. RUSI received funding from BAT, Imperial Tobacco, and PMI to provide “additional qualitative research” to the study.
Siracusa International Institute (SII)
Until his death in September 2017, Mahmoud Cherif Bassiouni of PMI IMPACT's Expert Council was SII's Honorary President.
Southeast European Law Enforcement Center (SELEC)
In 2013, SELEC held an event on ‘combating illicit trade’ in conjunction with JTI. For several years, SELEC have held annual meetings on fraud and smuggling which often feature representatives from tobacco companies.
PMI has funded a series of reports, several focussed on illicit tobacco trade, by Transcrime academics. For more information on these reports and Transcrime’s links to the tobacco industry, see: Transcrime.
Second Funding Round (2017)
On 29 September 2017 PMI opened the second funding round of PMI IMPACT.
The second funding round called for initiatives that addressed "converging forms of illegal trade and related crimes, such as corruption, money laundering, and organized criminal networks."
The projects could be implemented anywhere in the world, but 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.
In November 2017, PMI announced that it had received 157 expressions of interests over 56 countries. The company's press release included the following statement from PMI executive Giustiniani:
“We would like to thank all applicants for their proposals. Our hope is that PMI IMPACT will be a global enabler for innovative projects against illegal trade, and we are encouraged to see this initiative materialize and evolve year after year.”
Hosted Illicit Trade Conference
In September 2017, PMI IMPACT and the newspaper Financial Times held a joint event titled Combating Illicit Trade: Progress, Challenges and Collaborative Solutions. The conference included panel discussions, dialogues, presentations, and interviews, including talks about the projects accepted through PMI IMPACT's first funding round, and an address from PMI’s Chief Executive Officer André Calantzopoulos.
Other speakers included members of PMI IMPACT's Expert Council, academics, and representatives of the EU Commission, Europol, Her Majesty’s Revenue & Customs (HMRC), Organization for Economic Cooperation and Developments (OECD), World Customs Organization (WCO), World Trade Organization (WTO), and UNODC.
Promoted Via United Nations Global Compact
PMI has used its membership of the United Nations Global Compact (UNGC) to promote PMI IMPACT and attempt to portray this association as evidence that PMI is in collaboration with the UN and supports “broader UN goals”.
The UNGC is a UN initiative that aims to encourage businesses to adopt sustainable and socially responsible policies. Members are encouraged to release annual ‘Communications on Progress’ reports to show their commitment to the UNGC’s aims.
In 2016 and 2017 respectively, PMI published two ‘communications on progress’ reports. The company's first report outlined the launch of PMI IMPACT as a “catalyst for a more holistic approach against the illegal tobacco trade, corruption and organized crime” (Image 3). Its second report described PMI IMPACT as “a global initiative governed by independent experts to sponsor third-party initiatives”.
These reports exemplify a Corporate Social Responsibility (CSR) strategy, whereby associations or partnerships with other organisations are used to enhance the tobacco company's reputation and present themselves as a good corporate citizen, despite the harms caused by its products. See: CSR Strategy
In September 2017, the UNGC announced that, from 15 October 2017, tobacco companies would be excluded from the UNGC so that its policies “more closely align with the broader UN system”. For more information, go to the UNGC page.
- Philip Morris
- PMI’s “Illicit Trade” Anti-Plain Packaging Campaign
- Tobacco Industry Attempts to Undermine the FCTC Illicit Trade Protocol (ITP)
- Tobacco Smuggling in the EU
- Tobacco Smuggling in the UK
- Influencing Science: Commissioning Research and Reviews
- Influencing Science: Funding Scientists
- Tobacco Industry Research Committee
- Unscrupulous methods used by the tobacco industry revealed over the illicit trade, K.A. Evans-Reeves, A. Rowell, 2015, The Conversation
- Tobacco industry rallies against illicit trade – but have we forgotten its complicity?, K.A. Evans-Reeves, A. Rowell, 2015, The Conversation
- Philip Morris International, Press Release: Philip Morris International Launches New Initiative to Fight Smuggling and Related Crimes; Pledges USD 100 million to Fund Projects, 27 May 2017, accessed October 2017
- PMI IMPACT, PMI IMPACT: Supporting projects with lasting impact against illegal trade, 2017, accessed October 2017
- PMI IMPACT, About PMI IMPACT: An inclusive approach to achieve better and more targeted results against illegal trade and related crimes, 2017, accessed October 2017
- PMI IMPACT, Application Terms and Funding Rules, Second Funding Round, 2017, accessed October 2017
- Key Terms of a PMI IMPACT Grant Agreement, 2017, accessed October 2017
- Philip Morris International, Expert Council, accessed June 2016
- L. Joossens, A. Gilmore, The transnational tobacco companies’ strategy to promote Codentify, their inadequate tracking and tracing standard, Tobacco Control, 2013, 23, e3-e6
- INTERPOL, INTERPOL Global Register unveiled at Google Ideas INFO summit,17 July 2012, accessed July 2017
- MacDonald Laurier Institute, Photos and Video: Anti Contraband tobacco working Group meets in Ottawa, 1 December 2014, accessed June 2016
- Dawson Strategic, Lobby Registration, accessed June 2016
- FITS, La lettre du président Alain Juillet, accessed June 2016
- L. Moreno Ocampo, A. Eibelshäuser, Workshop on the Investment Dispute between Philip Morris and Uruguay, Global Order Project website, 2017, accessed December 2017
- Philip Morris International, Expert Council, 2017, accessed October 2017
- H. Smith, M. Cherif Bassiouni, ‘father of international criminal law,’ dies at 79, 26 September 2017, accessed October 2017
- A. Calantzopoulos, In memory of Professor M. Cherif Bassiouni, Philip Morris International, accessed October 2017
- M. Bassiouni, Biography, accessed June 2016
- Philip Morris International, Explore: Funding Theme, accessed June 2016
- Philip Morris International, PMI IMPACT September 2016 Press Release, 15 September 2016, accessed October 2016
- Philip Morris International, The Expert Council of PMI IMPACT selects 41 proposals for final review as part of global initiative to fund projects dedicated to fighting illegal trade, 14 December 2016, accessed December 2016
- Philip Morris International, Philip Morris International Announces First Round Of Projects To Be Funded Through PMI IMPACT, A USD 100 Million Global Initiative To Fight Illegal Trade, 7 September 2017, accessed September 2017
- PMI IMPACT, Selected Projects: First Funding Round, 2017, accessed September 2017
- JSC Grodno Tobacco Factory Neman, About company, accessed December 2017
- Members of the Association, 2017, accessed September 2017
- J.D. Kulick, J.E. Prieger, M. Kleiman, Unintended Consequences of Cigarette Prohibition, Regulation, and Taxation, January 2015, accessed September 2017
- J.E. Prieger, J. Kulick, Cigarette Taxes and Illicit Trade in Europe, 20 January 2016, accessed September 2017
- A. Aziani, J. Kulick, N. Norman, J.E. Prieger, Empty Discarded Pack Data and the Prevalence of Illicit Trade in Cigarettes, 26 January 2017, accessed September 2017
- Center for the Study of Democracy, International Conference: Counteracting Cigarette Smuggling in the Balkans, undated, accessed December 2017
- Center for the Study of Democracy, Round Table: Cigarette Markets in Bulgaria: Current State and Trends, undated, accessed December 2017
- GLOBSEC, Partners in detail, undated, accessed December 2017
- GLOBSEC, Panelist: Alvise Giustiniani, 2017, accessed September 2017
- Kazazi Consulting, main clients are:, 2017, accessed December 2017
- Endole Suite, Panta Rhei Research Limited, 1 September 2017, accessed December 2017
- Companies House, Panta Rhei Research Limited, undated, accessed December 2017
- Z. Hauser, Zora Hauser LinkedIn Profile , undated, accessed October 2017
- KPMG, Project SUN: 2016 Results, 2017, accessed December 2017
- RUSI, Project SUN: A Study of the Illicit Cigarette Market in the European Union, Norway and Switzerland, 4 July 2017, accessed October 2017
- Illegal cigarette market costs UK taxpayer nearly £2bn, study finds, The Telegraph, 4 July 2017, accessed October 2017
- Siracusa International Institute, Board of Directors, undated, accessed October 2017
- SELEC, Croatia led the regional combat against illicit trade of tobacco products, 2016, accessed December 2017
- SELEC, Anti-Fraud and Anti-Smuggling Task Force, 2016, accessed September 2017
- Philip Morris International, Philip Morris International Calls For Proposals In Second Funding Round of PMI IMPACT, a Global Initiative to Fight Illegal Trade and Related Crimes, 29 September 2017, accessed October 2017
- Philip Morris International, Press Release: Philip Morris International Welcomes Strong Interest for PMI IMPACT Global Initiative Against Illegal Trade and Relates Crimes Receives 157 Applications In Second Funding Round, 28 November 2017, accessed December 2017
- Financial Times Live, Combating Illicit Trade: Progress, Challenges and Collaborative Solutions, undated, accessed October 2017
- Philip Morris International, PMI UNGC Communication on Progress, 2015, 2016, accessed October 2016
- United Nations Global Compact, Our Mission, undated, accessed October 2017
- United Nations Global Compact, The Communication on progress (COP) in Brief, undated, accessed October 2017
- Philip Morris International, Communication on Progress, 2016, 12 September 2017, accessed October 2017
- United Nations Global Compact, UN Global Compact Integrity Policy Update, 12 September 2017, accessed October 2017