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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.


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.


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.


TRACIT is partnered with several other similar organisations including the Anti-Counterfeiting Group and is part of the UN Global Compact.[4]



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]

It 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.

Work programmes

Global Illicit Trade Index

The Global Illicit Trade Index is 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.[7] The report’s sponsors include Philip Morris International, British American Tobacco and Japan Tobacco International.

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.[8]

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).[9] TRACIT Director General Jeffrey Hardy addressed the meeting with contributions from UN officials.[10] 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.[11]


Senior Management

The senior management team is made up of the following people:[12]

  • 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.[13] Hardy is listed in the EU lobbying register.[14]
  • 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 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: [15]

Advisory Council

The organisation’s Advisory Council is made up of independent experts providing advice in a personal capacity.[18] 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.[19].
  • Leonard McCarthy, founder of integrity and risk management firm LFMcCarthy Associates, prior to that an investigator at the World Bank.[20] 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.[21]


  1. Tracit,Tracit launch, Tracit website, 6 September 2017, accessed October 2019
  2. Financial Times, Combatting Illicit Trade, FT Website, date unknown, accessed October 2019
  3. World Intellectual Property Organization, Advisory Council on Enforcement, WIPO website, 8 August 2019, accessed October 2019
  4. Tracit, Partners, Tracit website, date unknown, accessed October 2019
  5. Tracit, Tobacco, Tracit website, undated, accessed October 2019
  6. KPMG, Project Sun report, KPMG website, 2015, accessed October 2019
  7. Tracit, Global Illicit Trade Index, Tracit website, date unknown, accessed October 2019
  8. Tracit, Illicit Trade and the UN sustainable development goals, Tracit website, July 2019, accessed October 2019
  9. Tracit, Event dialogue on illicit trade and the SDGs, Tracit website, undated, accessed October 2019
  10. UNCTAD, Meeting Details, UNCTAD website, unknown date, accessed October 2019
  11. Expose Tobacco, UNGA briefing, Expose Tobacco website, 1 September 2019, accessed October 2019
  12. TRACIT,Team TRACIT website, date unknown, accessed October 2019
  13. IDA Consulting, About, website, date unknown, accessed October 2019
  14. Lobby Facts EU, Transnational Alliance to Combat Illicit Trade, undated, accessed October 2019
  15. State of Florida, 2019 corporate filing May 2019, acccessed October 2019
  16. Website, Who We Are, ACC website, date unknown, accessed October 2019
  17. Website, A Complete List of ACG Members, date unknown, accessed October 2019
  18. Tracit website, Advisory Council, date unknown, accessed October 2019
  19. 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
  20. LFMcCarthy Associates, website, date unknown, accessed October 2019
  21. Staff reporter, Former Scorpions boss lands big job monitoring Russian telecoms firm, City Press, 23 August 2019, accessed October 2019