AITI Resources

24 May 2023

David Luna was quoted in an article for mlex entitled, “Brazil must redouble efforts to fight corruption, OECD official says.”

Brazil must redouble its efforts to fight corruption, Business at OECD Anti-Illicit Trade Expert Group Chair, and co-Director at AITI at TraCCC, David Luna told MLex. He said it’s also important that the private sector become engaged in putting more pressure on the government to take the issues of corruption and money laundering more seriously.

In an exclusive interview with Paula MarianeMLex Market Insight, a LexisNexis companyDavid M. Luna (罗文礼) 🦏🌎🐘 said, “Brazil must redouble efforts to fight corruption…it is important as well that the private sector becomes engaged” on these issues. “To put more pressure on, in this case, [Luiz Inácio Lula da Silva], because he is the president now, on his administration to take the issues of corruption, organized crime, of criminality, of money laundering more seriously because it weakens efforts in other areas to have more prosperity, to have more development, to have more stability.”

In addition to encouraging government leaders, Luna said it’s necessary to address the issue of enablers. “That includes the lawyers, banks, to be able to fight the money laundering and corruption war.”
Luna also said public-private partnerships can “play a leading role in pushing for better reforms, for better laws, and for more regulatory enforcement.”

During an event today* in Brazil, Luna presented a global report on hubs of illicit trade and corruption, which was organized by the Terrorism, Transnational Crime and Corruption Center.

14 April 2023

Find new report by TraCCC Senior Fellow for National Security, David M. Luna, and ICAIE:

Emerging Transnational Organized Crime Threats in Latin America: Converging Criminalized Markets & Illicit Vectors

16 March 2023

Ushering in a new era of public-private partnerships on clean trade by prosecuting  greater enforcement action against the dark forces of illicit trade and crime convergence 

David M. Luna 
Chair, Anti-Illicit Trade Expert Group (AITEG)
Business at OECD
CEO, Luna Global Networks & Convergence Strategies LLC
11th Meeting of the OECD Task Force on Countering Illicit Trade 
16 March 2023
Paris, France

Remarks and Statement

Good morning.

Mr. President, Piotr (Stryszowski), thank you for your warm words on the “visionary leadership” related to my time as the first Chair of the OECD Task Force on Countering Illicit Trade (TF-CIT).  But the reality is that since the beginning of the Task Force, it has been a collective vision by all TFCIT members over the years, leveraging our collaborative energies, realizing a commitment to partnerships, and harnessing our political will and collective action towards meaningful impact and more clean trade.

It is a great pleasure to be participating at this 11th Meeting of the TF-CIT. I am proud to have attended all 11 of these Task Force meetings, including serving the first five years as the Chair of this important OECD group.  

Today, I am also proud to represent Business at OECD as the Chair of the Anti-Illicit Trade Expert Group (AITEG), as well as the Anti-Illicit Trade Committee, US Council for International Business (USCIB).  

First, I want to thank the OECD Member States, TFCIT Bureau, and co-Chairs from the UK (Chris Martin) and US (Steve Francis) for their continued leadership of the Task Force.  

Let me also extend our appreciation to colleagues in the GOV Directorate for supporting the Task Force over the years, especially Piotr Stryszowski, Senior Economist for his steady stewardship in the TF-CIT Secretariat, and Jack Radisch, Senior Project Manager, High Level Risk Forum, who helped early on in strategically shaping our work.  Of course, we thank the OECD Trade Directorate for welcoming our group and for their commitment to maintain our indispensable leadership within the international community on countering illicit trade.  

Finally, I would also like to extend our gratitude to Hanni Rosenbaum, Executive Director, Business at OECD for helping us in recent years to realize a true TFCIT-AITEG public-private partnership with the OECD on these important issues.

As we enter a second decade of the work of the Task Force, there is much that we have achieved together through our collective energies, including our very dynamic public-private partnership between the OECD, Business at OECD, EUIPO—let me also thank Paul Maier (Director of the EU Observatory on infringements of intellectual property rights) for his leadership–and other partners here today.  

Since 2013, the Task Force has achieved an impressive record of success. 

As the Task Force transitions its home from the Public Governance Directorate to the Trade Committee, we must build on these efforts, and chart it to greater policy heights and action-oriented initiatives, projects,  and cross-sectoral collaborations, using holistic, whole-of-society approaches.

This includes now leveraging the collective interests of the Trade community to examine the dynamics between licit and illicit trade; between formal trade markets and illicit markets; between legitimate commerce and dark commerce; and also addressing the systematic barriers and impediments to cleaner trade, investment, and economic recovery and development around the world such as corruption and money laundering.

The OECD TFCIT webpage showcases the breadth of our work over 10 years on fighting illicit trade including the trafficking and smuggling of counterfeits, humans, narcotics, environmentally-sensitive goods such as endangered wildlife, timbers, fish, oil and natural resources.  We have also examined supply chain risks and illicit vectors across vulnerable sectors and industries around the world. 

During the COVID-19 pandemic, we worked to highlight how criminals exploited market vulnerabilities and illicit economies, including across online digital platforms through cybercrime and frauds, and the sale of counterfeit personal protective equipment (PPE), medicines, vaccines, and other illicit goods that harm and endanger communities and consumers alike.

In both OECD and non-OECD states, illicit trade enables organized crime to penetrate markets, infiltrate public institutions, and co-opt the rule of law.  In these instances, cartels, gangs, criminal syndicates, and oligarchic business elites corrupt public officials and sustain their illicit-licit commercial investments through intimidation, violence, or assassinations of politicians, judges, and police and security officials.  

From the day of its creation, the Task Force has also been inclusive of civil society and academia as an integral part of our work here at the OECD through their evidence-based research contributions.  For example, Dr. Louise Shelley from the Terrorism, Transnational Crime and Corruption Center (TraCCC) at George Mason University has provided invaluable data points, insights, and analyses on various aspects of our work including hubs of illicit trade, crime convergence, dark commerce, professional enablers, and other areas.  So too have other university centers, think tanks, and non-governmental organizations (NGOs) from other OECD countries contributed to the work of the Task Force.  

Through our dynamic partnership between the Business at OECD Anti Illicit Trade Expert Group (AITEG) and the OECD’s TFCIT, we are committed to also work with OECD member states to counter the harms caused by dangerous and illicit goods that have serious effects on our environment, workforce, innovation, and again the health, safety, and security of our people.

Moving forward, public-private partnerships can be force multipliers to counter illicit trade and illicit economies.  

I would like to touch upon each specific topic that we should address going forward.

Free Trade Zone (FTZs)

We congratulate the OECD on not only on the effective implementation of the OECD Recommendation of the Council on Countering Illicit Trade: Enhancing Transparency in Free Trade Zones, promoting compliance with its Code of Conduct through best practices, standards, and enforcement measures; but also on finalizing and launching this week the OECD FTZ Certification Scheme and processes to ensure strong compliance with the provisions of the Code of Conduct.

We must build on our achievements and momentum in recent years on combatting the abuse of FTZs in expanding illicit trade, and make this project our highest priority. 


We applaud the work to address e-commerce challenges in illicit trade in fakes, and related governance gaps, and hope that we can further develop a voluntary set of ‘Guidelines for Countering Illicit Trade in Counterfeit Products on Online Marketplaces’ for government and industry partners.

Misuse of Containerized Maritime Shipping in the Global Trade of Counterfeits

We must not lose momentum on our earlier work related to the misuse of containerized shipping and maritime transport channels for illicit trade, and hope that we can further advance this important project in 2023-2024.  

Dangerous Fakes and Illicit Goods and Illicit Trade in High-Risk Sectors

We commend the continued joint OECD-EUIPO research on dangerous fakes and illicit goods, and illicit trade in vulnerable, high-risk sectors and global supply chains including in areas that present significant health and safety risks.

Targeting Corruption and Money Laundering as Critical Elements to Counter Illicit Trade

As noted earlier, we highly believe in cross-fora synergies and hope that we can work with the Anti-Bribery Working Group and the Financial Action Task Force (FATF) on tackling the corruption and money laundering/trade-based money laundering (TBML) that are financing illicit trade globally.

In many of these cases, with the help of professional enablers, the profits generated from illicit trade are laundered through the use of anonymous shell companies, hubs of illicit trade, Free Trade Zones, criminalized ports, cryptocurrency, and other legal and illegal mechanisms.

Investing in Partnerships to Counter Illicit Trade

In closing, we must ensure that governments and the private sector take the necessary actions to mitigate the future risks posed by illicit trade to our prosperity and security. 

A few final thoughts: We need to also find ways to examine more closely how corruption, illicit trade, money laundering, black markets, and gray zones help to finance today’s autocrats, who use their dirty money to finance violent conflicts and unjust wars such as the one in Ukraine, and contribute to destabilization in other parts of the world.

We support the OECD bringing its energies and expertise to Poland for a possible regional OECD dialogue to examine the impact of illicit trade to regional conflicts, criminalized violence, stability of markets and community of democracies, and to buttress economic recovery efforts, sustainable development, and shared prosperity.  

Finally, after 10 years of outstanding work, we welcome the OECD’s TFCIT on-going move from a Level-three OECD body to a Level-two body. We believe that the support that OECD and member countries provide to the Task Force is crucial to collectively address illicit trade at the OECD level, and see it one day as a Part II programme similar to the work of the Financial Action Task Force (FATF) and other OECD peer review bodies.

Again, on behalf of Business at OECD, we have high hopes that the Trade Committee can take the work of the Task Force to greater heights and further strengthen our OECD-BIAC public-private partnership to counter illicit trade.

Thank you.

9 February 2023

Summit for Democracy (S4D) Working Group Dialogue 2023 on Countering Kleptocracy and Illicit Trade, TraCCC-AITI Co-Chairs’ Statements, 9 February 2023

Click here to view the video.

Click here for the final report.

6 December 2022

TraCCC-AITI co-Director Luna’s Keynote,

“We Have Had Enough Nonsense! Teaming Up and Leveraging Collective Action to Keep Corruption and Criminality Out of Sport”,

SIGA Global Leadership and Anti-Corruption Summit, Ponta Delgada, Azores (Portugal), 6 December 2022.

27 October 2022

On October 27, 2022, David M. Luna, National Security Fellow, TraCCC, participated in the launch of the new Global Financial Integrity (GFI) report, “Made in China: China’s Role in Transnational Crime & Illicit Financial Flows”.  According to Luna, “China today is helping fuel the multi-trillion-dollar global illegal economy. China is benefiting financially through the illicit manufacturing and unauthorized exporting of harmful products such as the chemical precursors to make deadly fentanyl and other opioids, fake goods that can cause great bodily harm or death, and through its international role in laundering dirty money from all corners of the globe.”

Statement from David Luna, Executive Director of the International Coalition Against Illicit Economies about the most recent Global Financial Integrity report:
Made in China: China’s Role in Transnational Crime & Illicit Financial Flows (GFI Report)

6 December 2021

Summit for Democracy–Side Event  
Authoritarian States’ Illicit Finance and Kleptocracy: Threats to Democracy, Peace and Security

Overview:The one-hour long webinar consisted of two sessions aimed at discussing possible ideas, solutions, and recommended actions to S4D, the United States, and S4D communities.

Session one, The Corruptive Influence of Authoritarian States: A Kleptocracy Security Threat to Democracy and Human Rights, featured Dr. Louise I. Shelley, director of TraCCC and Claudia Escobar, former Judge of the Court of Appeals of Guatemala and a respected legal scholar. The first session was moderated by David M. Luna, Co-Director, TraCCC-AITI.

Session two, Illicit Financing of Crime, Violence, and Insecurity in Authoritarian States, featured two internationally-recognized experts and instructors of the TraCCC-AITI ongoing program on authoritarianism, John Cassara and Lakshmi Kumar, Global Financial Integrity (GFI). Session two was moderated by Dr. Layla Hashemi.

The event also featured Corina Rebegea from the National Democratic Institute (NDI).

Find more information about the TraCCC-AITI event for the Summit of Democracy including the Final Chairs’ Report:

Event Details

Opening Statements

Final Report

Event Recording (Video)

Find all civil society side events for the Summit for Democracy:

For more information, click here

21 October 2021

David Luna’s keynote address at the Countering Corruption and Illicit Trade to Secure Greater Prosperity in Central America event, organized by the American Chamber Costa Rica

8 September 2021

Free Trade Zones: How to Combat Illicit Trade and Counterfeiting

Given the scale of cross-border threats posed by the multi-trillion dollar illicit trade and illicit economies globally, we need to recalibrate our past approaches and pivot to newer strategies, innovations, and capabilities to ensure greater transparency and enforcement in free trade zones (FTZs).

Criminals and corrupt officials exploit FTZs when there are weaknesses in governance, poor oversight, and a lack of information sharing and coordination processes.

To combat risky and unruly illicit spaces in Free Trade Zones, we need to address not only corruption and organized crime within these unique hubs for trade and economic growth, but also extend our focus across source, transit, and demand markets where money laundering is occurring, including counterfeits, drugs, opioids, endangered wildlife, and humans. To learn more click here.