Table 1

Comparison of the FCTC Protocol on Illicit Trade, MoUs and EU Settlement

IssueFCTC Protocol on Illicit Trade27 HMC&E MoUs with Gallaher69 and BAT74 EU Settlement with PMI, JTI, Imperial and BAT79–81
Global tracking and tracing system run exclusively by governmentYesNoNo
Record-keeping of illicit products independent of TTCsYesNoNo
Prosecutions and sanctions for criminal offencesYesNoYes
Seizure payments for lost taxes and dutiesYesNoYes
  • FCTC Protocol on Illicit Trade: approved in 2012 and in effect September 2018.

  • HMC&E MoUs with Gallaher and BAT: 2002.

  • EU Settlement: PMI (2004), JTI (2007), Imperial (2010), BAT (2010).

  • BAT, British American Tobacco; EU, European Union; FCTC, Framework Convention on Tobacco Control; HMC&E, HM Customs and Excise; MoUs, memoranda of understanding; PMI, Philip Morris International; TTC, transnational tobacco company.