Comparison of the FCTC Protocol on Illicit Trade, MoUs and EU Settlement
| Issue | FCTC 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 government | Yes | No | No |
| Record-keeping of illicit products independent of TTCs | Yes | No | No |
| Prosecutions and sanctions for criminal offences | Yes | No | Yes |
| Seizure payments for lost taxes and duties | Yes | No | Yes |
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.