February 18, 2025 • 48 mins
From smuggling and trafficking to cyber fraud and trade-based money laundering, the illicit economy is estimated to represent more than $2 trillion of illegal activity annually. And the international criminal networks that drive the illicit economy have continued to evolve and grow more sophisticated with every operation. This shadow economy is massive and its real-life consequences are widespread resulting in deaths by overdose, violence in communities, and government destabilization.
David M. Luna is a true expert on the illicit economy. He is the Founder and Executive Director of the International Coalition Against Illicit Economies (ICAIE). He also held senior positions with the U.S. State Department and at the White House. and has worked internationally with the Organization of Econ and Dev. And the UN.
Coercive Capital host Elaine Dezenski recently spoke with David M. Luna about the contours of the shadow economy and why breaking the corruptive power and financial power of these transnational criminal networks is a critical element of our national security strategy.
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Speaker 1 (00:03):
Today's program is supported by K two Integrity. K two
is the premier global risk advisory firm in an ever
changing world filled with uncertainties and risk. K two helps
its clients with better insights, better solutions, and better decisions.
K two Integrity believe in better for more. Visit K
two integrity dot com Emaline Dozinski and this is coercive
(00:35):
capital on the illicit edge network. The ilicit economy is large, opaque,
and destabilizing. From smuggling and trafficking to cyber fraud and
trade based money laundering, the shadow economy is estimated to
represent more than two trillion dollars of illegal activity annually.
The real life consequences deaths by overdose, violencing communities, and
(00:57):
destabilizing governments in the international criminal networks that drive the
elicit economy have continued to evolve and grow more sophisticated
with every operation. My guest, David Luna, is an expert
on the ilicit economy. He is the founder and executive
director of the International Coalition Against Elicit Economies. He has
also held senior positions with the US Department of State
(01:19):
and in the White House, and has worked internationally with
the organization for Economic Cooperation and Development and the UN.
We recently spoke about the countours of the shadow economy
and why breaking the corruptive power and financial power of
these transnational criminal networks is a critical element of our
national security strategy. This is a great time to be
(01:40):
talking about the ilicit economy, and your work in this
space over the last well more than two decades now,
probably three decades, has been defining. When I think about
combating the elicit economy, I think of your work both
at the State Department, where you advise successive administrations on
(02:02):
understanding and rooting out the illicit financial risks and illicit
economy risks that we're going to talk about today, and
now the work that you're doing in the private sector
and through ICAIE, which we'll also talk about. So you've
seen the challenges from a variety of perspectives and as
you've defined it, combating the dark side of globalization. I
(02:27):
always think it's interesting to share with people how you
got started in this field and ultimately your transition from
a career at State Department into the private sector. How
did you get into this work?
Speaker 2 (02:41):
Well, that is a very interesting story. You know, it's
funny when I went to college, I want to be
a doctor. Wanted to be a doctor, and took all
these pre met courses. But part of being in college
is to find yourself and really grow as a person
as well, to find interests at our more relevant as
(03:02):
one matures. And after deciding it, deciding that I don't
want to do pre mad anymore, I heard pivoted first
pre law and ended up taking more history courses. I
took a lot of archaeology of courses as well. Back
I became an archy major, and that was very interested
(03:26):
in college on cultures and in history and cleaning from
a geo political perspective. And so how you pivoted to
law school? I spent three years three and a half years,
said Catholic University in one of them here in Washington,
d C. And one of the great things about being
(03:48):
in Washington, D C. And the opportunities the internships, and
while I was working for a couple of law firms,
I also had the opportunity to work on and the
US Congress, where I got to learn more about batterly
the legislative branch, but how the legislative branch the US
Congress works with the executive branch on formulating various policies,
(04:13):
but my interest was more on foreign policy and as
secure you. So, having spent some time in the US
Senate working on congression investigations, I went onwards to work
for the White House for the US Apartment Labor working
on trade and international agreements related to the environment and labor.
(04:37):
And then through fortune, I was able to get a
position at the US Department of State working for the
Bureau of International Arcotics M Law Enforcement. Where's I in now,
which is a great bureaus. You from missed the called
the drugs and thugs, but there are got exposed to
(04:58):
issues like corruption, organized crime, less trade, obviously up to
nine to eleven caller terrorists and became a very prominent
issue for not only the Safe Department, across the NASA
security community.
Speaker 1 (05:14):
In your role at ICAIE, where your executive director and
founder the International Coalition Against the Illicit Economy, you're doing
some interesting work on really continuing to define but also
move into the solution sets around what it means to
combat the influence of illicit actors, transnational criminal networks, those
(05:40):
that are really working outside of the formal financial systems
to sol a lot of chaos in economies, in political systems.
Tell us a little bit more about ICAI E. How
it got its start and how it's approaching this she said, right, So.
Speaker 2 (06:02):
After twenty two years some working for the US government,
mostly at the State Department, and how we worked, you know,
the bilateral reagion of multilateral accounts, again primarily working on corruption,
organized crime, and terrorists have been during the four success
of administrations that you mentioned upfront. You know, it was
(06:26):
really interesting to see the nest security framework as related
to those transnational threats. Embedded in some of these strategies
and initiatives was the importance of public private partnerships. So
having worked again to build and many respects, a really
global infrastructure and capacities to counter organized crime, for example,
(06:53):
you know, we got or I got exposed more to
the importance of public private partnership. So you reach it.
You know, I won't reach the point in one's career
where one sinceus it's time to try new things in
life and exercise my energies to develop new entities like
(07:15):
the n GLD and Cash Coalition against Economies, to really
bring the private sector more to the fly to counter
a lot of these subtransceational security threats, so including UISIC trade.
So in twenty seventeen, after I left of the State Department,
you know, we were able to establish I guy in
(07:38):
the coalition that I just mentioned. But since that time,
we have been able to really build some dynamic private
sector partnerships that really complement what governments are doing, including
working with the Used Chamber of Commerce, the US concept
for international business businesses that we see the to bring
(08:00):
private sector are because I really believe, and then the
imbortance of whole society collective action so that different sector
is could do more together and countering some of these
illicit threats.
Speaker 1 (08:17):
And when we talk about the ilicit economy, I think
it would be helpful for listeners to understand how you
would define that, what comprises the elicit economy as you
think of it, and then let's talk a little bit
about the scope and the scale of the problem of
the ilicit economy. So what comprises that notion of the
(08:38):
elicit economy?
Speaker 2 (08:40):
So in many respects of the global illegal illicit economy
is huge, right, I mean, it's really an ecosystem of
criminality and corruption to converges with the other listed vectors.
As you may recall, we work together World Economic Forum
(09:01):
and really good un studies that we're done at that time,
including efforts by the US Interagency and other partners as
well to really try to project or estimate the scale,
the breath and scale of the global it is a
economy which is really staggering. I mean, it constitutes between
(09:22):
seven to fifty percent of global GDP, and I mean,
what we're to do the math, it's really brillions of dollars, right,
I mean at the very lowest levels, it could be
between five to seven trillions of dollars every year, so
whether it's money laundering and I think the latest IMF
(09:47):
semts were two point six trillion from bribery, which is
another one trillion, to counterfeits which is half a billion,
and some of the other illicit areas like human drafficking environments,
the illegal tobacco trade really you know, also has some
(10:10):
tens of billions of dollars that are really generated by
criminal organizations and a listed network. So again, the scale
of today's ecosystems of criminality and corruption is just simply
I'm staggering. So you know that really cuts friend and center,
(10:32):
just the magnitude of some of these illicit threats.
Speaker 1 (10:36):
It really does, and I think we see pieces of
this coming out in the public conversation about fentanyl, and
we'll get back to that a bit later. In terms
of this convergence of drug trafficking, money laundering, the impact
on societies like the US, and what it means to
(10:58):
really both understand and dismantle transnational networks that are having impact,
it's a really good example I think of how US
security is being impacted by one aspect of the elicit economy,
but more generally, how do you think that our security
and foreign policy is undermined by these aspects of the
(11:23):
elicit economy, And how do we need to start thinking
about this space, perhaps a little bit differently as a
disruptor to free and open economies and societies.
Speaker 2 (11:36):
So on many levels, you know, these global ecosystems of criminality,
the illucitrade, ELSI economies do impact not only American security,
American competitive as really every day American citizens across some
communities in the United States. If you look at the
(11:59):
issue as you mentioned, narcotics or pentanol or we have
had too many Americans die every year. I think some
of the estimates were the past four or five years,
it is that we have lost more American citizens through
through you know, the deaily ventanyl that compare it to
(12:21):
our involvement in various wars from Vietnam to Iraq, the Afghanistan.
So it does have a very significant impact. I think
in addition to the lives that are lost every day,
it's the proceeds that are derived from fentanyl that really
(12:42):
help to finance other insecurities. For example, in Mexico, some
of the profits really go towards you know, human trafficking,
towards illicit medicines, so on and so forth. That from
a convergence perspective, any one of these solicit threats is
(13:05):
a big challenge for the United States and our partners.
But when it converges, you know, again with other criminalities,
it just becomes a bigger threat altogether. And again, some
of these thirty moneys starting that are derived from fentanyl
or other listed activities helped to destabilize governance and market institutions.
(13:31):
And we see that clearly in Mexico house the Siniloa
or the current tel HBBI school and then i SI
continue to penetrate government institutions and infiltrate critical industries and
that's just one ariat. But again, if you look at
(13:53):
the issue of counterfeit medicines, illicit pharmaceuticals, they obviously end
up doing a severe harm to the help and safety
of our citizens. And we kind of saw that during
COVID nineteen how a lot of these some kind of
medicines and personal protective equipment ended up really doing some
(14:18):
harm to our citizens.
Speaker 1 (14:21):
Yeah, so you've pointed to a couple of interesting trends.
One is the proliferation of business lines for cartels for
criminal organizations. Whereas you know, maybe twenty years ago we
would know a particular criminal network for their activity and
(14:43):
drugs and narcotics trafficking, now they might be operating across
a range of issues from smuggling and trafficking to counterfeiting
and money laundering on a much larger scale. So that
is that seems to me like that the one angle
that we really need to be thinking about the proliferation
(15:05):
of these different operational models and business lines, if you will.
And then there's another question that I would raise about
how these transnational networks are cooperating with each other. What's
your take on that? And for example, what we've seen
around Chinese money laundering networks operating across many different countries,
(15:30):
the extension of Mexican cartel operations into Africa. Can you
talk to us a little bit about what you're seeing
in that space.
Speaker 2 (15:41):
There has been in many respects transformation transnational criminal organizations
where you do see more, if you will, joint venture
or the lebraging of some organizations working with other criminal organizations.
We see it with Canada, for example, where you do
(16:05):
have the Mexican cartels. I'm quite active at laundering their proceeds,
including working with the Chinese manulauning organizations to to really
clean that money in. But in other parts as well.
In South America, you're beginning to see not in the
Mexican cartels, but some other gangs, so from from Central
(16:28):
America or the band that I from from Venezuela. You
have a more active presence in some of the economies
in South America. But you're also seeing Eurasian mafias really
engaging and profiting from from some of the ellisit markets
(16:51):
in in South America, and you're beginning to see, you know,
some of the devastating the facts from some of the
convergence and alliances between transnasal criminal organizations in places like
Ecuador or you have like local gangs there affiliated in
many respects with the Mexican cartels to destabilize of the
(17:15):
government and Ecuador, you're beginning to see more of the
fentanyl trade emanator become a bear concern in place like
ti there in that part of the world. I mean
you also have hespalah Uh terrorist organization that is really
(17:39):
leveraging the insecurities and really the corruption in a place
like Baaguay or it enables them to really engage in
the whole array of elistid out trade activities including twander
proceeds that in the past have held the finance the
more global operations leading supporting Hamas and Gazo. There. You
(18:05):
also see the PCC, the First Capital Command from Brazil
also engaging with all sorts of illicit bad actors those
networks in South America. So they're leveraging again, They're leveraging
infrastructure expertise to export not only the violence been you
(18:29):
know a lot of illicit goods and contraband to all
parts of the world.
Speaker 1 (18:34):
Yeah, I want to pick up on the South America
or Western hemisphere, the theme for just a minute, because
there's so much discussion right now about resetting US relations
in the Western Hemisphere, And one question I've been thinking
about is can we really establish a productive economic and
(18:56):
political environment for the US and partners and allies in
the region without addressing some of the underlying elsted finance
and elicted economy risks that are pervasive. And you've mentioned
various examples of that influence throughout the hemisphere. So what
(19:16):
do you think, I mean, can can we look at
these issues separately from a broader foreign policy and trade
reset in the Western Hemisphere?
Speaker 2 (19:30):
No, I mean I think we need to be looking
at at all of these issues from an interconnected ness
of vectors, if you will. This is why I think
what the President is trying to do by elevating more
leveraging tarofts to really encourage partners like Mexico and glob
(19:53):
to really elevate their gay to fight defensant all trade
and th we go after the money lauering UH enablers
as well. So I think they do have a ripple
of fact of the criminality. And none of these countries
but in South American and Africas up there in Africa
(20:15):
in Europe, you know, all over the world were because
of the diversification from the illicit trade to delicted, a
lot of these organizations are again able to penetrate financial markets,
economic markets, and the critical industries as well. So it
(20:37):
does have not only a law enforcement uh criminal impact
that it does harm you know, other aspects of a
national life in some of these countries, including economic trade,
(20:57):
and you know obviously public health and safety, and so
it's all interconnected. And you know, I think the US
has smart, smartly always leverage our diplomatic, our intelligence, are
our military in some cases, and economic tools to take
a more robust approach to combating transnational organized crime. And
(21:20):
I do a plot the Trump administration for again elevating
this threat convergence approach because it is tied to all
aspects of life in some of these countries.
Speaker 1 (21:37):
Yeah, I totally agree with that. I just wrote a
piece in the New York Post on the executive order
that Trump issued a couple of weeks ago on designating
international cartels as foreign terrorist organizations. And I think that
was a specific response to the federal challenge. But the
implications of that and the ability of the US and
(22:01):
hopefully allies and partners to use the full range of
financial warfare tools against cartels could be meaningful in a
way that we really haven't seen up to this point.
So I think the implications of.
Speaker 2 (22:17):
That will we'll see.
Speaker 1 (22:18):
We have to resource properly. But what would you tell
us agencies, uh, you know, to do or to how
to direct these efforts in ways that could be more meaningful.
Is it, you know, building on programs and initiatives that
we already have in place. Is it looking at new
(22:39):
ways to address these transnational threats? What would you what
would you tell the Trump administration?
Speaker 2 (22:46):
Well, it's all of that. I mean, you do have
to take a more full spectrum approach to more holistic
including the holl of society, and I do think what
is born there is to get take a more elevated
approach to countering whether it's the cartels, whether it's test
a Lot, whether it's Eurasian mafia's or the Chinese. And
(23:09):
that gets the key. I think in these efforts it's
always information sharing, coordination between the various agencies that have
big task to commit some of these threats. And I
do see, you know, the follow up to the executive
(23:30):
words that you know, the HS has been coordinating more
with DA. The FBI obviously is going through a transformation
in some way has been they too, along with the
other parts of fields, they have been asked to really
bring some other capabilities to get more robustly target the cartels.
(23:54):
So actionable intelligence is very important, but obviously needs to
be related and foremost within the US NAW security community,
but also having good discussions with our Mexican and Canadian
partners strain as relates to the current US homeland approach
(24:16):
to the cartels of Bentanol, because it's also important to
put that political pressure to strengthen the political will in
Mexico and Canada, and and and you saw some of
the response from the Mexican president and the Canadian Prime
minister to to bring more resources to the fight. And
(24:39):
the case of Canada, hopefully with the announcement of the
new Benton ALSAR, they can coordinate more with VA and
other law enforcement agencies again to do more disruptions, more
investigations to really dismantle not only the cartel. But I
(25:01):
think the approach that the trumpet Trump administration is taking
is to really focus on financial tools as well, because
I do think I'm going after so many en neighbors,
including banks in Mexico and Canada and China. I think
it's credical to begin to really turn the tide against
(25:25):
the cartels. To the extent that the US collaborates some
of those military capabilities as well from the thousands perspective,
to do more damage, I think that's important as well.
Speaker 1 (25:38):
Yeah, yeah, So let's pull this right a little bit
on this engagement with governments, because I do think that
there's another challenge, which is instances where we have stay
capture through transnational criminal networks. There is major concern that
(25:59):
cartel have infiltrated state and local government structures within Mexico.
I think that's probably been happening for years. We have
examples of the Chinese communist parties supporting the production of
fentanyl precursors and through that emboldening the Chinese money laundering
(26:21):
networks that are managing all of this. When we see
this convergence of transnational criminal networks and states, that's a
particularly thorny problem. And there are probably examples with Russia
and North Korea and Iran where we see the blurring
of lines between these illicit actors and and and sovereigns,
(26:47):
if you will. What about that challenge and are there
different ways that we need to be thinking about those interactions.
Speaker 2 (26:59):
Well, based on my experience work in the State Department,
I think one always has to be honest and frank
with these governments. I mean I worked on the US
China law enforcement quite a lot of cooperation mechanism, focusing
more in corruption, and you know, I think it's important
to again have those frank discussions with China, with Veezuela,
(27:20):
with Mexico, you mentioned Russia and many others in Pantaguay
as well. But it is a more complex environment, is
not when you start integrating issues of migration, issues of trade.
Not that we compromise any overnational interests with any of
these governments, but we do need to underscore the importance
(27:44):
of joining the US and fighting again the cartels in
the case of China, really helping the US to really
disrupt these Chinese somebody longing operators organizations, including in the US.
(28:05):
So DHS is done a really good job of really
outlining the extent of these Chinese county laundering organizations in
the United States, and a lot of focus tends to
be along the border, whether it's Canada or Mexico or
inside these countries. But I think we need to also again,
(28:26):
this is where the coordination taking a more strategic, holistic
approach to really go after the neighbors as well in
the United States will be very important. I think it
is very significant really sanctioned PD Bank in Canada because
they to have been part of the problem and then
(28:48):
helping to launder the proceeds for the cartels and the
Chinese try it. So one has to be honest, and
you know, a part of of diplomatic efforts is to
really try to work through a lot of these sub
geopolitical foreign policy issues. And you know, Venezuela, it's tricky
(29:13):
right now, Vias some migration that you know, we need
to put pressure on Maduro to also find the dread
to address the complicity of the government involved in in
transnational organized criminal activity.
Speaker 1 (29:30):
Dave, I'm going to go back to the foreign terrorist
designation that was part of Trump's executive order. We talked
about it in the context of fentanyl. It's very clear
that we need a variety of tools to address threats
in the illicit economy and how transnational criminal networks are operating.
(29:54):
One aspect of that, I think is getting to beneficial
ownership structures. Another is looking at how we can use
authorities around prosecuting corruption related to these criminal networks. How
do you see this tool set and what would what
would we be thinking about or should be thinking about
(30:15):
in terms of leveraging different kinds of tools to achieve
different objectives in weakening these transnational entities.
Speaker 2 (30:28):
Great question, Elaine. Similarly to how the US do laborate
pres foinancing tools to go after al Qaeda, Eleban and
other terrorist organizations. I do think that we need to
be using these financial crime tools to go after the gartels,
including supporting the corporate transparency. Yet, because I do think
(30:51):
that a lot of these bed actors and the Wizard
Network's criminals high behind and now the mess shell companies
are really you know, putting the issue of beneficial ownership
of these entities corporate entities that help to to really
launder again the criminal league, the right proceeds of cartels
(31:14):
of criminal organizations and others like Again, the Chinese sun
Priads were profiting enormously from the drug invent in all trade.
So I do think again some of the schools are
very important. I do think examine or developing a national
(31:35):
strategy to combat trade based money laundering is very important
because some of these bad actors again are leveraging these
these other forms of money laundering, including in the digital
commerce space, using crypt crypto currencies, using other forms of
(32:00):
digital finance to under these proceeds. I do think as
well that we need to sustain and even fun more
of the trade transparency units that I think have been
effective systems, to work with our partners in Mexico and
other parts of Latin America now globally, and to really
(32:22):
bring that financial intelligence to the fight you mentioned corruption.
I do think I'm looking at the executive orders that
the Department of Justice and other law enforcement enforcement agencies
that have been asked to really look at the corruption
related to the pentanel, the illegal functional trade and kind
(32:47):
of narcotic efforts. But at the same time, I am
concerned about weakening the Foreign Corrupt Practices Act because that
has been a powerful tool really courage our other governments
to make the fight against corruption UH an important priority.
(33:08):
If you look at China with their The Road initiative
and how they really leverage strategic corruption, they're they're able
to really expand their their global security footprint around the
world to do not only control ports, to to be
(33:32):
more active in free trade zones, to make inroads into
the both illicit and the illicit economies in our partners countries.
So I think we can need the s c p
A also really harms our efforts to make strategic corruption
(33:55):
by China, Iran, UH and others more difficult to combat
a bigger transnational security threat. So I would encourage the
Trump administration to really recalibrate tools like the SCPA, the CTA,
(34:19):
the Corporate Transpancy Act. You may bring these authorities and
incapacities to the fight against global transnational criminal organizations and
threats of deposed.
Speaker 1 (34:33):
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(35:17):
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So you've done a lot of work in the multilateral
space with the OECD countering illicit financial networks and a
(35:37):
lot of anti bribery work. You mentioned our work at
the World Economic Forum, You've been active in other multilateral
engagements with the UN. Where do you think we have
the most opportunity to work through multilateral engagement at this
time which is a particularly challenging time for multilateral but
(36:04):
you know, you spend a lot of time cultivating those partnerships,
thinking through how we can leverage not only US but
broader international frameworks. Is there a future for this when
it comes to combating the illicit economy and where are
the opportunities going to be in the next few years.
Speaker 2 (36:25):
Yeah, you know, I do think that international organizations, whether
it's the OECD, whether it's Interpol, Europe, all the World
Customs Organization you focus more on ulicit trade and combating
and transnational organized crime. Are very important to have those
partnerships because so now I don't need the leveraging again
(36:46):
of action intelligence, but bringing their expertise, their capacities to
do more together is very critical. How you worked with
some of these organizations, I do think that that they
work in helping the United States to do more disruptions,
more dispense bereen not only against the cartels, but again
(37:09):
human trafficking, counterfeit, environmental crime, which is really a new
illicit trade area that's just exploding because some of these
newer areas of illicted trade are easy money for criminals.
So as as as the administration embarks on the review
(37:32):
of some of some of these international organizations, I hope
that they see the value and the expertise and the
capacities that they can bring to really achieve higher results
for presidents of priorities including the cartels, the illegal fudgebal trade,
and money monitoring. I think that IF and the OECD
(37:57):
I've done a really good job on doing that in
space research that helps to inform the US, the private sector,
simple society on the scale of somebody's threat. So you know, again,
I'm a believer of collective action, of bringing a whole
society approach, and I do think our partners within these
(38:21):
international organizations can help the United States and the comp
administration to do more.
Speaker 1 (38:28):
So, how should we bring this conversation around the ILYSSA
economy more effectively to the American public? I assume you
agree we should be doing that, although if not, I'd
love to hear your thoughts on it. But there's a
story here. I think it's it's certainly about ventyl. You know,
ten years ago it might have been focused on the
(38:48):
impact of counterfeits and why there's a supply chain behind
purchasing a counterfeit that's problematic for our country, for other countries.
What should we be talking about around the illicited economy
and how do we position that right now?
Speaker 2 (39:11):
Well, you know, I think the efforts and you're doing
with Course of Capital and the Lucid Edge is a
forum beginning to educate you know, different communities only on
some of the threats some of the bed actors been
in the scale and harm said citizens and how they're
(39:32):
impacted every day. Yeah, from the fence and all to
conferent medicines to human trafficking, So building I think in
awareness nationally the more globally as well. On again, the
convergency interconnectedness of all of these threats and how at
(39:54):
the end of the day they they do end up
having severe armed to community and and constituents. This is
why I I you know, I'm hoping to work with
these Congress to develop the Anti Listed Trade Caucus, to
to begin to work with the administration, to work with
(40:16):
the private sector, to work with communities to help inform
on the scale of these criminalities but in the way
that harms them on a daily basis. So I do
think education is in public awarenice of the harms are critical,
(40:39):
but so are like infographics. I think Dewey Investigative a
docu series and we were beginning to see a lot
of that, and a Gaya is devlding some energies to
really bring digital tools to educate our communities. On again,
(41:00):
the interconnect is between fence and all money laundering, human
trafficking on our fits and how that impacts all aspects
of American life and the lives of our allies around
the world.
Speaker 1 (41:13):
One other area that may need to be recalibrated is
how we think about these threats in the illicted economy
from a national intelligence perspective. How should we be doing that?
Do we need a kind of a recalibration or refocusing
of national intelligence priorities and what what would that look like.
Speaker 2 (41:35):
The admitt of respects. The President has started doing that
right through executive orders elevating and unless a threat like
the illegal fentanel trade he's been the administration has started
doing that by encouraging calling UH, not only the law
Enforcement Commune, but across the entro agency to work with
(41:59):
the HS, work with d A to bring more of
the expertise, capabilities, and resources to the fight. But you
make a good point because in the past, areas more
threats like human trafficking counterfeits were not necessarily your first
(42:19):
tier national security priority. I will get into how the
national our intelligence community determines a different tiers.
Speaker 1 (42:33):
UH.
Speaker 2 (42:33):
In many respects, some of the newer criminal areas were
always relegated to third or even fourth tier priorities within
this framework. That is important because human well human resources
and and and campbeller resources attached to the different tiers.
(43:00):
I mean historically, whether it was fresh and shining weapons
of mass destruction terrorism. I think the cartels, the drug
wars were all these first here and that some of
these other areas have not. So, you know, I hope
that the President Trump, that the administration can really build
(43:22):
on efforts for example, that the President Bush had undertaken
from the threat convergence and really President Obama and our
good friend wants to Rodze, did I think an excellent
job in bringing attention to how a lot of these
sub criminal threats are interconnected in the way that begins
(43:45):
a process to lebagy again, leveraging resources unless investigators, prosecutors,
to really combat some of these threat environments more and
more robustly again, and to internationalize the fight as well,
(44:06):
to engage on the government's other international organizations, regional bodies.
Really take that threat convergence approach because as your combatie
defendant al trade or other narcotic threats, he can leverage
the capacities in some of the solicit environments to similarly
(44:30):
tackle counterfeits, human trafficking, the illegal wildlife trade. That again,
historically we're not a higher priority within the Intelligent Spring work,
but now through that threat convergence lens takes a higher,
higher priority. And the important there is to again, whether
(44:55):
it's suption in Africa or South South America, Mexico, Canada,
you're bringing all of these resources in the more coordinated
manner to do more damage for all us an illicted
environment in these spaces.
Speaker 1 (45:11):
So the threat convergence framework is pretty compelling and could
be an interesting mechanism for further engagement with the private sector.
Can you talk to us a little bit about how
you see private sector engagement in this challenge. Certainly there
are instances of counterfeiting, and you know, issues that impact
(45:37):
supply chains directly probably get more attention from from the
private sector. But what else could we be doing to
raise the profile of this threat convergence and what the
implications are for private sectors.
Speaker 2 (45:53):
So integrating more public private partnerships into the various national
strategies initiatives, Because you're right, I think the private sector,
you know, they have a lot of capacities, a lot
of resources. Often the times they have boots in the
ground because they're operating in somebody's markets, whether it's manufacturing
(46:15):
or selling their goods, that they can see clearly some
of these criminal threats because they're impacted not only from
a market share, but oftentimes from a physical security as well.
And again they often do have really good market intelligence,
if you will, that can really help our law enforcement
(46:38):
communities to be able to target to do more targeted enforcement.
You're right, you see that a lot as it relates
to counterfeits and nine, the National IPR centered does a
really good job of working with the private sector, and
that we should be taking. That is some model to
(47:00):
really do more to counter defense and all trade and more,
you know, more strategically across the listed environments and in
places for bringing that private sector capability to really help
out leave the US by our partners in those countries,
(47:22):
to reduce to mitigate some of the risk and some
of the harms I'm caused by national criminal organizations and
their enagblers.
Speaker 1 (47:33):
Tackling the ilicit economy, one that spans geographic borders and
implicates sophisticated criminal networks is both daunting and urgently needed.
For too many years, we have allowed cartels to operate
with impunity. However, the Trump administration appears ready to unleash
financial warfare on these networks. Thanks to David Luna for
shedding some light on these issues. For listeners interested in
(47:55):
learning more about the work of the International Coalition against
Elicit Economy, check out their website at I C A
i e dot com. I'm Moline Dozinski and this is
course of capital on the Illicit Edge Network.
Today's program is supported by K two Integrity. K two
is the premier global risk advisory firm in an ever
changing world filled with uncertainties and risk. K two helps
its clients with better insights, better solutions, and better decisions.
K two Integrity believe in better for more. Visit K
two integrity dot com Emaline Dozinski and this is coercive
(00:35):
capital on the illicit edge network. The ilicit economy is large, opaque,
and destabilizing. From smuggling and trafficking to cyber fraud and
trade based money laundering, the shadow economy is estimated to
represent more than two trillion dollars of illegal activity annually.
The real life consequences deaths by overdose, violencing communities, and
(00:57):
destabilizing governments in the international criminal networks that drive the
elicit economy have continued to evolve and grow more sophisticated
with every operation. My guest, David Luna, is an expert
on the ilicit economy. He is the founder and executive
director of the International Coalition Against Elicit Economies. He has
also held senior positions with the US Department of State
(01:19):
and in the White House, and has worked internationally with
the organization for Economic Cooperation and Development and the UN.
We recently spoke about the countours of the shadow economy
and why breaking the corruptive power and financial power of
these transnational criminal networks is a critical element of our
national security strategy. This is a great time to be
(01:40):
talking about the ilicit economy, and your work in this
space over the last well more than two decades now,
probably three decades, has been defining. When I think about
combating the elicit economy, I think of your work both
at the State Department, where you advise successive administrations on
(02:02):
understanding and rooting out the illicit financial risks and illicit
economy risks that we're going to talk about today, and
now the work that you're doing in the private sector
and through ICAIE, which we'll also talk about. So you've
seen the challenges from a variety of perspectives and as
you've defined it, combating the dark side of globalization. I
(02:27):
always think it's interesting to share with people how you
got started in this field and ultimately your transition from
a career at State Department into the private sector. How
did you get into this work?
Speaker 2 (02:41):
Well, that is a very interesting story. You know, it's
funny when I went to college, I want to be
a doctor. Wanted to be a doctor, and took all
these pre met courses. But part of being in college
is to find yourself and really grow as a person
as well, to find interests at our more relevant as
(03:02):
one matures. And after deciding it, deciding that I don't
want to do pre mad anymore, I heard pivoted first
pre law and ended up taking more history courses. I
took a lot of archaeology of courses as well. Back
I became an archy major, and that was very interested
(03:26):
in college on cultures and in history and cleaning from
a geo political perspective. And so how you pivoted to
law school? I spent three years three and a half years,
said Catholic University in one of them here in Washington,
d C. And one of the great things about being
(03:48):
in Washington, D C. And the opportunities the internships, and
while I was working for a couple of law firms,
I also had the opportunity to work on and the
US Congress, where I got to learn more about batterly
the legislative branch, but how the legislative branch the US
Congress works with the executive branch on formulating various policies,
(04:13):
but my interest was more on foreign policy and as
secure you. So, having spent some time in the US
Senate working on congression investigations, I went onwards to work
for the White House for the US Apartment Labor working
on trade and international agreements related to the environment and labor.
(04:37):
And then through fortune, I was able to get a
position at the US Department of State working for the
Bureau of International Arcotics M Law Enforcement. Where's I in now,
which is a great bureaus. You from missed the called
the drugs and thugs, but there are got exposed to
(04:58):
issues like corruption, organized crime, less trade, obviously up to
nine to eleven caller terrorists and became a very prominent
issue for not only the Safe Department, across the NASA
security community.
Speaker 1 (05:14):
In your role at ICAIE, where your executive director and
founder the International Coalition Against the Illicit Economy, you're doing
some interesting work on really continuing to define but also
move into the solution sets around what it means to
combat the influence of illicit actors, transnational criminal networks, those
(05:40):
that are really working outside of the formal financial systems
to sol a lot of chaos in economies, in political systems.
Tell us a little bit more about ICAI E. How
it got its start and how it's approaching this she said, right, So.
Speaker 2 (06:02):
After twenty two years some working for the US government,
mostly at the State Department, and how we worked, you know,
the bilateral reagion of multilateral accounts, again primarily working on corruption,
organized crime, and terrorists have been during the four success
of administrations that you mentioned upfront. You know, it was
(06:26):
really interesting to see the nest security framework as related
to those transnational threats. Embedded in some of these strategies
and initiatives was the importance of public private partnerships. So
having worked again to build and many respects, a really
global infrastructure and capacities to counter organized crime, for example,
(06:53):
you know, we got or I got exposed more to
the importance of public private partnership. So you reach it.
You know, I won't reach the point in one's career
where one sinceus it's time to try new things in
life and exercise my energies to develop new entities like
(07:15):
the n GLD and Cash Coalition against Economies, to really
bring the private sector more to the fly to counter
a lot of these subtransceational security threats, so including UISIC trade.
So in twenty seventeen, after I left of the State Department,
you know, we were able to establish I guy in
(07:38):
the coalition that I just mentioned. But since that time,
we have been able to really build some dynamic private
sector partnerships that really complement what governments are doing, including
working with the Used Chamber of Commerce, the US concept
for international business businesses that we see the to bring
(08:00):
private sector are because I really believe, and then the
imbortance of whole society collective action so that different sector
is could do more together and countering some of these
illicit threats.
Speaker 1 (08:17):
And when we talk about the ilicit economy, I think
it would be helpful for listeners to understand how you
would define that, what comprises the elicit economy as you
think of it, and then let's talk a little bit
about the scope and the scale of the problem of
the ilicit economy. So what comprises that notion of the
(08:38):
elicit economy?
Speaker 2 (08:40):
So in many respects of the global illegal illicit economy
is huge, right, I mean, it's really an ecosystem of
criminality and corruption to converges with the other listed vectors.
As you may recall, we work together World Economic Forum
(09:01):
and really good un studies that we're done at that time,
including efforts by the US Interagency and other partners as
well to really try to project or estimate the scale,
the breath and scale of the global it is a
economy which is really staggering. I mean, it constitutes between
(09:22):
seven to fifty percent of global GDP, and I mean,
what we're to do the math, it's really brillions of dollars, right,
I mean at the very lowest levels, it could be
between five to seven trillions of dollars every year, so
whether it's money laundering and I think the latest IMF
(09:47):
semts were two point six trillion from bribery, which is
another one trillion, to counterfeits which is half a billion,
and some of the other illicit areas like human drafficking environments,
the illegal tobacco trade really you know, also has some
(10:10):
tens of billions of dollars that are really generated by
criminal organizations and a listed network. So again, the scale
of today's ecosystems of criminality and corruption is just simply
I'm staggering. So you know that really cuts friend and center,
(10:32):
just the magnitude of some of these illicit threats.
Speaker 1 (10:36):
It really does, and I think we see pieces of
this coming out in the public conversation about fentanyl, and
we'll get back to that a bit later. In terms
of this convergence of drug trafficking, money laundering, the impact
on societies like the US, and what it means to
(10:58):
really both understand and dismantle transnational networks that are having impact,
it's a really good example I think of how US
security is being impacted by one aspect of the elicit economy,
but more generally, how do you think that our security
and foreign policy is undermined by these aspects of the
(11:23):
elicit economy, And how do we need to start thinking
about this space, perhaps a little bit differently as a
disruptor to free and open economies and societies.
Speaker 2 (11:36):
So on many levels, you know, these global ecosystems of criminality,
the illucitrade, ELSI economies do impact not only American security,
American competitive as really every day American citizens across some
communities in the United States. If you look at the
(11:59):
issue as you mentioned, narcotics or pentanol or we have
had too many Americans die every year. I think some
of the estimates were the past four or five years,
it is that we have lost more American citizens through
through you know, the deaily ventanyl that compare it to
(12:21):
our involvement in various wars from Vietnam to Iraq, the Afghanistan.
So it does have a very significant impact. I think
in addition to the lives that are lost every day,
it's the proceeds that are derived from fentanyl that really
(12:42):
help to finance other insecurities. For example, in Mexico, some
of the profits really go towards you know, human trafficking,
towards illicit medicines, so on and so forth. That from
a convergence perspective, any one of these solicit threats is
(13:05):
a big challenge for the United States and our partners.
But when it converges, you know, again with other criminalities,
it just becomes a bigger threat altogether. And again, some
of these thirty moneys starting that are derived from fentanyl
or other listed activities helped to destabilize governance and market institutions.
(13:31):
And we see that clearly in Mexico house the Siniloa
or the current tel HBBI school and then i SI
continue to penetrate government institutions and infiltrate critical industries and
that's just one ariat. But again, if you look at
(13:53):
the issue of counterfeit medicines, illicit pharmaceuticals, they obviously end
up doing a severe harm to the help and safety
of our citizens. And we kind of saw that during
COVID nineteen how a lot of these some kind of
medicines and personal protective equipment ended up really doing some
(14:18):
harm to our citizens.
Speaker 1 (14:21):
Yeah, so you've pointed to a couple of interesting trends.
One is the proliferation of business lines for cartels for
criminal organizations. Whereas you know, maybe twenty years ago we
would know a particular criminal network for their activity and
(14:43):
drugs and narcotics trafficking, now they might be operating across
a range of issues from smuggling and trafficking to counterfeiting
and money laundering on a much larger scale. So that
is that seems to me like that the one angle
that we really need to be thinking about the proliferation
(15:05):
of these different operational models and business lines, if you will.
And then there's another question that I would raise about
how these transnational networks are cooperating with each other. What's
your take on that? And for example, what we've seen
around Chinese money laundering networks operating across many different countries,
(15:30):
the extension of Mexican cartel operations into Africa. Can you
talk to us a little bit about what you're seeing
in that space.
Speaker 2 (15:41):
There has been in many respects transformation transnational criminal organizations
where you do see more, if you will, joint venture
or the lebraging of some organizations working with other criminal organizations.
We see it with Canada, for example, where you do
(16:05):
have the Mexican cartels. I'm quite active at laundering their proceeds,
including working with the Chinese manulauning organizations to to really
clean that money in. But in other parts as well.
In South America, you're beginning to see not in the
Mexican cartels, but some other gangs, so from from Central
(16:28):
America or the band that I from from Venezuela. You
have a more active presence in some of the economies
in South America. But you're also seeing Eurasian mafias really
engaging and profiting from from some of the ellisit markets
(16:51):
in in South America, and you're beginning to see, you know,
some of the devastating the facts from some of the
convergence and alliances between transnasal criminal organizations in places like
Ecuador or you have like local gangs there affiliated in
many respects with the Mexican cartels to destabilize of the
(17:15):
government and Ecuador, you're beginning to see more of the
fentanyl trade emanator become a bear concern in place like
ti there in that part of the world. I mean
you also have hespalah Uh terrorist organization that is really
(17:39):
leveraging the insecurities and really the corruption in a place
like Baaguay or it enables them to really engage in
the whole array of elistid out trade activities including twander
proceeds that in the past have held the finance the
more global operations leading supporting Hamas and Gazo. There. You
(18:05):
also see the PCC, the First Capital Command from Brazil
also engaging with all sorts of illicit bad actors those
networks in South America. So they're leveraging again, They're leveraging
infrastructure expertise to export not only the violence been you
(18:29):
know a lot of illicit goods and contraband to all
parts of the world.
Speaker 1 (18:34):
Yeah, I want to pick up on the South America
or Western hemisphere, the theme for just a minute, because
there's so much discussion right now about resetting US relations
in the Western Hemisphere, And one question I've been thinking
about is can we really establish a productive economic and
(18:56):
political environment for the US and partners and allies in
the region without addressing some of the underlying elsted finance
and elicted economy risks that are pervasive. And you've mentioned
various examples of that influence throughout the hemisphere. So what
(19:16):
do you think, I mean, can can we look at
these issues separately from a broader foreign policy and trade
reset in the Western Hemisphere?
Speaker 2 (19:30):
No, I mean I think we need to be looking
at at all of these issues from an interconnected ness
of vectors, if you will. This is why I think
what the President is trying to do by elevating more
leveraging tarofts to really encourage partners like Mexico and glob
(19:53):
to really elevate their gay to fight defensant all trade
and th we go after the money lauering UH enablers
as well. So I think they do have a ripple
of fact of the criminality. And none of these countries
but in South American and Africas up there in Africa
(20:15):
in Europe, you know, all over the world were because
of the diversification from the illicit trade to delicted, a
lot of these organizations are again able to penetrate financial markets,
economic markets, and the critical industries as well. So it
(20:37):
does have not only a law enforcement uh criminal impact
that it does harm you know, other aspects of a
national life in some of these countries, including economic trade,
(20:57):
and you know obviously public health and safety, and so
it's all interconnected. And you know, I think the US
has smart, smartly always leverage our diplomatic, our intelligence, are
our military in some cases, and economic tools to take
a more robust approach to combating transnational organized crime. And
(21:20):
I do a plot the Trump administration for again elevating
this threat convergence approach because it is tied to all
aspects of life in some of these countries.
Speaker 1 (21:37):
Yeah, I totally agree with that. I just wrote a
piece in the New York Post on the executive order
that Trump issued a couple of weeks ago on designating
international cartels as foreign terrorist organizations. And I think that
was a specific response to the federal challenge. But the
implications of that and the ability of the US and
(22:01):
hopefully allies and partners to use the full range of
financial warfare tools against cartels could be meaningful in a
way that we really haven't seen up to this point.
So I think the implications of.
Speaker 2 (22:17):
That will we'll see.
Speaker 1 (22:18):
We have to resource properly. But what would you tell
us agencies, uh, you know, to do or to how
to direct these efforts in ways that could be more meaningful.
Is it, you know, building on programs and initiatives that
we already have in place. Is it looking at new
(22:39):
ways to address these transnational threats? What would you what
would you tell the Trump administration?
Speaker 2 (22:46):
Well, it's all of that. I mean, you do have
to take a more full spectrum approach to more holistic
including the holl of society, and I do think what
is born there is to get take a more elevated
approach to countering whether it's the cartels, whether it's test
a Lot, whether it's Eurasian mafia's or the Chinese. And
(23:09):
that gets the key. I think in these efforts it's
always information sharing, coordination between the various agencies that have
big task to commit some of these threats. And I
do see, you know, the follow up to the executive
(23:30):
words that you know, the HS has been coordinating more
with DA. The FBI obviously is going through a transformation
in some way has been they too, along with the
other parts of fields, they have been asked to really
bring some other capabilities to get more robustly target the cartels.
(23:54):
So actionable intelligence is very important, but obviously needs to
be related and foremost within the US NAW security community,
but also having good discussions with our Mexican and Canadian
partners strain as relates to the current US homeland approach
(24:16):
to the cartels of Bentanol, because it's also important to
put that political pressure to strengthen the political will in
Mexico and Canada, and and and you saw some of
the response from the Mexican president and the Canadian Prime
minister to to bring more resources to the fight. And
(24:39):
the case of Canada, hopefully with the announcement of the
new Benton ALSAR, they can coordinate more with VA and
other law enforcement agencies again to do more disruptions, more
investigations to really dismantle not only the cartel. But I
(25:01):
think the approach that the trumpet Trump administration is taking
is to really focus on financial tools as well, because
I do think I'm going after so many en neighbors,
including banks in Mexico and Canada and China. I think
it's credical to begin to really turn the tide against
(25:25):
the cartels. To the extent that the US collaborates some
of those military capabilities as well from the thousands perspective,
to do more damage, I think that's important as well.
Speaker 1 (25:38):
Yeah, yeah, So let's pull this right a little bit
on this engagement with governments, because I do think that
there's another challenge, which is instances where we have stay
capture through transnational criminal networks. There is major concern that
(25:59):
cartel have infiltrated state and local government structures within Mexico.
I think that's probably been happening for years. We have
examples of the Chinese communist parties supporting the production of
fentanyl precursors and through that emboldening the Chinese money laundering
(26:21):
networks that are managing all of this. When we see
this convergence of transnational criminal networks and states, that's a
particularly thorny problem. And there are probably examples with Russia
and North Korea and Iran where we see the blurring
of lines between these illicit actors and and and sovereigns,
(26:47):
if you will. What about that challenge and are there
different ways that we need to be thinking about those interactions.
Speaker 2 (26:59):
Well, based on my experience work in the State Department,
I think one always has to be honest and frank
with these governments. I mean I worked on the US
China law enforcement quite a lot of cooperation mechanism, focusing
more in corruption, and you know, I think it's important
to again have those frank discussions with China, with Veezuela,
(27:20):
with Mexico, you mentioned Russia and many others in Pantaguay
as well. But it is a more complex environment, is
not when you start integrating issues of migration, issues of trade.
Not that we compromise any overnational interests with any of
these governments, but we do need to underscore the importance
(27:44):
of joining the US and fighting again the cartels in
the case of China, really helping the US to really
disrupt these Chinese somebody longing operators organizations, including in the US.
(28:05):
So DHS is done a really good job of really
outlining the extent of these Chinese county laundering organizations in
the United States, and a lot of focus tends to
be along the border, whether it's Canada or Mexico or
inside these countries. But I think we need to also again,
(28:26):
this is where the coordination taking a more strategic, holistic
approach to really go after the neighbors as well in
the United States will be very important. I think it
is very significant really sanctioned PD Bank in Canada because
they to have been part of the problem and then
(28:48):
helping to launder the proceeds for the cartels and the
Chinese try it. So one has to be honest, and
you know, a part of of diplomatic efforts is to
really try to work through a lot of these sub
geopolitical foreign policy issues. And you know, Venezuela, it's tricky
(29:13):
right now, Vias some migration that you know, we need
to put pressure on Maduro to also find the dread
to address the complicity of the government involved in in
transnational organized criminal activity.
Speaker 1 (29:30):
Dave, I'm going to go back to the foreign terrorist
designation that was part of Trump's executive order. We talked
about it in the context of fentanyl. It's very clear
that we need a variety of tools to address threats
in the illicit economy and how transnational criminal networks are operating.
(29:54):
One aspect of that, I think is getting to beneficial
ownership structures. Another is looking at how we can use
authorities around prosecuting corruption related to these criminal networks. How
do you see this tool set and what would what
would we be thinking about or should be thinking about
(30:15):
in terms of leveraging different kinds of tools to achieve
different objectives in weakening these transnational entities.
Speaker 2 (30:28):
Great question, Elaine. Similarly to how the US do laborate
pres foinancing tools to go after al Qaeda, Eleban and
other terrorist organizations. I do think that we need to
be using these financial crime tools to go after the gartels,
including supporting the corporate transparency. Yet, because I do think
(30:51):
that a lot of these bed actors and the Wizard
Network's criminals high behind and now the mess shell companies
are really you know, putting the issue of beneficial ownership
of these entities corporate entities that help to to really
launder again the criminal league, the right proceeds of cartels
(31:14):
of criminal organizations and others like Again, the Chinese sun
Priads were profiting enormously from the drug invent in all trade.
So I do think again some of the schools are
very important. I do think examine or developing a national
(31:35):
strategy to combat trade based money laundering is very important
because some of these bad actors again are leveraging these
these other forms of money laundering, including in the digital
commerce space, using crypt crypto currencies, using other forms of
(32:00):
digital finance to under these proceeds. I do think as
well that we need to sustain and even fun more
of the trade transparency units that I think have been
effective systems, to work with our partners in Mexico and
other parts of Latin America now globally, and to really
(32:22):
bring that financial intelligence to the fight you mentioned corruption.
I do think I'm looking at the executive orders that
the Department of Justice and other law enforcement enforcement agencies
that have been asked to really look at the corruption
related to the pentanel, the illegal functional trade and kind
(32:47):
of narcotic efforts. But at the same time, I am
concerned about weakening the Foreign Corrupt Practices Act because that
has been a powerful tool really courage our other governments
to make the fight against corruption UH an important priority.
(33:08):
If you look at China with their The Road initiative
and how they really leverage strategic corruption, they're they're able
to really expand their their global security footprint around the
world to do not only control ports, to to be
(33:32):
more active in free trade zones, to make inroads into
the both illicit and the illicit economies in our partners countries.
So I think we can need the s c p
A also really harms our efforts to make strategic corruption
(33:55):
by China, Iran, UH and others more difficult to combat
a bigger transnational security threat. So I would encourage the
Trump administration to really recalibrate tools like the SCPA, the CTA,
(34:19):
the Corporate Transpancy Act. You may bring these authorities and
incapacities to the fight against global transnational criminal organizations and
threats of deposed.
Speaker 1 (34:33):
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So you've done a lot of work in the multilateral
space with the OECD countering illicit financial networks and a
(35:37):
lot of anti bribery work. You mentioned our work at
the World Economic Forum, You've been active in other multilateral
engagements with the UN. Where do you think we have
the most opportunity to work through multilateral engagement at this
time which is a particularly challenging time for multilateral but
(36:04):
you know, you spend a lot of time cultivating those partnerships,
thinking through how we can leverage not only US but
broader international frameworks. Is there a future for this when
it comes to combating the illicit economy and where are
the opportunities going to be in the next few years.
Speaker 2 (36:25):
Yeah, you know, I do think that international organizations, whether
it's the OECD, whether it's Interpol, Europe, all the World
Customs Organization you focus more on ulicit trade and combating
and transnational organized crime. Are very important to have those
partnerships because so now I don't need the leveraging again
(36:46):
of action intelligence, but bringing their expertise, their capacities to
do more together is very critical. How you worked with
some of these organizations, I do think that that they
work in helping the United States to do more disruptions,
more dispense bereen not only against the cartels, but again
(37:09):
human trafficking, counterfeit, environmental crime, which is really a new
illicit trade area that's just exploding because some of these
newer areas of illicted trade are easy money for criminals.
So as as as the administration embarks on the review
(37:32):
of some of some of these international organizations, I hope
that they see the value and the expertise and the
capacities that they can bring to really achieve higher results
for presidents of priorities including the cartels, the illegal fudgebal trade,
and money monitoring. I think that IF and the OECD
(37:57):
I've done a really good job on doing that in
space research that helps to inform the US, the private sector,
simple society on the scale of somebody's threat. So you know, again,
I'm a believer of collective action, of bringing a whole
society approach, and I do think our partners within these
(38:21):
international organizations can help the United States and the comp
administration to do more.
Speaker 1 (38:28):
So, how should we bring this conversation around the ILYSSA
economy more effectively to the American public? I assume you
agree we should be doing that, although if not, I'd
love to hear your thoughts on it. But there's a
story here. I think it's it's certainly about ventyl. You know,
ten years ago it might have been focused on the
(38:48):
impact of counterfeits and why there's a supply chain behind
purchasing a counterfeit that's problematic for our country, for other countries.
What should we be talking about around the illicited economy
and how do we position that right now?
Speaker 2 (39:11):
Well, you know, I think the efforts and you're doing
with Course of Capital and the Lucid Edge is a
forum beginning to educate you know, different communities only on
some of the threats some of the bed actors been
in the scale and harm said citizens and how they're
(39:32):
impacted every day. Yeah, from the fence and all to
conferent medicines to human trafficking, So building I think in
awareness nationally the more globally as well. On again, the
convergency interconnectedness of all of these threats and how at
(39:54):
the end of the day they they do end up
having severe armed to community and and constituents. This is
why I I you know, I'm hoping to work with
these Congress to develop the Anti Listed Trade Caucus, to
to begin to work with the administration, to work with
(40:16):
the private sector, to work with communities to help inform
on the scale of these criminalities but in the way
that harms them on a daily basis. So I do
think education is in public awarenice of the harms are critical,
(40:39):
but so are like infographics. I think Dewey Investigative a
docu series and we were beginning to see a lot
of that, and a Gaya is devlding some energies to
really bring digital tools to educate our communities. On again,
(41:00):
the interconnect is between fence and all money laundering, human
trafficking on our fits and how that impacts all aspects
of American life and the lives of our allies around
the world.
Speaker 1 (41:13):
One other area that may need to be recalibrated is
how we think about these threats in the illicted economy
from a national intelligence perspective. How should we be doing that?
Do we need a kind of a recalibration or refocusing
of national intelligence priorities and what what would that look like.
Speaker 2 (41:35):
The admitt of respects. The President has started doing that
right through executive orders elevating and unless a threat like
the illegal fentanel trade he's been the administration has started
doing that by encouraging calling UH, not only the law
Enforcement Commune, but across the entro agency to work with
(41:59):
the HS, work with d A to bring more of
the expertise, capabilities, and resources to the fight. But you
make a good point because in the past, areas more
threats like human trafficking counterfeits were not necessarily your first
(42:19):
tier national security priority. I will get into how the
national our intelligence community determines a different tiers.
Speaker 1 (42:33):
UH.
Speaker 2 (42:33):
In many respects, some of the newer criminal areas were
always relegated to third or even fourth tier priorities within
this framework. That is important because human well human resources
and and and campbeller resources attached to the different tiers.
(43:00):
I mean historically, whether it was fresh and shining weapons
of mass destruction terrorism. I think the cartels, the drug
wars were all these first here and that some of
these other areas have not. So, you know, I hope
that the President Trump, that the administration can really build
(43:22):
on efforts for example, that the President Bush had undertaken
from the threat convergence and really President Obama and our
good friend wants to Rodze, did I think an excellent
job in bringing attention to how a lot of these
sub criminal threats are interconnected in the way that begins
(43:45):
a process to lebagy again, leveraging resources unless investigators, prosecutors,
to really combat some of these threat environments more and
more robustly again, and to internationalize the fight as well,
(44:06):
to engage on the government's other international organizations, regional bodies.
Really take that threat convergence approach because as your combatie
defendant al trade or other narcotic threats, he can leverage
the capacities in some of the solicit environments to similarly
(44:30):
tackle counterfeits, human trafficking, the illegal wildlife trade. That again,
historically we're not a higher priority within the Intelligent Spring work,
but now through that threat convergence lens takes a higher,
higher priority. And the important there is to again, whether
(44:55):
it's suption in Africa or South South America, Mexico, Canada,
you're bringing all of these resources in the more coordinated
manner to do more damage for all us an illicted
environment in these spaces.
Speaker 1 (45:11):
So the threat convergence framework is pretty compelling and could
be an interesting mechanism for further engagement with the private sector.
Can you talk to us a little bit about how
you see private sector engagement in this challenge. Certainly there
are instances of counterfeiting, and you know, issues that impact
(45:37):
supply chains directly probably get more attention from from the
private sector. But what else could we be doing to
raise the profile of this threat convergence and what the
implications are for private sectors.
Speaker 2 (45:53):
So integrating more public private partnerships into the various national
strategies initiatives, Because you're right, I think the private sector,
you know, they have a lot of capacities, a lot
of resources. Often the times they have boots in the
ground because they're operating in somebody's markets, whether it's manufacturing
(46:15):
or selling their goods, that they can see clearly some
of these criminal threats because they're impacted not only from
a market share, but oftentimes from a physical security as well.
And again they often do have really good market intelligence,
if you will, that can really help our law enforcement
(46:38):
communities to be able to target to do more targeted enforcement.
You're right, you see that a lot as it relates
to counterfeits and nine, the National IPR centered does a
really good job of working with the private sector, and
that we should be taking. That is some model to
(47:00):
really do more to counter defense and all trade and more,
you know, more strategically across the listed environments and in
places for bringing that private sector capability to really help
out leave the US by our partners in those countries,
(47:22):
to reduce to mitigate some of the risk and some
of the harms I'm caused by national criminal organizations and
their enagblers.
Speaker 1 (47:33):
Tackling the ilicit economy, one that spans geographic borders and
implicates sophisticated criminal networks is both daunting and urgently needed.
For too many years, we have allowed cartels to operate
with impunity. However, the Trump administration appears ready to unleash
financial warfare on these networks. Thanks to David Luna for
shedding some light on these issues. For listeners interested in
(47:55):
learning more about the work of the International Coalition against
Elicit Economy, check out their website at I C A
i e dot com. I'm Moline Dozinski and this is
course of capital on the Illicit Edge Network.
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