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It falls into a few holes. States"transfer pricing" is an illicit financial flow 
. ...it quotes statements like GFI's that "trade and transfer mispricing are responsible for some 80% of IFFs" but doesn't make any attempt to analyse whether this is well evidenced.
It gives brief overview methods used to estimate IFF & mentions problems w them (noting papers by me & @nitschv etc) but states that " it is unlikely that large, consistent discrepancies in trade data can be explained entirely by errors in reporting"
Which is odd. Because it actually references a post about exactly how large, consistent discrepancies have resulted from glitches in the way that trade gets reportedhttps://www.cgdev.org/blog/illicit-financial-flows-and-trade-misinvoicing-time-reassess …
It concludes that "the current methodologies are not appropriate for measuring the precise quantity of IFFs, they are appropriate and robust as indicators of magnitude. They can therefore be used to understand the risk of IFFs in countries and regions." ...
...but it doesn't say *how* they are judged to be appropriate and robust enough as indicators of magnitude, and risk of IFFs. >> I don't think we can rule out that theses measures are mainly noise, and not signal.
So we get a few pages of repeating GFI #s for Africa. It notes without blinking that some countries have "v-high-risk (> 100% GDP)" while others have "low risk (> 1%)" >> If we can't relate statements like this to something in the real world we should if they mean anything!
Then a section on the difficulty of AML. It wants to differentiate IFFs from money laundering. But I think what it is really finding is that 'IFFs' are successful money laundering flows that are not caught by AML efforts.
The tendency in reports on IFF is to repeat what has been said before, so that it looks like a growing volume of knowledge about 'IFFs' as a thing distinct from money laundering. The truth is we know much less than the volume of paper suggests.
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