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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.
A few quick Qs where I think there's room to differ. IFFs reduce tax revenue but only to extent they're taxable income and then only at tax rates? Hard to see how income is transferred illicitly and still be taxed? BEPS not about legally ambiguous txs - needed because legal?pic.twitter.com/b8y60Emiay
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. ...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.