Summary

Global Financial Integrity (GFI) agrees with Cobham that the original targets proposed by the High-Level Panel (HLP) were undermined by framing them in dollars rather than percentage terms, that illicit flows are substantially larger than Overseas Development Aid, and that they adversely affect economic growth, development outcomes, inequality, and governance. However, in contrast to the challenge chapter, we believe that the Open Working Group's reframing of the original proposals both muddies the focus and detracts from the primary objective.

We also feel that Cobham's proposals do not adequately advance the current state of play and therefore miss an opportunity to make significant progress. Although the proposed steps toward financial transparency are extremely important, they are already being addressed in numerous global for a, and great progress has been made toward their implementation. Their inclusion in the post-2015 SDG targets could therefore be seen as redundant.

Financial transparency is only one side of the coin, and only limited progress can be made toward curtailing IFFs without also making efforts in source countries to detect and interdict misinvoiced trade. An appropriate SDG target would lead to developing country governments taking responsibility for addressing their part of the problem.

We agree with Cobham that ”… the [current] specific proposal is flawed – but this does not imply that it should be dropped …” Rather, it should be changed in two important ways. First it should stand alone rather than being linked to reductions in corruption and related issues; our data suggest that a very low percentage of illicit flows is due to corruption and is likely under 20 percent of the total. Second, more precise language is needed than that used in the current draft. Specifically, it should read: “reduce illicit financial flows related to trade misinvoicing by 50 percent.”

This concentrates on the largest part of the IFF problem (about 80 percent according to our data), depoliticizes the issue by eliminating any linkage to government corruption, and provides a specific role for donor countries and agencies to build capacity in customs departments in developing countries. It would have numerous benefits, particularly as a development enabler. Including an SDG target on IFFs will generate revenue needed to help achieve the other likely SDG targets such as ending malnutrition and achieving universal health coverage.