The Standing Committee on Finance met jointly with the Portfolio Committee on Trade and Industry for a briefing on illicit financial flows. The following stakeholders and entities gave submissions: the Alternative Information and Development Centre; National Prosecuting Authority; Financial Intelligence Centre; South African Revenue Service; South African Reserve Bank; Department of Trade and Industry, and National Treasury.
The Alternative Information and Development Centre pointed out that Illicit financial flows are a major problem. They do not only deprive the state of much needed financial resources, they also force the state to be overly dependent on attracting foreign capital and/or borrowing. Furthermore, profit shifting deprives minority shareholders of their fair share in dividends and exposes local businesses to unfair competition. The three main priorities beyond rebuilding the South African Revenue Service were: the need to implement a General Anti-Tax Avoidance Act to reduce the space for profit shifting; enhanced transparency as a tool of compliance and as a step towards a unitary tax system; and paying special attention to strategic sectors such as mining and the digital economy.
The Hawks gave an update on the work done in partnership with the Inter-Agency Working Group on Illicit Financial Flows. During 2018 the Terms of Reference for the coordinating forum were drafted and approved, resulting in the Inter-Agency Working Group on Illicit financial flows. Two levels of illicit financial flows coordination have been created: the operational committee responsible for the overall coordination and the Task Working Group, responsible for the receipt and selection of cases. In addition to the eight current combined cases, the Hawks deals with all cases reported under the umbrella of illicit financial flows. The Hawks now has dedicated members that deal with the illicit financial flow cases.
The Prosecuting Authority and the Hawks dealt with Illicit financial flows where there was a criminal element and most of the prosecuted cases involved matters relating to tax evasion, exchange controls as well as fraudulent activities committed through Ponzi schemes. The Prosecuting Authority remained reliant on the Revenue Service and the Reserve Bank to identify criminality and to make referrals to the police. 16 Illicit financial flow-related cases had been finalised and there were currently eights cases on the court roll.
The Financial Intelligence Centre spearheaded the illicit financial flow but inter-departmental and inter-governmental cooperation was being emphasised. The National Intelligence Coordinating Committee was conducting a risk assessment around illicit financial flows which would assist in quantifying the figure for South Africa. The Financial Intelligence Centre had also developed a centralised, integrated, recordkeeping and statistical coordinating mechanism which would help to coordinate feedback to the appropriate stakeholders.
The South African Revenue Service said as part of it mitigation efforts at a strategic level, the revenue service was involved in public collaborations through inter-governmental consensus; private cooperation with businesses and professional industry bodies; international cooperation and participation in organisational structures with leading stakeholders. Cooperation efforts were focussed on capacity-building on SARS core discipline in Tax and Customs & Excise critical skills, country-by-country reporting and curtailing trade mis-invoicing. SARS was also developing a digital economy strategy to enhance legislation for the challenges associated with the Fourth Industrial Revolution and the Gig economy.
The South African Reserve Bank was working in collaboration with stakeholders that include Authorised Dealers, and had seen an increase in the number of referrals received. It also shared information for inspection purposes with the Prudential Authority. Since the last feedback in March 2017, seven cases had been successfully prosecuted, two prosecutions had been declined and two were currently in court. Efforts had resulted in preventing illicit financial flows of an estimated R2 billion. Enhanced detection and deterrence measures for debit/credit card abuse had also been implemented. Under investigation were cross-border Ponzi schemes involving approximately R70 million and the unauthorised export and sale of aircraft, in which R19 million had been ‘blocked’.
National Treasury told the Committees that state capture had stymied efforts to combat illicit financial flows. Government was now making real progress against illicit financial flows, largely due to a changed political climate and new leadership at the Hawks, the Prosecuting Authority as well as the Revenue Service. There was now much greater commitment in government to deal with illicit financial flows. The dismantling of SARS’ large business and illicit economy units under the former Commissioner had been deliberate in order to facilitate IFFs, but those units were now being restored. On actual progress, the National Treasury was fixing up SARS and its customs and excise regime, implementing the spirit and letter of FIC Amendment Act, and sharing of information between various agencies.
The Department of Trade and Industry was amending the Companies Act to include the obligation to disclose beneficial owners of shares when filing annual returns. The Department was targeting the end of Quarter Two of 2019 for Cabinet approval to introduce the Bill to Parliament.
Members appreciated progress in curbing illicit financial flows. Members asked about the span of the ongoing investigations. Did the Alternative Information and Development Centre believe there was a lacuna in the existing legislation, and if so, in what sense? Were there any particular strategies for deterrence and actual investigations? What were the challenges and successes, and how was success being measured? What were the targets in the area of illicit financial flows? Was there a way to decipher cases involving individuals who were not driven by malice or greed but by the need to take shortcuts? How well was SARB tracking issues with banks? There seemed to be more emphasis on post-mortems than early detection?
Members asked the NPA what the impediment was to speedy prosecutions. Where were some of the blockages? Did the blockages lie in the identification, or was it the process of convictions itself?
Chairperson Carrim welcomed everyone and indicated the Portfolio Committee on Mineral Resources could not be in attendance as it had confused the dates but it conveyed its good wishes. The main culprit in any illicit financial flow was the mineral industry. The Committees would want to know what stakeholders, particularly law enforcement agencies were doing to curb illicit financial flows (IFFs). He invited submissions from stakeholders present.
The Chairperson informed the Committee that he had recently spoken at a workshop organised by Mr Dominic Brown of the Alternative Information and Development Centre and he had been impressed with the deliberations, although, obviously, it was getting g the results that really mattered. But He had asked Mr brown to give a 15-minute input which would allow a quick overview.
Alternative Information and Development Centre (AIDC) submission
Mr Dominic Brown, Coordinator: Economic Justice Programme, AIDC, in submission pointed out that Illicit financial flows (IFFs) are a major problem. They do not only deprive the state of much needed financial resources, but also force the State to be overly dependent on attracting foreign capital and/or borrowing. Furthermore, profit shifting deprives minority shareholders of their fair share in dividends and exposes local businesses to unfair competition. Moreover, the state is under increasing pressure to do more, with limited and declining resources to do so. In the context of a growing debt burden, increasing budget deficit, stagnant economic growth and the desperate need to increase the tax base, tackling IFFs and base erosion and profit shifting (BEPS) was critical.
Unlike initiatives that attempt to give an estimate of the aggregate scale of IFFs and BEPS, such as the Global Financial Integrity and the Africa Union High Level Panel on IFFs from Africa for example, AIDC had undertaken concrete case studies to get a sense of exactly how these Transnational Corporations (TNCs) operate. Over the years AIDC had done a number of case studies, including into Lonmin, Total, Barplats, and Robertson Winery. AIDC just recently completed another investigation into another mining company which was discovered to have been involved in transfer pricing arrangements and fraud. It was important that these corporations are taken to court. Therefore, AIDC was in the process of putting together a case against the aforementioned corporation (currently the name is confidential). However, litigation should start in June/July this year, which would allow release of the information to the public.
In October 2018, AIDC hosted a high-level seminar on IFFs and BEPS, which was attended by a host of important stakeholders including ex-SARS officials, the former head of the large business centre, some parliamentarians, including the current chair of the Standing Committee on Finance, international experts, NGOs, and journalists. One of the main outcomes at the seminar was the launching of the Stop the Bleeding campaign: a platform that brings together organisations and people already working on issues of IFFs and BEPS in order to have a more coherent strategy to stop IFFs and BEPS from the country. AIDC hoped that this would help to ensure that profit shifting remains a core issue in the political debate. There were also concrete proposals that came out of the seminar, such as the restoration of the institutional capacity of the state, including the South African Revenue Service (SARS), and other state institutions. The work that had been done and the commitment to tackle IFF and BEPS was noted. The commitment from regulators and parliamentary Committees was also commended. These were all critical steps, but not enough.
Mr Brown told the Committees that state capture only partly explained declining revenue collections and parallel levels of profits shifting from South Africa annually. That was because IFFs and BEPS has been a problem since before the state capture. Therefore, beyond restoring the capacity of state institutions, the said seminar underscored the importance of increasing the state’s capacity through legal mechanisms in order to tackle tax evasion more adequately by TNCs. To this end, the AIDC argued for a move towards the legislation of a General Anti-Tax Avoidance (GATA) Act which will allow SARS to prosecute parties implicated in tax evasion.
In conclusion, the three main priorities beyond rebuilding SARS should be as follows: the need to implement a GATA Act to reduce the space for profit shifting; enhanced transparency as a tool of compliance and as a step towards a unitary tax system; and paying special attention to strategic sectors such as mining and the digital economy.
Ms P Nkonyeni (ANC) was delighted to learn that state institutions were now taking the need to curb IFFs seriously. She wondered how much IFFs had happened before the dawn of democracy. Had AIDC done an investigation on this? Why was BEPS happening? Was it because of greed or the desire to sabotage SA’s growth prospects? She emphasised the need to capacitate law enforcement agencies in their fight against IFFs.
Ms G Ngwenya (DA) noted that there had been many forums where the challenge of IFFs has been discussed - the Davies Tax Commission being one example. She was worried the Committees were rehashing past conversations. There was need to pick up from where the previous discussions left off because it was clear everybody understood what IFFs are all about. She found the recommendation that there be a unitary tax system deeply problematic. Tax was not the only consideration taken by companies who wish to invest in a particular jurisdiction.
Mr Carrim said the two Committees sought to meet twice a year, and SARS and National Treasury were obliged to report back on what they were doing about IFFs every quarter. He asked the AIDC to furnish Members with a summary of the key issues that came out of the AIDC seminar held recently. He indicated he had also spoken to the Minister of Justice and Constitutional Development who was very empathetic about the need to curb IFFs. It was good the AIDC was taking a company to court. He wished the AIDC well and hoped the transgressing company would be nailed, as profiteers must pay their fair share of taxes. The biggest criminals come from the private sector and mining companies are the biggest culprits. He urged the AIDC to keep up its good work. He pointed out that the legislation for now was largely adequate but the challenge was more about the lack of capacity to implement it. He asked if the AIDC believed there was a lacuna in the existing legislation, and if so, in what sense? He noted that there was tax avoidance which was legal, and tax evasion which was illegal. However, for the majority, there was no moral justification for either of the two.
Mr Brown said the AIDC had reason to believe IFFs predated the democratic transition and were a problem not unique to SA. What was difficult was being able to access records for those periods. There has been a growing trend for these past two decades. The scale has been increasing dramatically globally. Calling for accountability was not an ideological proposition but was informed by the need to ensure people’s lives improved. BEPS might not be illegal per se, but definitely immoral. He emphasised that curbing IFFs was a matter of urgency and everything should be done to reduce them. It was difficult to determine exactly how much was leaving the shores of SA, but some estimates put funds flowing illicitly out of the country through transnational companies at 4 to 10% annually. Even if it was one cent leaving the shores, it had to be nipped.
He added that the fact that there was a problem was undeniable, but SA was in a position to be a global changer. He agreed that the capacity for enforcement had to be improved but that was just not enough. It was important that loopholes in existing legislation were closed. Putting in place legislation to ensure that those transgressors go to an immediate prosecution would go a long way in closing the space for profit shifting. Measures should go beyond being combative; they should also be preventative. There should both be deterrent and preventative mechanisms in place.
Submission by the Directorate for Priority Crimes Investigation (Hawks)
Lt-Gen Godfrey Lebeya, Head, Directorate for Priority Crimes Investigation (DPCI), gave an update on the work done by the Hawks in partnership with the Inter-Agency Working Group (IAWG) on Illicit Financial Flows (IFFs). During 2018, the Terms of Reference (TOR) for the coordinating forum were drafted and approved, resulting in the Inter-Agency Working Group on IFFs. Two levels of IFF coordination had been created through the TOR, namely the Operational Inter-Agency Working Group (OIAWG) and the Task Working Group. The operational committee was responsible for the overall coordination and direction of IFF matters while the Task Working Group was responsible for the receipt and selection of cases requiring a multi-agency, multi-disciplinary approach. In addition to the eight selected cases on which there was high level cooperation between all agencies (on which the FIC would provide feedback), the DPCI dealt with all cases reported under the umbrella of IFFs. The DPCI had dedicated members that dealt with the IFF cases.
Lt-Gen Lebeya highlighted some cases recently handled by the Hawks. In a current pending matter, an amount of R70 million had been seized. An investigation was also being conducted into a Ponzi scheme that was managed from South Africa and the funds were transferred to Dubai and had been traced to the UK as well. The funds in the UK (approximately 5 million Euros) were currently preserved under an order. The funds in Dubai were approximately US$5 million and that process had not yet started. The 450 investors were all South Africans, 41 statements had already been obtained and 30 witnesses had been lined up.
Lt-Gen Lebeya informed the Committee that another case was one of a suspect who operated various companies and purported to be importing goods. The suspect offered a Reserve Bank official R20 million not to pursue the matter. She was arrested and convicted of corruption and was currently serving a 10-year sentence. In Durban North, 12 accused were convicted in terms of the Exchange Control Regulations and sentenced to fines of R5 000 or imprisonment of between six months and five years, suspended for five years. The total amount involved was R16 million. Lastly, in Komatipoort, two accused persons were found guilty of illegally exchanging currency at the Border Post and sentenced to four months imprisonment suspended for five years.
Submission by the National Prosecuting Authority (NPA)
Adv Mpho Doubada, Deputy Director of Public Prosecutions, NPA, said the NPA was part of the government agencies which formed the coordinating forum on IFFs, spearheaded by the Financial Intelligence Centre (FIC). Before the advent of the IAWG on IFFs, the NPA and the DPCI dealt with IFFs where there was a criminal element. Most of the cases prosecuted by the NPA involved matters relating to tax evasion, exchange controls as well as fraudulent activities committed through Ponzi schemes. The NPA remained reliant on SARS and SARB to identify criminality and to make referrals to the police. The total number of IFFs related cases finalised was 16 and there were currently eights cases on the court roll.
Apart from being part of the IAWG-IFF, through the Special Commercial Crimes Unit (SCCU), the NPA had, in 2015, constituted a team of dedicated prosecutors in different provinces to deal with IFFs. During the course of the previous year, the SCCU had interacted with a team of forensic auditors appointed by the Reserve Bank in connection with the repatriation of funds frozen by the London Authorities in connection with the project. During the second week of March 2019 the NPA had attended a forum that was speared-headed by the South African Banking Risk Information Centre (SABRIC) on the debit order scams which were a recent crime phenomenon through which IFFs activities were committed. The NPA had already dedicated resources to the project teams that were to be formed in Gauteng and KZN where most criminal activities in connection with debit order scams are committed.
Mr A Lees (DA) wanted to know about the span of the ongoing investigations. That would give a better feel of whether law enforcement agencies were being effective or not, because it appeared they were just scratching the surface.
Ms Ngwenya said it appeared there was work being done, judging from the presentations. However, she wanted to know about the overall strategy for tackling IFFs. Were there any particular strategies for deterrence and actual investigations? What were the challenges and successes, and how was success being measured? What were the targets in that area? That would give a comparative analysis on whether there was progress or not. She asked if international comparisons were being done to track performance of South African regulators. She also wanted to know about the relative cost of pursuing those cases versus the amount of money being recovered.
Ms Fubbs appreciated the presentations and said the Hawks were certainly making some progress in curbing IFFs, and that was rather pleasing. She asked where the hold-ups were on speedy convictions. Were they on the identification or the process of convictions itself? She asked the NPA what the impediment was to speedy prosecutions. Where were some of the blockages?
Mr Carrim welcomed the marginal improvement in the submissions by law enforcement agencies. Given the colossal scale of IFFs, while the progress was welcome, it was far too little. Some of the individuals and companies involved were serial transgressors and the fines were small slaps on the wrist. Given that billions of Rand were leaving SA, having convictions and successful prosecutions was a positive signal. He urged the law enforcement agencies to do more.
Lt-Gen Lebeya stated that regular meetings were being held on two levels: the principal level and operational levels. The modus operandi changed from time to time but false invoicing and transfer of funds were the foremost cases of IFFs. Some of the Hawks’ modus operandi could not be discussed in public. He indicated that it was difficult to set targets of convictions because that would mean chasing numbers instead of dealing with cases effectively. The Hawks would want to stamp out the entire scheme.
Adv Doubada said there were challenges involved in charging the accused of crimes such as money laundering without an element of proof, in term of the Prevention of Organised Crime Act. Pertaining to the setting of prosecution targets, that would be problematic and would not be effective as the NPA would end up chasing numbers instead of substance.
Submission by the Financial Intelligence Centre (FIC)
Ms Xolisile Khanyile, Director, FIC, in providing an update on the FIC’s efforts in fighting IFFs, said inter-departmental and inter-governmental cooperation was being emphasised. The National Intelligence Coordinating Committee (NICOC) was undertaking a risk assessment around IFFs which would assist in quantifying the figure for South Africa. That was being done through a joint development of typologies/risk information and bringing together experts from the public and private sectors to better understand typologies used by criminals and develop risk indicators for industry to better detect this activity. The FIC had also developed a centralised, integrated, recordkeeping and statistical coordinating mechanism which would help to coordinate feedback to the appropriate stakeholders.
The FIC recommended that additional resources be availed to fully capacitate the team that dealt with those matters to ensure that there was dedicated focus. That would assist in capacitating financial intelligence units (FIUs) and law enforcement agencies so that they could track, disrupt and repatriate what had left the country. On the way forward, the FIC would continue to explore new ways or opportunities in the development of better technology and systems around big data to improve the integration and the FIC would also be analysing and disseminating financial intelligence. FIC would create partnerships with the private sector to efficiently access relevant financial information to support law enforcement investigations (e.g. South African Anti-Money Laundering Integrated Taskforce (SAMLIT); develop mechanisms to improve the feedback received from law enforcement agencies; seek improved access to government databases; and conclude additional MOUs with stakeholders in government and law enforcement agencies to improve the quality of financial intelligence produced.
Submission by the South African Revenue Service (SARS)
SARS said that, as part of it mitigation efforts at a strategic level, the revenue service was involved in a number of engagements. They included: public collaborations through inter-governmental consensus, including trilateral agreements with all economic and security cluster stakeholders; private cooperation with businesses and professional industry bodies. Key to the efforts of SARS was international cooperation and participation in organisational structures with leading stakeholders such as the International Monetary Fund, the World Bank, Interpol, SADC amongst others. The aforementioned cooperation efforts were towards: capacity-building on SARS core discipline in Tax and Customs & Excise critical skills (transfer pricing, BEPS), and country by country reporting (trade asymmetries), including the Automatic Exchange of Financial Information, implementation of OECD/G20 BEPS initiatives, and curtailing trade mis-invoicing. A critical aspect was coming up with a digital economy strategy to enhance legislation for the challenges associated with the Fourth Industrial Revolution and the Gig economy, and enhancing the integrated risk management approach to focus on compliance intervention.
On an operational and tactical level, SARS had established an integrated investigation across all the taxes to deal with the illicit economy, and prosecutions were expected from the NPA. The priority and focus would be on organised crime in Tax, Customs and Excise evasion schemes. SARS had also implemented the following: electronic Cargo Manifest by Sea and Air carrier; ‘Track & Trace’ markers for cigarettes including excisable products and the physical presence of Customs & Excise officials at manufacturing plants; customs intrusive and non-intrusive driven intervention such as deployment of an air cargo scanner at OR Tambo International Airport and a mobile cargo scanner at City Deep; improved Customs & Excise risk identification and targeting capabilities. SARS had accredited 27 B-BBEE Level Two Preferred Trader clients.
Submission by the South African Reserve Bank (SARB)
Mr Elijah Mazibuko, Head: Financial Surveillance Department at SARB, said the Reserve Bank’s Financial Surveillance Department (FinSurv) was empowered to investigate illicit foreign currency transactions and to take administrative action against alleged perpetrators by blocking funds, attachment of money and/or assets, forfeiture and/or the referral to law enforcement, where appropriate. Upon referrals, law enforcement agencies were expected to pursue matters from a criminal point of view.
The FinSurv, in its efforts to curb IFFs, was working in collaboration with stakeholders that included Authorised Dealers (ADs), and had seen an increase in the number of referrals received. FinSurv also shared information for inspection purposes with the Prudential Authority. Since the last feedback in March 2017: seven cases had been successfully prosecuted; two prosecutions declined; and two were currently in court. On the interventions by FinSurv, the set-off scheme operated abroad had ‘blocked’ R74 million and prevented IFFs of an estimated R2 billion. Enhanced detection and deterrence measures for debit/credit card abuse had also been implemented. On cross-border Ponzi schemes, the Financial Surveillance ‘blocked’ approximately R70 million and the matter was subsequently handed over to law enforcement. There was also an ongoing criminal investigation involving the unauthorised export and sale of aircraft, of which R19 million was ‘blocked’ in that transaction. He assured the Committees that the SARB would continue doing everything in its capacity to curb IFFs.
Mr Carrim said the inputs were encouraging. Although the task at hand was unenviable, regulators were going in a positive direction. The Committees had been despairing over the last three years and suddenly things were picking up. There seemed to be more coordination and verve on the part of regulators, which was encouraging.
Ms Fubbs emphasised the need for concerted efforts and collaboration to effectively deal with the challenges faced by SA in terms of IFFs. She asked if VAT fraud was affecting particular sectors or whether it was broadly across many sectors. How well was SARB tracking issues with banks? There seemed to be more emphasis on post-mortems than early detection?
Ms Ngwenya asked if there was a way of getting some sense as to how the digital economy was contributing to IFFs. Were there timelines for legislative proposals that regulators were looking forward to? Was there a way to decipher cases involving individuals who were not driven by malice or greed but by the need to take shortcuts? Was there something in the regulations to ensure that people who would not ordinarily engage in IFFs would be found if doing so?
SARS said the intention was to monitor cigarette manufacturers to determine the current level of production and feedback would be provided in due course. For the digital economy, strategies were being developed to ensure it was easier for SARS to control declarations within the industry.
Ms Khanyile said that FIC followed global standards in terms of curbing money laundering in digital financing and virtual assets. Capacity had been built to track and block virtual currency transactions. FIC had worked with such cases recently.
Submission by National Treasury
Mr Ismail Momoniat, DDG: Tax and Financial Sector Policy, National Treasury, told the Committees that state capture had stymied efforts to combat illicit financial flows. Government was now making real progress against IFFs, largely due to a changed political climate and new leadership at the Hawks, the NPA as well as SARS. There was now much greater commitment in government to deal with illicit financial flows. State capture could now be openly talked about. That had been difficult to do before a certain date in February 2018. Before that, even many Members refused to talk about it. Some officials were certainly talking about it, but one got one’s head chopped off if one dared to talk about it. He said that the dismantling of SARS’ large business and illicit economy units under the former Commissioner had been deliberate in order to facilitate IFFs, but those units were being restored. Leadership changes at the Hawks and the NPA had led to a mind-set change and there was now ground for hope. At that time, it was known that the Hawks and the NPA would do sweet nothing, although they did cover up for the wrong people.
Mr Momoniat informed the Committee that, on actual progress, National Treasury was fixing up SARS and its customs and excise regime, implementing the spirit and letter of the FIC Amendment Act, and there was better sharing of information between various agencies. Treasury was involved with policy on tax, regulation of financial sector, anti-money laundering and exchange control policy.
Submission by the Department of Trade and Industry (DTI)
Mr Desmond Ramabulana, Director: Commercial Law and Policy, DTI, highlighted progress made by the Department since the last engagements. The DTI had initiated the process of amending the Companies Act, which was going to be modified to include the obligation to disclose beneficial owners of shares when filing annual returns. That had been formulated in liaison with the suggestion from the FIC.
Clause 8 of the Bill to amend the Companies Act proposed amendments to section 33 of the Act by requiring companies to file copies of the annual financial statements and copies of the company’s securities register when filing their annual return. That would ensure transparency and enable the use of such information in decision-making by the public and interested stakeholders, and align with the G20 countries agreement that all affiliated countries had to encourage beneficial owner disclosure in all their legislation governing business and investment institutions. Clause 13 of the Bill proposed an amendment to section 56 in that the requirement to disclose and maintain a register of beneficial owners was extended to all companies and not only regulated companies. This would also align the Companies Act with international requirements.
On way forward, the Bill to amend the Companies Act had been presented to Cabinet in August 2018 for approval to publish the Bill for wider public consultation. The draft bill was published in the Government Gazette for 60 days for public consultation before closing in December 2018. The DTI was currently reviewing the comments and revising the Bill accordingly while consulting with affected government departments and stakeholders. The Department was targeting the end of quarter two of 2019 for Cabinet approval to introduce the Bill to Parliament. He added that IFFs cut across various regulators and the DTI would collaborate on various coordination efforts to address the serious challenge that impacted on the economy by eroding funds from the country.
Ms Fubbs commented on transfer pricing as part of IFFs. The nature and damage to industries and the economy at large was huge. She welcomed the progress made on amending the Companies Act as it would help a great deal.
Mr Carrim said the DTI was crucial in dealing with IFFs, particularly on transfer pricing. The departments really did have an important role to play. He appreciated the engagements and thanked all Members for their participation and cooperation over the past five years. He emphasised the need for greater cooperation in the national interest, whatever their political and ideological differences.
The meeting was adjourned.
- National Treasury - Illicit Financial Flows
- SARS - Illicit Financial Flows
- SARB - Illicit Financial Flows
- National Prosecuting Authority - - Illicit Financial Flows
- HAWKS - Report on Illicit Financial Flows
- Department Trade and Industry - Illicit Financial Flows
- Financial Intelligence Centre (FIC) - Illicit Financial Flows
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