Tuesday, November 29, 2005

I.R. Realism and Cartels

The struggle for power between Cartels and the Governments of Latin America.

In the main body of literature written on South America, and in particular organised crime within the continent, there have been no attempts to explain the behaviour of the Mafia’s or as they are known in the region ‘Cartels’. This essay intends to explain the rise and rise of these organised criminals and the effect that they have had on everyone from the people of Latin America and the US, worldwide Governments from Latin America to Europe. The second part of this paper the changing face of the strategies used to combat these organisations, concluding with what may be the best ideas for the future.


For the reason of being impartial many different sources have been used throughout this essay, the result being that the top and bottom ends of the figures used can, and do, differ. Due to the nature of the drug trade there can be no accurate measure of it’s value, the number of victims and how far around the globe it has managed to successfully penetrate.


Organised Crime.

Firstly, to save any confusion, I will explain the definition of ‘Organised Crime’ that I will be using throughout this essay.

“Organised crime is present whenever two or more persons are involved in a common criminal project for a prolonged period of time in order to obtain power and profits”.
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Although there are many constantly evolving definitions of the phrase, this definition holds true to the main part of most modern definitions. The only differing aspect regarding the definition of criminal groups such as the Yakuza, Triads, Mobsters, Mafias and most importantly Cartels, is that they are internationally operating . When this is the case the definition would include that the groups are presently working in two or more countries.

The phrase ‘Columbian Cartel’ mostly conjures up images of assassinations, gun fights and heartless, gargantuan drug smuggling operations, however, upon closer inspection there is much more organisation than meets the eye. Firstly, the Columbian Cartels – as with every form of organised crime – operated multijouristictionally. For example a group in one county or country would be in charge of producing or collecting raw materials, the next faction would be in charge of producing the cocaine, the next for distribution and so on. Internationalised Crime uses the same notion, but requires a group to work in two or more countries.

The main reason for this is safety, so if one part of the operation is arrested or taken out, it has a relatively small impact on the rest of the business. This sophisticated network means that groups work alone, like terrorist cells, with little or no knowledge of the others and only a handful of people know the workings of the entire system. Whilst this is a relatively safe and intricate system it has been argued that it is based on, but not as impassable as the Sicilian Mafia’s structure (Ryan, 1997). The presence of such a powerful Cartel has led to the emergence of two main problems.



Abusing Columbia’s Geography.

Covering a topic of this nature inevitably finishes revolving around Columbia, simply because the bulk of research into organised crime in Latin America has been written on the Columbian Cartels due to their overwhelming success in exploiting the vast profits available from the drugs trade. Looking at the geography of Columbia – and Latin America in general it is easy to see the potential for trade of any kind due to the various ways of fast transportation to larger trading countries like America, be it by land, sea or air.

Almost everything about Columbia, and Latin America in general is perfect for internationalised trading. It is the only country in South America to have coastlines in two different seas, the Pacific and the Caribbean. The latter being more useful for the transportation of illicit good because of the potential stops in many of the Islands such as Jamaica, Cuba and the Bahamas. By land there is the route through Central America witch, again offers many different paths to the US. Finally there is the straight forward possibility of air transport, but again with many possible stops through the any of the countries and islands between South and North America.


The topography of Columbia is another feature that has proven to be extremely useful to the Cartels. Large areas of dense forest and unexplorable marsh land have been utilised to conceal laboratories and air landing strips (Abadinsky, 1994). These factors, combined with the motivation from unthinkable profits generated through selling drugs, were all that was needed to set the ball rolling that would see a small group of criminals from rural Columbia become some of the most infamous people in criminal history.


The scale of the drugs industry.


While no accurate calculation of the scale of the drugs trade can be made due to the secretive nature of this shadow economy. With the growth and compression of the trade there have been many different estimates of its size, with the top and bottom estimates proving to be a significant distance apart.

The Cartels in Columbia certainly fit the International Organised Crime definition, and with the potential cash benefits from entering the drug trade has been the single biggest temptation for people getting involved in the business, it is also one of the driving factors behind the ‘globalisation’ of the Columbian Cartels. For instance, in 1990 it cost a mere £140 to purchase the materials required to make 1 kilogram of cocaine in a laboratory; on the streets of Europe a kilogram would have sold for around £70,000 (Clutterback, 1990). This 50,000% profit is perhaps one of the most simple ways of explaining why organised criminals who engage in the drugs trade manage to attain such vast amounts of hard cash.

For instance, the wealth accumulated by the individual Pablo Escobar – possibly the most infamous, and successful, criminal in history – was so monumental that he tried to barter for his freedom by offering to pay off Columbia’s national debt. He is also reported to have written off $40 Million in notes because it rotted in a basement as there was nowhere else to store it (Robinson, 1998). In the heyday of the Columbian trade three of the Cartel leaders were thought to be among the five richest men in the world, and that was only one Cartel, which didn’t even have a monopoly of the Latin American drugs market.




Explaining the rise of Cartels.


For the purpose of explaining the Cartel’s behaviour I intend to show that the theory of Classical Realism is the only ideology that can even begin to draw a comparison. If only for it having the most pessimistic view of human nature. The very first sentence of the ‘bible’ of classic realism reads ‘International politics, like all politics is a struggle for power’ (Morgenthau, 1949). When the emphasis of this sentence is taken away from the state and projected on to groups within a state it provides a perfect synopsis of the power struggle between the ongoing struggle between the organised criminals and the Government of Columbia.

Classical Realism is also know to distort and twist parts of the human semblance, which depicts a rather bleak vision of reality where humans are ‘pessimistic about the prospect of eliminating war’ (Walt, 2005). Again, this realist viewpoint is almost a perfect explanation for the stigma of bestial behaviour linked to Columbia’s war torn past and periods of violence.

Looking at realists perspective of human being, political realist Thomas Hobbes described the life of man as being ‘solitary, poor, nasty, brutish and short’ (1668). At this point is important to note that not all Columbians, nor everyone per se, would be best described by this pessimistic sentence but when coming to describe the cartels ruthless and crude behaviour, again this is a nicely fitting blueprint.

The presence of one of the worlds largest and most infamous has led to several problems, regarded as security issues, in Columbia. The first being that due to the relentless nature of the way that they conduct their business, and in particular their ‘silver or lead’ policy the Cartels have made the problem of violence a much larger issue. Secondly, the money raised by the Cartels has not simply been kept as pure profit, but they have used it to buy influence, from politicians to policemen, making the problem off corruption a national issue.



Violence.


The first negative trait, associated with Cartels is that they have ‘made the pre-existing problem of violence more severe and complex’ (Peeler, 1998). However, violence in Columbia is far from a contemporary element, After the assassination of a praised populist leader in 1949 triggered a period of insurrection and turmoil (Coller, 1990). It is also true that political competition is also no stranger to violence, of the eight civil wars in the nineteenth century no less than six were between two political parties (Kline, 1983). From these facts it is clear to see that Columbia has had a riotous, brutal past.


With regards to the Cartels, the volume and intensity of violence has definitely had a severe impact on the people of Columbia. In 1986 the average murder rate per day, calculated in monthly increments fluctuated between two and six in Medelín and could be anywhere between six and ten in the city of Calí depending on the time of year (Bergquist, 1992). Everybody living in these areas would experience first hand the more dangerous side of the Cartels, with such extreme acts of violence becoming part of daily life.


Several armed groups have dominated most of Columbia’s rural areas, by controlling sections of the countryside and imposing their own laws on communities. Since 1964 the guerrilla group FARC, with around 16,000 fighters has ruled large parts of the countryside. The National Liberation Army (ELN) was also a large contributing factor to violence in Columbia. More recently – and disturbingly – a group of fighters known under the acronym AUC was formed by drug traffickers to fight the previously mentioned groups. These three dominant groups have been the causes for the country’s chronic violent tendencies, and are all on the EU and US lists of terrorist organisations.
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Violence is not limited to the those civilians caught up in the drugs trade through the purchasing of drugs or debts to the Cartels. Public officials and members of political institutions were among the top targets for the Cartels ‘Silver or Lead’ policies, accepting a bribe or being murdered. The judicial system was amongst the hardest institutions hit in the 1980’s with over fifty judges being murdered and hundreds resigning under pressure. (Walker, 1996). Violence or intimidation / threat was used when the Cartels money could not make the Judge more sympathetic to their cause.

Whilst it is true that violence in Columbia has been present for centuries the drugs trade has aggravated this process, making the historic problem one of a new security threat, even for a notoriously violent nation. In the past violence had been used as a ‘catalyst for the masses’ (Fals-Borda, 1969). Civil wars were fought by the people in hope of overthrowing the political system, but now the people were being plunged into the middle of the Cartel’s ‘new’ violence, caught in the crossfire between guerrilla groups, cartels and the paramilitaries. This is also out of the control of most citizens and peasant farmers, who are usually the victims of such violence.

Whilst we can see that the Cartels have predominantly used violence and intimidation against public and institutional figures to create a bedrock of influence, it shows that, in the tradition of Realism not only are these acts brutish, but they are all have one common aspect, the pursuit of power. The second problem is one that managed to slip undetected for quite some time, but is now possibly the biggest black mark against Columbia, and could severely alter its relations with other states; corruption.


Corruption.

Corruption is not only limited to Columbia; Latin America as-a-whole is generally associated with corrupt governments. Of the 146 countries in the 2005 Global Corruption Report – 146 being the most corrupt – Brazil scores 59th, Columbia 60th, Peru 67th, Nicaragua 97th, Argentina 108th and Bolivia an atrocious 122nd.
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Some countries within the area are affected more than others. In Rio De Janeiro the cities military police have been plagued with corruption, ‘entangled with organised crime and accustomed to violent and illegal methods of action’ (Aguero, 1998). The national army had to be called into the city after the 1994 election to control violent crimes associated with narcotrafficking and weapons smuggling.

The idea of a drug cartel illegally becoming part of Latin America’s oldest democracy seems implausible, but underneath the magnifying glass Columbia’s national government is – or at least was, in the heyday of the drugs trade, – rotten to the core. For the citizens of Columbia this severely undermined their rights to free and fair elections, a condition of modern democracy, but for the Cartels it was one of the more beneficial ways to spend their spare change. It has also been put forward that a corrupt political system is ‘more powerful than civil society’ itself (Jordan, 1999).

In one of the worst cases of corruption uncovered Columbian government agent Carlos Rodrigo Polania was found laundering money. He had previously been inspector general of Columbia’s intelligence agency; the liaison official with the DEA, US Customs and Interpol (Freemantle, 1995). Involvement with the drugs cartels at this high level of the national government shows how big the security threat is. Intelligence or counter-intelligence supplied by this bribed agent could have amounted to millions of pounds worth of drugs slipping through the borders.

Douglas Farah coined the phrase ‘Columbianisation’, using it as a description of any countries ‘democracy’ that shows a similarly a high level of corruption (1990). He goes on to argue that these states experience the disintegration of political, economic and social structures and that states are soon hurled towards a permanent position of violence, with assassinations and human rights violations. Looking at this through the eye of security, corruption, as a side-effect of the drug trade, could be more dangerous to the citizens in a country than the actual violence itself, especially when it is present at such highly levels capable of turning a democratic state into a corruption-driven tyranny; where the politicians are more concerned about the interests of the minority Cartels than the majority of the country’s population. In this sense, Cartels can be seen as a very powerful pressure group.

Many writers use other terms for this change in a corrupt political system. ‘Anocracy’ (Foweraker, 2003) is another fashionable term in usage just now. This implies that the state has become so deeply corrupt – but not necessarily through a drug trade – that it has become a blend of democracy and autocracy, where the high up officials maintain power despite democratic procedures. Even in 2003 there was still sufficient evidence to show that the governing party, opposition party, federal institutions and congress had all been infiltrated by Cartels.

I would argue that the dilemma of institutional corruption in Columbia presents more shades of an Oligarchy than anything else described thus far. The Cartels have used their economic leverage (by having politicians on their payrolls) with hard ruthlessness and violence in order to indirectly take control of the country. The rule of many by a small group, through the use of ‘professional’ politicians being used as marionettes, hiding the power behind the scenes. This is yet another device of the cartels used to acquire more power and influence.



The Public perception.


Not only do the cartels enjoy the benefits of having the many of the Nations politicians in their pockets, or wallets, but they also put much of their money into helping the people of Columbia. By the end of the 1980’s they owned several newspapers and broadcasting companies and invested approximately a third of their income into Columbian industry, real estate and agriculture. They were actively involved in more than half of the national football league and gave money to peasant farmers and charities 4. This not only meant that they had the forced backing of politicians, but they were seen as a powerful economic and social entity, using this masquerade to win the public over and lure them into forgetting the more negative aspects of Cartels.

It was also noticeable that after the seizure of Los Rodriguez – a high-ranking cali cartel member – there was a ‘marked decrease in the economic fortunes of the community’ (Moser, 2004). Again, this displays that Cartels didn’t bring just negative aspects to the table regarding the people of Columbia, but that they can also be beneficial to the local everyman.

However the motives for all of the nicer aspects are ambiguous. In the mid 1980’s Columbian president Betancour began a crackdown campaign against the traffickers but was soon forced to dilute his policies with the threat from the Cartels to ‘close down 1,800 businesses and assemble an army of over 18,000 people’ (Napoleoni, 2004: 55). Again this highlights that the driving force behind what could be seen as pseudo-benignity toward the civilians of Columbia was just another method used to obtain power in an almost invisible form or mass bribery.

The international problem of Realist Behaviour.


Corruption at this level poses another problem, state accountability. From an outside states’ point of view it de-legitimises the government and state as not being trustworthy. This could potentially be a larger security issue than anything mentioned because the presence of organised crime in such high level institutions could act as a deterrent for other countries to cooperate with Columbia. The legitimacy of states and how they act internally is one of the major factors that will change the willingness of states to cooperate with one another. The most damaging act to Columbia’s international reputation in recent times has most likely been Pablo Escobar’s infamous ‘jailbreak’ in 1992. Columbia would have appeared an international harlequin as the worlds most infamous criminal walked out of jail.

The aspect of corruption puts the paradigm of Realism between a rock and a hard place. On one side, the behavioural aspect of corruption – using wealth to buy influence – is most obviously related to realism in that the Cartels are using their disposable resources to attain more power. On the other side it completely breaks down everything that Realism is associated with on anything above the state level.

By having infiltrated some of Columbia’s top figures the Cartels have seriously undermined the countries ability to govern itself. Cases such as Carlos Rodrigo Polania highlights that the state, by itself, does not always make international decisions, thus breaking down the State-Centric realist view. It is true however that on a Global scale, these illegal sub-state actors have not been the soul reason – or even the primary reason – the breakdown. It would be foolish to dismiss the influence of International Organisations and legitimate sub-state actors amongst other things as being part of the breakdown of classical Realist thought.

Another problem associated with this is that the government not only loses its power to govern the country successfully, but that it also means that the ability to perform regarding what is best for its citizens, be it human rights, societal security, health security or a more general human security are compromised.



Strike One: Initial Strategies.

In April of 1986 US president Ronald Reagan officially declared drug trafficking as a threat to ‘U.S. National Security’. This was a move legitimised the use of hard military force 5. This would have also moulded public opinion into supporting the war on drugs, diverting attention from the final stages of the grid locked cold war. Several years later, in 1990, many US and Latin American leaders reached the conclusion that ‘drug production, smuggling and abuse as serious threats to national security and societal well-being' (Kapiszewski, 2002). Since this view on the drugs trade emerged it has become the dominant issue in US-Latin American relations.

Towards the end of the 1980’s ‘drug related crime, common delinquency, guerrilla terrorism and the military response’ claimed the lives of approximately 300,000 people each year (Strong, 1996). Because of the international effects of the drugs trade has led to many operations being conducted by states and organisations worldwide. With governments putting vast amounts of resources into attempts to stop the drugs trade we have seen many different strategies, some of which have displayed better results than others. One of the biggest projects to date has failed to produce any substantial results.


Plan Columbia.

The US has given over $1.3 Billion to this ambitious plan hoping eradicate all traces of the drug trade from Columbia, however this funding has mostly gone to hardware and interdiction, leading to dismal results. In 2002 the US aimed for an 11% defoliation of the coca plant, by spraying coca fields with toxins that kill the plant, but because of the nature of these hard tactics the final satellite surveillance of Columbia at the end of the year showed an overall increase of 25% as it had just been pushed to other areas (McCoy, 2003). However, although America has dealt with a lot of the problems presented by the drugs trade, since the 1990’s many more countries have began to feel it’s devastating effects.

Towards the end of the 1980’s the Cartels had surpassed the demand for drugs in the US and had flooded the market, which saw prices plummet. In 1982 a kilogram of cocaine was being sold in the US for $60,000 but by 1988 the price had dropped to $20,000. The Cartels had to think of other ways to maintain their enterprise and keep things as profitable, their final solution was simple; Expand into Europe. The weight of drugs confiscated in Europe more than doubled between 1989 and 1990 from 6 tons to over 14 tons. (Hargreaves, 1992). There were several logical reasons for this move.


One reason would have been the pressure applied by the US as the War On Drugs budget grew, along with it’s support, putting more and more pressure on the Cartels. Secondly, because of cultural and language similarities with the Spanish and Portages it made shipping and communications between. Thirdly, Europe was a relatively new market, with prices being far higher, making the long trip worthwhile and finally, the solidification of the European Union and push for cross-border trading of goods made for some perfect cover and decreased the chances of a shipment being caught.

The effects have been felt all over Europe. In the UK the average value of a drugs seize increased from £46,200 to £80,400 between 1990 and 1997. Cocaine and Heroin seizures increased by 54% and 139% respectively
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. This was not a coincidence that the same trends present in America in the 1980’s were appearing all over the European Union.


Globalisation as a factor?


Some have argued that globalisation was one of the key factors in contributing to the expansion of the Columbian drug dealers; this is a greyish statement. Scott Burchill (2001) shows that if globalisation is measured as economic interdependence of ‘trade and capital as a percentage of the national GDP’ the levels in 1999 are approximately similar to those of 1910. However, this is only one side of globalisation that the Cartels would have taken advantage of.

The communications aspect of globalisation however would have been fully utilised by organised criminals worldwide. It is true technological advances have revolutionised the way people communicate, and in true organised crime style the Cartels and Mafias have taken something and utilised it to their advantage. The ‘globalisation’ of organised crime and growth of communication did not fortuitously fall out of the sky at the same time. With these technological advancements the leaders of drug rings can now ‘work from home’ in countries like the United Kingdom and the US. (Ciprut, 2001). This position is just one example of the mafia using modern technology to their advantage.

It has also been rumoured that the organised criminals worldwide have come together and began to cooperate with each other in order to maximise their profits. The Columbian Cartels have successfully integrated parts of their business empire with Russian mobsters to expand their operations. From as early as 1992 some Columbians have been spotted visiting Russia, with an estimated 40 tons of Columbian cocaine infiltrating the Russian border in 1997 (Thompson, 1998).


Strike Two: New solutions to old problems?


During the years of the cold war, and the initial expansion of the Latin American drug trade we saw how Richard Nixon and Ronald Reagan, although taking tough anti-drug stances, only referred to the problem as criminal and health issues. However, by the time the cold war had finished and more attention was given to the drugs trade it soon became obvious that the problem was greater than first thought.


Recently there has been some success in reducing the volume of cocaine produced in Latin America, Columbia has gone from producing over 80% of the world’s cocaine in the mid 90’s to a more conservative 50% in 2005 7. However coca production in Bolivia and Peru have increased by 17% and 14% in 2004 alone, showing how success in one area of the Andes simply leads to the re-location of production into a neighbouring area.

One of the new tactics used in Latin America to decrease the effectiveness of Cartels and their support among the general public is simply raising some awareness regarding the harm inflicted by Cartels. A recent study has shown that because many Latin American governments in the past have been affiliated with – and even sponsored cartels – that it shows a ‘widespread lack of awareness of how harmful Cartels are’. 8. This new mechanism attempts to increase cooperation with the Latin American governments, which has not been optimal due to this misunderstanding about how cartels are more harmful than good. I would argue that a similar scheme aimed at the citizens of the most effective countries will also help to clear away any illusions about how positive the Cartels really are for their area.

Another modern approach to bringing down a Cartel is to ‘Penetrate their cloak of secrecy’
9. This method involves having getting a gang member to testify against fellow Cartel members with first hand information with a promise of a reduced sentence, even political immunity. Since this began in 1993 it has generated dozens of convictions and fines of over $1 Billion.


While the success of many of these plans may sound large the overall War on Drugs has not produced any strong results. Hundreds of billions of dollars have been spent in many different ways without ‘significantly reducing the levels of illegal drug use or potency of illegal drugs on the street’ (Woodiwiss, 2001). This only goes to sow that a change of tactics are needed for the future.


One of the largest problems in the War on Drugs is the location of the manufacturing plants in Columbia. Paul Deihl (1994) lists some of the handicaps placed against the Columbian and external troops. High risk of combat (Cartels have no reason to co-operate), Rebel guerrilla group alliances roaming the country, rugged and unfamiliar terrain and the risk of peasant farmers also becoming violent are all factors against any troops deployed into the region. Again, using state terms the – hard military aspects of the – war on drugs is not dissimilar to a Civil War between a rebel group and a state, with the possibility of external states providing backup.

Despite all of the military and hard action against Columbia and the drug groups within the country, marijuana is arguably the bigger target within the United States. Approximately 1 in 3 people above the age of 12 have smoked marijuana at least once and America has over 2 million daily users at present (Schlosser, 2004).



Strike Three: An answer for tomorrow.


To this day, some twenty-five years after the Cartels and their leading role in organised crime began to flourish, Columbia is still a relatively dangerous area of the world. It shows major examples of ‘human insecurity’ to its citizens and the criminal organisations still ‘undermine the capacity for the government to rule the country’ (Hough, 2004).

Whilst it would perhaps be slightly unethical to give the Cartels any praise, through the eye’s of a Realist thinker they have managed to successfully become one of the most powerful and influential groups worldwide. They converted the use of violence into a tool used simply for the gain of power in one way or another. They have made the most of technology, using it to create a vast global empire, finding and exploiting new markets worldwide, to achieve more power. They spend their profits, not just on luxurious items, but on bribes and weapons that will make the future easier for themselves. Their organisational structure has, for the most part, remained almost impenetrable to any form of action; even the death or jailing of the most powerful leaders have had minimal effect on their operations. If there was a business award ceremony for illegal organisations it’s safe to say that the Columbians would have a good chance at winning any category, from power to profit and everything in between.


A final argument is that drugs generate money for governments. Whilst much of Latin America struggled with economic recession in the 1980’s Columbia remained relatively unaffected. Loretta Napoleoni (2004: 153) also notes that banks in Florida get a substantial cut of the money generated when drugs come into the country, which adds to the national money supply. This, she argues, is why the government continues to put pressure on Latin American governments instead of reducing domestic consumption.


The only ‘solutions’ I can put forward, that have not already been worn-out by governments and organisations worldwide would be; to increase the number of undercover spy’s – or moles – that infiltrate criminal organisations and systematically deconstruct entire sections thorough hard evidence and testifications gathered from the government agents. Although it is undoubtedly a very dangerous method, especially for the agents involved, it would be cost-effective and has the potential for success.

The other method I can suggest would be to legalise all drugs. Whilst it sounds like a radical statement this move could wipe out all types of drug orientated groups off of the map in a relatively short time. Governments could control and tax the drugs with, prices being more reflective of the cost of manufacturing. This would also reduce the crime rate associated with drug users. This could easily be done by any willing government but at what price?



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Reports.

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2: Profile: Columbia’s Armed Groups. Accessed on 18th November 2005.
http://news.bbc.co.uk/1/hi/world/americas/4528631.stm

3: Transparency International. ‘Global Corruption Report 2005’. Part Three: Country reports. Accessed on 24th November 2005 from website.
http://www.globalcorruptionreport.org/download.html

4: The Committee on Foreign Relations, Subcommittee on Terrorism, Narcotics and International Operations. ‘Drugs, Law Enforcement and Foreign Policy’. US government printing office, Washington 1989. Accessed 23rd November 2005:
http://www.gwu.edu/%7Ensarchiv/NSAEBB/NSAEBB113/north06.pdf

5: President Reagan: Message to congress on America’s Agenda for the future.
February 6th 1986. Accessed on 20th November 2005:
http://www.reagan.utexas.edu/archives/speeches/1986/20686c.htm

6: The Prevention of Drug Smuggling: Report by the Comptroller and Auditor general. H.M. Customs and Esxise. 1998. Page 2.

7: United Nations, Office on Drugs and Crime. ‘The World Drugs Report 2005’. Page 12. Accessed: 16th November 2005 from
http://www.unodc.org/unodc/en/world_drug_report.html

8: OECD & Inter-American Development Bank. ‘Fighting Hard Core Cartels in Latin America and the Caribbean’. 2005. Accessed on 18th November 2005.
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9: OECD. ‘Fighting Hard Core cartels: Harm, Effective sanctions and leniency programmes’. 2002, Page 7. Accessed on 19th November 2005.
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