Submitted:
02 July 2024
Posted:
04 July 2024
You are already at the latest version
Abstract
Keywords:
1. Introduction
1.1 Problem Statement
1.2 Towards Addressing IFFs
1.3. Research Question
1.4. Research Objectives
2. Materials and Methods
2.1. The Use of Qualitative Propositions
- Content propositions which present attributes of entities in a framework and are indicated by pCi, for i a natural number, i.e., i ∈ {1, 2, 3, …}.
- General propositions, which present general ideas and are indicated by pGj, for j a natural number, i.e., j ∈ {1, 2, 3, …}.
3. Results
3.1. Interviews
3.1.1. Identification of Types and Characteristics of IFFs
- "There is [are] high risks for price skimming, evading tax through abusive profit-shifting."
- “Investments in an offshore account that is not traceable, those are the things that you look into to see whether it is legit or is it a matter of just station some funds in an offshore account, but like I said, it's a bit tricky when it comes to a company tax. It's easier with an individual tax where you have access to the information you start asking questions, and that's when you can conclude that this transaction; it's definitely an offshore transaction, and there are no further details or proper documentation that has been provided to back up the taxpayer’s intention. And also, fictitious transactions to evade paying tax, so those are the kind of things that you look into when you're trying to figure out if it's a legit transaction or if it's sort of a fictitious transaction just to evade paying taxes.”
3.1.2 The Effectiveness of Financial Reporting in Curbing IFFs
- “There may be an increase in transparency in terms of reporting, such as the topics covered. Potentially having a full income statement; you might have some form of lead schedule displaying the clearance or providing a description behind, say, the five highest transactions during the year.”
- “I'd say just everything on the financial statements, especially where users can make decisions based on financial statements, there [they] needs to be sufficiently disclosed.”
- “Management should put certain controls in place and then from the internal auditors to make sure that those controls are actually working and the external auditors to make sure that it's actually addressing or preventing or identifying illicit funds.”
- “I think, especially where the board is concerned, they need to be able to hold the finance directors and finance management accountable for what they've put in their financial statements.”
- “When it comes to the consequences of such activities. Then it must be clearly specified, and then it must be clearly executed. So, it can't only be something declared to be a threat; it must also be appropriately performed in such instances.”
- "I think education for taxpayers is important, more especially to the SMEs. I think most [of] SMEs should learn how to separate business accounts with their personal accounts. Some, they believe in transferring money to their personal accounts rather paying tax. So, we need to engage with the SMEs now and then to emphasise the importance of paying taxes to SARS and impact of not paying tax, which is severe”.
3.1.4. Causes of Non-Compliance with Accounting Standards and Principles in Financial Reporting
- “I believe the accounting standards are also making it harder to apply. I believe that the IFRS standards should be simplified so that they are easy to understand and applied, as well as removing parts where you have options to do an event and just stating, this is how we want you to do it.”
- “If the framework for financial reporting was less open to interpretation. So, for example, when we consider a cash basis financial framework, we can see that, while it has limitations, it also has advantages. For instance, statement of cash flows, there aren't many ways to manipulate that you have to record and present your cash flows as they are. So, if we could have a method that is not susceptible to manipulation, areas where there is judgments and estimates, I would propose very thorough disclosure.”
- “I would say there is a lot of unwilling to comply with income tax payable to SARS.”
3.2. Focus Group
3.2.1. Characteristics and Types of IFFs- (Financial System Stability, Geographical Position, Trade of SA Links, Porous Borders and Crime-Related Profit-Making)
3.2.2. The Enhanced Framework
3.2.3. Specific Recommendations or Relevant Issues
3.2.4. The Associations (Links) among the Entities (Shapes) in the Framework
3.2.5. Other Issues Relevant to the Framework
3.3. Enhanced and Validated Framework

3.3.1. Final Framework Discussion
4. Discussion
5. Conclusions
Author Contributions
Funding
Data Availability Statement
Acknowledgments
Conflicts of Interest
Appendix A: Interview Protocol
| Name and surname (optional) |
| Gender |
| Current Position |
| Working experience (in years and months) |
| Place |
| Date |
| Time |
References
- Bao, D-H.; ee; omeo. Comparisons on selected ratios between IFRS and US GAAP companies. Journal of Financial Reporting and Accounting. 8. Pp. 22–34 2010. [Google Scholar] [CrossRef]
- Cobham, A., 2018. Target 2030: illicit financial flows. Globalization, Development and Governance. Available online at: https://www.realinstitutoelcano.org/en/analyses/target-2030-illicit-financial-flows/.
- Collin, M. , 2020. Illicit financial flows: concepts, measurement, and evidence. The World Bank Research Observer, 35, 44–86. [CrossRef]
- Combes, J-L, , Minea, A. and Sawadogo, P.N. Do Illicit Financial Flows Hurt Tax Revenues Evidence from the Developing World (English). Policy Research working paper no. WPS 9781, Impact Evaluation series Washington, D.C.: World Bank Group. http://documents.worldbank.org/curated/en/920391632411569911/Do-Illicit-Financial-Flows-Hurt-Tax-Revenues-Evidence-from-the-Developing-World.
- Dainoff, C. A., 2021. Outlaw paradise: Why countries become tax havens. Rowman & Littlefield.
- Dyer, T., Lang, M. and Stice-Lawrence, L., 2017. The evolution of 10-K textual disclosure: Evidence from Latent Dirichlet Allocation. Journal of Accounting and Economics, 64, 221–245. [CrossRef]
- Dyntu, V. and Dykyi, O., 2018. Cryptocurrency in the system of money laundering. Baltic Journal of Economic Studies, 4, 75-81. [CrossRef]
- Elosiuba, J.N. and Okoye, E.I., 2018. Effects of international financial reporting standards on corporate performance of selected banks listed on Nigeria stock exchange. Annals of Spiru Haret University Economic Series, 19. [CrossRef]
- FATF, 2021. ‘FATF Annual Report 2020-2021. Available online at: https://www.fatf-gafi.org/en/publications/Fatfgeneral/Annual-Report-2021-2022.html.
- Fanusie, Y. J. and Robinson, T., 2018. Bitcoin Laundering: An Analysis of Illicit Flows into Digital Currency Services’, Center on Sanctions and Illicit Finance, 15. MEMO_Bitcoin_Laundering.pdf (fdd.org).
- IFRS, n.d., IFRS Home Page. Available online at: https://www.ifrs.org.
- Jo, A., 2023. The promise and peril of generative AI. Nature 614, 214–216.
- Khalaf, M.L.O. Khalaf, M.L.O. and Alnwairan, T.A., 2020. Virtual Currencies (Bitcoin): The Stand Of Islamic Economy On The Use Of Such Currencies. Journal Of Critical Reviews, 7. 61f2a8be5a5477.31100877.pdf (jcreview.com).
- Kurniasih, L. and Suranta, S., 2017. Earnings management, corporate governance and tax avoidance: The case in Indonesia. Corporate Governance and Tax Avoidance: The Case in Indonesia (December 9, 2017). Journal of Finance and Banking. Review, 2, 28-35. [CrossRef]
- Lev, B., 2018. The deteriorating usefulness of financial report information and how to reverse it. Accounting and Business Research, 48, 465-493. [CrossRef]
- Mahajan, K; 2019. ‘State Capture’: How the Gupta Brothers Hijacked South Africa Using Bribes Instead of Bullets. Vanity Fair, 3. How the Gupta Brothers Hijacked South Africa Using Bribes Instead of Bullets | Vanity Fair.
- Mashayekhi, B; and Kalhornia, H., 2016. Relationship between Financial Reporting Transparency and Investment Efficiency: Evidence from Iran, World Academy of Science, Engineering and Technology, International Journal of Economics and Management Engineering, 10(7), pp. 2433–2437.
- Mazikana, A.T., 2023. Causal Relationship Between Remittances and Industry Value: A Case of Selected Sub-Saharan Africa Countries. International Journal of African Studies. 3, 69-74. [CrossRef]
- Montes, M.F., 2020. The Role of South-South Cooperation in Combatting Illicit Financial Flows. Tax Cooperation Policy Brief núm, 11. TCPB11_The-Role-of-South-South-Cooperation-in-Combatting-Illicit-Financial-Flows_EN.pdf (southcentre.int).
- Muslim, H.S., Al-Shimari, K.K.J. and Jihad, J.F., 2021. Illicit financial flows and their impact on domestic resource mobilization in the Arab region. Journal of Global Scientific Research, 6, 1200–1210.
- Mwita, R.M., Chachage, B., Mashenene, R.G. and Msese, L.R., 2019. The role of Financial accounting information transparency in combating corruption in Tanzanian Saccos. African Journal of Applied Research, 5, 108-119. Retrieved from https://www.ajaronline.com/index.php/AJAR/article/view/310.
- Ndikumana, L., Boyce, J. K. and Ndiaye, A. S., 2015. Capital flight from Africa: Measurement and drivers. In S. I. Ajayi and L. Ndikumana (Eds.), Capital Flight from Africa: Causes, Effects and Policy Issues (pp. 15–54). Oxford: Oxford University Press.
- Netshisaulu, N.N.; Van der, Poll; Poll, H.M.; Van, der. A Conceptual Framework to Analyse Illicit Financial Flows (IFFs). Risks, 10, 172 2022. [Google Scholar] [CrossRef]
- Netshisaulu, N.N., 2024. A framework to curb illicit financial flows. DBL Thesis submitted for examination, Graduate School of Business Leadership (SBL), University of South Africa (Unisa), South Africa.
- Onyabe, J.M., Okpanachi, J., Nyor, T., Yahaya, O.A. and Ahmed, M., 2018. Effect of audit committee tenure on financial reporting quality of listed deposit money banks in Nigeria. European Scientific Journal, 14, 257-271. [CrossRef]
- Rapanyane, M.B. and Ngoepe, C.C., 2020. The impact of illicit financial flows on the South African political economy under Jacob Zuma, 2009–2018. Journal of Public Affairs, 20, e2020. [CrossRef]
- Robb, N., 2020. Policy Brief: Illicit financial flows and industrial development in South Africa : A discussion of policy options. Available online at: https://www.tips.org.za/policy-briefs/item/3980-illicit-financial-flows-and-industrial-development-in-south-africa-a-discussion-of-policy-options.
- Salehi, M., Ammar Ajel, R. and Zimon, G., 2023. The relationship between corporate governance and financial reporting transparency. Journal of Financial Reporting and Accounting, 21, 1049-1072. [CrossRef]
- Saunders, M.N.K., Lewis, P. and Thornhill, A. 2023. Research Methods for Business Students, 7th edition. Pearson Education Limited, Harlow.
- UNODC and UNCTAD, 2020. Conceptual framework for the Statistical Measurement of Illicit Financial Flows, October 2020, 28 pp., Available online at: https://unctad.org/publication/conceptual-framework-statistical-measurement-illicit-financial-flows.
- UNCTAD, 2021a. Promotion of international cooperation to combat illicit financial flows and strengthen good practices on assets return to foster sustainable development: Achievements, challenges and ways forward. Paper prepared by UNCTAD, in collaboration with UNODC, in compliance with A/RES/74/206. United Nations conference on trade and development. Available online at: https://unctad.org/system/files/official-document/webosg2021d1_en.pdf.
- UNCTAD, 2021b. SDG Pulse 2021: UNCTAD TAKES THE PULSE OF THE SDGS, United Nations Conference on Trade and Development, 275 pp. Available online at: https://unctad.org/system/files/official-document/SDGPulse2021_en.pdf.
- United Nations, n.d., Department of Economic and Social Affairs: Sustainable Development. Available online at https://sdgs.un.org/goals.
- Van der Poll, J.A. and van der Poll, H.M., 2023. Assisting Postgraduate Students to Synthesise Qualitative Propositions to Develop a Conceptual Framework. Journal for New Generation Sciences (JNGS), 21, 146–158. https://journals.co.za/doi/epdf/10.10520/ejc-newgen-v21-n1-a13.
- Wier, L. and Reynolds, H., 2018. Big and "unprofitable": How 10% of multinational firms do 98% of profit shifting (No. 2018/111). WIDER Working Paper. Big and ‘Unprofitable’: How 10% of MNEs do 98% of Profit Shifting (taxobservatory.eu).
- Wier, L., 2020. Tax-motivated transfer mispricing in South Africa: Direct evidence using transaction data. Journal of Public Economics, 184, 104153. [CrossRef]


| Content Proposition# | Description |
|---|---|
| Proposition pC1 | IFFs require strong international cooperation and concerted efforts to facilitate the curbing of IFFs. |
| Proposition pC2 | The World Bank and the EU have a critical role in combating IFFs and can help curb them by ensuring a more transparent financial system. |
| Proposition pC3 | Tax evasion is the reason for cross-border transfers. |
| Proposition pC4 | Funds are moved to other destinations through deliberate misreporting. |
| Proposition pC5 | Trade transactions disguise the origins of proceeds from crime. |
| Proposition pC6 | Profits are shifted to countries with lower tax rates through transfer pricing. |
| Proposition pC7 | Aggressive tax avoidance is legal, but it is viewed as an IFF. |
| Proposition pC8 | A legal due diligence report can be a useful tool to remedy cross-border financial transactions associated with IFFs. |
| Proposition pC9 | When earnings management is employed to move funds across the border or to evade tax, it might be viewed as IFFs. |
| Proposition pC10 | Criminal enterprises profit from illicit activities. |
| Proposition pC11 | Engaging in complex transactions appears to be driven by the desire to create wealth through IFFs |
| Proposition pC12 | Undeclared money transfers in breach of currency controls need to be identified. |
| Proposition pC13 | Transactions that are lower than the reporting point can remain silent and not be detected as transactions in breach of currency control. |
| Proposition pC14 | Monies acquired through misappropriation of funds manifest mainly as IFFs. |
| Proposition pC15 | Accounting fraud, owing to the actions of managers and employees in a company, influences the occurrences of IFFs. |
| Proposition pC16 | Financial irregularities, such as falsification of information, misrepresentations, or omissions, create more room for IFFs. |
| Proposition pC17 | Transparency in financial reporting discourages disclosure opacity to assist with curbing IFFs. |
| Proposition pC18 | High tax rates are viewed as a major driver of IFFs. |
| Proposition pC19 | Resource-rich countries are prone to IFFs. |
| Proposition pC20 | Low institutional capabilities create a conducive environment for IFFs. |
| Proposition pC21 | Political instability leads to IFFs. |
| Proposition pC22 | A low regulatory framework allows IFFs to be widely spread. |
| Proposition pC23 | Simplified financial reports, auditing, and transparency in financial statements may assist in addressing IFFs. |
| Proposition pC24 | The lack of a commonly agreed-upon definition of financial reporting transparency could impact benefits that could curb IFFs. |
| Proposition pC25 | More robust internal control over financial reporting transparency may facilitate the curbing of IFFs. |
| Proposition pC26 | Regarding financial reporting transparency: Country-to-country reporting may be a significant tool to curb IFFs. Companies and policymakers should enhance their views or perceptions of crash risks. Regulation can have crucial effects on financing decisions around the globe, where trust has a greater impact in opaque information environments. |
| Proposition pC27 | Additionally, regarding financial reporting transparency: Improvement can assist in addressing the challenge of IFFs. It provides stakeholders with useful information to make informed decisions and combat IFFs. |
| Proposition pC28 | The quality of financial reporting: Alleviates the extent of information asymmetry and can boost investment efficiency. Enhances investment efficiency in entities with stronger corporate governance. |
| Proposition pC29 | Adopting IFRS by a country, results in more flexible reporting standards that create an environment that allows cultural pressures to influence illegal activities more freely and with less regulation practice. |
| Proposition pC30 | The stewardship role within the company should adhere to good corporate governance guidelines to maximise shareholder wealth and protect assets. |
| Proposition pC31 | To curb IFFs: Every sector should implement a sound risk management system, a strong governance system, and effective anti-IFF activities. Systematic controls and a robust global body that focuses on strong policies and regulations on financial intelligence at a global level are key to curbing IFFs. Effective controls should be implemented to eliminate the detrimental marginal repercussions of trade related IFFs. Inspection and validation of import and export invoices should be improved. IFFs should be regulated, and progressive tax policies applied to ensure that corporate taxes are paid by entities in the countries they operate. Policymakers should safeguard companies from IFF practices that hamper social and economic development. Local and cross-border information exchanges should be reinforced. The improved quality of all international commercial trade transactions should be recorded and shared with institutions responsible for commercial data. Attention should be paid to the use of holding/majority entities and proper analyses of cross-border ownership associations. Transfer pricing accounting practices to revenue collection agencies to encourage the curb of IFFs. |
| Proposition pC32 | Compliance with IFRS, IPSAS and GAAP will assist in curbing IFFs. |
| Proposition pC33 | Accounting principles and standards should be implemented to curb IFFs. |
| Proposition pC34 | To address IFFs, entities ought to adhere to rules and regulations, including corporate governance principles, as per King IV. |
| Proposition pC35 | Auditing services are vital for stakeholders and to address IFFs. |
| General Proposition# | Description |
|---|---|
| Proposition pG1 | IFFs hinder state resources and revenues and weaken governance. |
| Proposition pG2 | Collaboration with partners like GFI and FATF may assist in curbing IFFs in line with the UN Sustainable Development Goal 16.4.1. |
| Interviewee (Ix) | Position | Company | Working Years | Gender |
| Interviewee 1 | Senior IFRS Manager | Firm A | 20 Years | Female |
| Interviewee 2 | Manager | Firm A | 7 Years | Male |
| Interviewee 3 | Quality and Risk Management | Firm A | 24 Years | Female |
| Interviewee 4 | Manager | Firm A | 8 Years | Female |
| Interviewee 5 | Senior Manager | Firm A | 9 Years | Female |
| Interviewee 6 | Manager | Firm A | 8 Years | Female |
| Interviewee 7 | IFRS Manager | Firm A | 10 Years | Female |
| Interviewee 8 | Senior Manager | Firm A | 21 Years | Female |
| Interviewee 9 | Director and Head: Business Process Solutions | Firm B | 20 Years | Male |
| Interviewee 10 | Associate Director: Business Process Solutions | Firm B | 12 Years | Male |
| Interviewee 11 | Business Development Manager | Firm B | 32 Years | Female |
| Interviewee 12 | Tax Compliance Manager | Firm B | 14 Years | Female |
| Interviewee 13 | Cloud Accounting Manager | Firm B | 11 Years | Female |
| Interviewee 14 | Director-Assurance | Firm B | 13 Years | Female |
| Interviewee 15 | Manager: Business Process Solutions | Firm B | 7 Years | Female |
| Interviewee 16 | Director-Assurance | Firm B | 12 Years | Male |
| Type of IFFs: Commercial |
Type of IFFs: Off-balance sheet financial crime |
Type of IFFs: Corruption |
|---|---|---|
|
Risk Indicators Tax evasion enabled by Tax havens. Profit shifting via offshore accounts. Related party transactions (not at an arm’s length). Financial system abuses for IFFs. |
Risk indicator of IFFs Drug trafficking by organised criminal gangs. Cash smuggling. Kickbacks. Collusion with suppliers. Bitcoin by criminal syndicates. Ghost employees. Shell companies. Misappropriation of assets. Petty cash theft. |
Risk indicators of IFFs Kickbacks (bribes). Collusion with suppliers. Operational irregularities. |
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