Illicit trade: expert warns about risks of distorting the market

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Illicit trade in the Dominican Republic: A challenge that evolves beyond traditional smuggling

The landscape of illicit trade in the Dominican Republic has undergone a significant transformation. According to lawyer and trade regulation specialist César Dmitri Roa Castillo, this scourge is no longer limited exclusively to practices such as smuggling, trademark counterfeiting, the adulteration of beverages, or the trafficking of cigarettes and pharmaceuticals. Currently, the problem has taken on more complex forms that require a comprehensive approach from the authorities.

Roa Castillo warns that, in many cases, the marketed product may be completely legitimate, but the operation behind its sale presents critical irregularities. Among these, the undervaluation of goods in customs, tax evasion, non-compliance with labor regulations, or the lack of proper accounting records stand out.

The need for a comprehensive approach

For the expert, the error lies in analyzing infractions in isolation. Although each irregularity—whether customs, tax, or labor-related—falls under different institutions, the economic fact constitutes a single commercial operation. Therefore, he proposes that the State observe the entirety of business activity to identify patterns of illicit behavior more efficiently.

An undervaluation is a customs matter, an undeclared sale corresponds to the tax administration, a labor or immigration irregularity has its own authorities; however, the company is a single entity and so is its economic operation.

César Dmitri Roa Castillo

Economic and fiscal impact

Globalization and the rise of e-commerce have facilitated the exchange of goods, but they have also opened gaps for new forms of illegal trade. Globally, the OECD estimates that the market for counterfeit products is worth around $467 billion, which represents approximately 2.3% of world imports.

In the local context, the data is alarming. During the year 2025, the General Directorate of Customs detected tax discrepancies valued at RD$1.592 billion after conducting 49 audits in specific sectors. Similarly, the General Directorate of Internal Taxes has reported investigations into omissions in the payment of Income Tax (ISR) and ITBIS, as well as undeclared sales processed through credit cards.

Efficiency vs. Illegality

Roa Castillo emphasizes that companies offering competitive prices should not be stigmatized. Logistical efficiency, high purchase volume, or the reduction of intermediaries are legitimate market practices that benefit the consumer.

The breaking point, the specialist underscores, occurs when the competitive advantage does not stem from process optimization, but from tax evasion, the undervaluation of goods, or the violation of workers’ rights. “When non-compliance becomes a competitive advantage, what begins to be at risk is the integrity of the market,” he concludes.

Towards better institutional coordination

The expert advocates for greater coordination between agencies such as Customs, Internal Revenue, the Ministry of Labor, Migration, and Pro Consumidor. The goal is to share strategic information that allows for distinguishing companies that operate within the framework of the law from those that use repeated non-compliance as part of their business model.

Finally, Roa Castillo maintains that capital, regardless of its origin, must be subject to the same rules of the game, thus guaranteeing the legal certainty necessary for the sustainable development of the nation.

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