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MALTATODAY 28 November 2021

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15 NEWS maltatoday | SUNDAY • 28 NOVEMBER 2021 supplies could also be tempted into trafficking surplus vol- umes to illicit, high-value mar- kets: one cannabis production facility in California with the capacity to process over 500 million pounds of marijuana was raided by police, which found only 20% of the cannabis grown being legal. The question is to what ex- tent could legalised cannabis clubs, specifically with their own growing facilities, end up dabbling in the illicit market. Sandra Scicluna, a criminol- ogy lecturer, notes that the Bill being debated is not clear enough when it comes to sup- ply. "How can you control the amount of plants being cul- tivated? It's impossible," she said. If someone wants to buy 20kg of 'licit' cannabis, people will be pushed into a new black market. The defining factor for the reform is how supply limits will be enforced. Un- der the new law, people would be allowed to grow up to four cannabis plants in a single res- idence. When cultivating, one can keep up to 50 grams of dried cannabis in a residence. Meanwhile, cannabis associ- ations will only be able to dis- tribute 7 grams per day to each member, with a maximum 50 grams per month. Assuming that government is able to enforce these restric- tions, risks of legalised can- nabis clubs spilling into the illicit market are low. "This is because of economies of scale," Scicluna explained. "It's not entirely unlikely, but the profit margin for this product locally isn't high. I'm not sure if it will be profitable." But as Scicluna said earlier, enforcing supply limits could be close to impossible. In this situation, Malta could also risk being used as an illicit pro- duction hub for cannabis to be sold on in places where the substance is banned. "It could facilitate the black market," Scicluna said. Existing organised crime groups who profit from Mal- ta's cannabis black market are unlikely to face disruption through the new reform. The Criminal Intelligence Service of Canada reported in 2019 that such crime groups involved in cannabis were unlikely to be disrupted by legalisation, be- cause they had other streams of revenue to benefit from. And while Canada's cannabis legislation made it harder for these crime groups to infiltrate the legal regime, these groups were adapting to changes in the market. Indeed, the EU Agency for Law Enforcement and Training says COVID-19 prompted a rise in the use of internet and social networks for purchase and distribution of drugs with DarkNet and postal services. "Criminals have used courier companies, food deliveries and car-sharing services to distrib- ute drugs. Retail of illicit prod- ucts has shifted from streets to rented accommodations. Can- nabis indoor cultivation and cannabis consumption have increased." The European Monitoring Centre for Drugs reports that the use of labour exploitation at cannabis cultivation sites is "a well-known phenomenon and remains an issue in some EU member states." Organised crime groups tar- get vulnerable victims, main- ly male irregular migrants, to work at indoor cultivation sites, where they are typically kept at the cultivation site, of- ten in very poor conditions, to look after the cannabis plants. The real challenge for Malta will be to stop legal growing facilities from turning into il- licit production factories in an attempt to use cannabis-grow- ing technology and expertise to generate high volumes of can- nabis beyond the legal limits – and then export the surplus to other EU member states.

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