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FINANCIAL INVESTIGATIONS INTO WILDLIFE CRIME
Produced by the ECOFEL
The Egmont Group (EG) is a global organization of Financial Intelligence Units (FIUs). The
Egmont Group Secretariat (EGS) is based in Canada and provides strategic, administrative,
and other support to the overall activities of the Egmont Group, the Egmont Committee, the
Working Groups as well as the Regional Groups.
The Egmont Centre of FIU Excellence and Leadership (ECOFEL), active since April 2018, is an
operational arm of the EG and is fully integrated into the EGS in Canada. The ECOFEL is
mandated to develop and deliver capacity building and technical assistance projects and
programs related to the development and enhancement of FIU capabilities, excellence and
leadership.
ECOFEL IS FUNDED THROUGH THE FINANCIAL CONTRIBUTIONS
OF UKAID AND SWISS CONFEDERATION
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permission and consent from the Egmont Group Secretariat.
Request for permission to reproduce all or part of this publication should be made to:
THE EGMONT GROUP SECRETARIAT
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E-mail: mail@egmontsecretariat.org
Copyright © 2020 by the Egmont Group of Financial Intelligence Units
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Table of Contents
List of Acronyms ..................................................................................................................... 5
Executive Summary ................................................................................................................ 6
Introduction ............................................................................................................................ 9
Objectives ................................................................................................................... 9
Methodology ............................................................................................................ 10
Key Definitions .......................................................................................................... 11
Legal Framework ....................................................................................................... 14
Key Species .......................................................................................................................... 16
Key Industries ....................................................................................................................... 17
Hunting/Eco-tourism ................................................................................................. 18
Timber ....................................................................................................................... 18
Transportation and Shipping .................................................................................... 19
Financial .................................................................................................................... 19
Traditional Medicine ................................................................................................. 19
Exotic Pet Trade ........................................................................................................ 20
Trinkets and Jewellery ............................................................................................... 20
Taxidermy ................................................................................................................. 20
Zoos/Breeding Facilities ............................................................................................ 21
Food/restaurants ....................................................................................................... 21
Fashion ...................................................................................................................... 21
Art and Décor ............................................................................................................ 21
Supply Chain ........................................................................................................................ 22
Geographic Supply Chain ......................................................................................... 22
Actors Supply Chain .................................................................................................. 23
Linking Financial Crimes to the Actor Supply Chain ................................................. 25
Concealment Methods .............................................................................................. 26
Payment Methods ..................................................................................................... 26
Links to Other Crimes ........................................................................................................... 29
Drug Offences ........................................................................................................... 29
Corruption ................................................................................................................. 30
Terrorist Financing .................................................................................................... 31
Illegal Weapons Trade .............................................................................................. 31
AML/CFT Relevance ............................................................................................................. 32
AML/CFT Legislation ................................................................................................ 33
Advantages of Utilising the AML framework ............................................................. 34
Risk Assessments .................................................................................................................. 36
Identifying the Financial Flows of Wildlife Crime ................................................................. 42
Suspicious Transaction Reports ................................................................................. 43
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STR Analysis .............................................................................................................. 45
Expanding Perpetrator Profiles ................................................................................. 47
Asset Recovery .......................................................................................................... 49
Information Dissemination to Law Enforcement Agencies ....................................... 51
Challenges to Conducting Financial Investigations ............................................................. 51
Interagency Cooperation ..................................................................................................... 52
Cooperation Mechanisms ......................................................................................... 53
Challenges to Interagency Cooperation ................................................................... 60
International Cooperation .................................................................................................... 60
FIU Cooperation ........................................................................................................ 60
Information Sharing Networks .................................................................................. 61
Initiatives ................................................................................................................... 62
Challenges to International Cooperation .................................................................. 63
Recommended Practices ...................................................................................................... 64
Conclusion ............................................................................................................................ 65
Annexes ................................................................................................................................ 67
Annex A: List of Participating Agencies .................................................................... 67
Annex B: FATF 40 Recommendations ..................................................................... 71
Annex C: FATF IWT Indicators for Financial Institutions ........................................... 74
Reference Lists ..................................................................................................................... 78
.
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List of Boxes
The Role of the CITES Management Authorities .................................................. 12
Rhino Horn Trafficking and Hunting in Poland ...................................................... 18
Online Wildlife Trafficking ..................................................................................... 27
Joint Parallel Financial Investigation to Dismantle Reptile Smuggling Network ... 28
Determinants of Prices .......................................................................................... 32
The Lacey Act – U.S. Legislation ........................................................................... 33
Co-mingling Legitimate and Illegitimate Products ............................................... 45
Wildlife Trafficking Smurfing Case Study .............................................................. 47
Access to Databases ............................................................................................. 48
Managing Seized Wildlife Products ................................................................... 50
Abalone Poaching Network Exporting Wildlife to China .................................. 50
SEPRONA and Financial Investigations ............................................................. 55
Interagency Cooperation with Tax Authority .................................................... 56
Cooperation Mechanism between Gibraltar’s FIU and EA ................................ 56
ACAMS and WWF Certification Process for Private Sector ............................... 58
CENTIF-CI Involvement in Wildlife Crime Investigation .................................... 59
Analyst Exchange Program on Wildlife Smuggling ........................................... 61
Creating an Analytical Unit within the FIU ......................................................... 65
.
List of Figures
Figure 1: Visual Diagram of Key Concepts ........................................................................... 14
Figure 2: Table of Popularly Species Traded ....................................................................... 16
Figure 3: Chart of Commonly Seized Species/Products by Percentage .............................. 17
Figure 4: Table of Geographic Supply Chain Question Responses ..................................... 23
Figure 5: Table of Financial Crimes in the Actor Supply Chain ............................................ 25
Figure 6: Chart of NRA Inclusion of Environmental and Wildlife Crime ............................... 37
Figure 7: Chart of Risk Rating Assigned to Environmental or Wildlife Crime in NRAs ........ 38
Figure 8: Chart of Risk Rating Assigned to Environmental or Wildlife Crime According to the
ECOFEL Questionnaire Responses ...................................................................................... 39
Figure 9: Charts of Regional ML/TF Risk Associated with Wildlife or Environmental Crime 40
Figure 10: Chart of FIUs Conducting Parallel Investigations into Wildlife Crime ................. 42
Figure 11: Chart of FIUs who Received Training Regarding Financial Flows Linked to Wildlife
Crime .................................................................................................................................... 52
Figure 12: Chart of Agencies Involved in Wildlife Crime Investigations .............................. 53
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List of Acronyms
AML/CFT
CITES
EA
ECOFEL
FATF
FIU
FIWFC
INTERPOL
IWT
LEA
ML/TF
NGO
NRA
STR
UNODC
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Executive Summary
1. Wildlife crime is a complex, global problem that needs to be addressed through
various strategies. Upon completing primary and secondary research on wildlife
crime, the ECOFEL developed the following report to provide financial intelligence
units (FIUs) with an enhanced understanding of wildlife crime. This report also
emphasises the importance of identifying the illicit financial flows and supporting
financial investigations relating to wildlife crime.
2. Wildlife crime refers to acts which breach international and domestic regulations
intended to protect natural resources. The acts may include, but are not limited to,
the illegal hunting, poaching, taking, possessing, transporting, or selling of protected
species of flora and fauna. The illegal wildlife trade is a subset of wildlife crime which
encompasses actions such as smuggling, trading or trafficking of CITES designated
species and/or other protected species, including their parts and products.
3. Thousands of species are targeted by wildlife crime. Certain species, such as
pangolins, elephants, rhinoceroses, and tigers, are particularly threatened by the
illegal wildlife trade. These animals and their products are used in numerous
industries, from eco-tourism to traditional medicine. Even the financial sector may
be abused to facilitate this illicit activity.
4. Wildlife crime should be considered a global problem rather than a regional one. All
regions around the world are involved in illicit supply chains as either source, transit,
or destination jurisdictions, or a combination thereof. Supply chains can also be
understood in terms of wildlife crime actors, ranging from poacher to retailer. Each
actor that facilitates wildlife crime conducts financial transactions that can be
analysed by FIUs.
5. By being aware of the concealment and payment methods used by wildlife crime
traffickers, FIUs can develop perpetrator profiles and bring light to the modus
operandi and money laundering techniques. FIUs may be able to accurately assess
risks posed by other serious crimes, such as drug offences and corruption, by
understanding how wildlife crime is linked to these transnational offences.
6. Historically, there have been few financial investigations into wildlife crime around
the world. A lack of financial scrutiny and low penalties make wildlife crime a highly
profitable, low-risk enterprise for perpetrators. There are numerous benefits to
supporting investigations into the financial flows of the illegal wildlife trade:
• Trigger higher penalties
• Address crimes committed by high-level actors
• Uncover wildlife crime networks
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• Support prosecutions of wildlife crime offenders
7. FIUs can get involved in supporting financial investigations into wildlife crime
through:
• Tracking the financial flows associated with seized and confiscated goods;
• Identifying criminal networks and shell companies involved in wildlife crime;
• Identifying payment mechanisms and money laundering techniques;
• Analysing the flow of wildlife crime proceeds;
• Detecting illicit wildlife activities by analysing suspicious transaction reports and
other financial intelligence.
8. While there are many challenges associated with conducting financial investigations,
there are recommended practices that can be utilised to increase the effectiveness of
FIU efforts. These practices include:
• Properly assessing the risks of wildlife crime in the jurisdiction’s National Risk
Assessment;
o Considering wildlife crime as a money laundering threat;
o Including EAs and relevant LEAs in risk assessment procedures;
o Identifying the jurisdiction’s location along the supply chain to understand
the risks and the financial flows of wildlife crime;
• Filtering and analysing STRs based on strategic assessments of wildlife crime
within the jurisdiction;
• Applying the techniques that FIUs currently use when analysing other predicate
offences where cash is the predominant payment method when supporting
wildlife crime investigations;
• Enhancing inter-agency cooperation and information exchange;
o Using established methods of inter-agency communication that have
been successfully used for other types of crime;
o Creating wildlife crime taskforces and working groups between
government agencies and relevant partners to facilitate trust and
information sharing;
o Using liaison officers to create efficient channels of communication and
cooperation between agencies;
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o Providing training sessions to EAs or LEAs on the AML/CFT regime and
how financial investigations can complement the traditional
investigative methods used for wildlife crime;
• Considering new partnerships with NGOs:
o Creating mechanisms for NGOs to submit relevant information about wildlife
crimes to the FIU;
o Involving NGOs in working groups and committees designed to combat
wildlife crime, while ensuring the confidentiality of sensitive data;
o Relying on established networks between NGOs and LEAs;
• Providing guidance, feedback, and training to reporting entities regarding the
financial flows of wildlife crime;
• Consider introducing a ‘follow the money’ approach to complement a ‘follow the
suspect’ approach.
9. By implementing the recommended practices mentioned, FIUs may be able to support
effective financial investigations into wildlife crime.
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Introduction
1. Wildlife crime is the illegal exploitation of the world’s flora and fauna. Types of
wildlife crime include poaching, destroying habitats, and trading protected species.
Such activities negatively impact ecosystems and economic prosperity globally.
While governments take steps to combat the illegal activities, historically there have
been very few financial investigations into wildlife crime anywhere in the world. A
lack of financial scrutiny and penalties means that wildlife crime is a highly
profitable, yet low-risk enterprise for perpetrators.
2. Financial Intelligence Units (FIUs), which are skilled in anti-money laundering and
countering terrorism financing (AML/CFT), have the experience and legal mandate
to support domestic law enforcement authorities in identifying and combatting
wildlife crimes. FIUs located in jurisdictions affected by organised crime have
developed the knowledge and tools which can be adapted and applied in cases of
wildlife and forestry crime. Through enhanced investigations and increased targeting
of perpetrators, the profitability of wildlife crime would decrease.
3. Since 2018, the Egmont Centre of FIU Excellence and Leadership (ECOFEL) has
researched the financial flow trends related to wildlife and forestry crime as part of
the Financial Investigations in Wildlife and Forestry Crime (FIWFC) project. The
over-arching objective of the FIWFC project is to reduce illicit financial flows linked
to wildlife crime by involving financial intelligence units (FIUs) within investigations.
4. The desired outcomes of the FIWFC Project are as follows:
• To provide stakeholders with an enhanced understanding of the way corruption,
money laundering, and economic crimes manifest in the wildlife trade context,
thereby increasing the capacity to disrupt actors engaged in wildlife crime.
• To improve stakeholder communication and cooperation, leading to operational
partnerships between financial institutions, financial intelligence units (FIUs),
governance bodies, and law enforcement agencies.
• To increase the consequences for criminals and corrupt actors looking to enter the
wildlife crime domain by essentially turning it into a higher-risk and less
profitable criminal endeavour, one in which they are less likely to engage.
Objectives
5. This report aims to facilitate the achievement of the first outcome by presenting the
trends and patterns associated with wildlife crime financial flows.
6. As a FIWFC project output, the objectives for this report include:
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• To provide stakeholders with an enhanced understanding of the financial aspects
of wildlife crime;
• To encourage a coordinated multi-disciplinary approach at the international,
regional and national levels between and within key jurisdictions to tackle the
financial elements of wildlife crime.
Methodology
7. From November 2019 until August 2020, the FIWFC project team conducted a
comprehensive review of existing reports by international organisations and peer-
reviewed journal articles. The project team also compiled a database of illegal wildlife
seizures around the world using open-source material. This secondary research
provided additional insight into the financial flows relating to wildlife crime.
8. Following the literature review and database compilation, from March 2020 until June
2020, the project team created and distributed questionnaires to FIUs and
environmental agencies (EAs) located in all jurisdictions around the world. The
ECOFEL received 59 responses from FIUs in every Egmont region,
1
and 29 responses
from EAs.
2
9. In some jurisdictions, custom agencies and other LEAs responded to the EA
questionnaires since they had essential knowledge regarding wildlife seizures and
enforcement. Out of the FIU responses, two jurisdictions chose not to answer the
particular questions due to a lack of prioritisation and understanding of wildlife crime
in their respective FIUs. The ECOFEL also received input from leading NGOs involved
in combatting illegal wildlife trade.
10. In addition to gathering primary information from the questionnaires, the ECOFEL
also led an in-person workshop in Bangkok, Thailand, from March 11-12, 2020. This
workshop was designed to facilitate an exchange of information between FIUs,
1
Albania, Algeria, Argentina, Australia, Azerbaijan, Bangladesh, Belarus, Belize, Bhutan, Bosnia and
Herzegovina, Botswana, Brazil, Burkina Faso, Cambodia, Canada, Cape Verde, Costa Rica, Cote d’Ivoire,
Denmark, Finland, Gabon, Gibraltar, Guatemala, Guinea, Hong Kong, Hungary, Iceland, Indonesia,
Ireland, Japan, Jersey, Kenya, Laos, Lebanon, Malaysia, Mali, Mexico, Mongolia, Netherlands, Niger,
Norway, Panama, Papua New Guinea, Peru, Central African Republic, Republic of Congo, Slovakia,
Slovenia, South Africa, Spain, St Kitts and Nevis, St. Vincent and Grenadines, Sweden, Senegal, Tchad,
Ukraine, United States, Vietnam, Zambia
2
Bangladesh, Belarus, Belize, Brazil, Burkina Faso, Canada, Costa Rica, Cote d’Ivoire, Croatia, Denmark,
Gibraltar, Guinea, Iceland, Laos, Madagascar, Malaysia, Mali, Mexico, Niger, Norway, Panama, Poland,
Slovenia, St Vincent & Grenadines, Sweden, Togo, United Kingdom, Yemen, Zambia
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customs agencies, NGOs, and EAs throughout the Asia and Pacific region.
3
While
additional in-person workshops were to be held, the project team decided to move to
an online format due to restrictions associated with the COVID-19 pandemic. From
June 2-5, 2020, the ECOFEL hosted a series of virtual workshops in English, French
and Spanish to gather input from the Americas, East and Southern Africa, Europe I
and II, and West and Central Africa Egmont Regional Groups. Key international
organisations involved in the fight against wildlife crime also presented their findings
on the last day of the eWorkshop series.
4
The questionnaire and live-event data,
alongside secondary information from existing sources, provided the basis for this
report's findings.
11. Challenges encountered during the research phase of the ECOFEL FIWFC project
included: the limited sample size of questionnaire respondents and travel restrictions
associated with the COVID-19 pandemic. Several FIUs were unable to complete the
questionnaire due to lack of prioritisation of the illegal wildlife trade or wildlife crime
within their unit. Additionally, certain questionnaire responses were underdeveloped
as wildlife crime has not been previously analysed or brought to the attention of FIUs.
Key Definitions
12. The following section outlines the key legal instruments, terms and definitions that
will be used throughout the report.
CITES
13. With over 180 parties, the Convention on International Trade in Endangered Species
of Wild Fauna and Flora (CITES) is the principal international instrument dealing
with wildlife trade. The convention covers over 37,000 species of wildlife and is
crucial in establishing rules and prohibitions for the trade of endangered wildlife
(CITES, 2020). CITES regulates the trade and sale of wildlife products by facilitating
the administration of permits and licenses depending on the species conservation
and protection status. Overall, the treaty seeks to prevent the overexploitation of
listed species and penalise those involved via national measures.
3
In attendance: Cambodia FIU, CITES, FREELAND Foundation, Indonesia PPATK, INTERPOL, Thailand
AMLO, Thailand Customs, Thailand Department of National Parks, UNODC, US Aid Wildlife Policy, WWF.
Virtual participants: Bangladesh FIU, India WCCB, Malaysia FIU, Mongolia FIU, Vietnam FIU
4
Brazil COAF, CITES, Cote d’Ivoire CENTIF, Cote d’Ivoire DPFE, FATF, Guatemala CONAP, INTERPOL,
Kenya FIU, Madagascar SAMIFIN, Mexico UIF, Niger DFC/PR Nigeria FIU, Senegal CENTIF, South Africa
FIC, South Africa HAWKS, Spain SEPRONA, UK NWCU, UNODC
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14. CITES (2020) divides the regulation of species into three separate appendixes
depending on the level of protection that the species requires;
• Appendix I lists the species threatened with extinction and completely bans all
trade in the species except in exceptional circumstances.
• Appendix II is for species not necessarily threatened with extinction, but for which
trade must be controlled.
• Appendix III is for species that are protected in at least one country, which has
asked other countries for assistance in controlling the trade.
Environmental Crime
15. Environmental crime is designated as a category of money laundering predicate
offences (Financial Action Task Force [FATF], 2019). In broad terms, environmental
crime is the category of illegal activities which cause harm to the environment and
threaten the sustainability of ecosystems. EUROPOL (n.d.) notes that environmental
offences can include, but are not limited to the:
• improper collection, transport, recovery or disposal of waste;
• illegal operation of a plant in which a dangerous activity is carried out or in which
hazardous substances or preparations are stored;
• killing, destruction, possession or trade of protected wild animal or plant species;
The Role of the CITES Management Authorities
As CITES is not self-executing, each jurisdiction must develop their own legislation and
designate CITES Management Authorities (MAs) to implement CITES. In most jurisdictions,
the CITES Management Authority is embedded within the environmental agency. CITES MAs
are responsible for issuing permits and certificates under CITES regulations. They must
interact with other departments and governmental agencies, as well as communicate with
the CITES Secretariat to coordinate actions to enforce the Convention. CITES MAs are also
responsible for cooperating with enforcement authorities to fight illegal trafficking. FIUs are
encouraged to reach out to their jurisdictions’ CITES MA as they are a valuable resource of
information and can help coordinate international cooperation for the fight against the
illegal wildlife trade.
Source: CITES Secretariat
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• production, importation, exportation, marketing or use of ozone-depleting
substances (para. 2).
16. Environmental crime can also include illegal logging, illegal fishing,
5
and illegal
mining. These industries are estimated to cause billions of dollars in revenue loss.
However, due to their intricacies, not all characteristics of these industries fall under
the scope of this report. Specific case studies will cover trafficking in popular fish and
forestry species such as totoaba and rosewood.
17. Although the majority of the species listed under CITES are plants, this paper will
specifically focus on crimes about wild fauna.
6
The in-depth exploitation of wild flora,
as well as other forms of environmental crime, may be addressed in future ECOFEL
research projects.
7
Wildlife Crime
18. Wildlife crime is generally considered to be a smaller subset of activities under the
broader category of environmental crime. Wildlife crime refers to acts which breach
international and domestic regulations intended to protect natural resources. The
acts may include, but are not limited to, the illegal hunting, poaching, taking,
possessing, transporting, or selling of protected species of flora and fauna. As CITES
(2020) highlights, “it also includes the concealment and laundering of the financial
benefits made out of these crimes” (para. 2). These activities are only considered a
crime if they are punishable by domestic penal codes.
Illegal Wildlife Trade
19. Illegal wildlife trade (IWT) is a type of wildlife crime that encompasses actions such
as smuggling, trading or trafficking of CITES designated species and/or other
protected species, including their parts and products.
8
Wildlife trade is illegal when
it violates the CITES provisions or any other international treaty and domestic law
protecting flora and fauna. A perpetrator involved in the IWT may not have proper
CITES permits, trade outside of designated CITES ports of entry, and/or may not
comply with CITES trade suspensions. The trade of illegal wildlife products is
5
Illegal fishing is commonly referred to as illegal, unreported, and unregulated (IUU) fishing.
6
The world’s fauna includes all animals, reptiles, insects, and fish.
7
Flora can be understood as earth’s plants such as flowers, timber, and non-timber forest products.
8
Domesticated species do not fall under the purview of IWT.
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typically conducted across borders, so wildlife crime is subsequently and frequently
considered to be a transnational activity.
Figure 1: Visual Diagram of Key Concepts
Legal Framework
International Environmental Legislation
20. There are differences in how countries handle wildlife crime offences. States may
choose to punish offenders by pursuing administrative, civil, or criminal sanctions.
In certain jurisdictions, wildlife trade has not been comprehensively addressed within
national legislation at all. To harmonise standards and approaches, as well as to
facilitate coordination and cooperation in the fragmented domain of IWT, an
extensive body of organisations, treaties, conventions, and agreements have emerged
over the last 40 years (OECD, 2019). These institutions may directly or indirectly
regulate and control the international trade in wildlife. While many non-binding
agreements exist, legally binding instruments pressure parties to integrate anti-IWT
provisions into their national laws.
21. In addition to CITES, several legally binding instruments are directly associated with
IWT, including:
9
• International Tropical Timber Agreement
• Convention on Biological Diversity
9
For links to the mentioned legal instruments, please see Reference List: Legal Instruments
Environmental
Crime
Wildlife Crime
Illegal Wildlife
Trade
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• Convention on the Conservation of Migratory Species of Wild Animals
• Agreement on the Conservation of African-Eurasian Migratory Waterbirds
• Agreement on the Conservation of Gorillas and Their Habitats, also known as the
Gorilla Agreement
• Convention Concerning the Protection of the World Cultural and Natural Heritage
22. Regional legal frameworks can also be used to combat IWT. For instance, the ASEAN
Mutual Legal Assistance for Law Enforcement (MLA) coordinates extradition
agreements between countries in the region, including Singapore, Thailand, and
Malaysia. Such general extradition agreements can be utilised to target IWT. Regional
cooperation mechanisms are necessary due to the transnational characteristic of
IWT, which makes it challenging to punish offenders.
23. Additional existing regional and sub-regional legal frameworks include:
10
• African Convention on the Conservation of Nature and Natural Resources
• Lusaka Agreement on Co-operative Enforcement Operations directed at Illegal
Trade in Wild Fauna and Flora
• Convention on the Conservation of European Wildlife and Natural Habitats
• Convention on Nature Protection and Wild-Life Preservation in the Western
Hemisphere
24. Regional efforts have also been taken to address wildlife trafficking. The Lima
Declaration on Illegal Wildlife Trade calls upon jurisdictions in the Americas to
“adopt the use of financial investigation techniques and support public-private
partnerships to identify the illicit financial flows and the criminal organizations, and
their networks associated with illegal wildlife trafficking” (Lima Declaration, 2019, p.
3). Similarly, the EU Action Plan against Wildlife Trafficking also includes an
objective to “boost capacity of relevant experts to tackle the links of wildlife
trafficking with organised crime, including cybercrime and related illicit financial
flows” (EU, 2016, p. 20). Although these are not legally binding documents, it signals
the movement in these regions to address the need to conduct financial
investigations into wildlife crime.
25. Finally, there are numerous United Nations instruments about wildlife crime.
Notably, the UN General Assembly Resolution A/71/L.88 (2017) calls on countries to
leverage AML laws in the fight against wildlife trafficking (UNEP, 2018). Three United
Nations Security Council Resolutions also pertain to IWT. Namely, Resolution 2121
10
For links to the mentioned legal instruments, please see Reference List: Legal Instruments
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(2013) and Resolution 2262 (2016), which specifically address wildlife poaching and
trafficking in the Central African Republic, and Resolution 2134/2136 (2014), which
endorses the use of sanctions to combat criminal networks and groups involved in
the illegal exploitation of flora and fauna.
Key Species
26. Thousands of CITES-protected species are implicated in the illegal wildlife trade.
Contextual factors, such as the market demand, availability, and geographical
location of the wildlife, determine the relative rate that a species is traded. Noting
the types of wildlife illegally traded in a jurisdiction is necessary for conducting
effective financial analysis as the typologies and investigation methods vary
depending based on species.
11
27. There are challenges associated with identifying the exact frequency that a species is
traded due to a general lack of wildlife regulation and adequate protection across
jurisdictions. However, based on the EA questionnaire responses collected by the
ECOFEL and open-source data, the following species have been identified as
significantly implicated in the illegal wildlife trade. Figure 2 outlines several key
species sourced in each region based on responses received in 2020. Figure 3
summarises the key species (or species group) implicated in open-source seizure
reports from 2015-2020. Although this does not reflect the entirety of seizures, it
depicts recent trends of illegal wildlife species and highlights seizures reported by
news agencies.
Figure 2: Table of Popularly Species Traded
12
AMERICAS
WEST & CENTRAL
AFRICA
EAST &
SOUTHERN
AFRICA
EUROPE
ASIA-
PACIFIC
Sea turtles
Elephant
Elephant
Birds of Prey
Tigers
Iguanas
Pangolin
Turtles/tortoises
Whale
Turtles
Parrots
Rosewood
Rhino
Bears
Pangolins
Totoaba
Crocodiles
Big Cats
European eels
Orangutans
Corals
Panther
Shark
Songbirds
Parrots
Source: The ECOFEL EA Questionnaires
11
For example, the trafficking in glass eels involves different countries, routes, and shipping methods than
ivory trafficking.
12
For more information on each of these species, please visit the ECOFEL’s ‘Introduction to Wildlife Crime’
course on its eLearning platform. Please note, access is limited to eligible users.
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Figure 3: Chart of Commonly Seized Species/Products by Percentage
Source: The ECOFEL Open - Source Seizure Database
13
28. There are many changing trends and nuances within IWT that are difficult to capture
with seizure or open-source data. FIUs and other LEAs would benefit from
cooperating with EAs and environmental NGOs as they have essential knowledge
regarding the technicalities of the illegal wildlife trade in a specific region. Certain
NGOs dedicate their resources to fighting the illegal wildlife trade, which would be
valuable sources for understanding these shifting trends.
Key Industries
29. Understanding the critical industries implicated in the illegal wildlife trade can help
FIUs with developing wildlife crime-related money laundering indicators and red
flags.
14
Although opportunistic individuals are involved in the illegal wildlife product
chain, the involvement of businesses may suggest a more sophisticated criminal
network dealing with larger quantities of illegal wildlife. For example, criminal
networks may use legal companies to launder the proceeds of wildlife crime. Financial
investigations must target the businesses involved in IWT to take down the larger
criminal syndicates.
13
As the data in this chart is based on open-source data, it does not capture all global wildlife seizures.
14
The FATF has developed a list of red flag indicators in their report, Money Laundering and the Illegal
Wildlife Trade that may be used by financial institutions to guide their identification of suspicious activity.
Please see Annex C of this report for the indicators.
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Hunting/Eco-tourism
30. Hunting companies may offer exotic wildlife species hunting to trophy hunters.
These businesses must abide by the regulations of both CITES and national
legislations. If the company does not obtain the proper permit for the hunting of
certain species, the business may be implicated in wildlife crime.
• The International Fund for Animal Welfare (IFAW) found that there is a link
between rhino poaching and trophy hunting. They reported a case where an
international rhino horn trafficker used legal loopholes in trophy hunting
legislation to obtain rhino horns illegally (IFAW, 2016).
• Like hunting companies, Zambia’s environmental agency noted the involvement
of eco-tourism companies in wildlife trafficking. Several bags of ivory were found
and seized at an eco-tourism safari lodge in Zambia. Three other jurisdictions also
observed the involvement of eco-tourism companies in the illegal wildlife trade.
Timber
31. Certain jurisdictions noted that timber companies are implicated in IWT when they
illegally export protected wood species together with their legal exports.
• The Environmental Investigation Agency ([EIA], 2019) found evidence of several
companies involved in the illegal extraction and exportation of protected tree
species in Gabon and Congo. These companies were affiliated with Dejia Group,
an influential Chinese timber group. The EIA also discovered that a timber
Rhino Horn Trafficking and Hunting in Poland
Upon receiving a request by the Ministry of Environment in Poland, the Polish Police
started an investigation in 2016 into hunters who import rhino horns into the country.
This investigation revealed that in numerous instances, ‘legally’ obtained rhino
trophies imported by Polish hunters disappeared from their collection. More than 40
hunters were involved. It is likely that hunting trips were arranged by an individual
who collected imported rhino horns for the black market in Asia. The investigations
are ongoing, but so far 100 rhino horns valued at around 25 million USD have gone
missing through this operating channel.
Source: CITES Management Authority, Poland
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importation company in the United States was complicit in this illegal trade (EIA,
2019).
• Panama’s environmental agency revealed in the ECOFEL’s questionnaire that
companies relating to timber, sawmills and wood products are involved in wildlife
crime.
Transportation and Shipping
32. Transportation companies are necessary for transferring wildlife products along the
supply chain.
• Eleven environmental agencies from different jurisdictions noted that
transportation companies are involved in the illegal wildlife trade. Among the
identified transportation methods are freight transport, yachts, private cars, and
rail cars.
• From 2009-2016, there were over 1000 seizures of illegal wildlife products shipped
via aeroplanes, whether in checked luggage, freight, mail, or carry-on (TRAFFIC,
2018).
• The transport chain is highly fractionalised and involves many air, sea, road, or
rail methods of transport through the various entry and exit points. The
transportation methods often vary depending on the species.
Financial
33. Financial intermediaries may be implicated in the illegal wildlife trade when they
knowingly or unknowingly facilitate money transfers amongst wildlife crime
perpetrators.
34. Many FIUs have not yet explored the payment methods involved in wildlife crime.
However, 17 questionnaire respondents identified that wildlife crime perpetrators
might take advantage of the financial sector by using banking services, remittance
providers, and online payment applications to facilitate their illicit activities.
• One study by Jing and Ling (2015) found that WeChat Pay, an online payment tool
used primarily in China, was being used to facilitate money transfers in the online
illegal wildlife trade.
Traditional Medicine
35. The products of certain protected wildlife species are used to treat a variety of
ailments as part of traditional medicinal practices.
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36. In seizure data from 2015-2020 provided by Environment and Climate Change
Canada, traditional medicine containing protected wildlife species made up the
majority of seizures of cross-border shipments into Canada.
37. Products of species such as rhinos, pangolins, tigers, jaguars, and bears are frequently
used as ingredients for traditional medicines.
38. In a study of a Ghanaian wildlife market, seven protected wildlife species were found
to have uses in traditional medicine (Gbogbo & Daniels, 2019).
• In China, pangolin scales are used in the pharmaceutical and traditional medicine
industry. The country's medicinal demand for scales is estimated to create the
demand for up to 150,000 pangolins annually (C4ADS, 2020).
Exotic Pet Trade
39. Pet stores and online retailers can be implicated in the illegal wildlife trade by selling
protected live animals to customers.
40. Three different environmental agencies responded that pet stores might be involved
in the illegal wildlife trade.
41. Animals implicated in the exotic pet trade include primates, big cats, reptiles, and
marine life such as sea otters.
• One study found that viral social media videos of pet otters fueled the illegal trade
of the animals in Thailand (Siriwat & Nijman, 2018).
Trinkets and Jewellery
42. Retail stores may sell wildlife products like jewellery or souvenirs. Consumers may
purchase them as a souvenir or to gift to family members and friends.
43. Parts from wildlife species such as elephant, rhino, and turtle, are processed into
necklaces, bracelets, and figurines. The small size of these items makes them easier
to smuggle than whole animals or parts.
• The environmental agency of Panama indicated that tortoiseshell jewellery is sold
with other legal items in retail stores.
Taxidermy
44. Taxidermy companies become involved in the illegal wildlife trade when they
preserve, or transport protected wildlife species and products without proper permits.
• In one case, a Canadian taxidermist was charged with violating wildlife protection
laws because he illegally transported black bear pelts from the United States to
Canada without the proper permits (Bell, 2019).
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• Poland’s CITES Management Authority also noted how taxidermy companies
might be involved in the illegal wildlife trade.
Zoos/Breeding Facilities
45. Zoos may be involved in the illegal wildlife trade when they illegally import or obtain
protected wildlife species without proper permits. Like zoos, breeding centres or
farms are also implicated in the illegal wildlife trade.
• Costa Rica’s environmental agency indicated that zoos might be facilitating the
illegal wildlife trade.
• In a raid of the Tiger Temple breeding farm in Thailand, there was evidence of
illegal trafficking of captive tigers (BBC, 2019).
46. Other industries implicated in the illegal wildlife trade that have been identified in
secondary research are:
Food/restaurants
47. Protected wildlife species are sold in markets, grocery stores, and restaurants to be
consumed as delicacies. If restaurants and retailers do not abide by national
legislation, they are engaging in illegal wildlife trade.
• For example, the demand for shark fin soup in Asia is a critical driver in the illegal
trade of sharks.
15
Fashion
48. Many reptiles, such as crocodiles, lizards, and snakes, are used to make handbags and
shoes. Furs from animals such as big cats, otters, and seals are also used in the high-
fashion industry.
• Countries in Europe are major exporters of fashion items made from illegal
wildlife products. In Sosnowski & Petrossian’s (2020) study on wildlife seizures
relating to the US luxury fashion industry, 56% of 474 seizure incidents came from
Italy, France, and Switzerland.
Art and Décor
49. Illegal wildlife products can be employed for artistic and decorative purposes. Parts
of wildlife, including big cat skins, can be turned into rugs and other home décor.
Species such as mongoose can be used to create paintbrushes.
15
In a 2017 survey in Thailand, WildAid found that 61% of respondents will continue to consume shark fin
soup in the future.
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• In a case involving the Indian Wildlife Crime Control Bureau (WCCB), the 2019
Operation Clean Art encompassed 31 raids and led to the confiscation of 113
kilograms of raw hair and 55,421 brushes made from mongoose (Singh, 2019).
Forty-nine wildlife criminals were arrested across India because of the operation
(WCCB, 2020).
Supply Chain
Geographic Supply Chain
50. The illegal wildlife trade supply chain is frequently outlined as involving source,
transit, and destination countries.
51. A source country is where the wildlife is initially extracted, exploited, taken, killed, or
poached.
• Example: The Democratic Republic of Congo is home to all four African subspecies
of the pangolin and is a primary source of pangolins, as found in seizure data from
2015-2019 (C4ADS, 2020).
52. A transit country is a hub for the import and subsequent export of illegal wildlife
products.
• Example: Nigeria is a significant transit country for the illegal pangolin trade.
From 2015-2019, international seizure data showed that over 87 tonnes of
pangolin scales transited through Nigerian maritime ports (C4ADS, 2020).
53. A destination country is where wildlife products are sold and consumed for various
purposes.
• Example: China is a major destination country for pangolins in the illegal
pangolin trade, where their scales are used in traditional medicine (C4ADS, 2020).
54. The geographic supply chain is not mutually exclusive. One region can serve as
multiple points along the supply chain. For instance, although Gabon is a source
country for pangolins, the nation can also be considered a destination point since
pangolins are consumed within the country as part of the bushmeat trade (Mambeya
et al., 2018). In the ECOFEL EA questionnaires, 38% of environmental agencies have
identified themselves as all three categories (See Figure 3).
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Figure 4: Table of Geographic Supply Chain Question Responses
Location on Supply Chain
% of
Respondents
Source, Transit and Destination
38%
Source and Transit
14%
Transit and Destination
10%
Source
17%
Transit
14%
Destination
0%
Destination and Source
0%
Unknown
7%
Source: The ECOFEL EA Questionnaire
Actors Supply Chain
55. An alternative method for examining the illegal wildlife trade supply chain is by
emphasising the various actors along the geographic route. This model can be utilised
to identify the links between the actors. This can help in tracing the illicit financial
flows linked to the illegal wildlife trade.
56. The UNODC (2020) value chain is a useful model that focuses on the actors along each
stage of the IWT supply chain. The actor descriptions below are adapted from the
UNODC model. FIUs may investigate each transaction throughout the actor supply
chain.
57. Poachers
• Poachers are those who illegally catch, poach, kill or capture the wildlife species
at the source, contrary to national laws.
• Cash is the primary payment method at this level in the supply chain.
58. Runners/brokers
• Runners and brokers purchase illegal wildlife products directly from the poacher
in the source community and transport it to the next actor in the supply chain.
• UNODC (2020) found that runners and brokers are essential to high-level
traffickers who want to separate themselves from the poaching incident as much
as possible.
• Many of the financial transactions between the broker and poacher are done in
cash in the local currency. Several respondents of the ECOFEL FIU questionnaire
suggested that mobile payment methods are also used in source countries to pay
poachers.
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59. Intermediaries
• Intermediaries are usually high-level traffickers that take care of the logistics
required for transporting illegal wildlife products. They work as middlemen
between brokers and exporters (UNODC, 2020).
• Unless the intermediary transports the wildlife product, there will also be a
financial transaction between the transporter (individual or company) and the
intermediary.
• Depending on the product, the intermediary may need to arrange and pay for
storage/stockpiling of the illegal wildlife species.
• Financial transactions at this level may begin to be conducted via banking
transfers, remittances, or online services since the transactions generally involve
larger amounts of money.
60. Exporters/Importers
• Exporters/importers are key actors in moving the illegal wildlife products from
one region to another. They may be responsible for preparing transportation
documents and concealing the products (UNODC, 2020).
• Exporter and importers may take advantage of front companies or corrupt
authorities to transport illegal products internationally (UNODC, 2020).
• Financial transactions may involve transferring large sums of money
internationally via banking transfers, remittances, or other online services.
61. Wholesalers
• Wholesalers purchase wildlife products in the destination countries and distribute
them to retail traders (UNODC, 2020).
• Wholesalers may sell illegal wildlife products alongside their legitimate goods.
• Depending on the size of the illegal wildlife shipment, larger financial
transactions may involve transferring money via banking transfers, remittances,
or other online services.
62. Retail traders
• Retailers sell the finished wildlife product to the end consumer (UNODC, 2020).
• Like wholesalers, retail traders may sell the wildlife product alongside their
legitimate goods, such as a jewellery store selling prohibited ivory beads alongside
their usual, legally traded jewellery.
• Although smaller transactions between retailer and customer may be cash-based,
online retailers may use online payment methods such as PayPal or WeChat Pay.
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63. The actors involved in wildlife crime may vary based on the case's circumstances.
While all actors may be interested in the trade of one species, a different species may
go straight from the poacher to the retailer. In some instances, actors may serve as
both the broker and intermediary or simultaneously as the wholesaler and importer.
The profits associated with wildlife products increases substantially along the supply
chain (May, 2017). For example, the price of great apes increases by 1000% between
the poacher and final buyer (Clough & May, 2018).
64. The different uses of a species may impact its supply chain. For example, pangolin
bushmeat involves a less sophisticated trade between rural communities and urban
areas. Therefore, this trade may involve fewer transactions and a greater reliance on
cash. While the trade in pangolin bushmeat is mostly local and involves fewer actors,
the international trade in pangolin scales involves a much larger supply chain. The
pangolin scale trade requires participants from different jurisdictions to coordinate
on transporting, shipping, storing, and selling the product.
Linking Financial Crimes to the Actor Supply Chain
65. Money laundering can be found at every level of the actor supply chain. However,
there are also additional financial crimes that may be more specific to certain actors.
The table below outlines several crimes within the AML/CFT financial crime
framework that can be associated with each actor along the wildlife crime supply
chain. These financial crimes are included in FATF's 2019 list of designated categories
of offences.
Figure 5: Table of Financial Crimes in the Actor Supply Chain
Actor
Financial Crimes
Poacher
Robbery or Theft,
Runner/Broker
Smuggling, Fraud,
Intermediaries
Fraud, Smuggling, Bribery and Other Forms of Corruption
Exporters/Importers
Fraud, Smuggling, Currency Violations, Bribery and Other Forms of
Corruption
Wholesalers
Fraud, Smuggling, Tax Crimes
Retail Traders
Fraud, Tax Crimes
* This list is not exhaustive and there may be other crimes depending on each jurisdiction’s national
legislation or the structure of the organized crime groups and the and the illicit techniques they use to
conduct the illegal activities.
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Concealment Methods
66. Traffickers develop concealment methods to avoid detection by authorities during
the transportation of illegal wildlife products. The cases where concealment methods
were discussed in the ECOFEL’s questionnaire indicated that such methods involved
standard techniques as outlined in this section.
67. Illegal wildlife products can be concealed and transported in personal baggage on
transportation such as private vehicles, passenger buses, and taxis. This simple
concealment method is often taken advantage of in regions with porous borders,
where there may be limited enforcement (Runhovde, 2017).
• In 2020, 75 python skins were seized in Ouagadougou, Burkina Faso by the local
customs authority. The bags were on route to Niger, transiting through Mali via
public transportation. The skins were concealed in empty corn bags.
68. Illegal products can be disguised as legitimate goods. Some legitimate goods
identified as being shipped with illegal wildlife products were timber, non-protected
species of animals, and alcohol.
• In November 2016, 422 Marginated tortoises were seized at BCP Županja by
Croatian Customs from Bosnia and Herzegovina. The protected tortoises were
concealed in bags alongside legitimate and declared salt products.
69. Illegal wildlife products are also frequently improperly declared or have falsified
documentation to avoid detection by law enforcement agencies. Illegal wildlife
products have been falsely declared as tea, plastics, peanuts and other goods.
• In June 2019, 10,400 kg of shark fins, to be shipped to the Philippines, were seized
at the Port of Manzanillo, Mexico, by the customs authority. The shipment was
valued at $208,000. They were concealed in cardboard boxes and had export
permits with false information.
70. Numerous FIUs noted that information from customs authorities, including details of
product seizures, is valuable for conducting financial investigations. Understanding
concealment methods can assist FIUs in developing perpetrator profiles and help
them understand the modus operandi. Developing actor profiles and understanding
patterns in the modus operandi can support the identification of future wildlife crime
transactions.
Payment Methods
71. The primary method of payment used in the illegal wildlife trade is cash. Cash is used
throughout the supply chain but is especially prevalent within source countries.
Transactions often involve small amounts between poachers and brokers. FIUs may
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apply the techniques that they currently use when analysing other predicate offences
where cash is the predominant payment method.
72. FIU questionnaire respondents identified additional payment methods used by
poachers and intermediaries in the supply chain. These payment methods include:
• Bank transfers (wire transfers or remittances)
• Internet banking (IB) or mobile banking (MB)
• Prepaid cards (Visa, iTunes)
• Barter systems (commodities such as cigarettes, minerals, chainsaws, etc.)
• Virtual assets
73. Several FIUs also mentioned that some online payment providers might facilitate
IWT transactions. Additionally, in one study by Jing and Ling (2015), WeChat Pay was
found to facilitate online IWT in China.
74. Informal remittance systems may also facilitate payments in the illegal wildlife
trade. For example, one study found that the Chinese informal value transfer system,
'feiqian' was used to facilitate payments in a rosewood smuggling scheme involving
Southern African countries and China (Oxpeckers, 2019). A study by Global Financial
Integrity (2018) noted that there might be the use of hawala in the illegal trade in
great apes in Africa. The use of informal value transfer system in IWT warrants
further exploration.
75. While various payment methods were identified in the ECOFEL’s research, many
jurisdictions reported that they were unaware of the payment methods used for
wildlife crime. More research is needed to understand the methods of transferring
illicit financial flows. Through understanding the trends and patterns of the payment
methods associated with wildlife crime, FIUs can provide useful guidance to financial
intermediaries in developing measures to prevent the illicit transfer of funds.
Online Wildlife Trafficking
Two individuals from Port Ritchey, Florida, were indicted with charges of conspiracy,
smuggling, and Lacey Act violation. They had traded over 3,100 wildlife products over
the span of 6 years, valued at a total of US$ 211,212. They sold the goods using eBay
and accepted payments via PayPal.
Source: The United States Department of Justice, 2020
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Joint Parallel Financial Investigation in Australia to Dismantle
Reptile Smuggling Network
"In 2016, the Australian Border Force (ABF) intercepted several outgoing international
mail parcels containing native wildlife. Together with several intercepted inbound
packages containing exotic wildlife they were linked to an Australian person of interest
(POI). To further investigate, the Department of the Environment and Energy (DoEE,
now known as the Department of Agriculture, Water and the Environment) undertook
a joint investigation with the Australian Federal Police (AFP), and coordinated
significantly with the ABF, the FIU (AUSTRAC), the Department of Agriculture and
Water Resources, and various state and territory wildlife authorities.
The AFP confirmed that the POI coordinated an IWT criminal network to export
Australian native reptiles. Many of the POI’s exports were destined for associates in
Sweden. The investigation involved sharing intelligence with Swedish Police
authorities on the activities of Swedish POIs.
A search was conducted on the POI’s residence resulting in their arrest. During the
search two Burmese pythons were discovered on the property, along with
approximately AUD 30,000 in cash.
Financial intelligence helped identify the broader criminal networks. Bank transaction
information obtained from the FIU linked the primary POI directly to several Swedish
wildlife traffickers, supporting the criminal investigation. Likewise, FIU analysis
identified that the same Swedish entities had been sending funds to another Australian
reptile trader.
The payment methods used by members of the network included:
• Cash;
• Bank transfers;
• Remittances through a large MVTS provider;
• “In-kind” transactions (exchange of wildlife of equal value);
• Transactions sent to related parties (associates and family members of wildlife
traffickers).
Box continued on next page
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Links to Other Crimes
76. As wildlife crime may be linked to other forms of criminal activity, the prioritisation
of wildlife offences could be reconsidered. Exploring these connections can
encourage the use of established analytical tools and typologies in the domain of
illegal wildlife trade and facilitate crime prevention through numerous fronts. This
section will introduce the connections between wildlife crime and other
transnational crimes.
Drug Offences
77. There may be connections that exist between drug smuggling and illegal wildlife
trade. According to the Directorate for Priority Crime Investigation (HAWKS), the
multi-million-dollar trade in illegal abalone is facilitated by Chinese organised
criminal groups and local South African gangs.
16
These groups have also been linked
16
As mentioned in ECOFEL’s eWorkshop from June 2-5
th
, 2020
Joint Parallel Financial Investigation in Australia to Dismantle Reptile
Smuggling Network Cont’d
The volume of financial flows is difficult to quantify; however, estimates indicate that the
primary POI stood to gain over AUD 500,000 from an intercepted import of fish, stingrays,
reptiles and turtles from Thailand.
The primary POI was convicted on six charges including:
• Attempting to export regulated native specimens (The Environment Protection and
Biodiversity Conservation Act 1999 (EPBC Act) 303DD);
• Importing of regulated live specimens (EPBC Act 303EK);
• Possession of illegally imported specimens (EPBC Act 303GN);
• Money laundering (Criminal Code Act 1995).
The POI was sentenced to four years’ imprisonment, with a non-parole period of two and
a half years. During the investigation, authorities confiscated approximately USD 30,000
cash as proceeds of crime, along with over USD 340,000 (estimated value of wildlife)."
Source: AUSTRAC
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to the drug trade. Sometimes, abalone is directly traded for recreational drugs
(TRAFFIC, 2018).
78. In a 2020 case, the United States Attorney's Office for the Southern District of Georgia
released an indictment for many members of a wildlife trafficking network that
illegally traded shark fins and totoaba bladders. These members were also charged
with drug distribution as they were found with thousands of kilograms of marijuana.
The network used seafood businesses as fronts to launder the proceeds from both the
drug distribution and the illegal wildlife trade (Ballard Spahr LLP, 2020).
79. In the ECOFEL questionnaire, FIU Mexico also noted how wildlife trafficking uses the
same routes as drug, arms, and human trafficking. Similarly, Global Financial
Integrity released an article that describes how drug smugglers have a symbiotic
relationship with wildlife traffickers, as they may use the same routes (Guen, 2020).
This contrasts with the 2016 study of wildlife trafficking in the Americas that found
that most wildlife trafficking was done opportunistically or by small networks
without involvement in illegal drug trafficking (Reuter & O’Regan, 2017). The
connection between the drug trade and wildlife crime may therefore depend on the
regional context.
Corruption
80. Corruption is a key enabler in the illegal wildlife trade. Corrupt practices can occur at
every level of the wildlife crime supply chain. Van Uhm and Moreto (2019) found that,
in various jurisdictions, low-level corruption facilitated poaching. For example,
forest rangers may provide patrol information to poachers in exchange for a small
bribe. In China, the cross-border illegal wildlife trade was facilitated by personal
networks and exchanges of gifts between various government officials and illegal
wildlife traders (Van Uhm & Moreto, 2019). In multiple cases of ivory trafficking,
shipping agents and customs officials are provided with bribes to ensure that fake
paperwork is filed, and shipments of ivory proceed without inspection (Wyatt et al.,
2018).
81. FIUs have also identified corrupt practices by wildlife crime perpetrators. In one case
involving the Financial Intelligence Centre (FIC) South Africa, a rhino horn poaching
ring was broken up with the aid of financial intelligence and other surveillance
tactics. This network was comprised of police officers, game rangers and community
leaders, which led to charges of illegal wildlife trade, money laundering and
corruption. As another predicate offence for money laundering, financial
investigations can also target corruption in the illegal wildlife trade.
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Terrorist Financing
82. The link between terrorism and the illegal wildlife trade has been explored in open-
source media, especially the connection between ivory trafficking and terrorist
groups in East Africa.
83. In a 2010 investigation by the Elephant Action League, the organisation found that
there may be a link between Al-Shabaab and ivory trafficking through Kenya. The
Elephant Action League suggested that Al-Shabaab’s involvement in the illicit trade
“could be supplying up to 40% of the funds needed to keep them in business” (as cited
by Save the Rhino, 2013, para. 6). With the profits made from wildlife products, the
groups can purchase weapons and pay soldier’s wages. As a result of the potentially
high involvement in the ivory trade, Al-Shabaab may play “a role in setting the prices
for ivory on the global markets” (as cited by ESAAMLG, 2016, p. 57).
84. FIUs in Africa have noted that there may be links between poachers and terrorism
financiers. Kenya’s Financial Reporting Centre exchanged information with another
FIU “on terrorism financing where some individuals were remotely linked to
suspected poachers in the country.”
17
85. In contrast, Nigeria’s FIU mentioned the involvement of Boko Haram in wildlife
trafficking in the Lake Chad Basin area, even though there have been no successful
prosecutions or public cases. Searcey (2018) also reports that Gabonese officials
announced that an extensive ivory smuggling network with ties to Boko Haram had
been broken up. In addition to the connection to ivory, Cameroon has observed that
there is a risk of Boko Haram illegally exploiting fish populations in Lake Chad
(GABAC, 2017).
86. A report by Groupe d'Action contre le blanchiment d'Argent en Afrique Centrale (GABAC)
also highlighted the link between the illegal wildlife trade and terrorism financing.
For instance, several individuals listed as members of the Lord’s Resistance Army and
the Seleka Group were arrested by Chadian Defence and Security Forces in connection
with poaching cases (GABAC, 2017). The members were in possession of various
wildlife products, including elephant tusks. The individuals stated that they obtained
the wildlife products to exchange the items for weapons, cars, and supplies, or to sell
them to the heads of the Janjaweed group based in Darfur (GABAC, 2017).
Illegal Weapons Trade
87. The illegal weapons trade is connected to wildlife crime in multiple ways. Firstly,
smugglers may use the same routes for trading illegal weapons as they do for
17
FIU Questionnaire response.
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trafficking wildlife products. During the ECOFEL eWorkshop series, a European
representative's presentation indicated that organised crime groups are using similar
methods for moving wildlife products as they do with other illicit goods. Moreover,
the representative also stressed that the crime groups are beginning to focus on
wildlife activities as there is less risk involved.
88. Secondly, INTERPOL (2018) reports that some wildlife traffickers may be implicated
with arms dealers and may use illegal weapons to poach animals. In a 2015 report by
the Small Arms Survey, the organisation “found that weapons and ammunition
collected at poaching sites are rarely entered into Interpol’s firearms tracing system”
(as cited in Bale, 2016, para. 6). For instance, previously seized illegal arms in
Mozambique later showed up at a poaching site (Bale, 2016).
89. Finally, perpetrators may use wildlife products as currency for the weapons trade. An
investigation by National Geographic mentioned there are occurrences of militia
groups trading ivory in exchange for guns (Bale, 2016). However, the use of weapons
as a currency in wildlife trafficking needs greater exploration.
AML/CFT Relevance
90. Wildlife crime can start to be addressed through national and international AML/CFT
frameworks. This section will outline some of the AML/CFT legislation that can be
applied when starting to conduct and support financial investigations into wildlife
crime. This section will also provide an overview of the advantages of using AML/CFT
legislation to target wildlife offenders.
91. The relevancy of AML/CFT legislation has recently become a focus of FATF. Under
the 2019-2020 Chinese presidency, AML/CFT investigations in fighting IWT became
Determinants of Prices
Estimates concerning prices of illegal wildlife products may vary greatly depending on
the source of the information. Factors that impact the prices of illegal wildlife
products include the location, the species traded, and the shipping route. Generally,
supply and demand of the product determine a scarcity level. The higher this level is,
the higher the associated price. The supply and value of wildlife products is associated
with the origin, characteristics, and regulation status of the species. As UNODC (2019)
notes, “[t]he more endangered a species becomes, the greater is the commercial value
that is put on the remaining specimens, thereby increasing the price and the incentive
for trafficking” (para. 7). The demand of the products is often associated with a desire
of consumers to showcase their wealth (UNODC, 2019).
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a priority. The FATF has also recently released a report entitled Money Laundering and
the Illegal Wildlife Trade which outlines the applicability of FAFT 40
Recommendations in conducting financial investigations into wildlife crime.
AML/CFT Legislation
92. On a national level, each country adopts either an ‘all crimes’ approach or a ‘predicate
offence’ approach to utilising AML/CFT legislation. An all crimes approach means
that “any crime can serve as the grounds for the application of the AML requirements,
fines, and penalties” no matter the severity or type of crime (Wingard & Pascual,
2019, p. 3). Under a predicate offence approach, “laws expressly limit the types of
crimes that trigger the jurisdiction of their AML statute. This limitation can take
several forms, including using either a list of named crimes, or some other defining
element (e.g. the level, severity or type of crime)” (Wingard & Pascual, 2019, p. 3).
93. The predicate offence approach can pose challenges for combatting IWT as
conditions can result in offenders not being prosecuted via AML/CFT laws. One
condition requires wildlife crime acts to be considered a predicate offence under the
national AML/CFT legislation. Depending on the federal legislation, predicate
offences can be listed, or they can meet the threshold for a serious crime. If wildlife
crime does not meet this threshold, it will be insufficient to trigger an AML/CFT
investigation. Another condition requires the species poached/trafficked to fall under
protection by national laws to be considered wildlife crime. Without meeting these
conditions, AML/CFT laws will not be triggered.
94. International cooperation frameworks developed by the United Nations Convention
against Transnational Organized Crime (UNTOC) and the United Nations Convention
The Lacey Act – U.S. Legislation
The Lacey Act is the United States’ oldest wildlife protection statute. Enacted in 1900,
the piece of legislation prohibits international and domestic wildlife trafficking. The
Lacey Act is unique in its ability to utilise foreign legislation to trigger a Lacey Act
violation. A wildlife crime perpetrator can be prosecuted in the United States by
referencing that the act violates a foreign law. For example, “a California defendant was
charged with selling tarantulas collected in violation of Mexican law. At trial, the
relevant Mexican law was admitted to serve as the underlying violation for a felony
conviction” (Webb, 2001, p.5). This type of legislation structure can take advantage of a
predicate offense designation in other states to punish wildlife crime perpetrators.
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against Corruption (UNCAC) enable the criminalisation, investigation, and
prosecution of certain wildlife and forestry offences (CITES, 2020).
While there are
no specific protocols embedded within the UNTOC convention associated with
wildlife crime, according to Resolution E/2013/30 of the Economic and Social Council
of the UN, the illicit trafficking in protected species of wild fauna and flora is a serious
crime covered under the agreement.
95. The UNCAC does not state specific provisions on wildlife crimes; however, the
UNCAC promotes and strengthens measures to prevent and combat corruption and
supports international cooperation and technical assistance in the prevention of, and
fight against corruption, including asset recovery. The enforcement of all measures
covered by the UNCAC are vital to reduce wildlife crimes. The international
community has recognized that corruption underpins the illegal trade in natural
resources. In 2016, at the 17th meeting of the Conference of the Parties to CITES, a
resolution was passed calling on Parties to take a broad range of measures to prevent
and combat corruption linked to the illegal wildlife trade. The G20 Leader’s
Declaration of 2017 committed to the fight against corruption related to illegal trade
in wildlife and wildlife products. In 2019, the States Parties to the UNCAC adopted a
resolution, the first of its kind, on preventing and addressing corruption linked to
crimes that have an impact on the environment (UNODC, 2020).
96. Even with legal frameworks in place, many loopholes can be utilised by actors. For
instance, licensing schemes for wildlife farms create a legal market which facilitates
the illegal production of IWT and offers the social acceptability of wearing,
displaying, and consuming animal parts (OECD, 2019). Further to the efficacy of the
agreements, a 2018 assessment demonstrated that no country was fully compliant
with FATF 40 Recommendations as many countries have moderate or significant
shortcomings (Wingard & Pascual, 2019). “In other words, even in the best-case
scenario (i.e. when an AML law fully recognises all forms of IWT), enforcement and
prosecution can still face many challenges that stem from gaps that may exist in other
critical areas of AML laws, such as the transparency of beneficial owners in bank
accounts or international cooperation in transnational financial investigations”
(Wingard & Pascual, 2019, p. 12).
Advantages of Utilising the AML framework
97. There are numerous advantages to using the AML framework to target perpetrators
of wildlife crime. Firstly, AML laws often trigger higher penalties than environmental
or wildlife crime. In most jurisdictions around the world, penalties relating to wildlife
crime are low. Although many jurisdictions are moving towards increasing
punishments for involvement in wildlife crime, many governments continue to issue
a warning or a fine only. An analysis of 432 wildlife crime cases from 19 jurisdictions
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demonstrated that only 7% of all reported cases resulted in a conviction with a prison
sentence, and only 1% of cases resulted in severe penalties of four or more years in
prison (UNODC & APG, 2017). These low penalties mean that perpetrators are not
deterred from committing wildlife crime since there are few associated consequences.
98. As money laundering is considered a significant crime with substantial penalties in
many jurisdictions, using AML laws to punish wildlife crime perpetrators may serve
as a better deterrent than pursuing them only through environmental legislation. In
this sense, during the ECOFEL workshops, the FIC South Africa mentioned that
several members of an abalone poaching syndicate were sentenced to over 18 years
for charges relating to money laundering, racketeering, and fraud. The money
laundering charges associated with renting properties to process the abalone with the
landlord being aware that rent was paid with the proceeds of illegal activities. This
punishment is much harsher than fines in place of imprisonment, which many
wildlife crime perpetrators are sentenced to globally.
99. A financial investigation could shift focus beyond poaching to include targeting
crimes (e.g. trafficking) as well. Through tracking the financials, organised crime
groups and the facilitators of organised crime could be identified. Targeting high-
level actors, such as businesses, and dismantling criminal networks, can reduce
instances of wildlife crimes. Such a comprehensive approach provides the framework
necessary to hold both entities and individuals accountable. In one case presented by
the Nature Protection Service of Spain (SEPRONA), financial investigations into an
ivory trafficker led to the arrest of the perpetrator as well as provided further
information on other actors in the supply chain.
100. Supplementing traditional law enforcement investigations with parallel financial
investigations can also lead to uncovering additional evidence against perpetrators.
The serious nature of money laundering offences often grants FIUs and LEAs more
investigative powers that have not been used while pursuing wildlife crime. For
example, financial investigations may uncover information about offenders' assets
and lifestyles and link them to other criminal activities and offenders. Such evidence
may help increase the rates of successful prosecution of wildlife criminals.
101. Finally, the potential for criminal assets to be seized or confiscated may also work as
a stronger deterrent than short prison sentences. Criminals could be deterred from
engaging in the illicit trade out of concern regarding the risk of losing material goods
and lavish lifestyles. Furthermore, frozen or seized assets may affect family members
and close associates of perpetrators. LEAs handling wildlife crime have recognised
that perpetrators' responsibility for the financial well-being of close contacts may
result in freezing/confiscating measures working as a significant deterrent.
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102. While using AML/CFT frameworks represent advantages for IWT investigations, it
has been an under-utilised approach. For example, only 1% of wildlife crimes
triggered money laundering related investigations, charges, or prosecutions in the
Asia-Pacific region due to failures in legislation, and a lack of coordination and FIU
involvement (Wingard & Pascual, 2019). The following section outlines some of the
measures that can be used to begin conducting financial investigations into wildlife
crime.
Risk Assessments
103. There are two levels of risk assessments that can be conducted in the AML/CFT
regime. The first would be the National Risk Assessments (NRA) that national
governments undertake to understand the significant ML/TF threats and
vulnerabilities in their jurisdiction. Risk assessments may also be conducted on an
institutional level, as reporting entities should regularly assess their ML/TF risks. In
this section, the focus will be on NRAs and how jurisdictions evaluate the threat that
wildlife crime poses to their AML/CFT regime.
104. As per FATF’s Recommendations, many national AML/CFT strategies and FIU
operations take a risk-based approach based on the NRA. However, many
jurisdictions may underestimate the risk of environmental and wildlife crime, or do
not include a risk assessment of this sector in their NRA. Having a low or non-existent
threat perception of environmental or wildlife crime within the NRA may lead to
limited financial investigations of wildlife crime.
105. Globally, there is a lack of focus on environmental and wildlife crimes in the
AML/CFT regime. The ECOFEL reviewed 78 publicly available National Risk
Assessments (NRA) published by jurisdictions between 2012 and 2020 to identify the
money laundering risk attributed to wildlife crime.
18
The review found that only 13%
18
Armenia (2014), Bangladesh (2015), Barbados (2019), Benin (2018), Bermuda (2017), Bhutan (2017),
Botswana (2017), Burkina Faso (2017), Cambodia (2018), Canada (2015), Cayman Islands (2020), Chile
(2017), Chinese Taipei (2018), Cook Islands (2015), Cote d'Ivoire (2018), Cyprus (2018), Czech Republic
(2016), Fiji (2015), Georgia (2019), Ghana (2016), Gibraltar (2016), Guernsey (2019), Guyana (2017), Hong
Kong (2018), Indonesia (2015), Isle of Man (2020), Israel (2017), Italy (2014), Japan (2018), Lao PDR (2018),
Latvia (2019), Liechtenstein (2018), Lithuania (2015), Macao (2015), Malawi (2013), Malaysia (2017),
Maldives (2012), Mali (2019), Malta (2018), Mauritius (2019), Mexico (2016), Monaco (2017), Mongolia
(2016), Myanmar (2018), New Zealand (2018), Niger (2019), Nigeria (2016), North Macedonia (2016),
Pakistan (2018), Papua New Guinea (2017), Peru (2016), Philippines (2017), Poland (2019), Russian
Federation (2018), Saint Kitts and Nevis (2019), San Marino (2019), Senegal (2017), Serbia (2013),
Seychelles (2017), Sierra Leone (2017), Singapore (2014), Slovak Republic (2017), South Korea (2018), Sri
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of jurisdictions included wildlife crime in their assessment. Another 27% of
jurisdictions included environmental crime in their assessment (see Figure 5). Of the
jurisdictions who mentioned these crimes, only 68% were able to apply a threat rating
to the crimes (see Figure 6). The other NRAs only cited environmental or wildlife
crimes as a potential money laundering threat but did not have enough information
to assess the risk rating.
106. In the NRAs, there were different methods of evaluation that provided a risk
assessment of environmental or wildlife crime. In some reports, jurisdictions
estimated the value of revenue loss due to environmental or wildlife crime. For
example, Uganda’s NRA applied a high rating to wildlife crime as “Uganda is
estimated to lose about UGX 2,000,000,000 (USD 588,235,000) annually in wildlife
offences ranging from commercial poaching to hunting for daily subsistence” (p. 21).
In other NRAs, the risk was measured based on the level of criminal cases investigated
during a specific period. In Tanzania’s NRA, poaching was considered a high money
laundering threat because there were over 4000 cases detected from 2011-2015. Many
National Risk Assessments also consulted their nation’s Ministry of Environment to
develop an adequate risk rating of environmental crime in their jurisdiction.
Figure 6: Chart of NRA Inclusion of Environmental and Wildlife Crime
Source: Global NRA Review
Lanka (2014), Sweden (2019), Tanzania (2016), The Bahamas (2016), Tunisia (2017), Turks and Caicos
Islands (2017), Uganda (2017), United Kingdom (2017), Ukraine (2016), Uruguay (2014), United States
(2018), Vanuatu (2015), Virgin Islands (2017), Zambia (2016), Zimbabwe (2015).
13%
27%
60%
0
10
20
30
40
50
60
70
80
# of Jurisdictions
Wildlife Crime Environmental Crime Did not Mention
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Figure 7: Chart of Risk Rating Assigned to Environmental or Wildlife
Crime in NRAs
Source: Global NRA Review
107. While examining the National Risk Assessments from around the world, a
geographical pattern is noticeable. Out of the 21 National Risk Assessments analysed
from Europe I, Europe II, and Eurasia regions, none of them mentioned
environmental or wildlife crime as a money laundering threat. Only jurisdictions from
the East and Southern Africa, West and Central Africa, Asia-Pacific, and Americas
regions mentioned environmental or wildlife crime. This geographical pattern
mirrors the general perception that wildlife crime is a source country issue, rather
than a problem for transit and destination countries.
108. In addition to analysing NRAs, as part of the ECOFEL FIU questionnaire, respondents
were asked to identify the level of risk of wildlife crime, or environmental crime more
broadly, as a ML/TF threat. Figure 8 demonstrates the risk rating attributed to the
crimes.
38%
10%
19%
9%
24%
High Medium High Medium Medium Low Low
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Figure 8: Chart of Risk Rating Assigned to Environmental or Wildlife
Crime According to the ECOFEL Questionnaire Responses
Source: The ECOFEL FIU Questionnaires
109. Through the NRA examination, the results found that the majority of FIUs rated the
risk of wildlife crime as a low or unknown ML/TF threat. The difference in risk levels
identified may be a result of numerous methodological aspects, such as the
differences in the number of respondents of the questionnaire, the geographical
locations of the respondents, and the countries of the analysed NRAs. However, these
results may also be indicative of a trend that, as of 2020, wildlife crime is not a priority
for the majority of FIUs. Furthermore, in some cases, FIU risk assessments may have
underestimated the threat of wildlife crime because there is a limited understanding
of the topic.
110. In the ECOFEL’s analysis of FIU risk perception of IWT divided by geographic
location, a similar trend of transit and destination countries perceiving the risk of
wildlife crime in their jurisdiction was prevalent. As per the charts below, many
source countries in African regions rated their risk as high, while jurisdictions in
Europe, the Americas, and the Middle East & North Africa region found their risk to
be lower.
23%
4%
12%
35%
26%
High Medium-High Medium Low Unknown
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Figure 9: Charts of Regional ML/TF Risk Associated with Wildlife or
Environmental Crime
Low
80%
Unknown
20%
Europe I
High
17%
Low
50%
Unknown
33%
Europe II
Unknown
100%
Eurasia
High
25%
Medium
25%
Low
25%
Unknown
25%
Asia-Pacific
High
46%
Medium
-High
9%
Low
18%
Unknown
27%
West & Central Africa
High
75%
Medium
High
25%
East & Southern Africa
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Region
Number of
Responses
The Middle East and North
Africa
2
East and Southern Africa
4
Asia-Pacific
12
Americas
11
West and Central Africa
11
Europe I
10
Europe II
6
Eurasia
1
Total
57
Source: The ECOFEL FIU Questionnaires
111. By conducting financial investigations into the predicate offences associated with
wildlife crime in destination and transit counties, poaching offences in source
countries are no longer the sole focus of investigations. Without proper
acknowledgement of wildlife crime or the risk it poses within the AML/CFT
framework, it will be more challenging to prioritise financial investigations into
wildlife crime.
112. When updating their NRAs, jurisdictions may need to recognise the illicit financial
flows of wildlife crime and that these flows may cross into jurisdictions beyond source
countries. In understanding their threat profile, a country may "consider their ML
risks emanating from IWT, whether the underlying wildlife crime takes place
domestically or in a third country" (FAFT, 2020, p. 25). Another factor to consider
Low
100%
Middle East & North
Africa
High
18%
Medium
37%
Low
18%
Unknown
27%
Americas
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when understanding risk is the role of financial institutions in wildlife crime
transactions.
Identifying the Financial Flows of Wildlife Crime
113. According to the FATF (2020), financial investigations are “at the centre of an
effective AML/CFT regime” (p. 27). The FATF standards may provide a useful
framework to understand how financial investigations into wildlife crime can be
conducted under the AML/CFT regime (See Annex B). While there are clear benefits
to conducting financial investigations, the ECOFEL found that only 22% of the 59
FIUs who responded to the FIWFC Project questionnaires have conducted or been
involved in parallel financial investigations (See Figure 9). In the ECOFEL
questionnaire, many FIUs indicated that they had not supported wildlife crime
investigations due to limited resources and not prioritising wildlife crime. Additional
reasons shared include FIUs serving a primarily administrative function, or LEAs
taking on the primary responsibility for such investigations.
Figure 10: Chart of FIUs Conducting Parallel Investigations into Wildlife
Crime
Source: The ECOFEL FIU Questionnaires
114. FIUs can play a pivotal role in financial investigations through:
• Tracking the financial flows associated with seized and confiscated goods;
• Expanding perpetrator profiles by:
Yes
22%
No
78%
FIU Conducts Parallel Investigations into
Wildlife Crime
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o Identifying the criminal networks and the shell companies involved in the
illegal wildlife trade;
o Identifying payment mechanisms and money laundering techniques;
o Analysing where the profits of wildlife crime go;
• Detecting illicit wildlife activities by analysing the relevant suspicious transaction
reports
115. These measures will be explored further in the following sub-sections.
Suspicious Transaction Reports
116. Suspicious transaction reports (STRs) are crucial elements for investigating the
financial flows of wildlife crime. Currently, the number of wildlife crime-related STRs
submitted to FIUs is relatively low compared to those being submitted concerning
other crimes. 78% of the FIUs who responded to the questionnaire had not conducted
any analysis of STRs related to wildlife crime.
117. Several jurisdictions have not received any STRs relating to wildlife crime and
therefore have not been able to filter them.
19
A lack of STRs may stem from reporting
entities having insufficient guidance on the subject and therefore not filing the
reports. However, the apparent lack of STRs may also stem from FIUs not recognising
an STR related to wildlife due to a lack of training and knowledge on the particular
subject matter. The STRs relating to wildlife may be filed, but may instead recognise
them as trade-based money-laundering STRs.
118. The second reason for the lack of STR filtering may stem from the low level of risk
attributed to wildlife crime in the jurisdiction. Many FIUs have not examined the
issue of wildlife crime because they do not see it posing a considerable threat to their
jurisdiction. The ML risk associated with wildlife crime could be higher. However,
wildlife crime may be overlooked due to misconceptions on the issue. Each
jurisdiction plays a role in the wildlife crime supply chain. Therefore the ECOFEL
encourages countries to assess and analyse the targeted species and illicit activities
that apply to them.
119. The quality of the STR will also impact an FIU’s ability to analyse the STR properly.
During the ECOFEL workshops, Brazil COAF discussed how many STRs received are
defensive STRs based on media reports of wildlife crime cases. These defensive STRs
are typically low quality and may make it challenging to analyse the case. A lack of
19
Algeria, Argentina, Belize, Bosnia and Herzegovina, Ireland, Slovakia, St. Vincent and the Grenadines
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detail in STRs makes it challenging to track the financial flows of suspects and their
associates.
120. Another challenge in receiving STRs relating to wildlife crime is that reporting
entities are generally unaware of the red flags relating to wildlife crime and therefore
do not submit STRs.
20
Some of the transactions pertaining to IWT can involve small
amounts of money which could be more difficult for reporting entities to flag. FIUs
may be able to provide reporting entities with some guidance. For example, Brazil's
COAF found that many of the STRs they analysed relating to wildlife crime were not
triggered by a red flag specific to wildlife crime. Instead, the STRs were triggered by
more traditional indicators of financial crimes or money laundering such as
incompatibility between cash deposits and income.
121. Wildlife crime red flags vary significantly depending on the species and/or product
involved, the jurisdiction where the transactions are conducted, the applicable
typologies, and the direction of the financial flows. This variation makes it difficult
to create general red flags and indicators. For example, due to differences in market
value and transportation logistics, indicators of the live animal trade and the animal
product trade may vary significantly. Illegal wildlife products such as ivory tusks may
be stored in a storage facility for a long time before being shipped in a large
consignment via sea container. In contrast, live baby apes need to be taken care of
after poaching and shipped very carefully, usually by air to its destination. FIUs
should examine the issue of IWT as it pertains to their jurisdiction and coordinate
efforts with national actors to create the most relevant and applicable red flags for
their jurisdiction.
122. Finally, numerous jurisdictions mentioned the comingling of legal and illegal funds
which makes it challenging to detect suspicious transactions. During the ECOFEL
workshops, the Bangladesh FIU and India Wildlife Crime Control Bureau highlighted
the challenge of segregating legitimate revenues from illegitimate revenues. Business
entities dealing with both types of revenue streams may go undetected. High-risk
industries should be investigated by examining invoices and requesting additional
details on the products being bought and sold.
20
Some financial institutions are making progress on tracking the financial flows of wildlife crime. For
instance, various banks have made progress on raising awareness to combat the financial flows relating to
the illegal wildlife trade. When the efforts of reporting entities are coupled with additional presence and
guidance from FIUs, initiatives to tackle the problem may be more effective.
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STR Analysis
123. This section will explore how some FIUs can aid financial investigations of wildlife
crime through the analysis of suspicious transaction reports. FIUs may filter STRs
using various keywords. Additionally, they may be able to cross-reference STRs with
other databases and sources of information.
124. 22% of FIUs who do currently analyse STRs use various wildlife crime indicators.
There are several STR filtering methods which include analysing:
• Environmental Crime Keywords:
o Jurisdictions may filter STRs based on general keywords or activities relating
to environmental or wildlife crime such as poaching, illegal fishing, or illegal
logging.
o One jurisdiction noted that they used keywords relating to environmental
crime legislation such as ‘CITES’ in their filtering methods.
• Species:
o FIUs may filter STRs based on highly trafficked species in either their
common (i.e. tiger) or Latin (i.e. tigris) names.
o These species names should reflect the popularly traded species within their
specific jurisdiction.
• Geography:
o Certain FIUs noted that they would filter STRs based on geographical criteria
such as regions or countries that have been identified as high-risk for the
illegal wildlife trade.
Co-mingling Legitimate and Illegitimate Products
In 2019, the India Wildlife Crime Control Bureau, various forestry and police
departments, and the postal service in India conducted 'Operation Clean Art' to
uncover a criminal network of illegal paintbrushes made from mongoose fur. They
were able to make 49 arrests and seize tens of thousands of mongoose fur brushes.
The successful operation was also able to identify a list of several wholesale
companies that purchased the mongoose fur brushes. One of the difficulties
identified in tracing the illicit financial flows of this illegal trade is the comingling of
the illegal brushes with legal paint brushes made of synthetic fibres.
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o Jurisdictions should be conscious of their position within the supply chain.
Source countries or regions are not the only locations that should be flagged.
o Filtering by geographic location should be combined with other risk factors
(i.e. product, species) to provide enough detail.
• Industry and/or Business Type:
o Some FIUs filter the STRs for wildlife crime based on industries commonly
implicated in the illegal wildlife trade in their jurisdictions.
o Two FIUs mentioned that they filter STRs relating to wildlife crime based on
the type of business (i.e. companies, sole proprietorships or other entities).
125. All these filtering methods require specific knowledge about the nature and extent
of illegal wildlife trade within a jurisdiction, which includes commonly trafficked
species, trade routes and the implicated industries. FIUs can obtain this information
from their environmental agency or CITES management authority.
21
126. The methods used to investigate further the transactions are similar to the analysis
conducted with other types of STRs.
127. FIUs may combine the analysis of different instruments:
• STRs;
• Regulatory reports (e.g. currency transaction reports);
• Open-source intelligence platforms;
• National and organisational priorities.
128. Data to cross-reference STR details may include:
• Information referenced in open sources (e.g. social media);
• Identified trends/typologies;
• The number of STRs linked to the same individual or entity;
• The value of all STRs linked to the same individual or entity;
• Whether the individual or entity conducts business with the state;
• The criminal history of the individual; and
• Cross-border transactions conducted by individuals or entities.
21
More information on how environmental agencies can support financial investigations into wildlife
crime will be discussed in a later section (p. 53).
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Expanding Perpetrator Profiles
129. To gain a complete understanding of actors participating in the illegal wildlife trade,
if available, FIUs can look at data such as:
• Customs information:
o Customs declarations
o Bills of lading
o Invoices
o Importing/exporting information
• Immigration and citizenship information of suspect(s):
o Travel history of the suspect(s)
o Passport(s) information
• Seizure information
• Logistical data including the date, and location, of the seizure:
o Species/product seized
o The estimated value of the good(s)
o Concealment methods
o Method(s) of payment
• Profile of Suspects/Companies:
Wildlife Trafficking Smurfing Case Study
The Brazilian COAF uncovered a wildlife trafficking case involving the illegal trade of
rare Black Arowana fish eggs. These endangered fish are sourced in Brazil. In this case,
the wildlife traffickers used a third-party account of a fisherman who had a low
income. The STRs that were analysed by COAF indicated that there were multiple cash
deposits in cities along the Amazon river, beyond the residence of the fisherman. A
cash withdrawal was made in a border city with Peru and Colombia. The STR was
triggered due to these cash deposits that were inconsistent with the fisherman’s
typical income and movements.
Source: Brazil COAF
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o Identities and aliases of the suspect(s) and/or companies
o Addresses
o Vehicle and other asset registrations
o Relationships
o Bank and tax records
o Phone records
130. Information may come from a variety of private and governmental sources,
including:
• Auditing entities
• Corporate or Business Registries and Licensing Boards
• Tele-communication providers
• Census documentation
• Transportation and shipping companies
• Environmental agencies
131. Supplementing perpetrator profiles with financial information can provide
additional evidence necessary to support the predicate offence prosecutions.
Access to Databases
In 2017, Thailand AMLO conducted a successful financial investigation into the Star
Tiger Zoo Operation where they found that the zoo had been used as a front for a
wildlife trafficking network of endangered species and wildlife products such as tigers,
pangolins, and ivory. AMLO was able to seize various assets of wildlife traffickers
valued over USD$ 6 million as they investigated the criminal network. AMLO’s access
to over 18 governmental databases contributed to their success in conducting
financial investigations into this network. They were able to trace financial transfers,
cross-border movements, purchase of assets and much more to uncover the wildlife
trafficking ring.
Source: Thailand AMLO
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Asset Recovery
132. Asset recovery relating to wildlife crime is gaining increasing attention.
22
However,
the powers to seize and confiscate assets depend on the country. These powers may
be distributed across different forms of legislation, not solely in those relating to ML.
In some jurisdictions, asset recovery for wildlife crime is incorporated into national
legislation on wildlife protection. For example, in Botswana, the Wildlife
Conservation and National Parks Act allows prosecutors to confiscate all vehicles
used in poaching and any property that the wildlife offender purchased with the
proceeds of poaching. Several other countries have also implemented similar
provisions into their wildlife protection laws.
133. In discussing wildlife crime assets, a distinction should be made between wildlife
assets (e.g. animal products, live animals) and the proceeds of wildlife crime. Often it
is the EAs and LEAs who conduct asset recoveries on the wildlife species or products.
There is a need for FIUs to support asset tracing by conducting analysis and tracking
the financial proceeds of wildlife crime.
134. Only a few EAs noted what happens to the proceeds of seized wildlife products. In
Canada, the environmental agency has set up an Environmental Damages Fund. The
forfeited proceeds of wildlife crime and fines from convicted wildlife offenders may
be directed to this fund. Similarly, the EAs from Zambia, Belize and Costa Rica
indicated that funds from the sale of seized proceeds go to the governments.
135. Asset recovery networks can also be useful in facilitating the exchange of financial
information on a regional basis. For example, the Asset Recovery Inter-Agency
Network of Southern Africa (ARINSA) has been able to engage East and Southern
African countries to share information regarding wildlife traffickers.
23
In some cases,
FIUs are involved in such networks.
22
For more information about connections between wildlife crime and asset recovery please look at the
following reports: Basel Institute on Governance’s “Asset recovery and wildlife trafficking” at
https://baselgovernance.org/sites/default/files/2020-06/Perspectives3_AssetRecoveryandIWT.pdf and
FATF’s “Money Laundering and Illegal Wildlife Trade” (pg. 36-37) at http://www.fatf-
gafi.org/media/fatf/documents/Money-laundering-and-illegal-wildlife-trade.pdf
23
According to ARINSA (2019), Malawi is currently undergoing asset recovery procedures in three different
wildlife trafficking cases of various wildlife products valued over USD 200,000.
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Abalone Poaching Network Exporting Wildlife to China
"The South African FIC assisted in providing financial intelligence at the request of
the Directorate of Priority Crimes Investigation on an identified abalone poaching
network that was exporting abalone to Asia. The subjects and business entity linked
to the unlawful activities were profiled and financial intelligence was provided.
The Directorate of Priority Crimes Investigation was able to identify the rerouting of
shipping containers back to South Africa from Asia. These containers were found to
contain abalone.
The business entity that was used for the exportation of the abalone in the containers
and its Director, together with other suspects, were convicted for racketeering and
money laundering activities.
Financial intelligence found payments referenced as “shares’ for payments from the
kingpin's South African based business entity to a business entity based in Asia. These
payments were allegedly disguised to facilitate payments for unlawful activities. As
part of the plea agreement, the subject was ordered to pay about R2 000 000.00 into
the South African Criminal Recovery Asset Account."
Source: FIC South Africa
Managing Seized Wildlife Products
Environmental agencies have various strategies for managing seized wildlife
products. Illegal wildlife products may be destroyed, stored for evidentiary purposes,
used for training purposes, or donated to a research facility. Live animals may be
reintroduced to their original habitat or given to a rehabilitation center, university, or
zoo. Understanding how an environmental agency manages its seized wildlife
products is important because there is potential for the wildlife product to re-enter
the legal or illegal market. For instance, the products can re-enter the legal market
when jurisdictions auction off a seized wildlife product to raise funds for their anti-
wildlife crime units or government programs. In contrast, seized wildlife products can
also re-enter the illegal market if a storage facility is robbed or corrupt officials sell
the products to make money. In 2015, Zimbabwean officials were able to intercept an
illegal shipment of ivory at the Harare Airport that was destined for China. An
investigation led them to discover that the ivory came from the government storage
warehouse for seized ivory. Authorities charged the game manager and his two
associate game rangers with facilitating the theft of ivory through corrupt practices
(Oxpeckers, 2016).
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Information Dissemination to Law Enforcement Agencies
136. FIUs can significantly support the work of LEAs by disseminating financial
intelligence and information connected to existing wildlife crime cases. Information
dissemination begins through the development of effective partnerships between
FIUs and LEAs. To develop effective dissemination strategies, FIUs should liaise with
EAs and the authorities with law enforcement powers for investigating wildlife crime.
This will allow FIUs to gain an understanding of their partners' informational
priorities.
137. Selective information dissemination may prove to be more effective for investigative
efforts than providing LEA partners with an over-abundance of financial intelligence.
FIUs are encouraged to start dialogues with relevant governmental agencies. Such
discussions may help FIUs understand the type of information necessary to develop
and disseminate a detailed intelligence package that provides the most value.
138. In addition to communicating with partners to ensure that the information
disseminated to LEAs is applicable for investigations, FIUs are encouraged to gain a
better understanding of wildlife crime. By conducting training, FIU staff could have
the opportunity to understand wildlife crimes' key risks better and use this
comprehension to analyse and assess the problem. With this knowledge, FIUs can
assist LEAs in linking environment crimes to financial crimes.
Challenges to Conducting Financial Investigations
139. One of the most considerable barriers to conducting financial investigations in
wildlife crime for FIUs is the lack of detailed understanding of jurisdictional wildlife
crimes. Several FIUs were unable to fully answer the questionnaires due to limited
knowledge and experience in this subject matter. Only 28% of FIUs who responded to
the questionnaire have been involved in financial investigations relating to wildlife
crime.
140. Additional challenges to conducting financial investigations into wildlife crime are
as follows:
• Gaps in national legislation that may prevent FIUs from analysing wildlife crime;
• Limited training for relevant authorities on wildlife crime investigations (See
Figure 10);
• Lack of coordination between FIUs and reporting entities to develop typologies on
the wildlife crime supply chain, including for the latter stages;
• Few STRs relating to wildlife crime from reporting entities;
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• Few cooperation mechanisms (formal or informal) exist between FIUs and
relevant authorities;
• The absence of MoUs between FIUs and their foreign counterparts may inhibit
information sharing;
• Limited resources within the FIU to analyse wildlife crimes (FATF, 2020); and
• New technologies such as cryptocurrencies make it more challenging to trace
illicit transfers between wildlife traffickers.
Figure 11: Chart of FIUs who Received Training Regarding Financial
Flows Linked to Wildlife Crime
Source: The ECOFEL FIU Questionnaires
Interagency Cooperation
141. Financial investigations into wildlife crime investigations require cooperation and
coordination between different national agencies, including FIUs. However, as seen
in Figure 11, many wildlife crime investigations are typically conducted by LEAs and
EAs. Only one jurisdiction noted that FIUs are involved in wildlife crime
investigations. This finding may demonstrate an opportunity for FIUs to start
collaborating with LEAs and EAs to assist in financial investigations into wildlife
crime.
Yes
17%
No
83%
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Figure 12: Chart of Agencies Involved in Wildlife Crime Investigations
Agencies Involved
Number of
Responses
LEA only
9
EA only
9
LEA & EA
38
LEA, EA & FIU
1
LEA, EA & NGO
2
Source: The ECOFEL FIU Questionnaires
Cooperation Mechanisms
142. The AML/CFT legal frameworks in jurisdictions permit information sharing between
FIUs and government agencies. Both formal and informal channels exist to facilitate
agency communication and coordination, although these channels may be under-
utilised.
143. Examples of formal channels include:
• MoUs outlining an agreement between agencies to cooperate on a specific issue.
• Governmental committees concerned with AML/CFT matters may consider
wildlife crime in their agendas.
• Several informal mechanisms may be used to improve the exchange of
information between FIUs and other government agencies.
LEA only 15%
EA only
15%
LEA & EA
65%
LEA, EA& FIU
2%
LEA, EA & NGO
3%
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• Annual meetings or workshops may provide networking opportunities for
relevant stakeholders to develop professional connections.
• As found in the ECOFEL’s questionnaire responses, FIUs may also participate in
secondment programs.
Environmental Agencies
144. Environmental agencies have not been traditional partners for FIUs. However, they
are crucial partners in the fight against wildlife crime and the identification of the
related illicit financial flows.
145. Environmental agencies have technical knowledge regarding the key species,
industries, and concealment methods of the illegal wildlife trade in their respective
jurisdictions. This knowledge is useful for developing analytical tools and STR
filtering mechanisms for FIUs. Additionally, environmental agencies are often the
national focal point for international cooperation regarding CITES and wildlife trade.
146. According to the questionnaire, environmental agencies were either the only agency
or were part of multiagency cooperation regarding wildlife crime investigations in
their jurisdictions. Even though EAs engage in multiagency collaboration, there is
limited cooperation between EAs and FIUs.
147. One reason for this limited cooperation is a general perception that wildlife crime is
not a financial crime. However, this perception is changing as key stakeholders are
increasingly focusing on the topic. The FATF's report Money Laundering and the Illegal
Wildlife Trade demonstrates this shift. The United Nations has also recently called
upon countries to start conducting financial investigations into IWT. Several cases
throughout this report also denote the increasing understanding that IWT and ML are
linked. As this trend continues, greater cooperation between EAs and FIUs should be
expected.
148. Cooperation may exist between EAs and other governmental agencies, including
FIUs. Mechanisms of information sharing may be included in specific legislation,
developed through MoUs, or other formal or informal channels. There are examples
of LEAs requesting information from EAs regarding the identification or origin of a
species.
149. EAs also post liaison officers at different LEAs to facilitate cooperation and
information sharing. In Thailand, the Department of National Parks has offices at
most major border checkpoints with Thai Customs to facilitate investigations into the
IWT and cooperation with Thai Customs. Moreover, in Canada, EA officers are posted
at the INTERPOL National Central Bureau to enable information exchange regarding
international crimes such as the illegal wildlife trade.
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55
150. Several jurisdictions also mentioned that there are national working groups or inter-
ministerial committees established to facilitate cooperation between EAs, LEAs and
other relevant government agencies such as prosecution offices. Questionnaire
respondents also described how these committees or groups have regular meetings
to share information and coordinate the priorities and activities of their respective
agencies regarding combatting wildlife crime.
Law Enforcement Agencies and Customs
151. Local, federal, and international LEAs and customs provide the legal enforcement
necessary to deter wildlife traffickers. They conduct investigations, compile
evidence, and locate perpetrators to prevent and combat wildlife crime. LEAs are the
primary focal point for obtaining information, including financial data, on the illegal
wildlife trade.
152. Presently, the coordination between FIUs and LEAs varies amongst jurisdictions
with regards to wildlife crime. In jurisdictions where wildlife crime is considered a
higher ML/TF risk, cooperation between LEAs and FIUs on wildlife crime is more
common. Out of the FIUs that indicated a high to medium ML/TF risk rating to
environmental or wildlife crime in the ECOFEL questionnaire, 77% of them have
cooperated with LEAs regarding wildlife crime. In comparison, 17% of FIUs who
indicated a low to unknown ML/TF risk for environmental or wildlife crime, have
cooperated with LEAs.
153. Customs agencies can be critical partners for FIUs in the fight against IWT. As
customs agencies monitor and regulate the international importation and
exportation of goods, they may be the best-suited stakeholder to intercept illegal
wildlife shipments. Customs agencies are in an excellent position to share vital
information such, as bills of lading, shipping routes, shipping payment methods, and
nationality of exporters/importers.
SEPRONA and Financial Investigations
The Nature Protection Service (in Spanish: Servicio de Protección de la Naturaleza,
SEPRONA) is Spain’s nature conservation and management authority. All SEPRONA
analysts have financial investigation capabilities due to the high value of utilising
AML/CFT frameworks. The agency also cooperates closely with the country’s FIU,
SEPBLAC, by sharing information on wildlife crime suspects. Under such cooperation,
SEPRONA has been able to conduct successful financial investigations of wildlife
crime.
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154. FIUs can use the seizure data provided by their Customs partners to analyse the
financial flows linked to the illegal wildlife shipment(s). For example, Thai Customs
closely cooperates with AMLO on wildlife trafficking cases. Thai Customs gathers
information on wildlife seizures which include concealment methods, the value of
products seized, suspect profiles, location of seizures and trade patterns. This
partnership has been valuable for the investigation of wildlife trafficking within
Thailand.
Reporting Entities
155. This report has focused on cooperation between governmental and non-
governmental organisations. The role of the private sector and reporting entities has
not yet been thoroughly explored in this phase of the FIWFC project. However,
reporting entities are vital for financial investigations. The primary input for FIUs'
analysis is STRs from reporting entities. As is the case with other predicate offences,
Cooperation Mechanism between Gibraltar’s FIU and EA
Gibraltar FIU (GFIU) signed a memorandum of understanding (MoU) with the
Department of the Environment in May 2020 which formalised the relationship
between the two units. The MoU seeks to strengthen the international efforts against
IWT and the financing of such trade. It establishes agreed protocols whereby
information can be exchanged within the parameters of Gibraltar’s legislative
framework and be able to receive scientific support or advice. This MoU was
considered when the GFIU responded to ECOFEL’s questionnaire. Gibraltar included
IWT in their latest NRA published in August 2020.
Source: GFIU
Interagency Cooperation with Tax Authority
Zambia’s Financial Intelligence Centre was able to analyse reports regarding a case of
illegal issuance of safari hunting licenses to an associate of a Politically Exposed
Person in Zambia. Their investigation led them to wire transfers to an offshore
account. Through an MoU, the FIC requested the assistance of the Zambian Tax
authorities who were able to request information from the country where the offshore
account was located. After analysis was completed, the intelligence report was
successfully disseminated to the law enforcement agencies.
Source: Zambia FIC
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there is a risk that reporting entities may file defensive STRs without completing a
real risk analysis.
156. Reporting entities should be aware of their obligations to report suspected cases
involving the illicit financial flows of wildlife crime. FIUs can communicate with
reporting entities regarding wildlife crime indicators and reporting obligations
24
, as
well as seek their input and feedback. As found in the ECOFEL's questionnaires, some
FIUs include in their regular training for reporting entities typologies relating to
wildlife crime.
157. Highlighted below are some short examples of how FIUs are currently engaging with
reporting entities about wildlife and forestry crime:
158. In collaboration with Fintel Alliance and the Department of Agriculture, Water, and
the Environment, the Australian Transaction Reports and Analysis Centre
(AUSTRAC) recently disseminated a paper to its private sector partners with
keywords and values relating to reptile trafficking. Similarly, AUSTRAC recently
published a public financial crime guide to increase awareness of how IWT operates
and how the financial sector is exploited to enable such activities.
25
• Indonesia’s Pusat Pelaporan dan Analisis Transaksi Keuangan (PPATK) conducts
training on illegal wildlife trade for financial service providers at the Indonesian
Financial Intelligence Unit. They present case studies related to IWT so that
financial service providers can recognise the high-risk parameters of IWT and its
financial flows. PPATK also conducts an on-site examination of financial
institutions where they can transfer knowledge on wildlife crime and encourage
proactive reporting for suspected wildlife crime cases.
• Kenya’s Financial Reporting Centre has developed guidelines for reporting
entities to detect matters relating to predicate offences, including wildlife crime.
The FRC also conducts training for reporting entities on emerging trends and
typologies of illegal wildlife trade.
• Papua New Guinea’s Financial Analysis and Supervison Unit (FASU) presented the
findings of their National Risk Assessment to reporting entities to ensure they
24
Establishing general indicators and red flags is challenging due to the various nuances of wildlife crime.
ECOFEL plans to develop a tool to assist FIUs in identifying indicators and red flags related to IWT.
Presently, the FATF has created a broad list of indicators which can be found in Annex C of this report.
25
Please access Stopping the illegal trafficking of Australian wildlife: Financial Crime Guide at
https://www.austrac.gov.au/sites/default/files/2020-10/AUSTRAC_IWT%20Guide_October%202020.pdf
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understand high-risk sectors (e.g. forestry crime) and their responsibilities in
conducting enhanced Customer Due Diligence measures in those cases.
Non-Governmental Organisations
159. Although STRs are a trigger for financial investigations into IWT, information
concerning wildlife crime may also come from external organisations. NGOs working
in the field of combatting wildlife crime may collect relevant data for conducting
financial investigations. These NGOs have detailed knowledge about the typologies
and patterns relating to species-specific wildlife trade.
160. The expertise of certain NGOs can be valuable for wildlife crime related training
courses, technological tools, and investigative support for relevant authorities,
including FIUs. International NGOs can facilitate dialogue and discussion between
jurisdictions and stakeholders which are not typically included in financial
investigations on wildlife crime. One way for FIUs to possibly identify the illicit
financial flows of wildlife crime is to interact with NGOs.
ACAMS and WWF Certification Process for Private Sector
The Association of Certified Anti-Money Laundering Specialists (ACAMS) launched a
joint initiative with WWF to create a certification programme for compliance,
regulators, and law enforcement agencies working in the anti-money laundering field.
The certificate will be ready by Autumn 2020 and will provide red flags and typologies
that the private and public sector can use to target wildlife related money laundering
in a precise and consistent manner (Davidson, 2020). The learning objectives of the
certification process include “exploring and supporting illegal wildlife trade legal and
regulatory reform, recognition of illicit wildlife and the financial footprints,
identifying and sharing of red flags and typologies, and sharing and strengthening
information gateways” (Davidson, 2020, para. 6).
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161. While there are benefits to utilising NGO expertise, the ECOFEL found that a limited
amount of FIUs have previously interacted with NGOs regarding wildlife crime.
During the ECOFEL’s workshop in Thailand, FIU representatives mentioned how it
was difficult for FIUs to share feedback with NGOs or request information from NGOs.
The lack of cooperation may stem from the confidentiality regulations of FIUs,
evidentiary challenges, and the need to conduct proper due diligence regarding
potential non-governmental partners.
162. FIUs, LEAs, and NGOs successfully cooperate on the issue of wildlife crime despite
the challenges. For example, the Freeland Foundation works with FIUs in the Asia-
Pacific region to share general information about wildlife and timber smuggling
networks. Eco-Activists for Governance and Law Enforcement (EAGLE) is another
NGO that actively works with LEAs in West African countries to conduct
investigations and seizures of the illegal wildlife trade. They coordinate with LEAs to
plan operations where undercover EAGLE investigators infiltrate wildlife trafficking
networks to find evidence against the perpetrators. EAGLE's investigation
contributed to tracing the illicit financial flows of a wildlife trafficking network.
CENTIF-CI Involvement in Wildlife Crime Investigation
In 2018, the Transnational Crime Unit (UCT) was alerted by the NGO, Eco Activists for
Governance and Law Enforcement (EAGLE), to a wildlife trafficking network. UCT was
also aided by EAGLE in conducting seizures and arrests of members of the network.
Authorities were able to seize thousands of kilograms of worked ivory, elephant tusks,
pangolin scales and leopard teeth and claws. As a result of these seizures, the FIU,
Cellule Nationale de Traitement des Informations Financières- Côte d'Ivoire (CENTIF-CI)
started an investigation into the local and foreign suspects implicated in this wildlife
trafficking case.
CENTIF-CI began their investigation by identifying the suspects using their own
internal databases and requesting information from other national and foreign
agencies. In the second stage of analysis, CENTIF-CI identified the origin of the funds
and any possible connections to underlying offences. They discovered that assets
came from both Côte d’Ivoire and surrounding West African countries. The illegal
wildlife products were destined for the international market. CENTIF-CI was able to
ascertain these international financial flows by requesting information from FIUs
from West Africa and Southeast Asian countries. In this case, the cooperation between
the FIU, various LEAs, EAGLE, and foreign FIUs led to a successful financial
investigation.
Source : CENTIF-CI
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Challenges to Interagency Cooperation
163. When conducting financial investigations into wildlife crime, some of the following
challenges may arise:
• Limited human, financial, and/or technical resources;
• Differences in issue prioritisation amongst agencies;
• Low level of commitment to address wildlife crime;
• Insufficient understanding of wildlife crime;
• Lack of training on how to conduct financial investigations into wildlife crime;
• Few formalised cooperation mechanisms for information exchange on wildlife
crime;
• Legal barriers that prevent information exchange between agencies and;
• Time delays in sharing information between agencies.
164. Other challenges noted by FIUs that prevent multi-agency cooperation were the
involvement of Politically Exposed Persons and corruption in the illegal wildlife
trade.
165. As many FIUs have not dealt with the issue of wildlife crime, some respondents to
the ECOFEL’s questionnaire were unable to identify challenges to effective inter-
agency cooperation.
International Cooperation
FIU Cooperation
166. FIUs use established methods of communication between foreign FIUs such as the
Egmont Secure Web,
26
FIU.Net,
27
or through MoUs to exchange information.
However, there is limited international exchange of information relating to wildlife
crime. The ECOFEL found that only 12 FIUs have shared information with foreign
counterparts regarding wildlife crime.
28
26
19 jurisdictions noted the use of ESW for exchanging information with a foreign FIU
27
FIU.Net is a secure computer network established by EUROPOL to facilitate information sharing between
FIUs within the European Union
28
This figure only includes FIUs that were named during ECOFEL workshops or in the ECOFEL
questionnaires and does not cover the entire extent of FIU exchanges in regard to wildlife crime.
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167. As mentioned in the case of CENTIF-CI (see Box 16), there was successful
international cooperation which included information sharing between various FIUs
from West Africa and Southeast Asia. These information exchanges can help trace
the global financial flows of wildlife trafficking networks.
Information Sharing Networks
168. There are established global information-sharing networks that LEAs and EAs use to
exchange information on IWT.
• INTERPOL’s I-24/7 database is a global criminal database that can be accessed to
find, request and store information relating to crimes, including wildlife crime.
FIUs can access this database through their jurisdiction's National Central Bureau.
• Trade in Wildlife Information eXchange (TWIX) databases are regional, online
tools that allow the sharing of seizure data of the IWT amongst LEAs, EAs, and
key international organisations. There are three different TWIX databases for the
three regions: European Union, Southern Africa, and Central Africa. FIUs may
access the two databases for African countries. FIUs could potentially take
Analyst Exchange Program on Wildlife Smuggling
“In 2015, AUSTRAC and its Indonesian counterpart [PPATK] (Indonesian Financial
Transaction Reports and Analysis Center) undertook an analyst exchange program
focused on wildlife smuggling. The program brought analysts from both agencies
together to share and jointly analyse financial intelligence relating to Indonesian
criminal syndicates illegally exporting wildlife (principally reptiles) from Indonesia to
numerous countries including Australia. The final intelligence product was given to
law enforcement agencies in both countries to support investigations.”
"In addition to the Analyst Exchange Program in 2015, PPATK and AUSTRAC also
conducted joint analysis related to IWT along with Thailand AMLO into an
international illegal wildlife trade syndicate. This syndicate was present in 32
countries and dealt in species such as snakes, reptiles, turtles, and others exotic
animals. The modus operandi was smuggling through the airport, which was detected
in source country area, transit country or destination country. The mapping of flow of
funds was conducted by PPATK. This information provided intelligence guidance for
the prosecutor that handled the case for surveillance and helped to arrest the suspect."
Source: AUSTRAC and PPATK
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advantage of access to these databases to gain a detailed understanding of the
commonly seized illegal wildlife products and trade routes in their jurisdiction.
Initiatives
169. The Financial Action Task Force, as the standard-setting body in AML/CFT matters,
plays a crucial role in bringing attention to new trends and emerging risks of ML/TF
such as IWT. The FATF has been a key partner and supporter of the work of ECOFEL.
They have released a report, "Money Laundering and the Illegal Wildlife Trade"
29
that
guides countries on measures to combat the illicit financial flows linked to the illegal
wildlife trade. The FATF has also hosted a public webinar
30
with various AML/CFT and
IWT experts to outline practical strategies that governments and the private sector
can adopt to tackle money laundering linked to illegal wildlife trade.
170. International organisations, such as INTERPOL and UNODC, provide various
training programs to LEAs, EAs, and FIUs on wildlife crime. INTERPOL is active in
working with FIUs to combat the illicit financial flows of wildlife and forestry crime.
For example, Papua New Guinea’s FIU, FASU, has collaborated with INTERPOL to
analyse payments relating to logging companies suspected of financial crimes.
171. The International Consortium on Combating Wildlife Crime (ICCWC) is a joint effort
by the CITES Secretariat, INTERPOL, UNODC, World Bank and World Customs
Organization to bring coordinated support to national law enforcement agencies to
help fight wildlife crime. Each of these organisations can pool their technical and
programming expertise to target the various challenges posed by the illegal wildlife
trade (CITES Secretariat, 2020). ICCWC has released multiple tools that can assist and
develop law enforcement agencies' capacity to fight wildlife crime. This initiative also
recognises the importance of conducting financial investigations into wildlife crime.
Several of their partners have begun projects and training programs to develop
countries' capacities to target the illicit financial flows linked to wildlife crime.
172. In 2014, United for Wildlife (UfW) was established to support innovative ways to
reduce wildlife crime and prevent the illegal wildlife trade. UfW has two taskforces;
the Financial Taskforce and the Transport Taskforce, which are comprised of various
private sector institutions, NGOs, and international organisation partners. The
Financial Taskforce seeks to involve the financial sector in the fight against the IWT.
Similarly, the Transport Taskforce seeks to involve transportation companies, such
29
This report may be accessed here: http://www.fatf-gafi.org/media/fatf/documents/Money-laundering-
and-illegal-wildlife-trade.pdf
30
The recorded webinar may be accessed here: https://www.fatf-
gafi.org/publications/methodsandtrends/documents/iwt-webinar-2020.html
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as airlines and shipping companies, in identifying and developing relevant solutions
to stop the transport of illegal wildlife products.
173. There is an understanding that illicit financial flows linked to wildlife crime are
transferred internationally using the financial and banking industry. UfW Financial
Taskforce members have access to the Information Sharing System (ISS)
31
, which
allows the sharing of intelligence, red flags, typologies, and trends.
Challenges to International Cooperation
174. There have been some examples of successful cooperation between FIUs to trace the
illicit financial flows of wildlife crime. There are also many ways in which the overall
level of international cooperation in combatting the financial flows linked to wildlife
crime can improve. The following are some of the challenges that may be
encountered:
• Lack of MoUs with foreign counterparts.
o Some FIUs noted that their legislation only allows them to share
information with counterparts where an MoU exists.
• Different legislations between jurisdictions
o Some jurisdictions have different legal requirements to trigger a financial
investigation into wildlife crime.
o Some jurisdictions have different information sharing laws that may prevent
an exchange of information regarding wildlife crime.
• Different levels of prioritisation of risk
o Some FIUs do not prioritise financial investigations into wildlife crime and
may not have any information to share with another FIU.
• Foreign FIU is not a part of the Egmont Group
o Some FIUs mentioned that they are unable to share information outside of
the Egmont Secure Web because there is no secure network to request and
share information.
31
The Basel Institute on Governance is an implementing partner of this system.
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Recommended Practices
175. The following recommended practices have been identified for FIUs for effective
financial investigations into wildlife crime.
• Properly assessing the risks of wildlife crime in the jurisdiction’s National Risk
Assessment;
o Considering wildlife crime in the assessment framework;
o Including EAs and relevant LEAs in risk assessment procedures;
o Identifying the jurisdiction’s location along the supply chain to understand
the risks and the financial flows of wildlife crime;
• Filtering and analysing STRs based on strategic assessments of wildlife crime
within the jurisdiction;
• Applying the techniques that FIUs currently use when analysing other predicate
offences where cash is the predominant payment method when supporting
wildlife crime investigations;
• Enhancing inter-agency cooperation and information exchange;
o Using methods of inter-agency communication that have been used
successfully for other types of crime;
o Creating wildlife crime taskforces and working groups between government
agencies and relevant partners to facilitate trust and information sharing;
o Using liaison officers to create efficient channels of communication and
cooperation between agencies;
o Providing training sessions to EAs or LEAs on the AML/CFT regime and how
financial investigations can complement the traditional investigative
methods used for wildlife crime;
• Considering new partnerships with NGOs:
o Creating mechanisms for NGOs to submit relevant information about
wildlife crimes to the FIU;
o Involving NGOs in working groups and committees designed to combat
wildlife crime, while ensuring the confidentiality of sensitive data;
o Relying on established networks between NGOs and LEAs;
• Providing guidance, feedback, and training to reporting entities regarding the
financial flows of wildlife crime; and
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• Considering a ‘follow the money’ approach to complement a ‘follow the suspect’
approach.
Conclusion
176. This report provides FIUs and relevant stakeholders with a comprehensive overview
of financial investigations into wildlife crime. It contains specific examples of how
FIUs can start to effectively conduct analysis and develop strong partnerships with
other agencies and organisations to help fight wildlife crime. FIUs can adopt the
recommended practices outlined above to design effective policy responses to
combat wildlife crime.
177. FIUs must increase their focus on wildlife crime. At the forefront of many
jurisdictions’ AML/CFT efforts, FIUs play a vital role in supporting financial
investigations into wildlife crime. However, there are few FIUs that have supported
such investigations, primarily due to lack of knowledge of wildlife crime and
associated risks. They may be able to provide analytical support and financial
intelligence to the relevant authorities working to fight wildlife crime.
178. To conduct efficient and successful investigations into the illicit financial flows
linked to wildlife crime, FIUs should develop effective partnerships with other
governmental agencies such as EAs and LEAs. FIUs can enhance investigative efforts
of these agencies through analysing the financial flows of wildlife crime. As wildlife
Creating an Analytical Unit within the FIU
In 2020, the Nigerian Financial Intelligence Unit (NFIU) created the Natural
Environment and Wild Life Trade Crimes Analysis Unit (NEWTCU) to combat the
financial aspect of IWT (Nigerian Financial Intelligence Unit Act, Section 10(1), and
Money Laundering Prohibition Act 2011 (as amended) Section 15(6)). This unit was
developed after the understanding within the Nigerian FIU that their jurisdiction is a
significant source and transit country for the illegal wildlife trade, which is worth
millions of dollars. The NFIU also recognised the importance in combatting IWT as a
predicate offence for money laundering, terrorism financing and arms proliferation.
The unit is tasked with analysing STRs and CTRs to generate intelligence that will be
disseminated to LEAs. The NEWTCU will also partner with foreign FIUs to develop
typologies and indicators that will be used to guide advisories.
Source: NFIU
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66
crime is highly nuanced, FIUs need to connect with national agencies and other
organisations with local expertise on this issue to develop specific responses and
strategies for combatting the illicit financial flows linked to wildlife crime.
179. International organisations and NGOs active in the fight against wildlife crime could
also be good partners for FIUs. These organisations can aid in providing contextual
information, technical knowledge, and capacity-building support.
180. There is an opportunity to conduct further exploration into the illicit financial flows
of environmental crime. Wildlife crime is just one form of environmental crime.
There are also additional activities that can be categorised as environmental crimes,
such as illegal fishing, illegal logging, illegal mining, and illegal waste management.
These illegal industries have massive consequences of revenue loss and ecological
degradation for jurisdictions. FIUs may be able to provide valuable assistance in
conducting financial investigations into these other forms of environmental crime.
181. Tackling environmental crime is becoming a priority for national governments and
organisations around the world. As a subset of environmental crime, wildlife offences
are transnational in nature, enabled by corruption and foster financial crimes.
Therefore, they should be understood as a money laundering risk in all jurisdictions.
Financial investigations into wildlife crime are crucial to target the illicit financial
flows and to start dismantling wildlife trafficking networks that facilitate this
lucrative industry.
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Annexes
Annex A: List of Participating Agencies
Country Agencies
Country
Agency
Albania
General Directorate for the Prevention of Money Laundering (GDPML)
Algeria
Financial Intelligence Processing Unit (CTRF)
Argentina
Financial Information Unit Argentina (UIF)
Australia
The Australian Transaction Reports and Analysis Centre (AUSTRAC)
Azerbaijan
Financial Monitoring Service (FMS)
Bangladesh
Department of Environment under Ministry of Environment, Forest and
Climate Change
Bangladesh
Bangladesh Financial Intelligence Unit (BFIU)
Belarus
The Department of Financial Monitoring of the Committee of State
Control
Belarus
State Customs Committee
Belarus
Ministry of Natural Resources and Environmental Protection
Belarus
The Department of Financial Monitoring of the State Control Committee
of the Republic of Belarus (DFM)
Belize
Forest Department
Belize
Financial Intelligence Unit Belize (FIU- Belize)
Bhutan
Financial Intelligence Department (FID)
Bosnia and
Herzegovina
Financial Intelligence Department (FID)
Botswana
Financial Intelligence Agency (FIA)
Brazil
Brazilian Institute for the Environment and Renewable Natural
Resources (IBAMA)
Brazil
Council for Financial Activities Control (COAF)
Burkina Faso
Direction de la Faune et des Ressources Cynégétiques
Burkina Faso
Cellule nationale de traitement des informations financières (CENTIF-
BF)
Cambodia
Cambodia Financial Intelligence Unit (CAFIU)
Canada
Environment and Climate Change Canada, Enforcement Branch
Canada
Financial Transactions and Reports Analysis Centre of Canada
(FINTRAC-CANAFE)
Cape Verde
Cape Verde UIF
Costa Rica
Sistema Nacional de Áreas de Conservación, Ministerio de Ambiente y
Energía
Costa Rica
Unidad de Inteligencia Financiera
Costa Rica
Ministerio Público
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Cote d'Ivoire
Ministère des Eaux et Forêts/Direction de la Police Forestière de l’Eau
Cote d'Ivoire
Cellule nationale de traitement des informations financières (CENTIF-
CI)
Croatia
Border Police Directorate
Croatia
Sector for Nature Protection Supervision
Croatia
Croatian Customs Administration
Denmark
Danish Customs Agency, Danish Analysis Unit
Denmark
The Money Laundering Secretariat (FIU Denmark)
Finland
Financial Intelligence Unit (RAP)
France
Traitement du renseignement et action contre les circuits financiers
clandestins (TRACFIN)
Gabon
Parquet de la Republique
Gabon
Agence National d'Investigation Financère (ANIF-Gabon)
Gibraltar
Department of the Environment, Sustainability, Climate Change and
Heritage, HM Government of Gibraltar
Gibraltar
Gibraltar Financial Intelligence Unit (GFIU)
Guatemala
División de Protección a la Naturaleza (DIPRONA), de la Policía Nacional
Civil (PNC) del país
Guatemala
Special Verification Indendancy (IVE)
Guinée
Ministère de l'Environnement des Eaux et Forêts
Guinée
Cellule nationale de traitement des informations financières (CENTIF-
Guinée)
Hong Kong SAR
Joint Financial Intelligence Unit (JFIU)
Hungary
Hungarian Financial Intelligence Unit (HFIU)
Iceland
Environment Agency of Iceland (Umhverfisstofnun)
Iceland
Financial Intelligence Unit- Iceland (FIU-ICE)
Iceland
The Directorate of Internal Revenue and Customs (DIR)
India
Wildlife Crime Control Bureau
Indonesia
Indonesian Financial Transaction Reports and Analysis Centre (PPATK)
Ireland
Financial Intelligence Unit- Ireland
Japan
Japan Financial Intelligence Centre (JAFIC)
Jersey
States of Jersey Police and Customs Joint Financial Crime Unit (FCU-
Jersey)
Kenya
Financial Reporting Centre (FRC)
Laos
Ministry of Agriculture and Forestry
Laos
Anti-Money Laundering Intelligence Office (AMLIO)
Lebanon
Special Investigation Commission (SIC)
Madagascar
Alliance Voahary Gasy (AVG)
Madagascar
Ministère de l’Environnement et du Développement Durable
Madagascar
SAMIFIN
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Malaysia
Department of Wildlife and National Park
Malaysia
Financial Intelligence Unit-Malaysia (UPWBNM)
Mali
Direction Nationale des Eaux et forêts
Mali
Cellule nationale de traitement des informations financières (CENTIF-
Mali)
Mexico
Unidad de Inteligencia Financiera
Mongolia
Mongolia Financial Intelligence Unit
Netherlands
Ministry of Agriculture, Nature and Food Quality
Netherlands
Netherlands Food and Consumer Product Safety Authority
Netherlands
Public Prosecutors Office for Serious Fraud and Environmental Crime
Netherlands
Police
Netherlands
Financial Intelligence Unit- Netherlands (FIU-NL)
Niger
Direction de la faune, de la chasse, des parcs et reserves
Niger
Cellule nationale de traitement des informations financières (CENTIF-
Niger)
Nigeria
Nigerian Financial Intelligence Unit (NFIU)
Norway
ØKOKRIM - The Norwegian National Authority for Investigation and
Prosecution of Economic and Environmental Crime
Panama
Ministerio Público
Panama
Financial Analysis Unit- Panama (UAF- Panama)
Papua New
Guinea
Financial Analysis and Supervision Unit (FASU)
Peru
Financial Intelligence Unit of Peru (FIU-Peru)
Poland
CITES Management Authority of Poland, Ministry of the environment
République
Centrafricaine
Agence Nationale d’Investigation Financière - République
Centrafricaine
République du
Congo
Agence National d'Investigation Financère (ANIF-Congo)
Saint Vincent and
the Grenadines
Ministry of Agriculture, Forestry, Fisheries, Rural Transformation,
Industry and Labour; Forestry Division
Saint Vincent and
the Grenadines
Financial Intelligence Unit St. Vincent and the Grenadines (FIU-SVG)
Sénégal
Cellule nationale de traitement des informations financières (CENTIF-
Sénégal)
Slovakia
Financial Intelligence Unit of the National Criminal Agency (FSJ)
Slovenia
Ministry of Environment and Spatial Planning
Slovenia
Office for Money Laundering Prevention (OMLP)
South Africa
Financial Intelligence Centre (FIC)
South Africa
Directorate for Priority Crimes Investigation (HAWKS)
Spain
Executive Service of the Commission for the Prevention of Money
Laundering and Monetary Offences (SEPBLAC)
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St Kitts and Nevis
Financial Intelligence Unit St. Kitts and Nevis (FIU-SKN)
Sweden
Swedish Environmental Protection Agency
Sweden
National Financial Intelligence Service
Tchad
Agence National d'Investigation Financère du Tchad (ANIF-Tchad)
Thailand
Anti-Money Laundering Office (AMLO)
Thailand
The Department of National Park, Wildlife and Plant Conservation
Thailand
Thai Customs Department
Togo
Ministère de l’environnement, du développement durable et de la
protection de la nature (MEDDPN) / Direction des ressources forestières
(DRF)
Ukraine
The State Financial Monitoring Service of Ukraine (SFMS)
United Kingdom
Department for Environment, Food and Rural Affairs
United Kingdom
National Wildlife Crime Unit
Vietnam
Vietnam Financial Intelligence Unit
Yemen
Environment Protection Authority
Zambia
Anti-Corruption Commission
Zambia
Financial Intelligence Centre (FIC)
Zambia
Drug Enforcement Commission
Zambia
Department of National Parks and Wildlife
Other Organisations
Organisation Name
CITES Secretariat
World Wildlife Fund
Financial Action Task Force
TRAFFIC
Freeland Foundation
UNODC
INTERPOL
US Aid Wildlife Policy
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Annex B: FATF 40 Recommendations
1. The FATF 40 Recommendations are recognised as the global AML/CFT standards. As
stated in the FATF's 2020 report, "the standards provide a useful framework for
jurisdictions to address [threats posed by the illegal wildlife trade] by strengthening
their national laws, policies, and co-operation at the domestic and international
level" (p. 5). Any measure implemented to comply with the Recommendations should
be assessed and evaluated following the 2012 FATF methodology.
2. This annex outlines the relevancy of wildlife crime within the global AML/CFT
standards and highlights opportunities to address wildlife crime per the FATF
Recommendations.
32
The ECOFEL does not seek to provide any guidance in
connection with the FATF Recommendations, but rather to provide useful ideas for
FIUs and relevant stakeholders. This section will cover a select number of
Recommendations.
R.1 Assessing Risk and Applying a Risk-Based Approach
3. Recommendation 1 outlines that jurisdictions should identify, assess, and
understand the ML/TF risks within their jurisdictions and take a risk-based approach
to mitigate those risks. According to the FATF, "depending on the threat profile, this
may require a country to consider their ML risks emanating from IWT, whether the
underlying wildlife crime takes place domestically or in a third country" (FATF, 2020
p. 25).
4. As a result of the limited analysis of environmental offences as financial issues, many
jurisdictions may not consider wildlife crime to be a significant ML risk. However,
wildlife crime is a global issue, and every region may be implicated in the supply chain
as either a source, transit, or destination point for illegal wildlife products.
Understanding the jurisdiction’s environmental landscape and location on the illegal
wildlife trade supply chain is necessary for adequately evaluating and addressing the
risk that wildlife crime poses.
R.2 National Cooperation and Coordination
5. Recommendation 2 emphasises that countries should have effective mechanisms in
place that facilitate cooperation, coordination, and information exchange between
relevant authorities on AML/CFT matters. Cooperation mechanisms can take on
various forms depending on the specific case, the actors involved, and the data
protection and privacy rules that the jurisdiction has in place.
32
For more information on the relevancy of the FATF Recommendations for conducting financial
investigations into the illegal wildlife trade, please reach out to the FATF for additional guidance.
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6. Environmental agencies may seem an unlikely partner for FIUs, yet for financial
investigations into wildlife crime, they have valuable background information and
technical knowledge. Designing multi-agency networks with FIUs, LEAs,
environmental agencies, and other relevant stakeholders is necessary to prevent the
duplication of efforts and avoid increasing competition between agencies operating
in similar domains.
R.3 Money Laundering Offence
7. According to Recommendation 3, countries should apply the charge of money
laundering to all serious crimes and include the broadest set of predicate offences.
According to the Palermo Convention (2012), a serious crime is defined as “conduct
constituting an offence punishable by a maximum deprivation of liberty of at least
four years or a more serious penalty” (p. 2). As wildlife crime has significant social,
economic, political, and environmental consequences, countries should recognise
wildlife crime in line with ML/TF risks. The current lack of recognition of wildlife
crime as a predicate offence may limit the involvement of financial authorities.
R.4 Confiscation and Provisional Measures
8. Recommendation 4 specifies that countries should enable competent authorities to
freeze and confiscate illicit proceeds and/or property connected to ML/TF and the
associated predicate offences. Confiscating the profits made from wildlife crime can
stifle criminal operations by reducing the rewards of crime (FATF, 2012). Confiscation
may also prevent the financial flows of wildlife crime from being laundered or
reinvested to facilitate other forms of crime.
9. Most commonly, authorities confiscate the illegal wildlife species or products during
seizures. There have been fewer successful cases of financial authorities tracing and
confiscating the proceeds and assets of more extensive wildlife trafficking networks.
R. 9-21 Preventative measures
10. Recommendations 9 to 21 are concerned with countries implementing various
measures applicable to reporting entities to prevent ML/TF.
11. As FIUs may provide valuable guidance to reporting entities, they should
communicate with relevant stakeholders to develop and communicate the red flags
and indicators of wildlife crime.
R. 36-40 International Cooperation
12. Recommendations 36 to 40 cover international cooperation mechanisms such as
governing legal instruments, forms of mutual legal assistance, and other tools. Given
that wildlife crime is transnational in many cases, cooperation between FIUs in
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different jurisdictions is imperative for successful financial investigations and
prosecutions of wildlife traffickers. FIUs should exchange information with foreign
counterparts on wildlife-related cases using established methods of FIU to FIU
channels such as the Egmont Secure Web. FIUs should also be able to cooperate with
other authorities, especially with environmental agencies, to establish "a prompt and
constructive exchange of information" (FATF, 2012, p. 110).
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Annex C: FATF IWT Indicators for Financial Institutions
The following indicators are sourced directly from pages 60-62 of the FATF’s 2020 Report
entitled Money Laundering and the Illegal Wildlife Trade
Preface
The below risk indicators are intended to be used by financial institutions to assist them
in identifying potential suspicious transactions and behaviour patterns that could be
indicative of ML linked to the illegal wildlife trade (IWT). The risk indicators identified
below have been developed based on country experiences in investigations and cases,
open source information as well as information provided by the United for Wildlife (UfW)
Financial Taskforce and the Basel Institute.
These intelligence-led risk indicators highlight potentially actionable patterns in client
profiles (individuals and corporates), transactions and client account activity, but should
not be considered in isolation. A risk indicator demonstrates or suggests the likelihood
of the occurrence of suspicious activity. However, one risk indicator alone, or without
additional information about the client or transaction, is not likely to be sufficient to
suggest illicit activity. Financial institutions should be careful when implementing risk
indicators into their transaction monitoring systems, as the introduction of stand-alone,
generic indicators could lead to the generation of large volumes of alerts that may end-
up being false positives. Importantly, these risk indicators should be contextualised with
information broader information on client profiles, and information obtained from the
public sector.
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Transactions and Client Account Activity
• Large cash deposit by government officials working in wildlife protection agencies,
border control or customs and revenue officials.
• Large cash or other deposits, wire transfers, multiple cash deposits and
withdrawals, and/or unexplained wealth from government officials working in
forestry agencies, wildlife management authorities, zoo and wildlife park
employees, or CITES Management Authorities (CMAs).
• Large cash or other deposits, multiple cash deposits and withdrawals, and/or
unexplained wealth from government officials from environment or other
ministries who have specific management or oversight authority of government
stockpiles of seized ivory, rhino horn, timber, or other illegal wildlife products.
• Shipments of legal wildlife (fauna and flora) with anomalous, incomplete, or
otherwise suspicious CITES certificates.
• Transactions using names of ingredients or products in the traditional medical
trade that refer to CITIES species.
• Illogical or anomalous loans between trading or import/export companies in key
IWT source or transit countries.
Box continues on next page
Client Profiles (Individuals and Corporations)
• Involvement of international trade companies, including import-export, freight
forwarding, customs clearance, logistics, or similar types of companies operating
in the following commodities long high-risk corridors or ports82 for IWT supply
and demand: raw or squared wooden logs, plastic waste or pellets, frozen food, fish
maws, various kinds of beans, stone or quartz blocks.
• Use of common containers, consignees, transporter, clearing agents, or exporters
as seen in other cases believed to involve IWT.
• Activity involving PEPs and wealthy businessmen/women, particularly those with
environmental, game, or forestry oversight or environmental or wildlife related
businesses
• Involvement of legal wildlife-related entities such as private zoos, breeders,
(exotic) pet stores, safari companies, pharmaceutical companies making medicines
containing wildlife and wildlife collectors or reserves.
• Individual or beneficial owner(s) of a corporate domiciled in jurisdiction that is a
prominent transit or demand country for illegal wildlife
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Transactions and Client Account Activity Continued
• Switched bills of lading by traders previously implicated in criminal activity
involving wildlife trafficking or trade fraud investigations or prosecutions.
• Transactions having discrepancies between the description or value, of the
commodity in customs and shipping documents and invoice, relative to the actual
goods shipped or quoted price or the actual value in payments made.
• Illogical or anomalous purchases, payments, or other transactions related to gold
trading from business accounts of clients. Payments for wildlife shipping are often
masked as payment for gold or to gold trading business.
• Escrow-type transactions from/to accounts and companies with same beneficial
owner in particular for payment of cross-border and transcontinental shipments.
• Transactions from known traffickers to individuals who then pay for couriers or
packages via the post.
• Transactions for hired vehicles and domestic accommodation from known members
of a trafficking syndicate who are not present in the country or region within a
country.
• Third-party wire transfers/cash deposits to, or withdrawals by, known wildlife
poachers and traffickers.
• Transaction references using specimen names or veiled speech.
• Transactions between licensed pet shop suppliers/breeders and known wildlife
poachers and traffickers.
• Transactions to licenced pet shop suppliers/breeders that originate from overseas,
and/or incommensurate with stated business activities.
• Large transactions to licenced pet shop suppliers/breeders where there is significant
discrepancies between the animal/product ordered and the value of the good.
• International wire transfers from known wildlife traffickers to a relative’s accounts
as tuition, allowance, or family support payments.
• Large dollar wire transfers between wildlife farms and firms operating in
inconsistent lines of business. Particular attention should be given to payments with
firms that produce goods which may be used as “cover loads” to hide illicit wildlife
products (e.g. manufacturers / traders of coffee, tea, beans, or used clothing).
• Payments between entities operating in disparate lines of business.
• Individuals or companies suspected of being involved, or linked to, IWT networks
using bank accounts and addresses located in different countries.
• Middleman transactions – large incoming payments followed by smaller outgoing
payments.
• Rental card transactions with two bookings close in time in neighbouring countries.
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Other
• Adverse media connected to wildlife or environmental crimes identified in open
and available sources on individuals and/or entities involved in reviewed financial
transactions.
• Airline passengers traveling on high-risk IWT routes on tickets paid for by a third
party or in cash.
• Payments from companies/owners from industries using IWT products (including
traditional medicine manufacturers, leather producers, auctioneers of wildlife
products, exotic food providers [including butchers, chefs, stall holders wildlife
markets and restaurants]) to known wildlife traders or their associates or other
entities above that have been identified as involved in IWT.
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UN General Assembly Resolution A/71/L.88 (2017)
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