Ending Illegal Wildlife Trade: Online Training Certificate Reading Materials

Ending Illegal
Wildlife Trade
Online Training Certificate
Reading Materials
September 2020
Supporting Partners:
ACAMS / WWF
Ending Illegal Wildlife Trade
ACAMS: Special Acknowledgments:

Angela Salter Dr. Marcus Pleyer,
President Financial Action Task Force
Lashvinder Kaur
& the FATF Team
Jérôme Beaumont,
Project Task Force: Executive Secretary, Egmont Group
Dr William Scott Grob, CAMS-FCI & CGSS David Fein,
ACAMS Chair of the United for Wildlife
Financial Taskforce
Brian Gonzales,
WWF Hong Kong Martin Wyard,
Head of AML/CTF capacity, HM Treasury
Chinali Patel,
UK SOCNet Illicit Finance lead Theresa Forbes,
Hong Kong Senior Policy Advisor, U.S. Dept of Treasury
Robert Campbell,
United for Wildlife
Authors:
Amanda Gore (Lead Author),
Centre for Global Advancement With Special Thanks To:
Dr. Patricia Raxter (Second Author), UK Foreign and Commonwealth Office
Basel Institute on Governance US Homeland Security
RUSI
Review & Technical Input: Environmental Investigation Agency (EIA)
Basel Institute on Governance Standard Chartered Bank
Juhani Grossman, Ant Financial
Timothy Wittig, Foreign Commonwealth and
Development Office
Manuel Medina
ADM Capital Foundation
Global Financial Integrity
Barclays
ACAMS / WWF
Ending Illegal Wildlife Trade
Global Contributors:
Justine Walker, Alexandra Reid,
ACAMS RUSI
Marco Tham, CAMS, Faith Bhaseen, CAMS,
ACAMS Standard Chartered Bank
Steve Oxman, CAMS, Zara Reid,
ACAMS Foreign Commonwealth and
Development Office
Todd Beck, CAMS,
ACAMS Akil Baldwin,
US Homeland Security
Sam Inglis,
ADM Capital Foundation Dr. David Olson,
WWF Hong Kong
Sophie Le Clue,
ADM Capital Foundation Dr. Eric Wikramanayake,
WWF-Hong Kong, Environmental
Heng Qin, Amber, CAMS,
Foundation Ltd. (EFL)
Ant Financial
Margaret Kinnaird,
Jessica Bartlett,
WWF International
Barclays
Sadayasi Tobai,
James Toone,
WWF Japan
Environmental Investigation
Agency (EIA) Livia Esterhazy,
WWF New Zealand
Channing Mavrellis, CAMS
Global Financial Integrity
Table of Contents
Table of Contents
Chapter 1: Illegal Wildlife Trade Overview....................................................................... 7

What is the Illegal Wildlife Trade?....................................................................................................................... 7
What are Wildlife Products Used For?................................................................................................................ 8
What are the Consequences of the Illegal Wildlife Trade?................................................................................ 9
The Illegal Wildlife Trade as a Serious Organized Crime................................................................................. 10
International Frameworks: (CITES)................................................................................................................. 11
Global Wildlife Crime Initiatives:....................................................................................................................... 12
Chapter 1 - Key Learning Points....................................................................................................................... 15
Chapter 2: Identifying Illegal Wildlife Trade Risks....................................................... 17
The Illegal Wildlife Trade Supply Chain........................................................................................................... 17
Wildlife Poaching and Trafficking Hotspots...................................................................................................... 20
Case Study: The Shuidong Connection............................................................................................................ 20
Chapter 3: Escalating Risks (Red Flags and Suspicious Activity)...........................24
Escalating Illicit Wildlife Trafficking Investigations......................................................................................... 25
Specific Advice on Escalating IWT Investigations to Senior Management and Board of Director Level ..... 25
High Level Corruption Enables the Illegal Wildlife Trade .............................................................................. 25
Case Study: US-linked Cases - The Kromah Case............................................................................................ 26
Case Study: US-China Turtle Smuggling Network (Paypal)........................................................................... 27
High Risk Industries........................................................................................................................................... 27
Illegal Wildlife Trade Red Flags......................................................................................................................... 28
Case Study: The Xaysavang Network............................................................................................................... 29
Chapter 4: Reporting Suspicious Activity.....................................................................32
The Financial Intelligence Cycle....................................................................................................................... 32
Triggering and Opening an investigation related to the Illegal Wildlife Trade............................................... 32
Conducting the Investigation............................................................................................................................ 33
Guinean Illegal Wildlife Trade Networks.......................................................................................................... 34
Drafting the Suspicious Transaction Report/Suspicious Activity Report (“SAR”)........................................ 35
Reporting to the FIU.......................................................................................................................................... 37
What role can Banks and Financial Institutions play?..................................................................................... 38
Public Private Partnerships to Combat Illegal Wildlife Trade......................................................................... 39
Chapter 4 – Key Learning Points...................................................................................................................... 40
Endnotes – Reading List...................................................................................................... 41

Other Supporting Organisations......................................................................................42
Welcome
Welcome
Welcome to the ACAMS-WWF Ending Illegal Wildlife Trade Certificate. This course aims to
give learners a broad overview of the illegal wildlife trade and the associated activities that
financial institutions and banks should consider to mitigate their money laundering risks.
The course is structured into four modules referred to as chapters:
• C
hapter 1 will define the illegal wildlife trade, the value of illicit financial flows associated with
the trade as well as examining the illegal wildlife trade as a trans-national criminal enterprise.
• C
hapter 2 will focus on understanding the illegal wildlife trade risks and explain how an illegal
wildlife trade supply chain generally operates. Financial flows and payment methods across
the illicit supply chain will also be examined to provide further insight into how these risks will
manifest within financial institutions.
• C
hapter 3 will identify how to escalate illegal wildlife trade risks. This chapter details a number of
short case studies along with typologies, red flag indicators and high risk industries linked to the
illegal wildlife trade.
• F
inally, Chapter 4 completes the course by simulating a bank investigation along with learning
about a detailed case study showing how illegal wildlife trade networks operate in West Africa.
It also examines public-private-partnership structures that can be used to combat the illegal trade.
The Course objectives are to:

1. Understand the illegal wildlife trade and its consequences
2. Comprehend the financial elements of how wildlife crime manifests
3. Identify organizational risks and exposure to the illegal wildlife trade.
4. Examine existing typologies and red flags along with global case studies
5. Report suspicious activity associated with the trade
5
1. Illegal Wildlife
Trade Overview
1. Illegal Wildlife Trade Overview What is Illegal Wildlife Trade?
Chapter 1: Illegal Wildlife Trade Overview
Chapter 1 sets out the background and context to the illegal wildlife trade. You will learn about the
illicit revenues generated, identify key publications and reports and examine wildlife crime as a
trans-national criminal enterprise.
By the end of Chapter 1, you will be able to:

1. Understand the illegal wildlife trade and how is it defined
2. Review statistics on the illegal wildlife trade
3. Identify the end markets for illegal wildlife trade
4. Grasp the illegal wildlife trade as a trans-national organized crime
What is Illegal Wildlife Trade?
Illegal wildlife trade1 is a component of a broader set of environmental crime which also includes
forestry and fisheries crimes, illegal mining, minerals trafficking, and the trafficking or illegal
dumping of hazardous materials, chemicals, and waste. The illegal wildlife trade is often referred
to as fauna and flora crimes, defined by ENACT Africa as: “The illegal poaching, smuggling and
transport of a specific animal product or species by criminal groups or individuals for the
purpose of financial profit or other material gain.2” The illegal wildlife trade is also considered to
be a low risk – high reward crime. The high profits and rewards for engaging in wildlife crime make
it an attractive crime for criminals to engage in due to the low risk of detection. As such the illegal
wildlife trade is often linked to transnational organized crime groups which rely on weak criminal
justice responses, corruption and disconnected global law enforcement to advance their crime.
The illicit nature of wildlife and environmental crimes make estimating the proceeds generated from
those crimes challenging, and unsurprisingly estimates range from the low billions to more than a
trillion dollars. Global Financial Integrity has estimated that trade in illegal fauna alone generates
between $7b and $23b in illicit criminal profits. When forestry and fisheries crime proceeds are
factored in, the value jumps sharply. In 2016, the United Nations Environment Programme (UNEP)
in conjunction with Interpol, estimated that illicit revenues from natural resource crimes cost
between $91 billion and $258 billion.3 The most recent revised figures published by the World
Bank in 2019 estimate the annual cost of these illegal activities as between $1 trillion to $2 trillion.
Environment crime has been ranked as the fourth most profitable crime globally, and the United
Nations (UN) estimates the annual value of environmental crime is expected to increase at 5-7%
each year as criminal groups expand the scope and scale of their activities.4 While the illegal
wildlife trade occurs domestically in every country, when the trade becomes transnational, values
increase, sometimes exponentially, attracting transnational organized criminal syndicates.
1. T he term wildlife crime is often used to refer to illegal wildlife trade. Throughout this study guide, wildlife refers to both flora and fauna, and includes fisheries.
2. ENACT Africa - https://enactafrica.org/research/explainers/what-is-wildlife-crime-and-why-does-it-affect-us#:~:text=The%20illegal%20poaching%2C%20smuggling%20or,profit%20
or%20other%20material%20gain.
3. https://financialtribune.com/articles/world-economy/42862/environmental-crimes-cost-258b#:~:text=The%20scourge%20includes%20a%20rise,%2470%20billion%20to%20%24213%20
billion.
4. https://wedocs.unep.org/bitstream/handle/20.500.11822/7662/-The_rise_of_environmental_crime_A_growing_threat_to_natural_resources_peace%2C_development_and_security-
2016environmental_crimes.pdf.pdf?sequence=3&isAllowed=y
7
1. Illegal Wildlife Trade Overview What are wildlife products used for?
For more information

Readers may want to refer to the United Nations Office of Drugs & Crime (UNODC) report
entitled, “World Wildlife Crime Report: Trafficking in Protected Species” for more information:
https://www.unodc.org/documents/data-and-analysis/wildlife/2020/World_Wildlife_
Report_2020_9July.pdf
Transnational Environmental Crime
Timber Trafficking
Wildlife Trafficking
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Data: World Bank5
What are Wildlife Products Used For?
Wildlife is coveted across the globe, including rare and endangered species, for medicine, art,
ornament, for pets, as a status symbol, an investment, and as an expression of culture, tradition,
and authenticity. Often, an animal’s rarity and endangered status drive increases in demand. Ivory
is commonly used in traditional carvings and for jewelry while chimpanzees may be trafficked for
the zoo and pet trade and for medical testing. High demand for tiger bone wine or Hu Gu Jiu, an
alcoholic beverage originally produced in China, drives the illicit tiger trade, pushing tigers and
other big cats to the brink of extinction. Rare hardwoods are used in the production of antique style
furniture in China, and illegally caught parrots and songbirds are regular features in households in
5. Illegal Logging, Fishing and Wildlife Trade: The Costs and How to Combat It. http://pubdocs.worldbank.org/en/482771571323560234/WBGReport1017Digital.pdf
8
What are the Consequences
1. Illegal Wildlife Trade Overview of the Illegal Wildlife Trade?
Latin America, Indonesia, and the Middle East. In Vietnam rhino horn is used in traditional medicine
to treat fever and other conditions, including as a cancer treatment. Reptile trafficking to Europe
and North America for the pet trade decimates snake, lizard, and frog populations in tropical regions
globally. Within Africa owl’s eggs and vulture heads are traded illegally for traditional medicine.
Legitimate zoos, pet stores, leather and fur manufacturers and other animal product vendors can
also be involved in the illegal wildlife trade, both wittingly and unwittingly, creating confusion for
customers and challenges for customs and border control officials and law enforcement.
Each year, hundreds of millions of plants and animals enter the wildlife trade, harvested from the
wild, a worryingly large proportion illegally.6 Over-exploitation is the second-largest direct threat
to many species after habitat loss, according to WWF, including legally and illegally traded species.
Global initiatives to combat the illegal wildlife trade include:
1. S top the Poaching: increasing wildlife stewardship by local communities and strengthening
field protection;
2. Stop the Trafficking: promoting action to expose and suppress trafficking;
3. Stop the Buying: encouraging initiatives to reduce consumer demand;
4. International Policy: mobilising policy responses at the international level to ensure that an
enabling environment is created to facilitate and sustain the fight against wildlife crime.7

WWF research highlights that high prices paid by consumers drive demand.
https://www.worldwildlife.org/threats/illegal-wildlife-trade
https://wwf.panda.org/our_work/our_focus/wildlife_practice/problems/illegal_trade/
What are the Consequences of the Illegal Wildlife Trade?
The illegal wildlife trade contributes to the loss of biodiversity, threatens endangered species
with extinction (i.e., lions, elephants, tigers, rhinos, whales and turtles), and increases exposure
to zoonotic diseases such as Ebola, monkey pox, Nipah Virus, SARS, salmonella, and various
coronaviruses as evidenced by the COVID19 pandemic. Areas awash in the illegal wildlife trade
often experience increased criminality and violence, including the penetration of organized crime
groups and other armed actors. The illegal wildlife trade robs communities of current and future
revenue generation opportunities at the same time it removes billions from government coffers in
the form of taxes, fees, and duties lost to illicit trade, undermining legal commerce and impacting
governments’ ability to provide public services such as infrastructure, education, and healthcare.
Rural households dependant on wild animals for their meat protein and fuel, and both wild animals
and plants provide components of traditional medicines used by people across the world.
6. WWF - https://wwf.panda.org/our_work/our_focus/wildlife_practice/problems/illegal_trade/
7. WWF - https://wwf.panda.org/our_work/our_focus/wildlife_practice/problems/illegal_trade/
9
The Illegal Wildlife Trade as
1. Illegal Wildlife Trade Overview a Serious Organized Crime
Unsustainable exploitation of wildlife resources can tip ecosystems out of balance permanently,
with broad negative impacts. For example, overfishing in West Africa is not only threatening
fisheries with collapse, it is also increasing economic insecurity for coastal communities and
increasing risks to food security for millions across the region. The loss of forests to timber
traffickers in the same region is speeding up desertification, with similar negative consequences
for communities. As human life depends on the existence of a functioning planet, careful and
thoughtful use of wildlife species and their habitats is required to avoid extinctions as well as
serious disturbances in the complex web of life.8
The planet has lost 68% of its biodiversity since 1970 according to the World Wildlife
Fund’s The Living Planet Report 2020. According to the report “humanity’s increasing
destruction of nature is having catastrophic impacts not only on wildlife populations but
also on human health and all aspects of our lives.”9
Conserving natural resources is also critical for advancing the Sustainable Development Goals
(SDGs). Three SDGs are especially relevant:
The Illegal Wildlife Trade as a Serious Organized Crime.
The high-value, low-risk nature of the illegal wildlife trade attracts individual criminals, corrupt
officials, opportunists, and transnational organized crime groups. According to the UN, “organized
criminal groups involve three or more people working together for a period of time, with the aim of
committing one or more serious crimes in order to generate financial or material benefits, often by
providing illicit goods and services.”10 Crimes become transnational when:
• their activities take place in more than one country;
• are planned in one country and executed in another; involves an organized crime group that
engages in activities in more than one state;
• when the effects are felt in more than one state.11
High volume, transnational illegal wildlife trade is made possible through the employment of
complex financial crimes including money laundering, tax evasion, fraud, corruption, and the use
of shell and front companies. Traffickers pay bribes to officials and politically exposed persons
(PEPs) corrupt the systems to allow safe passage of illicit goods, often utilizing falsified permits
and documentation. To facilitate these transactions and access and transfer illicit proceeds, wildlife
traffickers regularly exploit weaknesses in the financial institutions, increasing risks to the financial
8. WWF Panda - https://wwf.panda.org/our_work/our_focus/wildlife_practice/problems/illegal_trade/

9. https://f.hubspotusercontent20.net/hubfs/4783129/LPR/PDFs/ENGLISH-FULL.pdf
10. https://www.unodc.org/documents/data-and-analysis/wildlife/2020/World_Wildlife_Report_2020_9July.pdf
11. United Nations Resolution. United Nations Convention against Transnational Organized Crime. http://www.unodc.org/pdf/crime/a_res_55/res5525e.pdf
12. http://www.fatf-gafi.org/media/fatf/documents/Money-laundering-and-illegal-wildlife-trade.pdf
10
1. Illegal Wildlife Trade Overview International Frameworks: (CITES)
system, according to FATF.12 The illegal wildlife trade converges with other serious organized
crime types including drug trafficking, human trafficking and arms trafficking and is enabled by
systemic corruption.

FATF published the following report entitled, “Money Laundering and the Illegal Wildlife
Trade” which should accompany your studying.
https://www.fatf-gafi.org/publications/methodsandtrends/documents/money-laundering-wildlife-
trade.html
International Frameworks: (CITES)
The Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) is
an international agreement between 183 member states to ensure that legal international trade in
specimens of wild animals and plants does not threaten their survival. The Convention entered into
force on 1 July 1975 CITES, providing protections for over 38,700 species – including roughly 5,950
species of animals and 32,800 species of plants. Member states vote to list species under CITES
Appendices according to how threatened they are by international trade and how much protection
they require. Some whole groups, such as primates, cetaceans (whales, dolphins and porpoises),
sea turtles, parrots, corals, cacti and orchids are listed. But in some cases only a subspecies or
geographically separate population of a species (for example the population of just one country) is
listed.13
• A ppendix I includes species threatened with extinction and provides the greatest level of
protection, including restrictions on commercial trade.
• Appendix II includes species that although currently not threatened with extinction, may become
so without trade controls. It also includes species that resemble other listed species and need to
be regulated in order to effectively control the trade in those other listed species.
• Appendix III includes species that are listed after one member country has asked other CITES
Parties for assistance in controlling trade in a species. The species are not necessarily threatened
with extinction.
Some examples of the types of species that are included in each of the Appendices are offered here.
• In Appendix 1 where there is no commercial trade, species include gorillas, sea turtles, most lady
slipper orchids, Asian elephants, tigers, and giant pandas.14
• In Appendix 2 where export permits are required by origin and destination country, species
include: American black bears, southern fur seals, Hartmann’s mountain zebra, toco toucans,
green iguanas, Pacific Coast mahogany, triangle palm and cyclamens.15
13. CITES https://www.cites.org

14. FWS https://www.fws.gov/international/pdf/factsheet-cites-overview-2013.pdf
15. http://hsi-old.pub30.convio.net/about/how_we_work/policy/treaties/CITES_resource_1.html
16 https://www.hsi.org/news-media/category/resource/page/33/
11
1. Illegal Wildlife Trade Overview Global Wildlife Crime Initiatives
• I n Appendix 3 where an export permit and Certificate of Origin is required include: two-toed
sloths from Costa Rica, African civets from Botswana, African waxbill, a bird species from Ghana,
and bigleaf mahogany in Costa Rica, Brazil, and Mexico.16
Importantly, while CITES is legally binding on member states, the convention does not take the
place of domestic legislation and does not address the illegal wildlife trade. Many countries do not
provide legal protections for non-native species, creating significant gaps in legislation traffickers
exploit to engage in laundering of species into legitimate trade.

More information about the Convention on International Trade in Endangered Species
of Wild Fauna and Flora (CITES):
https://www.cites.org/eng/app/index.php
Global Wildlife Crime Initiatives:
The International Consortium on Combating Wildlife Crime (ICCWC)

The International Consortium on Combating Wildlife Crime or ICCWC, launched in 2010,
co-ordinates criminal justice system responses and builds capacity across criminal justice systems
globally in recognition of the transnational nature of illegal wildlife trade.
The Consortium includes representatives from:

• United Nations Office on Drugs and Crime (UNODC)
• INTERPOL
• The World Bank
• The World Customs Organization (WCO)
• The Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES)
The consortium works with the national wildlife law enforcement agencies and the sub regional and
regional wildlife enforcement networks (WENs) that act in defense of natural resources. WENs are
regional inter-agency and inter-governmental initiative to counter the illegal wildlife trade, helping
share information on and tackle cross-border wildlife crime and facilitate the exchange of regional
best practices in combating those crimes.
Regional wildlife enforcement networks include:

• Southeast Asian Nations Wildlife Enforcement Network (ASEAN WEN): Brunei, Cambodia,
Indonesia, Laos, Malaysia, Myanmar, the Philippines, Singapore, Vietnam and Thailand
12
• S outh Asia Wildlife Enforcement Network (SAWEN): Afghanistan, Bangladesh, Bhutan, India,
Maldives, Nepal, Pakistan, Sri Lanka
• Central America Wildlife Enforcement Network (CAWEN/ROAVIS): Belize, Costa Rica, El
Salvador, Guatemala, Honduras, Nicaragua, Panamá, and Dominican Republic
• South America Wildlife Enforcement Network (SUDWEN): Argentina, Brazil, Chile, Colombia,
Ecuador, Paraguay, Peru and Venezuela
• Horn of Africa Wildlife Enforcement Network (HAWEN): Djibouti, Eritrea, Ethiopia, Kenya,
Somalia, South Sudan, Sudan, and Uganda.
The International Union for Conservation of Nature (IUCN)

The IUCN is an international organization comprised of government and civil society organizations
and is a recognized global authority on the status of the natural world and the measures needed to
safeguard it.17 The IUCN publishes its Red List which compiles scientific data and information on
the global extinction risk status of flora and fauna. While the list fills key knowledge gaps on the
120,000 species listed, including more than 32,000 species threatened with extinction, to date these
figures represent less than 5% of described species.
United Nations Office of Drugs and Crime

The United Nations Office of Drugs and Crime (UNODC) assists the UN in coordinating a response
to transnational organized crimes including drug trafficking, terrorism, corruption, and wildlife
crime and provides guidance to governments on adoption and implementation of crime related
conventions. The UNODC “works with legal systems and law enforcement agencies of Member
States to strengthen policy, legislative and regulatory frameworks; enhance knowledge and skills
to investigate and prosecute related criminal activities; increase awareness regarding the nature
and scale of wildlife and forest crimes; and enhance cooperation on national, bilateral, regional and
international levels.” In 2016 the UNODC publishes its first World Wildlife Crime Report, updated
in 2020, to identify trends in illegal wildlife trade by species and region, providing analysis on supply
chains, pricing, and illicit financial flows related to the illegal wildlife trade.
United Nations Environment Program

The United Nations Environment Programme (UNEP) sets the UN’s global environmental
agenda and advocates for the global environment. According the UNEP, the “illegal wildlife trade
constitutes a barrier to the achievement of both sustainable development and environmental
sustainability.” The UNEP notes the human, economic, and national security implications of
unfettered illegal wildlife trade and environment crime, as well as noting the role corruption
and financial crimes play in multiple comprehensive reports on the illegal wildlife trade and
environmental crime. In its 2014 assessment of environment crime the UNEP noted that the illegal
wildlife trade “often violates tax laws, anti-money laundering laws, and it may include involvement
in organized crime, violence, trafficking and even funding of non-state armed groups.”18
17. https://www.iucnredlist.org/about/background-history
18. http://wedocs.unep.org/bitstream/handle/20.500.11822/9120/-The%20environmental%20
crime%20crisis%3a%20threats%20to%20sustainable%20development%20from%20
illegal%20exploitation%20and%20trade%20in%20wildlife%20and%20forest%20resources-
2014RRAcrimecrisis.pdf?sequence=3&isAllowed=y
13
The International Criminal Police Organization (INTERPOL)

INTERPOL is an intergovernmental organization enabling information sharing and access to data
on crimes and criminals between its 194 member state law enforcement agencies. INTERPOL’s
Environment Security Program encompasses four global enforcement teams (Fisheries, Forestry,
Pollution and Wildlife) providing member states investigative support to international cases,
develop targets, and coordinate operations against illegal wildlife trade organizations across the
supply chain. INTERPOL runs multiple species-specific operations and programs aimed at arrests
and seizures, and strengthening member capabilities to investigate wildlife crime, serving a key role
in both coordinating across countries and across law enforcement agencies such as customs and
border patrol, wildlife ministries, and national police.
Other Supporting Organizations

There are a number of organizations specializing in investigation and exposing wildlife and
environment crimes and the individuals and syndicates behind the crimes including the
Environmental Investigation Agency (EIA), TRAFFIC, World Wide Fund for Nature (WWF), Global
Financial Integrity (GFI), Wildlife Justice Commission (WJC) and the Centre for Advanced Defense
Studies (C4ADS). Non-profit organizations and other key supporting entities can help financial
institutions detect suspicious activity linked to the illegal wildlife trade by providing lead data,
lists of known illegal wildlife trade offenders and context and background on illegal wildlife trade
trends, and tactics, techniques, and procedures utilized by wildlife traffickers. A number of reports
are publicly available to reference relevant materials and to understand more about the trade, the
syndicates and illicit financial flows.
United for Wildlife

United for Wildlife (UfW) is a component of the Royal Foundation, the charitable vehicle for the
Duke and Duchess of Cambridge. UfW is tackling the illegal wildlife trade by bringing together
conservation organizations, governments, and global corporations through its Transport and
Finance Taskforce. The Transport Taskforce was created in 2014 and has been working to facilitate
collaboration between the transport sector and law enforcement to prevent the illegal wildlife trade.
The taskforce began with 12 members and quickly grew to 40 members with the initial signing of
the Buckingham Palace Declaration in March 2016, the Transport Taskforce now has more than
100 signatories. The Financial Taskforce was sealed with the Mansion House Declaration in 2018,
bringing together financial sector actors to raise awareness and co-ordinate efforts to combat the
illegal wildlife trade. UfW provides Taskforce members actionable intelligence on illegal wildlife
trade risks, trends, and typologies, including a widely read monthly Taskforce Intelligence Bulletin.

More information about the United for Wildlife (UfW):
https://unitedforwildlife.org/about-us/
https://www.zsl.org/united-for-wildlife-free-conservation-courses
14
1. Illegal Wildlife Trade Overview Key Learning Points
Chapter 1 - Key Learning Points

1. T he illegal wildlife trade is defined as “The illegal poaching, smuggling and transport of a specific
animal product or species by criminal groups or individuals for the purpose of financial profit
or other material in contravention of national and international laws,” inclusive of forest and
fisheries crimes.
2. The illegal wildlife trade is considered a Low Risk-High Reward Crime.
3. The illegal wildlife trade is estimated as the fourth most profitable crime globally with recent
estimates of up to $1 to $2 trillion annually, according to the World Bank in 2019.
4. The illegal wildlife trade contributes to the loss of biodiversity and threatens endangered species.
5. Transnational crime syndicates are involved in the illegal wildlife trade for profit and financial
gain.
15
2. Identifying
Illegal Wildlife
Trade Risks
2. Identifying Illegal wildlife trade Risks The Illegal Wildlife Trade Supply Chain
2. Identifying Illegal Wildlife Trade Risks
Chapter 2 will look at organizational risks as a result of the illegal wildlife trade and detail the
mechanics of the illegal wildlife supply chain and how illicit financial flows manifest across the
supply chain.

• Understand the illegal wildlife trade supply chain
• Recognize the payment methods and financial flows associated with the illegal wildlife trade
• Delineate the key source, transit and destination countries for ivory trafficking
• Understand the financial flows and payment methods associated with a trans-national organized
crime group trading in ivory
The Illegal Wildlife Trade Supply Chain
As with many legitimate businesses, wildlife crime organizations operate across global supply
chains to poach, consolidate, transport, and distribute wildlife. The UNODC describes a supply
chain as “a set of actors involved in the (licit or illicit) flows of products, services, information
and finances from the source to the end customer.”19 A general framework for the wildlife supply
chain, adaptable for location or species-specific dynamics, includes multiple layers and levels of
interactions and transactions from the local to transnational aspects of the trade.
1. L
evel 1 of the illegal wildlife trade supply chain consists of poachers and those in source
countries procuring wildlife products illegally. Motivations for poaching range from economic
vulnerability and poverty to desires for additional income or as a political act. Along the supply
chain poachers typically receive the smallest share of illicit proceeds of illegal wildlife trade,
and in certain instances may be paid through bartering. Poachers earn varying sums depending
on the difficulty of locating animals, the species involved, and the point of origin. In Africa ivory
poachers in some areas may only receive trade goods in exchange for tusks, while in other areas
they can earn $80-100/kg for ivory. Pangolin poachers in Uganda receive between $8-$25 for live
pangolins,20 depending on species, while jaguar poachers in Suriname barter skins for weapons,21
and timber poachers in India earn around $6/kg of cut wood.22
2. L
evel 2 actors include local facilitators who purchase wildlife products directly from poachers,
often to fulfill set orders, and transporters specializing in transporting and delivering the products
to the exporter. At this level of the supply chain, there is a high use of cash, cheque, money
transfer services and mobile money payments like M-PESA in East Africa. Often associated bank
accounts will show a number of cash and cheque deposits and withdrawals, rapid movements
of funds in and out of the account and structuring deposits just under suspicious transaction
19. https://www.unodc.org/documents/data-and-analysis/wildlife/2020/World_Wildlife_Report_2020_9July.pdf
20. https://www.unodc.org/documents/wwcr/2020/Wildlife_crime_Pangolin_UNODC.pdf
21. https://www.traffic.org/site/assets/files/13031/brazil_wildlife_trafficking_assessment.pdf
22. https://www.latimes.com/world/asia/la-fg-india-wood-2018-htmlstory.html
17
reporting thresholds. The Ivory Queen case in Tanzania is a good example of the prevalence
of cash payments being used across the local network to obtain, secure, transport and store
ivory prior to onward shipment. In this case, cash payments were made to those sourcing and
transporting ivory, calculated by the weight of the ivory delivered. The same case also involved
the use of international banking accounts linked to the sale of ivory to foreign military officials,
illustrating the vulnerability of the financial system to illegal wildlife trade risks.
4. L
evel 3 and Level 4 involves exporters and importers. At the exporter/importer level,
individuals are likely to be part of organized crime groups, often operating through front
companies. These individuals work with specialist packers and shippers to obfuscate wildlife
products in legitimate seeming shipments. These actors often maintain contacts in ports
and customs authorities who assist in the export and import of wildlife undetected, and can
procure falsified or fraudulent documentation. Wildlife is consolidated and shipped, often
through circuitous routes (both air and maritime) to obscure the true origins of shipments and
evade detections. Upon imported wildlife may be reexported over land to the final destination.
Export/import actors show an increasing use of various money value transfer systems (MVTS)
including licensed systems and informal systems based on money brokers (rather than the use
of cash), such as Hawala, fei chen (flying money) or hundi. FATF notes at this stage exporters/
importers also rely on bank transfers, cash, mobile or social media based payments, and third
party payments.23 In some cases nominee accounts facilitate the bank transfers where locals in
source, transit or destination countries serve as a front for the true bank account owner. The
Xaysavang case highlighted later in the course details a number of international wire payments
from an import-export company in Laos and personal accounts in Thailand to pay game farms in
South Africa for the purchase of rhinos, rhino horns, and lion bones. In other cases, legitimate
companies like pet stores, zoos, and timber companies are used to hide the movement of illicit
proceeds through commingling with licit funds in the same account. Importers may utilize
nominee accounts and cash couriers as payment mechanisms for wildlife products.
5. L
evel 5 – At destination points wildlife may be processed through wholesalers and further
distributed to retailers and finally, consumers. In some instances, consumers may travel across
borders to zones with fewer controls over the illegal wildlife trade to purchase items restricted in
their home countries. In these instances traders may maintain accounts in key destination points
to avoid trans-national money transactions which might alert authorities. In an investigation
led by the Wildlife Justice Commission, the Nhi Khi village in Vietnam, known as a hotspot for
illicit goods, illustrates how Vietnamese traders in the village held bank accounts within China
to make transactions appear as domestic exchanges to avoid any suspicions by Vietnamese law
enforcement.24
24. https://wildlifejustice.org/investigation/operation-phoenix/
18
The Illegal Wildlife Trade Supply Chain
Flow of Products
Source Countries Transit Countries Destination Countries
Medicine
Local poacher
Regional Food and Wine

Professional
middleman or
hunter (national Local fixer Logistics Local fixer
international
or international)
trader
Pet Stores/Zoos
Transporter/
Consumer
Exporter
Corrupt Enablers: law enforcement, border officials, customs officials goods -
Arts/Crafts
Flow of Money
Figure 1: The Illegal Wildlife Trade Supply Chain
The above diagram provides a general framework of the illegal wildlife trade supply chain. The
framework conforms most closely to the trafficking of dead wildlife products (ivory, rhino horn,
pangolin scales, etc) most closely, as trafficking in live animals may require inclusion of specialists
in animal care in addition to overlapping with individuals and groups simultaneously involved in
the legal wildlife trade like within zoos, pet stores, aquariums, and wild animal ranches and farms.
Corruption facilitates and enables wildlife crime at every stage of the supply chain, with park
rangers, local law enforcement, customs and border patrol, and wildlife, environment, and forestry
ministries particularly susceptible. High risk business activities include low value cash businesses,
import/export firms, shipping agents, companies within extractive industries (e.g. logging, mining)
wild animal farms and ranches, pet stores, leather processors, and zoos.

Please refer to TRAFFIC’s website for research and latest publications:
https://www.traffic.org/publications/
https://www.traffic.org/site/assets/files/8832/countering-illegal-wildlife-trade-along-
transportation-and-supply-chains.pdf
19
2. Identifying Illegal wildlife trade Risks Wildlife Poaching and Trafficking Hotspots
Wildlife Poaching and Trafficking Hotspots
The illegal wildlife trade occurs globally and involves the exploitation of plants and animals from
orchids to spiders to elephants, tigers, and polar bears, though research and media typically focus
on high value trafficking of ivory, rhino horn, and pangolin scales from Africa to Asia. Within Africa
poaching hotspots include pangolins and ivory across West and Central Africa and rhino horn in
South Africa. China, Vietnam, Hong Kong, Thailand, and Laos are the most common destination
markets for these products, based on seizure data. Cheetah trafficking from the Horn of Africa to
the Middle East is a growing concern, as is parrot trafficking from West Africa to Turkey. From
Europe, eels flow to Asia and caviar is exported worldwide, while South America and Australia are
hotspots for reptile trafficking. Shark fins illegal harvested in South America flow through ports in
the United States on their way to China, and globally illegal timber exports ship to Asia. The below
case study provides one example of ivory trafficking from East Africa to Shuidong, China, a major
ivory trafficking center associated with high volumes of African ivory imports to China, according to
an in depth investigation by the Environmental Investigation Agency (EIA). The EIA’s investigation
provides analysis of every aspect and level of the illegal wildlife supply chain, and is condensed on
the next few slides.
Case Study: The Shuidong Connection
EIA research and intelligence shows that Chinese and other Asian criminal syndicates dominate
the illegal wildlife trade in Africa. This case study, “The Shuidong Connection” published in 2017,
refers to entities that were operating between Tanzania, Mozambique, Nigeria, South Korea, Hong
Kong and China between 2016-17.25 During the investigation period, the gang claimed involvement in
trafficking of ivory of over 20 tonnes (equivalent to 3,000 dead elephants), with a sales value of $16m
USD in China. The syndicate hailed from Shuidong in Guangdong Province and claimed to be active
in the ivory trade for at least 10 years; they also claimed to EIA investigators that syndicates from
Shuidong were responsible for about 80% of the total volume of ivory traded globally. In 2019, 14
member of the syndicate were arrested and sentenced to between 6 and 15 years in prison.
Eight categories of entities were identified as part of the investigation: Elephant Poachers, Ivory
Collectors, Ivory Buyers, Customs Officers, Coordinators, Money Changers, Freight Agents and
Investors. EIA Investigations focused on the last four entities to scrutinize the money flows. The
eight categories of involved persons also had some overlap, with key actors playing more than one
role. For example: one individual was both a co-ordinator and an investor in the ivory trade.
By late 2016, the network shifted their ivory trafficking operations to Nigeria taking advantage of
weak enforcement and prevalent corruption. The network relied upon complicit freight agents to
secure the route and safe passage for the illicit goods including an unscrupulous freight agent in
Busan, South Korea. Ivory traffickers are known to use circuitous routes through different ports to
avoid suspicion and obscure the origin of shipments. The Shuidong network used a timber company
to front their activities in Nigeria. They concealed illegal wildlife in shipments of plastic pellets as
25. https://eia-international.org/wp-content/uploads/EIA-The-Shuidong-Connection-FINAL.pdf
20
2. Identifying Illegal wildlife trade Risks Case Study: The Shuidong Connection
this was deemed to be a suitable cover that would not raise any suspicions between Busan and
Hong Kong. One of the members of the network owned a plastics production factory in Shunde,
southern China, providing a useful cover for this activity. Most of the buyers for this syndicate came
from known ivory carving centres in Putian and Xianyou in China. Analysis of the money flows
shows the following payment rates per kilogram to key facilitators based on a three-tonne shipment
of ivory (3000 kg):
• P oachers were paid $80-100 per kg of ivory

• Local collectors received $200-300 per kg
• Customs officers were offered $30 per kg in Nigeria in 2017 while $70 per kg was the going rate in
Tanzania in 2014
• In 2014, the South Korea freight agent earnt $450,000
• Coordinators all got a share of $65,000 whereas investors get a larger cut
The Shuidong network operated as a wholesaler with no physical shop premises, selling to
underground buyers at around $720 per kg. Profits were immediately recycled and reinvested into
subsequent shipments. There were also one-off costs such as bribes in case the container gets
held up, which is what happened to this group in South Korea. The hidden investor in Hong Kong
never travelled to Africa and never came into contact with the product. Financial investigations to
advance the gathering of evidence including potential trade-based money laundering would further
identify financial linkages between licit and illicit transactions.
Cash Wire
Cash Chinese deposit Account in transfer Money US$
Currency RMB China RMB changer disbursement
Tanzania
Figure 2: The Shuidong Case Study – Illicit Financial Flows (Credit: EIA)
The Shuidong network conducted international financial transactions using multiple currencies and
vehicles, summarized below:
• RMB Cash Payments were paid into bank accounts in China for the successful delivery of a
shipment of ivory to China
• Following this, international payments were made via wire transfer to a money changer agent in
the source country who then disbursed the money in USD to the ivory collector
• Once the USD was obtained, the funds were distributed to other network players and associates.
Payments would occur in cycles and schedules and in the case of poachers, may have been via
mobile money payment platforms such as Mpesa
21
2. Identifying Illegal wildlife trade Risks Key Learning Points
The primary financial flows associated with this network include:

• F unds transfer from China to Africa – Payments were made from a bank account in China to a
Tanzanian based money changer (of Chinese origin, originally from Fujian) where the funds were
then disbursed in USD to facilitate cash payments for the sourcing of ivory and other payments.
• Bank transfer or cash payment.

More information about Environmental Investigation Agency (EIA) or the “The Shuidong
Connection,” please refer to the following link:
https://eia-international.org/wp-content/uploads/EIA-The-Shuidong-Connection-FINAL.pdf
For information on criminal sanctions resulting from the EIA investigation:
https://news.mongabay.com/2019/01/china-busts-major-ivory-trafficking-gang-following-eia-
investigation/
• T he illegal wildlife trade supply chain intersects with the financial sector in many ways
• Legitimate companies, the use of personal accounts and a high level of cash payments are
observed in relation to the illegal wildlife trade
• Illegal wildlife trade hotspots at the source, transit, and destination locations are a good starting
point for evaluating your illegal wildlife trade risks
• The EIA “Shuidong Case Study” highlights financial transactions originating from China being
sent to money changers in Tanzania in payment for wildlife products
22
3. Escalating Risks
(Red Flags and
Suspicious Activity)
3. Escalating Risks (Red Flags and
Suspicious Activity) Risks Associated with Illegal Wildlife Trade

Suspicious Activity)
Chapter 3 will identify how to escalate illegal wildlife trade risks. This chapter details a number of
short case studies along with typologies, red flag indicators and high-risk industries linked to the

• Identify typologies through short case studies
• Review US Government approaches to combatting the illegal wildlife trade
• Understand high risk industries and red flags
• Analyze a South African Case Study - The Xaysavang Network
Risks Associated with Illegal Wildlife Trade

Investigations into individuals and businesses likely associated with illegal wildlife trade should
be escalated through normal channels when possible. But sometimes, special attention must be
given in order for illegal wildlife trade investigations to be given appropriate weight within an
organization.
Reasons for this can include especially:

• IWT is not considered a “core” risk area
• Little/no knowledge of IWT among senior management
• Assumption that IWT investigations requires special outside knowledge
Wildlife traffickers engage in money laundering, wire fraud, other complex fraud, tax evasion,
and bribery to enable their illicit enterprises, often conducted through front and shell companies.
Traffickers regularly utilize legitimate banking services, mobile money services, and MVTS to fund
their criminal activities and as money laundering vehicles. Illegal wildlife trade investigations
rarely include financial crime investigations, despite the reality that trafficking presents financial
institutions with serious legal, financial, and reputational risks.
Illegal wildlife trade investigations should be escalated through normal channels when possible.
But sometimes, special attention must be given in order for illegal wildlife trade investigations to be
given appropriate weight within an organization.
24
3. Escalating Risks (Red Flags and Escalating Illicit Wildlife
Suspicious Activity) Trafficking Investigations
Escalating Illicit Wildlife Trafficking Investigations
IWT investigations should be escalated through normal channels when possible.

But sometimes, special attention must be given in order for IWT investigations to be given
appropriate weight within an organization.
Specific Advice on Escalating IWT Investigations to Senior

Management and Board of Director level
• R eference financial institution commitments under the 2018 Mansion House Declaration
(especially applicable for organizations which are members of the United for Wildlife Financial
Taskforce)
• Reference key publications highlighting the scale and importance of IWT-related financial crime,
e.g.:
• Money Laundering and the Illegal Wildlife Trade, Financial Action Task Force (FATF),
June 2020
• Illegal Logging, Fishing, and Wildlife Trade: The Costs and How to Combat It, World
Bank, October 2019
• Contact the United for Wildlife Financial Taskforce for case-by-case advice
High Level Corruption Enables the Illegal Wildlife Trade
As evidenced above, the illegal wildlife trade often involves individuals in high level official
positions, including diplomats and politically exposed persons (PEPS). Numerous reports link
high level officials in source and destination countries to illegal wildlife trade operations. A report
from the Global Initiative against Transnational Organized Crime in 2017 shows that North Korean
diplomatic passport holders are linked to at least 18 cases of rhino horn and ivory smuggling
over the past 30 years.26 An EIA report also tied North Korean diplomats to rhino trafficking out
of Zimbabwe, finding that “70% to 80%” of the rhino horn traded by the DPRK’s Harare embassy
originated in Zimbabwe. Additionally, a trafficker in Tanzania dubbed the “Ivory Queen” was
allegedly tied to ivory purchases by members of a foreign military during a port visit to Dar es
Salaam.27 The EIA has documented involvement in rosewood trafficking by PEPs and other high-
level officials in multiple countries in Africa including Gambia, Nigeria, and Zambia.28
Corruption enables and facilitates the illegal wildlife trade as well as other forms of unsustainable
or criminal exploitation of natural resources; the possibility of laundering the proceeds of these
illegal activities makes such environmental crime a very lucrative pursuit. In 2017, the G20
addressed combating corruption related to IWT, noting that illegal wildlife trade investigations
“extend to potential corruption linked to the illegal trade in wildlife and wildlife products, including
26. h
ttps://globalinitiative.net/diplomats-and-deceit-north-koreas-criminal-activities-in-africa/#:~:text=A%20new%20report%20by%20The,%2C%20ivory%2C%20cigarettes%20and%20
minerals.
25
3. Escalating Risks (Red Flags and Case Study: US-linked Cases
Suspicious Activity) - The Kromah Case
through the tracking of financial flows.”29 And in 2020 the OECD issued recommendations that anti-
corruption investigations occur alongside investigations into the illegal wildlife trade to identify and
prosecute related criminal network and “reinforce the engagement of financial intelligence units in
follow-the-money investigations related to wildlife crime.”30
Case Study: US-linked Cases - The Kromah Case
In June 2019, US Authorities indicted Moazu Kromah along with three accomplices- Amara Cherif,
Mansur Mohamed Surer, and Abdi Hussein Ahmed, for participating in a conspiracy to traffic in
rhinoceros horns and elephant ivory, both protected wildlife species, valued at more than $7 million
that involved the poaching of approximately 35 rhinoceros and more than 100 elephants. Kromah,
Cherif, and Surur were also charged with conspiracy to commit money laundering, and Surur and
Ahmed were charged with trafficking 10kg of heroin.31
Kromah, a Liberian national residing in Uganda, was first arrested in Uganda on wildlife crime
charges in February 17, 2017 for possession of 437 pieces of ivory (1303kg) valued at Ugandan
Shilling 9,358,120,000. Alongside Guinean nationals, Bangaly Kourouma and Mohammed Kourama,
he was charged with possession, unlawful importation, conspiracy to commit a felony and money
laundering. The Ugandan case showed financial flows from a Laotian company, Vannaseng Trading,
to his personal account in Uganda of $190,000 through the formal banking system. Kromah was
extradited to the US in June 2019, followed by Cherif in April 2020, and Surur in June 2020.
The US-based Kromah case (2019) also highlighted:

• That syndicate members originating in Uganda used the Kenyan financial system to transfer
funds for illicit wildlife products with falsified documents
• That the syndicate had a preference for using money transfer service businesses to transfer
illicit cash
• The transcontinental and transnational nature of illegal wildlife trade syndicates
• Convergence with drug trafficking

More information US Department of Justice case please refer to the following link:
https://www.justice.gov/usao-sdny/pr/members-african-criminal-enterprise-charged-large-
scale-trafficking-rhinoceros-horns
https://www.justice.gov/usao-sdny/press-release/file/1173366/download
30. http://www.oecd.org/gov/illicit-trade/brochure-illegal-wildlife-trade-sea.pdf
31. https://www.justice.gov/usao-sdny/pr/members-african-criminal-enterprise-charged-large-scale-trafficking-rhinoceros-horns
26
3. Escalating Risks (Red Flags and Case Study: US-China Turtle
Suspicious Activity) Smuggling Network (Paypal)
Case Study: US-China Turtle Smuggling Network (Paypal)
In 2019, the US authorities revealed an indictment for a Chinese national posing as an exchange
student in the US, Kang Juntao, allegedly involved in trafficking five species of turtle from the US
to Hong Kong for onward sale in the illegal pet trade in China, Hong Kong and Japan. Kang Juntao
arranged for the illegal export of about 1,500 turtles poached across the US valued at approximately
$2.2m USD. Kang Juntao is alleged to have engaged in illegal wildlife trade from Canada before
moving operations to the US. Over a period of 18 months, from June 2017- December 2018, 40
payments were made via Paypal from Chinese banks totaling $78,382. The transactions ranged in
value from as little as $472- $4,000, and flowed through accounts the accused opened at a Chinese
bank, sometimes involved the use of an alias. Additional transactions involved mobile banking
platforms such as Zelle and WeChat.32 Malaysian authorities arrested Kang Juntao at the Kuala
Lumpur airport in 2020, and he is awaiting extradition to the US on a money laundering charge.
This case is significant as US authorities were able to target a Chinese national living in China
through money laundering laws. The case also shows how money laundering can be applied as a
stand-alone offence in the context of wildlife crime.33

Please refer to the following link:
https://www.moneylaundering.com/news/wildlife-traffickers-face-us-money-laundering-charges/
High Risk Industries
This section details some examples of high-risk industries that have been observed linked to the
illegal wildlife trade. Financial institutions can potentially leverage these indicators to review
high-risk clients. It is important to note this list is not comprehensive, and the illegal wildlife trade
can be facilitated through other entities not captured by this list.
High risk industries in source countries include:
• Game lodges, safari parks
• Captive-breeding farms, ranches, and facilities, especially involving CITES listed species
• Animal product exporters- (e.g. donkey skins, seafood, hunting trophies)
• Any environmental product supplier
• Secondhand car dealers and other cash intensive businesses
• Companies that sell low value/high bulk agricultural products (key exports that may be exempted
or fast-tracked for export i.e.: tea in Kenya)
• Import-export companies, shipping logistics providers
• Restaurants
• Logging companies, timber companies, other extractive industries
32. https://www.moneylaundering.com/news/wildlife-traffickers-face-us-money-laundering-charges/
33. https://eu.courierpostonline.com/story/news/crime/2019/02/18/turtle-smugglers-diamondback-
terrapin-kang-jungtao-david-sommers/2904453002/
27
Suspicious Activity) Illegal Wildlife Trade Red Flags
In the destination market high risk industries include:

• Medicine production, medical testing facilities
• Pet stores, zoos and breeding farms
• Leather goods importers, manufacturers
• Import-export companies
• General trading companies
• Furniture production companies
• Arts, crafts, curios and antiques retailers
The following entities are commonly observed across the supply chain.
• Import-export companies
• Cash intensive businesses (e.g. used clothing and shoe sales, used car sales)
• Any company involved in the legal wildlife industry
• Travel Agents
• Restaurants
• Timber trading companies
• Seafood and Marine Products importers/exporters
• Transport and logistics companies
• General trading companies and free-trade zone companies
This list is by no means exhaustive but can be offered as preliminary guidance. There are three
key public reports that also detail red flags and typologies that should be leveraged for further
understanding, in addition to regularly updated United for Wildlife Taskforce alerts. In 2016, the
East and Southern Africa Anti-Money Laundering Group (ESAAMLG) produced a detailed study
from the region called: ESAAMLG A Special Typologies Report on Poaching, Illegal Trade in
Wildlife and Wildlife Products associated with Money Laundering in the ESAAMLG Region.
In 2017, UNODC in partnership with the Asia Pacific Group on Money Laundering (APG) produced
the report Enhancing the Detection, Investigation and Disruption of Illicit Financial Flows
from Wildlife Crime. More recently, in 2020, FATF has released its first report on wildlife crime
titled: Money Laundering and the Illegal Wildlife Trade. All three reports provide additional insight,
typologies and case studies to further understand the financial flows associated with the illegal
wildlife trade.
Illegal Wildlife Trade Red Flags
A review of financial transaction red flags presented in existing literature combined with practical
hands-on experience with investigating wildlife crime show that the red flag indicators are often
generic money laundering red flags and cannot always be distinguished as wildlife crime within the
bank or financial institution. However, some red flags that are common include:
32. https://www.moneylaundering.com/news/wildlife-traffickers-face-us-money-laundering-charges/
33. https://eu.courierpostonline.com/story/news/crime/2019/02/18/turtle-smugglers-diamondback-terrapin-kang-jungtao-david-sommers/2904453002/
28
Suspicious Activity) Case Study: The Xaysavang Network
• Account activity is inconsistent with the client profile

• Multi-country accounts and payment schemes34
• International bank transfers via general trading companies
• Heavy use of cash, linkage of local PEPS and public officers (bribe payments) and the use of
nominees
• Deposits followed by immediate withdrawals of similar amounts
• Commingling of personal and business proceeds
• Use of money transfers services
• Illogical or anomalous loans between trading or import/export companies in key illegal wildlife
trade source or transit countries
• Unexplained large financial transactions from companies in high risks destinations to freight
forwarding/customs clearance companies operating in high risk origin countries
When the above red flag indicators are combined with data on high risk client profiles, geographies
and industries, they can be powerful tools to identify suspicious transactions. Wildlife crime often
occurs alongside legitimate business, and criminals nest illicit activities within licit enterprises.
Involvement of legal wildlife-related entities such as private zoos, breeders, pet stores, safari
companies and pharmaceutical companies can often be seen to operate legitimate and illegal
business. As RUSI argued in 2020, while financial investigations are labor intensive they are an
“absolutely essential tool in disrupting organized crime.”35
Case Study: The Xaysavang Network
The Xaysavang Network is a well-known international illegal wildlife trade syndicate involved in
the killing of endangered elephants, rhinos, pangolins, and other species for products such as ivory
and rhino horn. In this case from South Africa, Chumlong Lemtongthai, a Thai national, played
an important role in the syndicate by obtaining rhinoceros horn and lion bones for Asian black
markets through pseudo-hunting techniques. Chumlong would periodically travel to South Africa
on a tourist visa to coordinate a network of players that helped facilitate the poaching of rhinos by
utilizing Thai sex workers to pose as hunters to circumvent national laws in South Africa. The so
called “hunters” were paid around US$300.
Financial investigations illustrate that the wildlife products (entire rhinoceros, rhinoceros horn
and sets of lion bones) were paid for with a combination of local cash payments and international
bank payments. The international bank transfers were made either from Xaysavang Trading Export
Import Company in Laos, or from the personal accounts of Lemtongthai in Thailand, to various
game farms for the illegal hunts. Chumlong routinely withdrew large amounts of cash in South
Africa from his Bangkok bank account at casino ATM machines in South Africa (up to ZAR1 million
per visit). Financial documentation shows that the invoices were sent from various game farms
and safari companies in South Africa for payment by Chumlong under the name of the Xaysavang
Export Import company. Chumlong paid other syndicate members in cash to obtain the wildlife
products and ensure they were ready for export via air travel. Vixay Keosavang, a Lao national
34. https://static1.squarespace.com/static/566ef8b4d8af107232d5358a/t/56af8242cf80a1474b572b85/1454342724100/Species+of+Crime.pdf
35. https://rusi.org/publication/rusi-newsbrief/case-closed-why-we-should-review-historic-wildlife-trafficking-cases
29
Suspicious Activity) Key Learning Points
was believed to be the leader of the network and has been called the “Pablo Escobar” of the
illegal wildlife trade. The Xaysavang Network has been linked to several major seizures of wildlife
products with the U.S. Authorities offering a reward of up to $1m for information leading to the
dismantling of the Xaysavang Network.36
Chumlong was originally sentenced in South Africa to 40 years under the National Environmental
Management: Biodiversity Act 10 of 2004 for failure to comply with permitting requirements and
the Customs and Excise Act 91 of 1964 for improper use of licenses, permits and documents. The
sentence was reduced on appeal by the Supreme Court of Appeal to 13 years plus a fine of ZAR1-
million or an additional five years in prison, however Chumlong has already been released and
deported to Thailand. The South African authorities originally considered a money laundering
charge which was subsequently dropped to speed up the prosecution. Assets accumulated with
the proceeds of crime were recovered in both South Africa and Thailand, including a high-value
vehicle in South Africa and Thai authorities located and forfeited multiple bank accounts linked
to Chumlong.

https://preview.state.gov/inl-rewards-program/transnational-organized-crime-rewards-program/
xaysavang-network/
https://www.worldwildlife.org/magazine/issues/spring-2014/articles/coming-to-america
• High level officials including PEPs and diplomats have been implicated in the illegal wildlife trade.
• US-led cases reveal a shift to focus on money laundering charges for illegal wildlife trade cases.
• High risk industries and red flags can be leveraged by financial institutions to manage their risk to
the illegal wildlife trade.
• The Xaysavang Case Study illustrates the use of the international banking system with payments
identified from an import-export company in Laos to South African game farms.
36. https://www.independent.co.uk/news/world/americas/1m-
bounty-on-the-pablo-escobar-of-animal-traffickings-
head-9069547.html
30
4. Reporting
Suspicious
Activity
4. Reporting Suspicious Activity The Financial Intelligence Cycle
4. Reporting Suspicious Activity
Chapter 4 completes the course by simulating a bank investigation and by detailing a case study on
illegal wildlife trade networks in West Africa. It also examines Public-Private-Partnership structures
that can be used to combat the illegal trade.

• Outline the financial intelligence cycle
• Undertake a real illegal wildlife trade investigation in a bank
• Describe trans-national criminal networks and their associated financial activity
• Know how and when to file a Suspicious Transaction Report (STR)/
Suspicious Activity Report (SAR)
• Share the benefits of Public-Private-Partnerships (PPPs)
The Financial Intelligence Cycle
The financial intelligence cycle is characterized by banks and financial institutions reporting
Suspicious Transaction Reports/Suspicious Activity Reports (STR/SAR) to a national financial
intelligence unit (FIU). At the FIU, intelligence is collated and a decision is made to pass the case
information on to the relevant law enforcement agency for further investigations. In the illegal
wildlife trade, financial investigations can fall under various law enforcement agencies depending
on the enabling national legislation, including customs tax and revenue agencies, national police,
organized crime units (where they have been established), wildlife crime units, and environmental
or wildlife agencies. Banks and financial institutions play a key role in generating financial data that
law enforcement can develop to advance criminal charges, and that judiciaries can utilize to apply
fines, penalties, custodial sentences, and asset forfeiture. If successful, these interventions can
telegraph strong messages to those engaging in wildlife crime and act as a deterrent.
Triggering and Opening an Investigation Related to the Illegal

Wildlife Trade
A number of different triggers should lead to opening an investigation in a financial institution that
links to the illegal wildlife trade including:
1. Internal watchlists and alerts of known illegal wildlife trade offenders
2. Adverse media, arrest, or seizure reports
3. Intelligence and lead data from external organizations
4. Official requests from law enforcement
36. https://www.independent.co.uk/news/world/americas/1m-bounty-on-the-pablo-escobar-of-animal-traffickings-head-9069547.html
32
Triggering and Opening an Investigation
4. Reporting Suspicious Activity Related to the Illegal Wildlife Trade
In this module, we will simulate an investigation showing how to investigate a case linked to the
illegal wildlife trade within your financial institution.
It is important to note, the best practices for illegal wildlife trade related investigations and STR/
SAR filings are the same as for any other crime type. When filing a STR/SAR an analyst should be
sure to provide as much detail as possible to answer the 5 Ws associated with the potential illegal
wildlife trade activity to answer the key questions: Who is involved in conducting the suspicious
activity? What instruments or mechanisms are being used to facilitate the suspicious transaction?
When did the suspicious activity occur? Where did the suspicious activity occur? And finally,
how did the suspicious activity occur? Additional illegal wildlife trade specific knowledge and
networking resources are often easily and freely available from external stakeholders and should be
leveraged during the investigative process.

“Guidance on Preparing and Submitting High Quality Suspicious Activity Reports,”
produced by the Financial Reporting Authority of the Cayman Islands
https://www.fra.gov.ky/app/webroot/files/2020-02-21%20FRA%20Guidance%20on%20
Preparing%20and%20Submitting%20High%20Quality%20SARs%20(Final).pdf
The case is based loosely on a real investigation, however some details have been changed for the
purposes of the example. The case details are:
Case Study: You have received intelligence from a non-profit organization that a Pet Store in your
city may have been involved in the illegal sourcing of live animals and other wildlife products. You
are able to search for the Pet Store and confirm that the company is a client of your bank.
What steps should you take?
Conducting the Investigation
Once a review of all the internal documentation and linked entities is complete, it’s time to
commence the investigation.
1. Conduct a review of the Customer Due Diligence profile. You can start by investigating the
company online through publicly available information
2. External databases - Check names against existing databases and additional sources including
arrest and conviction records
3. Conduct a transaction review – This review reveals a number of transactions with African
counterparties. After checking these names through publicly available media, there is a mention
of one key counterparty: Doumbouya. This name comes up with the following results:
33
4. Reporting Suspicious Activity Guinean Illegal Wildlife Trade Networks
Busted: Guinean Wildlife Official arrested for trafficking chimpanzees

Media sources show that at the CITES Management Authority in Guinea, the public officer in
charge of approving the export of protected species, Mr. Doumbouya, was providing fraudulent
CITES permits to illegal wildlife trade networks for the illegal export of chimpanzees, monkeys,
manatees and parrots. Open source information further states that CITES officials found that 69
chimpanzees were exported in 2010 to Chinese zoos and safari parks based on certificates signed
by Mr. Doumbouya. His signature was also found on fraudulent CITES permits that allowed
for the export of bonobos (a close relative of chimpanzees) to Armenia in 2011, according to the
media reports you’ve uncovered. The animals were exported on certificates claiming they were
bred in captivity, though no such facilities exist in Guinea. You start to consider what action
you might need to take with the bank’s risk tolerance in mind. Your client, the Pet Store, has had
transactions with Doumbouya, the individual that is named in media sources as involved in
the illegal wildlife trade There are also a few transactions paid to Ansoumane Doumbouya in
the amount of $4,000 and USD$10,000. Is this the same Doumbouya linked to your client? You
search the public media for secondary identifiers to avoid misidentification.
Guinean Illegal Wildlife Trade Networks
Upon further investigation from open source information, you find information that the allegedly
corrupt official Doumbouya is in fact the individual linked to your client, and is also likely linked to
well-known trafficking networks in the region including the Traore and Sidibe networks, known to
traffic chimpanzees and rare birds.37 A study published by Global Financial Integrity in 2018 “lllicit
Financial Flows and the Illegal Trade in Great Apes”38 details the background to the illicit trade in
great apes and a case study relating to the Guinean networks and associated financial data that was
obtained as part of the investigation. The global investigation documented online showed that the
network was responsible for the export of more than 100 chimpanzees to your country. Ansoumane
Doumbouya was a key facilitator of the illicit trade by providing falsified permits to obfuscate the
illegal capture and sale of the animals.39 Media sources further state: “Doumbouya allegedly issued
fraudulent CITES permits for the export of various species… although the full extent of his
activities remains unknown.”
Financial Data
Financial investigations of the syndicate members revealed they operated across multiple countries
and jurisdictions, hiding their illicit activities behind legitimate wildlife trading companies, including
a farm to hold wildlife. They engaged in the large scale trafficking of CITES Appendix I species
including chimpanzees. The syndicate utilized the formal financial system to conduct transactions
from bank accounts in your country, Japan, Hong Kong SAR, Macau SAR, China and Singapore
into West Africa, primarily Guinea and Ghana. The amounts ranged from $5,000 for the purchase
of a falsified CITES permit to $30,000 or $50,000 per animal. Payments were made through a
combination of transactions from business and personal accounts.
37. https://www.bornfree.org.uk/storage/media/content/files/LAGA%20reports/EAGLE__
Briefing_March_03_2017_public_1.pdf
38. https://gfintegrity.org/report/illicit-financial-flows-and-the-illegal-trade-in-great-apes/
39. https://cites.org/eng/guinea_arrest_20150903#:~:text=Ansoumane%20
Doumbouya%2C%20the%20former%20wildlife,issuance%20of%20CITES%20export%20
permits.
34
Drafting the Suspicious Transaction Report/
4. Reporting Suspicious Activity Suspicious Activity Report (“SAR”)
According to a BBC investigation, members of the Traore family also received wire transfers to
a bank account in Guinea for the purchase of chimpanzees. In addition to bank transfers, one of
the accused received large sums from China through money transfer services in the amount of
US$450,000. Investigations into the pet store indicated fraudulent CITES permits were purchased
from Doumbouya for about US $5,000.
Financial Data
Financial data from the transaction review showed:
1. Payments from Hong Kong to the accused’s personal bank account in Ghana, relating to the
purchase of manatees or chimpanzees (US$5,400)
2. Payments from Japanese banks to a company called Fatim Aquarium for the purchase of
manatees (USD $8,525, $9,542, $4,000)
3. Payments from your country to Guinea to a personal account for the purchase of chimpanzees
The network also utilized Western Union to transfer payment for the network. Wire transfers
referenced live animals; e.g. ‘Purchase of Live Birds”, “Birds Payment”, “Payment for African Grey
Parrot” or more generic information e.g. “Advance Payment for Goods” or “Freight Charges.”
The Enforcement Outcome

In 2015 Doumbouya was convicted of forgery, falsification of records, and usurpation of function
related to his involvement in the illegal wildlife trade ring. For the charge of forgery alone he was
eligible for 3-10 years of imprisonment and/or a fine of GNF 1,000,000 to 10,000,000 for committing
forgery in the performance of his duties. The court sentenced him to 18 months imprisonment and
a fine of GNF 500,000, however he appealed the ruling, and received a presidential pardon before a
decision was ever handed down about the ruling.
Drafting the Suspicious Transaction Report/Suspicious Activity

Report (“SAR”)
Now that you have examined the wider networks that the Pet Store may have been linked to, you
need to make a decision on what action to take. Your review of the media has not found anything
further on the Pet Store but your transaction review has revealed transactions paid to an individual
implicated in the illegal wildlife trade. You consider the risks of maintaining the client in line with
the bank’s risk appetite and decide to submit a STR/SAR in your jurisdiction. You note in your
report:
• The Pet Store does not have a formal web presence
• The owner of the Pet Store also does not have a public profile
• The transaction review revealed a number of transactions to African names but you were unable
to determine who the counterparties were
• The transaction detail was not consistent with the Customer Due Diligence records in terms of
transaction geographies and volume/value of transactions
• There were transactions to a CITES Management Official in Guinea who was convicted of
falsifying CITES permits
35
Drafting the Suspicious Transaction Report/
4. Reporting Suspicious Activity Suspicious Activity Report (“SAR”)
The decision of whether or not to file a suspicious transaction report often involves weighing up
a number of risk factors. Should the bank file the STR/SAR and/or monitor the accounts? The
final decision should be documented and supported by the reasoning that was used to make the
determination. Depending on the jurisdiction, threshold for filing might differ.
In this case risk factors involve high risk geographies, high risk industries, transactions related to
repeat wildlife crime offenders, and transactions involving species protected from commercial trade
through an international treaty.

Suspicious Activity Reporting for Dummies, prepared by VERAFIN
https://verafin.com/wp-content/uploads/2017/01/suspicious-activity-reporting-for-dummies-DE-
Verafin.pdf
Good and bad practices in IWT investigations and STR/SAR filing

Best practices and common mistakes for IWT-related investigations and STR/SAR filings are the
same as for any other crime type.
Most common mistake to avoid:

• Forgetting to fill out the narrative section completely and with sufficient detail.
Best Practices (according to Financial Crime Enforcement Network):40

Make sure the following are included:
• Who? (person, company name)
• What? (instrument of mechanism that facilitate the transaction)
• When? (date, frequency, period, detection)
• Where? (branch, department location, account numbers, types of account)
• Why? (type of client, cause for suspicion, other relevant information)
• How? (describe how transaction was completed and as completely as possible the cycle of funds,
including source and application)
40. F
inancial Crimes Enforcement Network, SAR Narrative Guidance Package: https://
www.fincen.gov/sites/default/files/shared/writingcompletesarnarrative_1103.ppt
36
4. Reporting Suspicious Activity Reporting to the FIU
Specific Advice on Escalating IWT Investigations to Senior Management and to

the Board of Directors
• R eference financial institution commitments under the 2018 Mansion House Declaration
(especially applicable for organizations which are members of the United for Wildlife Financial
Taskforce)
• Reference reputational risk for being seen as associated with spread of zoonotic disease like
covid-19
• Reference key publications highlighting the scale and importance of IWT-related financial crime,
e.g.:
• Money Laundering and the Illegal Wildlife Trade, Financial Action Task Force (FATF),
June 2020
• I llegal Logging, Fishing, and Wildlife Trade: The Costs and How to Combat It, World
Bank, October 2019
• Contact the United for Wildlife Financial Taskforce for case-by-case advice
Reporting to the FIU
Once the investigation has been completed and a decision to file an STR/SAR has been taken,
existing channels for other financial offenses should be followed. Most FIU’s have online systems
for filing STRs/SARs. There typically are no special IWT channels.
• Once the STR/SAR has been reported, the FIU will review it, conduct initial checks, and if deemed
credible, refer it to the appropriate law enforcement agency for further investigation.
• The reporting party will be unable to control which law enforcement agency has access to the
data.
• Depending on the jurisdiction, there might be no feedback on whether or how the information
filed has been used.
Separately, the bank will need to decide whether to retain the client and accept risks associated
with their activities, conduct further checks and monitor the account, and/or exit the client based
on the risk evaluation management feedback and decisions.

Sample SAR forms from the Financial Intelligence office in Macau SAR, PRC (in English,
Portuguese and Chinese)
https://www.gif.gov.mo/web1/en_forms.html
Disclaimer: Despite using it for this exercise, Macau’s trade in pets is actually quite limited
these days. You can read more about IWT in Macau in this report by TRAFFIC: https://www.
traffic.org/site/assets/files/12452/macau-report-web.pdf
37
What Role Can Banks
4. Reporting Suspicious Activity and Financial Institutions Play?
What Role Can Banks and Financial Institutions Play?
In 2020 FATF noted the threat to biodiversity, public health and governance associated with
transnational organized illegal wildlife trade, and highlighted how criminals “exploit weaknesses
in the financial and non-financial sectors, enabling further wildlife crimes and damaging financial
integrity. Despite this, jurisdictions rarely investigate the financial trail left by this crime.”41
Banks and financial institutions can address this shortfall and play a key role in “following the
money,” and can provide substantive data to financial intelligence units to further law enforcement
investigations and ultimately disrupt and dismantle criminal networks.
For financial institutions to play a role in combatting the illegal wildlife trade, they can:
• Monitor the media and trigger investigations where illegal wildlife trade suspects are named.
• Work with counterparts in other countries where the funds may be sourced or being sent to.
Connect with regional and global intel units, and share information.
• Lead and participate in regular PPP forums with law enforcement and NGOs focused on
combatting illegal wildlife trade to understand the problem or the criminal “business model.”
• Share “patterns and trends” on investigations completed for the illegal wildlife trade.
• Create internal watchlists and link to existing Environmental Crime Watchlists that will flag
potential illegal wildlife trade offenders for further review.
• Join the United for Wildlife Finance Taskforce and receive regular alerts on illegal wildlife trade
syndicates, trends, typologies, and red flags.
Case Studies: Leveraging the United for Wildlife Financial Taskforce
Case Study 1:
From IWT Red Flags to Actionable Intelligence
PROCESS:
• United for Wildlife via the Basel Institute on Governance publishes IWT red flags regarding IWT
related financial activities near national parks and corruption in wildlife protection authorities.
• Africa-based financial institution screens accounts and transactions (a) geolocated to towns and
villages nearby national parks and/or (b) connected to national park employees and officials.
OUTCOMES:
• Financial institution identifies series of previously unnoticed suspicious account and transaction
activity.
• Appropriate AML controls and reporting obligations implemented
• Sanitized findings shared with to other United for Wildlife Financial Taskforce member
institutions.
• Further refinements made to relevant red flag typologies and screening protocols
38
Public-Private-Partnerships to Combat
4. Reporting Suspicious Activity Illegal Wildlife Trade
Case Study 2:
Public Private Intelligence Sharing Against the Illegal Wildlife Trade
PROCESS:
• Law enforcement agency requests assistance with sensitive information on the subject of an
investigation.
• Law enforcement agency passes information to United for Wildlife via the Basel Institute on
Governance.
• United for Wildlife analyzes and enriches information with open source research and provides
onwards to relevant financial institutions
• United for Wildlife connects law enforcement agency officials directly with financial institution
representatives
OUTCOMES:
• Financial institution receives high quality actionable information on IWT activity
• Law enforcement is able to have direct discussions with financial institutions on active cases
within lawful protocols and limitations.
• Appropriate AML controls and reporting obligations implemented
Public-Private-Partnerships to Combat Illegal Wildlife Trade
FATF noted in 2020 the importance of collaboration between the public and private sector to
identify and disrupt financial flows linked to the illegal wildlife trade. Public-Private Partnerships
(PPPs) can improve crime prevention and detection by bringing together law enforcement and
the private sector to share intelligence and information. A well-established model is the UK’s Joint
Money Laundering Intelligence Taskforce (JMLIT) which combats a number of priority crime
types in the United Kingdom. A similar, newly established PPP, is the South African Anti-money
Laundering Integrated Taskforce (SAMLIT). SAMLIT has established key working groups within the
PPP to tackle the illegal wildlife trade, bringing together law enforcement, the financial sector, and
experts on the illegal wildlife trade.
While PPP models vary, the more formal JMLIT or SAMLIT models utilise existing laws to
provide pathways to share information across taskforce members. More informal PPPs have also
been trialled across Southern Africa; however limitations persist in the sharing of intelligence
information. One of the key benefits of the PPP model is the creation of a dedicated network
of professionals working toward a common goal- disrupting illegal wildlife trade networks and
increasing arrest and conviction rates. The ability to know who to call in each agency has sped up a
number of financial investigations in Africa, including cases investigating corruption and the illegal
wildlife trade. In the illegal wildlife trade space, the United for Wildlife Financial Taskforce is a
powerful example of the ways in which public-private partnerships can birth innovative approaches
to traditional problems.
39
4. Reporting Suspicious Activity Key Learning Points
Chapter 4 – Key Learning Points

ACAMS Chapter efforts - A Whole System Response to Tackling IWT (4P Model):
https://www.acamstoday.org/breaking-down-barriers-to-combat-illegal-wildlife-trade/
• Financial institutions have a key role to play to combat the illegal wildlife trade.
• Media, external sources of information, and internal alerts can act as triggers to open a financial
investigation linked to the illegal wildlife trade.
• Corruption plays an enabling role with falsified documents and linkages to PEPs to facilitate the
• Public-private-partnerships can provide increased collaboration and ability to combat the illegal
wildlife trade.
Thank you for completing the ACAMS-WWF Ending Illegal Wildlife Trade Certificate,
supported by The Royal Foundation, United for Wildlife and the Basel Institute on Governance.
Together we can combat illegal wildlife trade.
40
Endnotes – Reading List
Endnotes – Reading List
1. U
NODC, World Wildlife Report, 2020. Available from: http://www.unodc.org/documents/data-and-
analysis/wildlife/2020/World_Wildlife_Report_2020_9July.pdf
2. U
NODC, World Wildlife Report, 2016 Available from: https://www.unodc.org/documents/data-and-
analysis/wildlife/World_Wildlife_Crime_Report_2016_final.pdf
3. U
NODC Education for Justice Modules, 2019: Available from: https://www.unodc.org/e4j/en/
wildlife-crime/module-3/key-issues/criminalization-of-wildlife-trafficking.html
4. U
NEP-INTERPOL, The Environmental Crime Crisis, 2016. Available from: http://wedocs.unep.
org/handle/20.500.11822/9120
5. U
NEP-INTERPOL, The Rise of Environmental Crime, 2016, Available from: https://wedocs.unep.
org/bitstream/handle/20.500.11822/7662/-The_rise_of_environmental_crime_A_growing_threat_
to_natural_resources_peace%2C_development_and_security-2016environmental_crimes.pdf.
pdf?sequence=3&isAllowed=y
6. R
USI, Follow the Money: using Financial Investigations to combat Wildlife Crime, 2017.
Available from: https://rusi.org/event/paper-launch-follow-money-using-financial-investigation-
combat-wildlife-crime
7. T
he East and Southern Africa Anti-Money Laundering Group (ESAAMLG) – A Special Typologies
Report on Wildlife Crime, 2016. Available from: https://esaamlg.org/reports/TYPOLOGIES-
REPORT-ON-THE-WILDLIFE-CRIMES-AND-RELATED-ML.pdf
8. U
NODC and the Asia Pacific Group on Money Laundering (APG) Enhancing the Detection,
Investigation and Disruption of Illicit Financial Flows from Wildlife Crime, 2017. Available
from: http://www.apgml.org/methods-and-trends/news/details.aspx?pcPage=1&n=1105
9. F
ATF, Money Laundering and the Illegal Wildlife Trade, 2020. Available from: http://www.fatf-
gafi.org/publications/methodsandtrends/documents/money-laundering-wildlife-trade.html
10. W
orld Bank, Illegal Logging, Fishing, and Wildlife Trade: The Costs and How to Combat it, 2019.
Available from: http://pubdocs.worldbank.org/en/482771571323560234/WBGReport1017Digital.
pdf
11. T
he Global Initiative against Trans-national Organized Crime, 2017. Available here: https://
globalinitiative.net/wp-content/uploads/2017/09/TGIATOC-Diplomats-and-Deceipt-DPRK-Report-
1868-web.pdf
12. G
lobal Financial Integrity, Illicit Financial Flows and the Illegal Trade in Great Apes, 2018.
Available from: https://gfintegrity.org/report/illicit-financial-flows-and-the-illegal-trade-in-great-
apes/
41
Other Supporting Organisations
Other Supporting Organisations
1. WWF – https://www.worldwildlife.org/threats/illegal-wildlife-trade
2. Basel Institute on Governance – https://baselgovernance.org/illegal-wildlife-trade
3. United for Wildlife – https://unitedforwildlife.org/
4. S
tandard Chartered Bank – https://www.sc.com/en/about/fighting-financial-
crime/#illegalwildlifetrade
5. Environmental Investigation Agency (EIA) – http://eia-international.org
6. TRAFFIC – www.traffic.org
7. Wildlife Justice Commission (WJC) – https://wildlifejustice.org
8. Global Financial Integrity – https://gfintegrity.org
9. Center for Advanced Defence Studies (C4ADS) – https://c4ads.org/
10. The Global Initiative against Trans-national Organized Crime – https://globalinitiative.net/
11. CITES – www.cites.org
12. INTERPOL – www.interpol.int
13. UNODC – https://www.unodc.org/
14. The World Bank – www.worldbank.org
15. World Customs Organisation – www.wcoomd.org
42
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Ending Illegal

ACAMS: Special Acknowledgments:

Chapter 1: Illegal Wildlife Trade Overview....................................................................... 7

Endnotes – Reading List...................................................................................................... 41

The course is structured into four modules referred to as chapters:

The Course objectives are to:

Chapter 1: Illegal Wildlife Trade Overview

By the end of Chapter 1, you will be able to:

What is Illegal Wildlife Trade?

For more information

Transnational Environmental Crime

Data: World Bank5

What are Wildlife Products Used For?

For more information

What are the Consequences of the Illegal Wildlife Trade?

The Illegal Wildlife Trade as a Serious Organized Crime.

8. WWF Panda - https://wwf.panda.org/our_work/our_focus/wildlife_practice/problems/illegal_trade/

For more information

International Frameworks: (CITES)

13. CITES https://www.cites.org

For more information

Global Wildlife Crime Initiatives:

The International Consortium on Combating Wildlife Crime (ICCWC)

The Consortium includes representatives from:

Regional wildlife enforcement networks include:

The International Union for Conservation of Nature (IUCN)

United Nations Office of Drugs and Crime

United Nations Environment Program

The International Criminal Police Organization (INTERPOL)

Other Supporting Organizations

United for Wildlife

For more information

Chapter 1 - Key Learning Points

2. Identifying Illegal Wildlife Trade Risks

By the end of Chapter 2, you will be able to:

The Illegal Wildlife Trade Supply Chain

The Illegal Wildlife Trade Supply Chain

Source Countries Transit Countries Destination Countries

Regional Food and Wine

For more information

Wildlife Poaching and Trafficking Hotspots

Case Study: The Shuidong Connection

• P oachers were paid $80-100 per kg of ivory

The primary financial flows associated with this network include:

For more information

Chapter 2 - Key Learning Points

3. Escalating Risks (Red Flags and

By the end of Chapter 3, you will be able to:

Risks Associated with Illegal Wildlife Trade

Reasons for this can include especially:

Escalating Illicit Wildlife Trafficking Investigations

IWT investigations should be escalated through normal channels when possible.

Specific Advice on Escalating IWT Investigations to Senior

High Level Corruption Enables the Illegal Wildlife Trade

Case Study: US-linked Cases - The Kromah Case

The US-based Kromah case (2019) also highlighted:

For more information

Case Study: US-China Turtle Smuggling Network (Paypal)

For more information

High Risk Industries

In the destination market high risk industries include:

Illegal Wildlife Trade Red Flags

8. WWF Panda - https://wwf.panda.org/our_work/our_focus/wildlife_practice/problems/illegal_trade/

• P oachers were paid $80-100 per kg of ivory

3. Escalating Risks (Red Flags and