The recognition of wildlife crime as a global transnational crime threat has taken on new urgency since President Obama’s 2013 Executive Order on Combating Wildlife Trafficking. Meanwhile, private transportation logistics and financial services companies have independently expressed concern due to their potential exposure to wildlife and environmental transnational organized crime (TOC) activity, and also a desire to take action. A key impediment to addressing their concerns has been a lack of information on both the types of supply chain abuse that may occur and the types of wildlife criminal networks that may be operating. Such information may help refine and strengthen compliance controls to ensure that funds and services reach their intended beneficiaries.
This paper begins to address this need by:
- Outlining context
- Identifying red flag indicators, high-risk jurisdictions and container profiles
- Providing typologies with examples of wildlife TOC network activity.
We intend for our research to launch a more robust examination of wildlife TOC activity. We hope our efforts may begin to bridge a critical knowledge gap by disseminating information to help African and East Asian-‐‑linked private-‐‑sector transport and payments businesses better monitor their risk. We also recommend that organizations review the US Federal Government’s “Implementation Plan“ for the National Strategy on Wildlife Trafficking, along with the Yearly Typologies Reports released by Asia/Pacific Group on Money Laundering.1 2
All information in this paper is available in open source. While it is far from exhaustive, we believe it may be broadly representative of the threats associated with wildlife TOC activity.
We identify 7 key typologies and conclude that wildlife trafficking networks:
- Nest illicit activities within licit financial and transport systems;
- Create complex means of physical obfuscation;
- Obfuscate beneficial ownership, sources of contraband, and funds by establishing shell or front organizations, or by other strategies;
- Manipulate multi-country accounts and payments schemes, including those that clear through Western Jurisdictions;
- Demonstrate convergence with high-risk illicit activity;
- Demonstrate convergence with bribery and exposure to politically exposed persons (PEPs);
- And demonstrate beneficial, financial, or client relations with environmental product suppliers.