Suspicious Activity Reports May Show a Rise in Wildlife Trafficking

Published: 23 December 2021

Elephant Pic

“Wildlife trafficking is a major transnational organized crime that fuels corruption, threatens biodiversity, damages fragile ecosystems, and can have a significant negative impact on public health and the economy” the The Financial Crime Enforcement Network (FinCEN) said. (Photo: tonyo_au, Pixabay, License)

By David Klein

The U.S. authority in charge of fighting financial crimes like money laundering and terrorist financing said on Monday that it’s seeing more and more suspicious financial transactions associated with illegal wildlife trafficking.

“Wildlife trafficking is a major transnational organized crime that fuels corruption, threatens biodiversity, damages fragile ecosystems, and can have a significant negative impact on public health and the economy” the The Financial Crime Enforcement Network (FinCEN) said in a statement accompanying its threat analysis.

The proceeds of the illegal trade are believed to range from US$7 billion to $23 billion a year.  Financial institutions in the U.S. are required to file Suspicious Activity Reports (SARs) within 30 days of witnessing what may be criminal activity, such as cash transactions over $5,000.

“FinCEN analysis of wildlife trafficking-related SARs filed through late 2021 indicates that wildlife trafficking affects the U.S. financial sector, but that financial institutions’ current identification and reporting of potential wildlife trafficking may not reflect the totality of wildlife trafficking and associated illicit financial activity with a nexus to the United States,” the agency said in the analysis.

The number of wildlife trafficking related SARs, Fincen is receiving has been steadily increasing for years.

“This trend potentially reflects an increasing overall prevalence of wildlife trafficking activity, as well as improved detection and reporting of possible illicit activity by financial institutions, which may be related to increased awareness of reporting obligations pertaining to wildlife trafficking,” FinCEN said.

A majority of the reports were concerned with suspicious fund transfers and money laundering,  according to FinCEN. Among the most common species trafficked were elephants (both ivory and other parts) and rhinoceroses. The proceeds are often masked amongst other industries stemming from the wildlife’s source countries.

Payments for wildlife shipping can be masked as payment to gold, diamonds, or precious metals dealers or to the precious metal trading business,” FinCEN said. “Additionally, gold, diamonds, and other precious metals might be used to facilitate payment as trade for wildlife or to conceal proceeds of wildlife trafficking.”

Cambodia, Cameroon, Democratic Republic of the Congo, Laos, Madagascar, and Nigeria were designated as regions of serious concern regarding the trade.

According to the agency, the crime is often fueled by corruption and vice versa.

“FinCEN identified a possible nexus between corruption activity and wildlife trafficking in 10 percent of the wildlife trafficking-related SARs,” the report said. “Corruption enables various forms of wildlife trafficking and occurs at several points in the wildlife supply chain. The corrupt activities include bribes to foreign government officials—including forest rangers, shipping agents, customs officers, and others—in exchange for information, ignoring illegal activity, not prosecuting, or otherwise facilitating access to obtaining and transporting wildlife.”

It’s also no longer individual actors driving the illegal trade, Fincen explained, but large scale organized criminal networks.

Wildlife trafficking is “largely carried out by international criminal organizations that are well structured, highly organized, and capable of illegally moving large commercial volumes of wildlife and wildlife products and laundering its proceeds,” the director of the U.S. Fish and Wildlife Service said in an April testimony before Congress.

The clients appear to be far more varied.

“Several SARs identified by FinCEN’s analysis mentioned private zoos, animal importers, breeders, pet stores, exotic parks, circuses, safari parks, or hunting-related businesses,” the report said.