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Written by Teodora Harrop, FICA on Monday February 21, 2022
The United Nations has proclaimed 3 March as World Wildlife Day, in order to celebrate and raise awareness of the world’s wild fauna and flora. This article, the first in a series on the illegal wildlife trade, examines the importance of disrupting it and the efficacy of sanctions as an effective tool in its prevention.
With imports ranging from caviar and orchids to traditional medicine, the EU is one of the world’s biggest markets for the trade in wildlife. Yet alongside this legal, legitimate trade, illegal wildlife trading has risen steadily, in part due to growing consumer demand for rare species.
Despite this growth, the imperative to prevent and disrupt illegal trade has been gaining momentum, with the pandemic contributing to a greater public awareness. This was reflected in the recent G7 2030 Nature Compact, with one commitment stressing the need to:
[Step] up our efforts at home and overseas to counter crimes that affect the environment: we will recognise and tackle illicit threats to nature such as the illegal wildlife trade (IWT) as serious organised crimes, including intensifying efforts to combat money laundering of the criminal proceeds of these crimes.
The G7 emphasis on domestic and international efforts begs the question of whether illegal wildlife trade risk is sufficiently well understood at a jurisdictional level.
In 2020, FATF recommended that:
Even countries without significant wildlife resources should consider whether criminals might be using their financial or non-financial system to lauder proceeds from IWT. In other words, transit, destination and third countries should consider assessing such risks.
Take as an example the 2020 UK national risk assessment. Though this underlined the risks associated with the illegal wildlife trade, it did not quantify the risk exposure or mitigating actions in any level of detail:
To varying degrees, the UK is a source, transit and destination country for illegally traded wildlife. Among a wider range of species, this includes the illegal sale of ivory products via online marketplaces and social media with payments made through online payment platforms. The proceeds involved can in some cases reach significant amounts but typically involve lower levels of proceeds in the UK, with the potential to generate exponentially larger proceeds when shipped overseas and resold in the jurisdiction of the purchaser.
At the other end of the spectrum, some jurisdictions, such as Laos, have not carried out national risk assessments yet. To put this into context, the country’s last FATF Mutual Evaluation report noted that in Laos, ‘a great variety of wildlife is currently openly traded in northern areas, often in large volumes.’
The Mutual Evaluation also highlighted the following concerns:
The ‘Golden Triangle’ represents an area where the borders of Laos, Myanmar and Thailand meet at the confluence of the Mekong and Ruak rivers. It is also one of the oldest illegal drug supply routes and the main opium production area of Southeast Asia.
Back in 2015, an investigative report published by the Environmental Investigation Agency revealed the dark underbelly of the highly lucrative illegal wildlife trade, with a restaurant based in the Golden Triangle reported to be serving ‘sauté tiger meat’ and ‘tiger bone wine’. The report also noted that, distressingly, bears ‘are not just poached and farmed for their bile, paws are soaked in liquor or cooked in soup’.
The Kings Romans Casino, also in the Golden Triangle, has allegedly been used for many years to launder cash from the illegal operations of a criminal network headed by one of its owners, Zhao Wei. This network has also been reported to be engaged in a wide range of criminal activities, including drug, human and wildlife trafficking.
Cognisant of the risks posed and their wide ramifications, the US OFAC imposed sanctions against the Zhao Wei Transnational Criminal Organisation in 2018, thus setting a precedent in sanctions imposed against persons engaged in the illegal wildlife trade. Despite the imposition of US sanctions, various news reports in 2021 revealed that Zhao Wei had ambitious expansion plans, including the construction of a $50 million port in another strategic area, continuing seemingly uninterrupted a successful business.
This example reveals that, on its own, the deployment of sanctions is an insufficient and ineffective response and that building a criminal case for prosecution is crucial in disrupting the illegal wildlife trade and other criminal activities.
Notwithstanding its significant contribution to G7, the UK can act swiftly through its autonomous sanctions regime to introduce sanctions against key actors involved in the illegal wildlife trade and prevent the financial system from being misused through laundering the proceeds of such a heinous crime.
The UK also has a mature criminal justice system and can take swift and decisive steps to prosecute any cases. The key challenges of gathering sufficient evidence and cooperating with law enforcement in other jurisdictions with less mature criminal systems do, however, remain.
Changing the behaviour of the consumer, and thus reducing the demand for wildlife products, is also a significant factor in the overall effort against the illegal wildlife trade. Combined, these initial steps are substantive and important measures with which any fight against the illegal trade in wildlife must begin.
The next article in this series will discuss measures that could be applied by corporate entities to prevent misuse of the financial sector.
 The United Nations, World Wildlife Day: https://wildlifeday.org/ - accessed February 2022
 G7, G7 2030 Nature Compact: https://www.g7uk.org/wp-content/uploads/2021/06/G7-2030-Nature-Compact-PDF-120KB-4-pages.pdf – accessed Dec 2021
 Financial Action Task Force, Money laundering and the Illegal Wildlife Trade, June 2020: https://www.fatf-gafi.org/media/fatf/documents/Money-laundering-and-illegal-wildlife-trade.pdf – accessed Dec 2021
 HM Treasury, National risk assessment of money laundering and terrorist financing 2020, December 2020: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/945411/NRA_2020_v1.2_FOR_PUBLICATION.pdf – accessed January 2022
 Asia Pacific Group on Money Laundering, ‘Mutual Evaluation Report Lao PDR July 2011’, 30 June 2011: http://www.apgml.org/members-and-observers/members/member-documents.aspx?m=a6c4a803-0e15-4a43-b03a-700b2a211d2e – accessed Dec 2021
 Environmental Investigation Agency: Sin City: Illegal wildlife trade in Laos’ Golden Triangle Special Economic Zone, March 2015: https://eia-international.org/wp-content/uploads/EIA-Sin-City-FINAL-med-res.pdf – accessed Dec 2021
 OFAC, Treasury sanctions the Zhao Wei Transnational Criminal Organization, 30 January 2018: https://home.treasury.gov/news/press-releases/sm0272 – accessed Dec 2021
 Radio Free Asia, ‘Chinese Casino Mogul Zhao Wei Explores Expansion Out of Laos’ Golden Triangle SEZ', 7 April 2021: https://www.rfa.org/english/news/laos/zhao-04072021142653.html – accessed Dec 2021
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