Wildlife Trafficking and Illicit Financial Flows: The role of Financial Investigation
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OECD HIGH LEVEL RISK FORUM - Task Force on Countering Illicit Trade WCO-OECD Regional Policy Dialogue on Countering Illicit Trade: Addressing the Governance Gaps in Europe WCO Headquarters, Brussels, Belgium 7-8 November 2016 https://www.eiseverywhere.com/file_uploads/baa570ac042f8bd70259b7688aaa07cb_AgendaVERSION4.pdf RUSI
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Wildlife Trafficking and Illicit Financial Flows: The role of Financial Investigation
- 1. Wildlife Trafficking & Illicit Financial Flows: The Role of Financial Investigation 8 November 2016
- 2. RUSI, finance and environmental crime • RUSI: defence and security think-tank • Range of security-related (not just military) programmes • Financial crime (Tom Keatinge) • Centre for Financial Crime & Security Studies • Policy focus: UK, EU, FATF, etc • Application of finance as security tool (CTF, HT, CPF) • Partner with other RUSI programmes to bring ‘financial angle’ • Environmental crime (Cathy Haenlein) • IWT and IUU
- 3. Topics for discussion • Wildlife trafficking: setting the scene • Wildlife trafficking as terrorist financing? • Wildlife trafficking as illicit trade and AML predicate offence
- 4. Setting the scene • Poaching v’s trafficking • Conservation v’s security • Wildlife crime v’s financial crime • Agent v’s principle IWT is illicit trade and predicate AML offence
- 5. Quantifying environmental trafficking • Narrow definitions: $7-23bn (2014, UNEP, INTERPOL) • Wider definitions: $70-213bn (14), $91-258bn (16), +5-7% • 4th largest illicit activity (after drugs, human trafficking, counterfeiting) • Wide uncertainty range, variation in estimates, inconsistent data collection, variation in seizure record, volatility in prices
- 6. The pricing incentive: ivory as an example
- 7. The supply chain: ivory
- 8. The supply chain: rhino horn
- 10. Wildlife trafficking as a security threat • Not traditionally viewed as a security threat: environmental security literature, conflict resource literature • View of wildlife trafficking as a conservation, regulation issue • Recent change this decade – rise of 3 narratives: • Poaching, wildlife trafficking and terrorism • Poaching, wildlife trafficking and organised crime • Poaching, wildlife trafficking and human security
- 11. Wildlife trafficking and terrorism • Are terrorist groups earning significant revenues from illegal ivory trade? • Al-Shabaab, LRA, Janjaweed • The narrative is strong • Research and conservation NGO campaigns/reports • Media (Western and East African) • High-level political statements • Main assertions related to Al-Shabaab • Involved directly in poaching • Plays a major role in ivory trafficking
- 12. Wildlife trafficking and terrorism (cont’d)
- 13. Wildlife trafficking and terrorism (cont’d) • Hillary & Chelsea Clinton (2014): • ‘We have seen al-Shabaab from Somalia, the Janjaweed from Sudan, the Lord’s Resistance Army in east Africa and other armed groups move into illegal wildlife trafficking. It has become a multibillion-dollar business…’ • Uhuru Kenyatta (2014): • ‘The money gained from the callous business [elephant poaching] is usually directed into funding terrorism’ • Uhuru Kenyatta (2014): • ‘The war against poaching should be treated as a double- edged sword, which decimates two evils at once’
- 14. Why has the narrative been propagated? • No one likes poachers or terrorists – combining the two makes a good story • ‘Softer’ way for the Western security community to frame increased CT intervention in Africa • For NGOs and private security firms: a way to tap into CT funding from Western governments (over conservation or counter-organised crime funding) • For Kenyan citizens, security forces and ministers, it continues a long-standing process of externalising and politicising Kenya’s security problems, in particular blaming Somalia
- 15. ‘An Illusion of Complicity’ • Exaggerated benefit • At most small-scale, ad hoc, opportunistic and indirect involvement • Conflation of Somali poachers with Al-Shabaab – trend of blaming Somalis • Few herds within easy striking distance of Al-Shabaab • Majority of poachers come from communities in major ranges • Most East African poaching has occurred in Tanzania
- 16. IWT as financial/organised crime • The role of organised crime and corruption at all levels of the chain is far more pervasive • Booming demand and prices – emergence of transnational, industrial-scale and organised operations • Growing evidence of OCG involvement. In East Africa, accepted that OCGs/corrupt officials are main facilitators
- 17. IWT as financial/organised crime (cont’d) • Huge scale/complexity, clear indicators of OC involvement, enabled by high and low-level corruption • This is evident by the difficulties involved in: • consolidating the hundreds of tusks necessary to make up the large volumes involved; • moving them across multiple borders along complex supply chain (air/land/sea routes) • and avoiding interdiction at each stage of these chains
- 18. IWT as financial/organised crime (cont’d) • Growing % of ivory seized in ‘large’ shipments of >500kg – CITES determinant of OC facilitation • CITES data: frequency of seizures has increased this decade. Prior to 2009, an average 5 such events occurred annually; 2009-13 rose to an average of 15 • 2012-14, such seizures accounted for 61% of all ivory confiscated worldwide
- 19. Tackling IWT as a financial crime • RUSI HMG-funded project investigating illicit financial flows related to IWT in Kenya, Tanzania, Uganda • Desk-top research; phone and field interviews • Private sector; local law enforcement; FIUs; anti- corruption offices; ODPP; NGOs; multi-lateral organisations • Next phase: in-country training for public/private sector
- 20. IWT: illicit trade, linked to OC and corruption Yang Fenglan: Chinese national, 70 tusks, 1.9 tonnes, US$1.4 million, in court Feisal Mohamed Ali, Kenyan national, 2 tonnes, jailed for 20 years – big success.
- 21. IWT: response must be shaped accordingly • Countries have made progress tackling ‘wildlife crime’ • Reduced poaching of rhino/ elephant (eg 80% in Kenya) • New laws (cf Kenyan Wildlife Conservation & Management Act, 2013) • But… • More ivory shipped through Mombasa than any other African trade route • Financial investigation techniques underused • Network analysis not exploited • Link between IWT and AML/financial crime not exploited • Rare use of financial evidence in court • Who pays bail and fines?
- 22. Considering responses • Champion financial investigation • Apply financial crime legislation Public Sector Capacity Building • IWT spans the globe; so do financial institutions • Support training for correspondent banks • Develop awareness in transport/logistics industry Private Sector Involvement • Raise IWT profile in appropriate for a addressing financial crime and illicit trade, e.g. FATF/OECD • Industry efforts; cf Royal Foundation logistics initiative International Support
- 23. Thank you and questions…? • Tom Keatinge, Director • RUSI Centre for Financial Crime & Security Studies • Tel: +44 7785 363 259 • Email: tomk@rusi.org • Cathy Haenlein, Research Fellow • Environmental Crime Research • Tel: +44 7762 718 992 • Email: cathyh@rusi.org
Notas do Editor
- In case it's not clear - 7-23 is basically flora and fauna alone. 70-213 /91-258 is flora and fauna (wildlife trafficking), illegal logging, illegal fishing, toxic waste, and UNEP/INTERPOL include one more. The diagram to the right is not UNEP/INTEROPOL (whereas the figures on the left are) - but that's fine, if you explain that there are different estimations.
- I think fine to use this map but do worth specifying that these prices are difficult to calculate and constantly changing - and that this map is from July 2014. I just checked and it's from a C4ADS report: the title they use for the map is 'Comparative Prices (per kg) Across Africa and Asia (July 2014)'
- Elephant losses: Africa: 1979, 1.3 million; today, 415,000 (IUCN) Tanzania: 60% drop: 109,000 in 2009 to 43,000 in 2014 (gov census) Central Africa: 62% drop in forest elephants, 2002-11 (Fiona Maisels et al.)
- White rhino: 19,682–21,077; black rhinos 5,042–5,455 South Africa, home to vast majority of white rhinos and 40% of black rhinos. 13 poached in 2007, 122 in 2009, 448 in 2011, up to a peak of 1,215 in 2014 (numbers dropped slightly to 1,175 last year)
- Al-Shabaab has not benefited from East African illegal ivory trade to anywhere near the extent that many have thought via direct engagement in poaching What little evidence there is suggests at most small-scale, ad hoc, opportunistic and indirect involvement Conflation of Somali poachers with Al-Shabaab – trend of blaming Somalis Very few elephant herds lie within easy striking distance of Al-Shabaab; the majority of poachers apprehended in Kenya come from communities in major ranges; and most East African poaching has occurred in Tanzania
- The role of organised crime and corruption at all levels of the chain is far more pervasive Booming demand and prices – emergence of transnational, industrial-scale and organised operations Growing evidence of OCG involvement. In East Africa, accepted that OCGs/corrupt officials are main facilitators Huge scale and complexity are the clearest indicators of OC involvement, enabled by high and low-level corruption. This is evident by the difficulties involved in: consolidating the hundreds of tusks necessary to make up the large volumes involved; moving them across multiple borders along complex supply chain (air/land/sea routes) and avoiding interdiction at each stage of these chains. Scale of WT: growing % of ivory seized in ‘large’ shipments of >500kg – CITES determinant of OC facilitation. CITES data: the frequency of such seizures has increased this decade. Prior to 2009, an average 5 such events occurred annually; 2009-13 this rose to an average of 15. 2012-14, such seizures accounted for 61% of all ivory confiscated worldwide.
- The role of organised crime and corruption at all levels of the chain is far more pervasive Booming demand and prices – emergence of transnational, industrial-scale and organised operations Growing evidence of OCG involvement. In East Africa, accepted that OCGs/corrupt officials are main facilitators Huge scale and complexity are the clearest indicators of OC involvement, enabled by high and low-level corruption. This is evident by the difficulties involved in: consolidating the hundreds of tusks necessary to make up the large volumes involved; moving them across multiple borders along complex supply chain (air/land/sea routes) and avoiding interdiction at each stage of these chains. Scale of WT: growing % of ivory seized in ‘large’ shipments of >500kg – CITES determinant of OC facilitation. CITES data: the frequency of such seizures has increased this decade. Prior to 2009, an average 5 such events occurred annually; 2009-13 this rose to an average of 15. 2012-14, such seizures accounted for 61% of all ivory confiscated worldwide.
- The role of organised crime and corruption at all levels of the chain is far more pervasive Booming demand and prices – emergence of transnational, industrial-scale and organised operations Growing evidence of OCG involvement. In East Africa, accepted that OCGs/corrupt officials are main facilitators Huge scale and complexity are the clearest indicators of OC involvement, enabled by high and low-level corruption. This is evident by the difficulties involved in: consolidating the hundreds of tusks necessary to make up the large volumes involved; moving them across multiple borders along complex supply chain (air/land/sea routes) and avoiding interdiction at each stage of these chains. Scale of WT: growing % of ivory seized in ‘large’ shipments of >500kg – CITES determinant of OC facilitation. CITES data: the frequency of such seizures has increased this decade. Prior to 2009, an average 5 such events occurred annually; 2009-13 this rose to an average of 15. 2012-14, such seizures accounted for 61% of all ivory confiscated worldwide.