Tackling the crossovers between forest and wildlife crime

The convergence between wildlife and forest crime

Wildlife and forest crimes are inextricably linked. Illegal wildlife and timber move through the same geographical hotspots. Traffickers use the same trading and shipping methods. The same transnational criminal syndicates are behind both illegal wildlife and forest crimes.

Given the breadth of our work and the wealth of information that we hold, EIA is uniquely placed to look at the connections between the illegal wildlife trade and illegal logging. We aim to fill a significant gap in the understanding of the links between the two areas and to share our expertise to help combat environmental crime.

Our work in this area includes:

• disrupting the transnational criminal networks behind these illegal trades;
• promoting cross-border and inter-agency collaboration;
• highlighting the crossover points, or ‘nexus’, between wildlife and forest crime;
• Pursuing the dirty money that flows from forest and wildlife crime;
• campaigning for stronger penalties for wildlife and forest crimes and effective enforcement:
• preventing the smuggling of fauna and flora through maritime routes.

Exposing the nexus of environmental crime

Our track record in combatting wildlife crime

EIA has unparalleled experience and expertise in the areas of the illegal wildlife trade and illegal logging, beginning work on wildlife crime in the mid-1980s and contributing to the global agreement to ban the international ivory trade in 1989.

Our work on illegal logging began in 1999 with a focus on Indonesia. Since then, we have been at the forefront of providing credible evidence to leverage reform within the forestry sector in producer countries in South-East Asia and among consumer states.

We have published a wealth of information on forest and wildlife crime, including investigative reports, policy recommendations, short films and enforcement guides.

EIA has considerable experience of relevant international processes, regularly attending conferences organised by CITES (an international agreement between governments to protect flora and fauna) and the United Nations Commission on Crime and Criminal Justice (CCPCJ).

We are engaged in multiple regulatory processes within East Asia and ensure information is available for enforcement through the European Union Timber Regulation (EUTR). Through this work, we have built an expansive network of enforcement contacts.

Environmental crime: a growing global threat

According to a 2016 INTERPOL-UNEP report, the value of environmental crime rose by 26 per cent between 2014-16 . Overall, it’s now the fourth largest crime type in the world monetarily, after narcotics, counterfeiting and human trafficking.

Destroying the environment and fuelling global crime

The cost of environmental crime goes far beyond the staggering $91-258 billion worth of natural resources stolen by criminals every year.

Illegal logging exacerbates deforestation and climate change, undermines ecological security and harms rural livelihoods. The illegal wildlife trade impacts rural economies and impairs the rule of law, destroys ecosystems and threatens biodiversity. Every day, endangered animals such as elephants, pangolins and tigers are forced closer to extinction due to trafficking and poaching.

The vast sums of money generated by environmental crime ensure that international criminal syndicates stay in business and are able to extend their reach ever further.

Falling through the gaps

While there are indications that the scope and severity of wildlife and forest crimes are belatedly being recognised by national governments and international institutions, all too often they are not seen as a law enforcement priority. As a result, they continue to offer criminal networks high profits at a low risk as lenient penalties do not act as a deterrent.

In addition, the regulatory response is all too often fragmentary, treating wildlife and forest crimes as distinct and separate. The first London Conference on the Illegal Wildlife Trade, in 2014, focused almost exclusively on fauna. And at a country level, different policies are often pursued to curb illegal logging and illegal wildlife trade and different government agencies are often involved in enforcement.

Clear links between illegal wildlife and timber crime

Yet there are clear linkages between wildlife and forest crimes. For example, CITES, the primary means of regulating trade in wildlife, increasingly lists tree species. Both crime types often involve money laundering and corruption and there are geographical overlaps in some regions.

Highlighting the nexus between wildlife and forest crime

Research by our Wildlife and Forests teams in Africa and Asia has revealed major crossovers between the illegal wildlife trade and forest crime, now published in our Double Impact report.

This follows on from the London Conference on the Illegal Wildlife Trade in 2018, when the UK Government asked EIA to explore possible missed opportunities in addressing forest crime that may also be relevant to the illegal wildlife trade.

EIA Senior Campaigner James Toone comments: “The value of this work lies in EIA’s intelligence-gathering and its unique understanding of wildlife and forest crime over more than three decades.”

Three areas where wildlife and forest crimes overlap

Our Double Impact report investigates three key areas where there is a connection between illegal timber and the illegal wildlife trade:

• geographical hotspots;
• illegal wildlife hidden in timber shipments;
• deforestation and poaching.

1. Geographical hotspots

In Africa and Asia, there is a significant convergence between illegal wildlife and illegal timber ‘hotspots’, transportation routes, processing hubs and key ports. EIA’s analysis further points to a geographic convergence at the local level, with specific towns and cities acting as hubs for both crime types in hotspot countries.

Transnational organised crime groups use the same networks of corruption from source to destination to facilitate the movement of both illegal wildlife and forest crime products.

Pangolin scales are trafficked from Africa to Asia in large quantities. This trade closely mirrors the trades in other illegally sourced wildlife and timber.

Hotspots in Africa

In Africa, there is considerable overlap in the ports used to export illegal wildlife and illegal timber. These tend to be the major ports in the nexus country hotspots. In particular, we would highlight Apapa Port Complex in Nigeria, Pointe Noire in Republic of Congo and Matadi in Democratic Republic of Congo.

Other areas of intra-country geographic convergence include towns such as Sagamu in Nigeria, which acts as a transit point for illegal timber and a consolidation hub for pangolin scales, and national parks such as Messok Dja in Republic of Congo, which are afflicted both by poaching (in this case, of forest elephants and pangolins) and illegal logging.

Chris Hamley, EIA’s Senior Pangolin Campaigner, discusses what’s driving the pangolin scale and ivory trade with two of our in-country partners in the Democratic Republic of the Congo and Uganda.

Hotspots in Asia

China and Vietnam are significant in the source, import, processing, sale and consumption of illegal wildlife and timber products from Asia, while Vietnam is also an important transit country.

Dong Ky, Vietnam is a major processing centre for ivory, rhino horn and rosewood. The area attracts Chinese buyers looking to source these products.

China and Vietnam are the countries in Asia most frequently identified as transit/destination points for ivory, pangolins and rhino since 2018.

Beyond Vietnam, Laos, Myanmar, Cambodia, Malaysia, Indonesia and Singapore are all frequently referenced as transit points for illegal wildlife in EIA intelligence reports.

2. Illegal wildlife hidden in timber shipments

In Africa and Asia, there is a significant convergence between the way illegal wildlife and illegal timber are traded and shipped. Traders in Africa and Asia deal in both.

Illegally sourced timber and wildlife products travel to and from similar destinations, require similar equipment to process and ship and rely on the same forms of bribery and corruption. Those operating timber companies can thus maximise their profits with minimal additional work by engaging in the harvesting of both timber and wildlife products.

Traders connected with Vietnam and China

Timber companies being managed by Vietnamese and Chinese individuals, based in Africa, present the highest likelihood of being engaged in the illegal sourcing or trading of wildlife. These individuals remain connected to their country of origin, understand the demand there and are therefore well-placed to shift between wildlife and timber products in response to prices.

Timber: a convenient way to cover illegal wildlife trafficking

Timber companies are useful front operations for the illegal sourcing or trading of wildlife because – provided it is logged legally, is an unprotected species and is moved following due processes – timber does not arouse suspicion.

Wildlife products can be placed among the timber in a container or disguised using more sophistication. One such method involves hollowing out logs before placing the items inside and then filling them with wax and resealing. Other examples are constructing crates to look like stacks of logs and filling the cavity with illegal wildlife products.

Illegal timber species can also be trafficked as a commodity alongside wildlife.

Hiding their tracks

Determining the extent of the use of timber companies as front operations is made complicated by the strategies that criminals use to hide their tracks. Bills of Lading, frequently handwritten, are easily altered to change the origin of the shipment, the commodity listed or the company responsible for shipping a container. This is done to ensure ‘red flags’ – such as a high-risk country of origin or cargo – would no longer be visible.

Discover more about our work to prevent the smuggling of fauna and flora through maritime routes.

3. Deforestation and poaching

In Africa and Asia, there is a significant correlation between deforestation and increased levels of poaching which, in turn, often leads to higher levels of illegal wildlife trafficking activity.

The elephant population in Gabon’s Minkébé National Park deteriorated dramatically in the early 2000s. This coincided with intensive logging near the border with Cameroon which made the area much more accessible to poachers.

Illegal logging threatens wildlife

Illegal logging and land clearance pose numerous threats to the environment, including habitat destruction and loss of biodiversity, as well as leaving wildlife vulnerable to poaching for consumption and trade[i]. There is also a significant link between logging and the destruction of certain species within forested areas[ii][iii].

Poaching has been found to have been carried out by employees of logging companies, which view wildlife as a free subsidy that can be used towards feeding their workers.

[i] Brodie JF, Giordano AJ, et al. 2015. Correlation and persistence of hunting and logging impacts on tropical rainforest mammals. ConservBiol. Feb;29(1):110-21. http://doi.org/10.1111/cobi.12389

[ii] Symes, W.S., Edwards, D.P., Miettinen, J. et al. 2018. Combined impacts of deforestation and wildlife trade on tropical biodiversity are severely underestimated. Nat Commun 9, 4052. https://doi.org/10.1038/s41467-018-06579-2

[iii] Robinson, John & Redford, Kent & Bennett, Elizabeth. 1999. Wildlife Harvest in Logged Tropical Forests. Science. 284. 595-596.https://doi.org/10.1126/science.284.5414.595

Roadbuilding makes wildlife accessible to poachers

Logging access roads, designed to facilitate the transportation of resources into and out of concessions, serve as a conduit for poaching. Poachers can enter the forest using these access roads and, either by placing traps or using guns, can hunt a wide variety of species. These areas of forest also happen to be those where animals have retreated to seek refuge; they therefore have relatively dense wildlife populations, which in turn attract poachers.

Pursuing the dirty money that flows from forest and wildlife crime

According to the 2016 INTERPOL-UNEP report mentioned above, the volume of money generated by wildlife and forest crime totals between $58-175 billion[i]. This amounts to a huge injection of dirty money flowing in and through the world’s financial system.

 $58-175 billion - money generated by wildlife and forest crime 

As a result, the importance of conducting financial investigations to disrupt the criminal syndicates associated with wildlife and forest crime has become a mainstream concept.

Numerous bodies have recommended taking action to tackle illicit financial flows and money laundered from wildlife and forest crime. The framework exists, but action is relatively limited.

[i] https://www.unep.org/fr/node/8026

Why isn’t more happening to pursue illicit financial flows?

Added to the low level of understanding of wildlife and forest crime, other reasons that stand in the way of financial investigations include:

• the absence of these crime types being on statute as predicate offences for money laundering;
• perceptions that these crimes are less serious and therefore lower priority;
• a lack of awareness of the ‘red flag’ indicators necessary to identify wildlife and forest crime financial flows (e.g. undue secrecy, unusual source of funds), meaning low numbers of suspicious transaction reports being generated;
• a lack of regulation of key elements of the financial system in most developing countries where wildlife and forest crime takes place;
• a lack of collaboration between relevant agencies;
• a lack of collaboration across borders to facilitate financial investigations;
• political factors which mean the institutions carrying out investigations may not be able or willing to act with impartiality.

Crossover in financial strategies in forest and wildlife crime

EIA has found notable similarities in the financial strategies of criminals engaged in wildlife and forest crime:

• significant use of cash in source countries to enable the payment of poachers, the small-scale purchase of equipment and for bribery necessary to secure the complicity of officials and politicians;
• a flow of funds back into Asian countries in which the most significant transnational organised criminal syndicates reside or originate from;
• the use of front companies to obscure funds;
• the use of the formal banking system and money service businesses to move funds between Africa and Asia.

Our work to track dirty money

EIA’s work to track flows of illicit funds from wildlife and forest crime through the global financial system includes:

• identifying financial flows linked to wildlife trafficking in our Money Trails report;
• calling for action in our report Tackling Financial Flows from Illegal Wildlife Trade in East Asia;
• lobbying for a crackdown on money laundering through our work with the Financial Action Task Force.

Shutting environment criminals out of the global financial system

In January 2021, EIA assumed responsibility for an innovative project seeking to exclude environmental criminals from the global financial system.

The Media Monitoring system helps financial institutions to curb the huge money flows associated with crimes such as the trafficking of elephant ivory, pangolin scales and other endangered species, as well as timber from illegal logging.

Through this system, EIA and other NGOs compile information from a range of open media sources naming individuals implicated in wildlife crime. This information is then provided to financial institutions to assist with due diligence and Know Your Customer checks to avoid doing business with wildlife traffickers.

We have been feeding data into the Media Monitoring system since 2017. In that time, information supplied has led to the creation of 1,100 new or updated profiles for the financial sector to draw on.

Julian Newman, our Campaigns Director, said: “We look forward to overseeing future development of this important tool to make it harder for wildlife criminals to move their money through the global banking system.”

Contributing to the FATF report on money laundering

In 2020, EIA was one of five non-profits that contributed to a major new report by the Financial Action Task Force (FATF) on Money Laundering and the Illegal Wildlife Trade.

The Financial Action Task Force is an independent inter-governmental body that develops and promotes policies to protect the global financial system against money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction. Its recommendations are recognised as the global standards for anti-money laundering and counter-terrorist financing.

The FATF report contains several case studies by EIA and includes a comprehensive series of recommendations on how to tackle the illegal wildlife trade by cracking down on the financial flows that fuel this billion-dollar business.

EIA has also been involved in the work of the FATF looking at risks and trends associated with money laundering linked to illegal logging and land clearances. This will see a report produced in 2021, with more work to follow.

Working with partners to use financial intelligence to disrupt criminal networks

We work with like-minded partners all around the world to unite our knowledge in how best to use financial intelligence to crack down on illegal wildlife crime.

We have recently launched new resources in partnership with the Royal United Services Institute (RUSI), the world’s oldest independent think tank on international defence and security.

Since 2017,  we have run a joint project to increase awareness and boost the ability of key stakeholders to disrupt criminal networks benefiting from illicit funds earned from wildlife trafficking.

Campaigning for stronger penalties for wildlife and forest crimes and effective enforcement

The illegal wildlife and illegal timber trades are run by transnational syndicates that operate across borders. The criminals behind these trades are rapacious in their pursuit of profit and quick to change their methods to exploit any loopholes and weaknesses in the system.

Combatting this level of organised crime is beyond the scope of any single agency or government and requires the engagement of enforcement agencies, prosecutors, judiciary, media, inter-governmental bodies and ordinary citizens.

EIA works with a variety of national and international governmental and non-governmental bodies, as well as with the judiciary and civic society to lobby for more effective law enforcement against wildlife and forest crimes.

Using law enforcement to tackle wildlife crime

As we stated in our Off the Hook report, legislation and law enforcement are powerful behaviour change mechanisms for tackling wildlife crime, stepping up anti-corruption efforts and enhancing access to information and justice.

We recommend the use of specific indicators to evaluate progress and identify key gaps in global efforts to end wildlife crime.

EIA was a partner in the development of the Indicator Framework for Combating Wildlife and Forest Crime, produced by the International Consortium on Combating Wildlife Crime (ICCWC). This includes identifying legislative loopholes and measuring progress by analysing the law enforcement outcomes following wildlife seizures.

Fighting environmental crime in the courts

For decades, EIA has campaigned vigorously for stronger penalties to combat wildlife and forest crimes and for more effective enforcement.

Time and again, our reports, investigations and campaigns have proved instrumental in exposing environmental criminals and bringing them to justice:

• following our investigation into The Shuidong Connection, two major ivory smuggling syndicates were disrupted and 44 people were arrested;
• after two decades of investigations and campaigning by EIA, in 2020 China amended its Forest Law to ban illegally sourced timber;
• we have consistently called on China’s lawmakers to end commercial exploitation of threatened wildlife;
• we successfully led a campaign to close the UK’s ivory market in 2018;
• Following a campaign by EIA and its partner, in 2020 Indonesia shelved plans to drastically dilute its timber regulations.

Gathering intelligence on organised crime networks

EIA’s Intelligence Team is central to investigating environmental crime and abuse. Thanks to the breadth of our investigations, we are able to spot patterns and address the nexus between wildlife and forest crimes.

Staffed by former law enforcement and private sector intelligence professionals, the team works closely with EIA’s field investigators to plan undercover operations targeting wildlife traffickers and individuals involved in other forms of environmental crime such as illegal logging.

Piecing together information from a wide range of sources, EIA's Intelligence Team builds an incredibly detailed picture of organised crime networks, trade routes, patterns and convergence involved in wildlife and environmental crimes.

Mapping locations linked to organised crime networks against events such as commodity seizures can assist in visually showing geographical hotspots and making links between events. This also helps with identifying trade routes for wildlife and timber trafficking.

The team shares its findings with government law enforcement partners and financial institutions around the world, leading to arrests and seizures while disrupting criminal networks and their financial resources.

The Intel Team at EIA also works closely with partners around the world to share knowledge on intelligence processes and assist in building capacity and skills in intelligence analysis.

Working with these partners, and ensuring they have the resources and capability to conduct intelligence-led investigations, is key in disrupting transnational organised crime groups and combatting environmental crime.

Preventing the smuggling of fauna and flora through maritime routes

The role of international shipping companies is increasingly under the spotlight in relation to the smuggling of illegal wildlife and illegal timber.

Illegal timber, ivory, pangolins and pangolin scales are often transported together from Africa to Asia by sea.

Our undercover investigators have discovered vital intelligence that exposes the networks and methods of the criminal syndicates behind the trafficking of illegal wildlife and timber. We are engaging with shipping companies and other private transport operators to do more to stop their services from being used in this way.

West Africa to Asia shipping routes are high risk for both illegal timber and illegal wildlife trafficking. EIA is aware that many shipping, freight forwarding and logistics companies do not have strong enough safeguards to assess whether the timber they are shipping is legal.

Employees of shipping companies can also be corrupted. EIA US’s Cashing-In On Chaos report (2020) presented evidence of how Maersk, CMA CGM and MSC Mediterranean Shipping Company were shipping illegal timber from The Gambia to China. The report led CMA CGM, the fourth largest shipping line in the world, to implement a temporary ban on timber exports from The Gambia.

Case study: Mr X – shipping from Nigeria to Vietnam

Our investigations uncovered the operations of Mr X, an experienced shipping agent who specialises in offering ‘clearing services’ at specific export hubs in Nigeria. We’re not naming him at this point because he is still under investigation.

Mr X regularly ships containers of illicit wildlife products from Apapa seaport to various destinations including Hong Kong, Malaysia, Singapore and Vietnam. The Maersk and Cosco shipping lines are frequently used for transportation. It takes approximately six weeks for a shipment exported from Nigeria to arrive at a port in Vietnam.

Mr X often uses timber, as well as cashew nuts and ginger, to conceal ivory and pangolin scales for his shipments to Asia. When he uses timber as a concealment method, he prefers to opt for a 20ft container as it can hold up to five tonnes of contraband.

Working with the United for Wildlife Transport Taskforce

In 2018, EIA became a member of the United for Wildlife (UFW) Financial Taskforce, which is designed to transform the detection, reporting and investigation of the illegal wildlife trade as a financial crime. This work is closely linked with our ongoing campaigns to recognise the importance of combatting money laundering as a way of tackling the illegal wildlife trade.

At the same time, we became a member of the UFW Transport Taskforce. This campaign’s objectives include researching and documenting hotspots and illicit flows of timber and wildlife, focusing on trafficking between Africa and South-East Asia and China.

One of our top priorities will be to engage with the International Maritime Organization (IMO), the United Nations agency responsible for the safety, security and environmental performance of international shipping.

Under the auspices of the UFW Transport Taskforce, we will work together with EIA US, United for Wildlife, TRAFFIC, WWF and the Wildlife Conservation Society to develop guidelines to prevent the smuggling of flora and fauna along maritime routes.

EIA, together with TRAFFIC, the United Nations Office on Drugs and Crime (UNODC) and WWF – as members of the United for Wildlife Transport Task Force – have also organised a roundtable with a broad range of actors across the maritime industry to deliver a coherent set of ambitious actions that the industry can coalesce around.

The way forward

Based on EIA research and investigations, we maintain it is essential to consider forest crime and illegal wildlife crime together when creating new national or international legislation to tackle them.

We urge the UK Government, international organisations and the governments of nexus hotspot countries to:

• recognise that a nexus between wildlife and forest crimes exists and support those countries affected to address it as it manifests;
• target nexus hotspots, using the Wildlife and Forest Crime Toolkit produced by the International Consortium on Combating Wildlife Crime, to comprehensively assess weaknesses and put in place action plans, which are made public and robustly monitored;
• ensure that where countries can report on or be assessed against progress on environmental crimes and associated enablers such as corruption and money-laundering, they do so;
• improve private sector cooperation to combat illicit wildlife and timber trafficking in containerised supply chains;
• take action to address corruption in ports.

How you can help us target the nexus between forest and illegal wildlife crime

EIA is one of the top 20 most effective environmental charities, according to the Environmental Funders Network.

Please donate today to support our vital work exposing the nexus between the illegal timber trade and the illegal trade in endangered wildlife species.

With our decades of experience in this field, we are ideally placed to spot where these illegal trades overlap, pursue the criminal syndicates who are making a killing behind the scenes, and campaign for stronger penalties and law enforcement.

Please support our work to fight the illegal timber trade and help save endangered wildlife from extinction. Any donation you are able to make today will help us disrupt the criminal gangs that threaten the biodiversity of our planet.