copy the linklink copied!2. Key Findings and Detailed Recommendations

This chapter provides summary of the key findings from the chapters in this report, and offers a series of detailed recommendations for government policymakers, international organisations and non-governmental actors.


copy the linklink copied!Regional context for combatting the illegal wildlife trade

Southeast Asia includes countries that are at once sources of endangered species, as well as transit points and destination markets for illegal wildlife products. This means that enforcement is a mixture of environmental protection, border control measures and market surveillance. The combined scale of the illegal wildlife trade in the region has been estimated to account for up to 25% of the global illicit market in wildlife products (Lin, 2005[1]). Illegal logging and export of exotic woods across Southeast Asia is depleting forests at an unprecedented rate due in part to a worsening poaching and snaring crisis. Illegally trapped wildlife from across the region are exported and transited, often through fraudulent certification schemes, legal loopholes and corruption among state officials. Finally, as a consumption hot-spot, wildlife products across Southeast Asia are consumed in increasing volumes and sold for growing value due to rising incomes among middle classes.

The consumption and poaching patterns across the countries studied are determined by preferences, and domestic and foreign demand factors that change over time and evolve in response to risks and incentives. For example, in Thailand, there is strong demand for ivory jewellery, whereas in Indonesia, millions of birds are traded in open markets for keeping as pets (WildAid, 2018[2]) (Rentschlar et al., 2018[3]). A sharp rise in demand from China for helmeted hornbills (i.e. the “ivory hornbill”) from Indonesia has led to the recent listing of this bird as Critically Endangered (Beastall et al., 2016[4]).

There are four main categories of consumption for illegal wildlife parts, each of which implies a role for a regulatory agency of a different industrial sector:

  • Consumption for clothing and luxury items (i.e. luxury goods for display)

  • Consumption for health and treatment of ailments

  • Consumption for food and beverage

  • Keeping of live specimens for exotic pets or zoos

Many of the same criminal syndicates that smuggle illegal wildlife from different continents abuse and destroy the biodiversity within Southeast Asian countries. For example, traders and vendors of African ivory also engage in domestic trafficking of local tiger parts, Asian birds, and Asian species of pangolin. In Viet Nam, poaching (and deforestation) has led to over 400 wild species of animals being listed as endangered and threatened. In Indonesia, poachers kill thousands of endangered and critically endangered pangolins annually and sell them in regional markets in nearby Viet Nam and China.

Across the focus countries, major transit hubs funnel illegal wildlife trade products into the region for refining, distribution and sale. Complex transit schemes are used across the region to conceal the origin of goods from authorities, including the use of registered companies to import and re-consign goods in Free Trade Zones (Sinagpore AVA, 2018[5]). Increased integration into global trade chains has outpaced developments of stronger institutional capacities in the focus countries required to enforce wildlife crimes. In countries with many islands and dense commercial maritime traffic, border control can be a practical challenge.

Management and responsibilities for enforcing laws and regulations to curb the illegal wildlife trade, and ancillary investigations, are generally structured across multiple agencies and departments. The exception is Singapore, where management of illegal wildlife trade is centrally structured and managed by the CITES management authorities. In the other countries, co-responsibility for enforcing laws against the illegal wildlife trade is pervasive, with the lead agency determined on where along the trade chain the illegal wildlife is located. Most frequently, the government agencies with responsibilities for policy, enforcement and investigations are the CITES Management Authorities and the national police administrations, but numerous institutions could potentially be involved in prevention of the illegal wildlife trade, with different remits and responsibilities for each agency or ministry.

copy the linklink copied!Multi Agency Co-ordination and Multi-National Co-operation: keys to tackling the illegal wildlife trade

As is the case with investigating other forms of transnational organized crime, co-operation across law enforcement agencies is key to gather evidence across geographic and statutory jurisdictions. The involvement of multiple government agencies and other actors (such as international organisations and non-governmental organisations) has enhanced the effectiveness of investigations and prosecutions. Multi-national co-ordination among like-minded agencies such as police, CITES management authorities, and other can widen the net of suspects involved, deepen the ability to investigate and provide wider access to serious criminal charges.

In some cases, governments have formalized multi-agency task forces in response to internal and external pressures. These Wildlife Enforcement Networks (WENs)1 generally involve relevant partner agencies such as police, customs, CITES authorities, prosecutors’ offices and, in some cases, financial intelligence units and anti-corruption agencies. Of the cases studied across Indonesia, Singapore, Thailand and Viet Nam, findings suggest that successful anti-IWT efforts (measured in successful prosecutions, length of penalty and size of monetary penalties) rely on a pro-active investigation, frequent co-ordination, and multi-pronged prosecution.

Multi-national co-operation is also vital for the successful investigation and prosecution of illegal wildlife trade as a transnational organised crime. There are several avenues for multi-national co-operation, from formal Mutual Legal Assistance Treaties (MLATs), to informal networks of law enforcement officials. For formal exchanges of information in the criminal justice pathway, MLATs allow the exchange of evidence and information for the criminal justice pathway. In the informal networks of law enforcement officials, law enforcement officials exchange information and intelligence with one another for investigations and tip-offs, or joint operations. In some cases, international co-ordination has been facilitated through multi-lateral agreements, and in other instances through bi-lateral co-operation.

There are mixed results on the uptake and performance of multi-agency task forces

Despite the stated existence of multi-agency task forces or networks in several countries, the recorded use of these inter-agency structures is infrequent. Pro-active investigations are few and the vast majority of wildlife crimes are prosecuted in silos. In such cases, governments do not rely on a broader charge sheet for increasing penalties.

In some exceptional cases, there have been cases of effective multi-agency co-ordination which have led to strong results. For example, the Thailand WEN has been used in several cases for the pro-active investigation and prosecution complex illegal wildlife trade cases, which have involved national police, customs, forestry and environment or CITES officials, attorney generals’ office and financial intelligence units. Consequently, sanctions have involved lengthy jail terms and asset seizures and forfeitures.

International Co-operation at a regional level (among ASEAN members) is progressing, but further efforts are needed to ensure successful co-operation against illegal wildlife trade

The ASEAN Experts Group on CITES (previously the ASEAN WEN) has facilitated the exchange of relevant information across CITES enforcement officials. However, CITES management agencies are not well equipped to handle or co-ordinate transnational criminal investigations. Therefore, further international co-ordination among police administrations is necessary. A Working Group on Illicit Trafficking in Wildlife and Timber was recently created under the leadership of Thailand within the ASEAN Senior Officials Meeting on Transnational Organised Crime (SOMTC) in 2018. The Working Group’s mandate and ambitions to tackle wildlife crime from an international law enforcement angle highlights a shifting attitude towards environmental crime as a serious form of transnational crime and reflects a positive development in potential international law enforcement co-operation. However, law enforcement co-operation through ASEAN would require dedicated and structured action plans and performance monitoring (such as joint-investigations, joint operations and prosecutions) for effective deployment and action.

Bi-lateral co-operation is relatively strong at the regional level, but gaps remain between illegal wildlife trade counterparts further afield in Africa and Europe

ASEAN countries have established a number of bi-lateral information sharing arrangements among each other in both a formal and informal manner. All of the focus countries have established reciprocal MLATs. Officials in CITES authorities, customs and police use a number of information sharing approaches, from INTEPROL secure messages to WhatsApp chats to keep in touch. Closer co-operation has been facilitated through face-to-face meetings focusing on wildlife crime through fora such as APEC, ASEAN, and regional training and capacity building workshops.

Bi-lateral co-operation between the focus countries and countries outside of the ASEAN region is significantly weaker. For instance, officials reported communication gaps and fewer MLATs between ASEAN and key transit countries and source countries beyond the region. Perceptions of corruption and mistrust among counterparts adds to difficulties in information exchanges across borders2.

Throughout all countries, there is an important role for non-government actors in the wildlife enforcement process

Working relationships between non-governmental wildlife NGOs, relevant intergovernmental organisations can lead to successful enforcement cases with fewer resources or limited government capacities. NGOs and intergovernmental organisations offer expertise, knowledge and programming to enhance institutional capacities of governments to tackle illegal wildlife trade and bridge a number of gaps in resources (which are often spread-thin for environmental crimes). In all focus countries, there are positive linkages between the engagement of non-governmental actors and outcomes for illegal wildlife trade cases. In many high-profile “Kingpin” arrests and prosecutions that were discussed in interviews, the OECD found that non-governmental actors had been involved in providing subject matter expertise, intelligence or information that is critical to the success of these cases3.

Intergovernmental organisations have had a positive impact by supporting training activities, capacity building and strategic policy development for relevant agencies4. Many of these organisations offer a network of international counterparts with whom national agencies and officials can liaise. NGOs offer highly specialized operational capabilities such as intelligence gathering with high tech and low tech devices, investigative assistance, expert legal reviews of environmental laws and court case development.

Non-governmental actors, particularly those working closely with civil society help to provide added transparency and visibility for illegal wildlife trade cases in the media and among communities to raise awareness. While NGOs and Intergovernmental organisations cannot replace the institutional capacities required from relevant agencies, their positive engagement signals a well-synchronised alignment of objectives between the public sector and engaged stakeholders committed to reducing environmental crimes.

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  • Create and develop a model of inter-agency co-operation to combat the illegal wildlife trade that involves ministries and agencies mentioned in the INTERPOL NEST model.

  • In all multi-agency structures, include non-traditional actors such as anti-corruption authorities and financial intelligence units.

  • Strengthen the uptake of multi-agency approaches to combatting the illegal wildlife trade with strategic planning, measurable targets and timelines of illegal wildlife trade cases, investigations and prosecutions. These strategic documents should include metrics for success, including, but not limited to: the number of successful prosecutions per year; number of money laundering investigations; use of instances illegal wildlife trade charged as organized crime and; number of corruption cases.

  • Establish performance budgeting: link budgets and budget approval processes to desired outcomes, in order to achieve complex objectives that may require inter-ministerial collaboration. These methods are outlined within the OECD report “Good practises for performance budgeting.”

  • Center of Government should promote a management culture focusing on performance and performance measurement. Incentives should be aligned to performance, and under-performance and missed-targets for investigations and prosecutions should be addressed through problem-solving rather than individual rewards of penalties .

  • Develop an international framework for reporting standards in consultation with relevant experts and officials. This framework should look beyond seizure incidents and values. Performance reporting and statistics could include the number of successful prosecutions, number of corruption prosecutions and value of assets seized.

  • Government authorities with responsibility for illegal wildlife trade should conduct a gap and needs analysis for legal information sharing instruments. To enhance trust and abilities to share operational information across borders with source countries, further working-level meetings are necessary to build networks of officials connecting source, transit and destination regions to facilitate closer ties and operational exchanges among law enforcement officials.

  • Countries should continue to support the engagement of NGOs and IOs throughout the illegal wildlife trade enforcement process, and international community should continue to support NGOs that foster collaborative approaches to illegal wildlife trade with governments.

  • The international conservation community should reinforce its focus to strengthen policies, legal frameworks and enforcement capacities to deter and combat the illegal wildlife trade in Southeast Asia. This should include a rebalancing of attention, moving towards anti-poaching, anti-corruption, anti-trafficking and anti-money-laundering programming in market countries in Southeast Asia.

  • Increase dialogue between central government agencies and key decision makers to strengthen political will to tackle the illegal wildlife trade. This should involve non-traditional actors to discuss strategic approaches to wildlife crime, including criminal justice officers and judges, national development agencies, public security ministries, ministries of finance and revenue, and financial intelligence units.

copy the linklink copied!Closing gaps in the legal and regulatory framework is essential to overcoming wildlife crime and preventing opportunities for criminal entrepreneurs

The focus countries are party to a number of International Legal Frameworks, including CITES, UN Convention against Corruption and the UN Convention on Transnational Organised Crime. Generally, the criminal sanctions available to punish traffickers are proportionate and deterrent. With the exception of Singapore, all focus countries treat illegal wildlife trade as a serious offense according to the UN Convection on Transnational Organized Crime (carrying maximum penalties in excess of four years’ jail time). Furthermore, illegal wildlife trade can also be considered a predicate offense under Money Laundering laws in all four countries5.

However, the deterrence of wildlife crime is significantly lessened by the inability of courts to prosecute or hand down lengthy or costly penalties. There are numerous gaps in the effectiveness of the domestic legal frameworks in all of the four countries observed. Legal loopholes can take the form of overlapping laws, ineffective legislation or opportunities for fraud and corruption in regulation and licensing schemes. These gaps and loopholes allow grey markets to flourish and create strong profit incentives for criminal entrepreneurs to brazenly operate under the guise of legitimate business dealings.

In several of the select focus countries, the enforcement of CITES Appendix Species only occurs at national borders and domestic trade is regulated by separate, less-stringent laws. Consequently, traffickers sell smuggled CITES listed wildlife products in open marketplaces because there is no way of proving their illicit origins. Consumers in open markets buy fraudulently labelled “captive bred” species which have effectively been laundered into a legal supply chain.

Under specific circumstances, there are laws for legal ivory sales in all four countries6. These laws have been widely abused as a loophole for traffickers to commercially sell illegal ivory into legal channels and stocks. Wildlife management authorities report that these laws are not enforceable, as they not have the capacity or the technologies to differentiate licit from illicitly sourced ivory on a commercial scale, particularly for carved ivory.

Local species fall victim to loopholes through captive breeding schemes

Criminal networks use licenses fraudulently obtained for so-called sanctuaries, zoos and research facilities to capture, breed and sell illegal wildlife products. For example, tigers and Asian black bears are “farmed” for purported use in scientific research or for educational purposes in zoos. However, due to ineffective regulatory oversight, these facilities are in fact used to exploit wildlife in a lucrative illicit market for animal parts, products, and pets.

Legal reforms to close gaps are emerging, but a number of challenges and inconsistencies remain

Governments are beginning to recognize the shortfalls of current laws. For example, Thailand has recently implemented legislation to tighten restrictions on the sale and displaying of ivory in storefronts. Since the legislation went into place, the number of vendors observed has dropped considerably. In Singapore and Viet Nam, governments are reported to be considering an outright ban on the sale of ivory. This would prohibit the open sale of any pre-CITES convention ivory that is presently legal for use.

Despite the efforts to address a number of legal loopholes, large gaps are likely to remain without significant reforms to laws, practises and policies. Many of the problematic legal frameworks in place appear to have been implemented without due consideration for the resources or the practical steps required for their enforcement and verification. Further changes are needed to remedy the status of illegal wildlife trade products being sold through legal channels across all countries of focus.

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  • In response to the open sale of endangered species in domestic markets, introduce legislative amendments that ensure that current wildlife protection laws and penalties make direct reference to all CITES category species (with relevant treatment by category) instead of the current laws which list only a limited number of wildlife species.

  • In response to the failure to control legal channels of ivory products due to persistent loopholes, examine the costs and benefits of an outright ban on the sale of all ivory products regardless of origin or date of kill.

  • To ensure the identification of ivory products that may have been legally acquired, deploy stringent guidelines for the registration, tracking and tracing of ivory pieces. Use vendor and consumer level fines and seizures if compliant certificates are not produced upon request.

  • Introduce capacities and exchange practises on use technological solutions to identify and differentiate new ivory from older ivory, and to identify African ivory to facilitate enforcement actions.

    • In countries where there are reports of zoos and sanctuaries and captive breeding facilities used in illegal wildlife trade, develop a stricter (and enforceable) licensing guideline for the keeping of endangered species. The license application process should include stringent background checks and checklists for suspicious “red flags”

  • Strengthen the traceability and monitoring for captive breeding facilities and implement a better system of oversight for breeders. Approve licenses based on scientific proof-of-concept. Expire current licenses if reasonable justifications or assurances cannot be given.

  • Conduct internal integrity reviews of license granting officers recognising the heightened incentives for corruption to obtain licenses.

  • Given legal loopholes in domestic markets, governments should consider the integration of significantly more CITES authority environmental enforcement officers at ports of entry in consideration of the fact that national points of entry are often the last and only line of defence against the entry and sale of illegal wildlife trade products.

copy the linklink copied!Targeted efforts are needed to address corruption, which continues to facilitate the Illegal Wildlife Trade in Southeast Asia

A 2018 OECD report on illegal wildlife trade and corruption confirmed the important and central role of corruption risks in source and transit countries for illegal wildlife trade across sub-Saharan Africa. Similarly, evidence collected by the OECD in three of the four focus countries in Southeast Asia also suggests that Corruption facilitates the entry, licensing and trafficking of illegal wildlife trade in the region. Through a multi-methods approach, which included open source data collection and in-person interviews with over 90 experts in government and three anti-corruption agencies, the research suggests a number of un-mitigated corruption risks along the trade chain as illegal wildlife trade makes its way to the end-user markets.

The body of evidence for corruption in illegal wildlife trade remains small and anecdotal

There is a dearth of quantitative data on corruption in Southeast Asia. Despite a number of cited corruption risks identified by relevant experts and officials that highlighted the modus operandi of criminal syndicates and corrupt actors, the authors were able to confirm just five cases of corruption investigations for wildlife crime7. Research in this field is also significantly lower than for other regions. In the OECD literature review conducted for this study, the OECD found approximately 20 reports of relevance on this topic in comparison with over 100 articles for the previous 2018 OECD report on this same topic in Southern and Eastern Africa.

OECD findings point to high corruption risks at national border crossings

OECD research indicates that corruption occurs in certain hotspots at national border crossings such as airports, inland border crossings and (likely) seaports. A number of large-scale seizures have taken place at ports, airports and land border crossings where several public sector officials have been arrested for involvement in illegal wildlife trade. Officials accept bribes in exchange for allowing goods to pass through, or to accompany the goods through checkpoints to avoid scrutiny. General corruption schemes, such as bribery for “red-tape” reduction and expedited clearance at borders pose an overall risk to the entry of illicit trade as well, which includes illegal wildlife trade products among other forms of environmental crime (such as illegal logging).

Government officials in airports are at a high risk of corruption. Several schemes have been uncovered that implicate government officials, such as customs, environment officials, police) in bribery and illegal wildlife trade trafficking schemes. Private sector actors in positions of trust are involved in corruption risks. Criminal conspiracies at large airports involving baggage handlers are a known risk. At land border crossings, corruption facilitates the regional movement of illegal wildlife trade products from one Southeast Asian country into the next. Levels of corruption among customs are an important risk to the integrity of the trade chain for illegal wildlife trade products and all other forms of illicit trade.

Investigations continue to focus on the predicate offense, instead of the underlying corruption risks (and corrupt actors)

The majority of charges and prosecutions that involve public officials are for wildlife trafficking offenses instead of corruption crimes such as bribery, embezzlement or abuse of authority. Law enforcement for illegal wildlife trade remains firmly on the predicate offences, and catching the offenders “red handed”, often ignoring any gross violations of public trust committed by officials.

Awareness of corruption and wildlife crime is increasing, but at a national level, more anti-corruption efforts are needed

Despite recognition at the multilateral level (e.g. CITES or G20) that illegal wildlife trade is facilitated by corruption, in nearly all of the anti-corruption agencies consulted, illegal wildlife trade does not feature as a high-level priority among many other competing issues. There is no strong political will or programming to support anti-corruption and illegal wildlife trade in Southeast Asia.

The perception of illegal wildlife trade among the anti-corruption authorities interviewed is that wildlife crimes are a lower priority in comparison with other corruption scenarios. In many cases, public corruption involving illegal wildlife trade does not meet the criteria set by administrations to trigger investigations into alleged corrupt acts.

Progress has been made in some countries. In Thailand, the National Anti-corruption Commission (NACC) enacted reforms to create a Bureau dedicated exclusively to environmental crime, which is staffed with subject-matter experts. In Indonesia, the anti-corruption commission (KPK) is a member of the “multi-door” inter-agency approach to wildlife crime. Despite advances, progress to address and prosecute corruption remains slow. Only a handful of cases in Thailand and Viet Nam have charged public officials with corruption related to wildlife crime.

Corruption remains a sensitive topic of discussion in the countries of focus nonetheless public dialogues are shifting amid broader international recognition of corruption risks. Civil society actors and international organisations have helped to enhance the visibility of wildlife crime. Increasing media attention is also contributing to a growing public recognition of the damages caused by corruption. A number of international organisations and NGOs have assisted in mobilising public opinion and support against corruption and wildlife crime; however, there are no known initiatives or capacity building schemes aimed at addressing illegal wildlife trade corruption risks head-on.

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  • Produce a national anti-corruption strategy for environmental crimes, with specific guidelines for illegal wildlife trade, describing a role for anti-corruption authorities.

  • Strengthen co-operation between anti-corruption authorities and wildlife conservation actors through meetings and regular exchanges of expertise and programming. Ensure that anti-corruption authorities are members of multi-agency task forces.

    • Prioritise systematic collection of corruption incident data on an ongoing basis to quantify the number of cases relating to corruption and illegal wildlife trade in Southeast Asia.

  • Encourage an active role for civil society and NGOs in drawing attention to corruption and to provide programming and expertise for investigators. Allow third-party observers and NGOs with legal expertise to monitor court cases and flag suspicious activities or outcomes during cases under investigation and before the courts.

  • Integrate the prosecution and sentencing of public officials involved in illegal wildlife trade schemes as part of the broader anti-corruption campaigns underway in the countries of focus. Highlight the estimated value, ecological and economic impact of repeat offenses as reasons for referral and investigation within anti-corruption agencies.

copy the linklink copied!Investigations into the illicit financial flows and money laundering investigations are necessary to deter and prosecute wildlife crime in full

Investigations into money laundering and the asset seizure or proceeds of crime are powerful tools that enhance institutional capacities against transnational organized crime and illicit trade in all goods. Wildlife crime is a predicate offense in all four countries studied8. However, ‘follow the money’ approaches to wildlife crime are rare.

Financial investigations, asset seizures and money laundering investigations remain the exception to the rule in the region

Financial Investigation Units (FIUs) feature on multi-agency task forces in two of the four countries studied. However, FIUs or financial investigations by other relevant authorities are rarely undertaken. Findings suggest that relevant officers lack the expertise, capacities, resources, and political support to conduct parallel financial investigations in response to wildlife crime on a consistent basis. Other environmental crimes such as illegal logging cases have been a key area of focus for financial investigations units in several cases across the countries studied due to the perceived costs and revenue loss estimates which are used to justify the involvement of FIUs.

Of the countries studied, Thailand is the only country that has successfully employed financial investigations and asset seizure under anti-money laundering legislation for wildlife crimes. Indonesia’s FIU is also a member of the national multi-agency task force on environmental crime (the “multi-door process”); however, they have not yet been engaged in any wildlife crime cases. In Singapore and Viet Nam, respondents noted that financial investigations units are not included in wildlife enforcement networks and are not core actors in tackling illegal wildlife trade.

At the international level, knowledge of money laundering and wildlife crime is growing, however this does not translate into action on the ground

At the international level, money laundering is widely recognized as a key facilitator of wildlife crime. For example, the World Bank and other consortiums such as the International Consortium on Combatting Wildlife Crime (ICCWC) partner organizations identify money-laundering cases as one of the most effective ways of effectively prosecuting wildlife crime. Despite this recognition among the international conservation community, the Financial Action Task Force (FATF) Style Regional Body (FSRB), the Asia Pacific Group (APG) on money laundering notes that over 70% of 45 FIUs responding to a survey do not find illegal wildlife trade to be a serious money laundering threat. These findings suggest that there is a continued implementation and prioritisation gap among relevant authorities. It remains clear that financial investigations have a role to play in tackling wildlife crime but existing efforts are not sufficient.

Recent private sector initiatives highlight a willingness of the financial sector to engage against illegal wildlife trade, but more effort is needed from regional private sector actors

Financial institutions play a key role in identifying suspicious transactions and reporting risks to governments for money laundering. A recently launched private sector Wildlife Crime Financial Task Force was set up through co-ordination between a number of NGOs and financial institutions under the aegis of the United for Wildlife Project. The Task Force’s objectives include raising awareness; develop training; and support policy development for illegal wildlife trade and money laundering. Of the 22 financial sector signatories, three are financial institutions based in the countries of focus of Southeast Asia.

The inclusion of the financial sector is an important component of anti-money laundering efforts to tackle the financing and proceeds of crime from wildlife crime. However, due to the fact that there are relatively few signatories from financial institutions from Asia, the effectiveness of this initiative may be limited by omission of a critical part of the global illegal wildlife trade supply chain.

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  • Treat illegal wildlife trade as a form of transnational organized crime, and conduct money laundering risk assessments for each case.

  • Elevate illegal wildlife trade as an economic crime (and priority risk for FIUs). Develop methods to calculate the economic and financial impact of illegal wildlife trade by looking at such factors as long-term economic consequences for bio-diversity, tourism revenue, and losses from corruption.

  • Include FIUs as part of multi-agency task forces. Strategic action plans for illegal wildlife trade should set targets that also include money-laundering investigations or asset identification or seizure as a performance objective to tackling illegal wildlife trade.

    • International coalitions should conduct ‘synthetic’ money laundering risk reviews highlighting likely proceeds of crime involved, and potential typologies for suspicious transaction types and share these reports with FIUs in the region.

  • Countries should leverage the expertise and global networks of the Asia Pacific Group (APG), a FATF Style Regional Body (FSRB) to build guidance on implementation of the FATF Recommendations in the context of the illegal wildlife trade illegal wildlife trade. Members could discuss an in-depth study on risks, trends and methods of environmental crimes and money laundering, for use by FIUs and competent authorities.

  • Work closely with banks and other financial institutions, as well as NGOs to strengthen practises in money laundering investigations for wildlife crime.

  • Countries should incentivise the engagement of regionally based Southeast Asia-based financial institutions, as well as financial intermediaries (such as clearing-houses) in the Financial Task Force, and work with private sector bodies to increase awareness, identify risks, strengthen capacities and share typologies.


[6] ASEAN-WEN, Freeland (2016), ASEAN Handbook on Legal Cooperation to Combat Illegal Wildlife Trade.

[4] Beastall, C. et al. (2016), “Trade in the Helmeted Hornbill Rhinoplax vigil : the ’ivory hornbill’”, Bird Conservation International, Vol. 26, pp. 137-146,

[1] Lin, J. (2005), Tackling Southeast Asia’s illegal wildlife trade, http://www.aseansec.

[3] Rentschlar, K. et al. (2018), “A Silent Morning: The Songbird Trade in Kalimantan, Indonesia”, Tropical Conservation Science, Vol. 11, p. 194008291775390,

[5] Sinagpore AVA (2018), Interview with Singapore Agriculture and Veterinary Authority, Singapore, October 15, 2018.

[2] WildAid (2018), Ivory Demand In Thailand, (accessed on 22 November 2018).


← 1. Also known as “multi-door approaches”, also known as inter-agency forces.

← 2. Officials have pointed to examples where evidence and information for prosecutions is vulnerable to corruption risks in several source countries. In one case, authorities interdicted an IWT shipment containing previously seized products stolen from courtroom stocks and smuggled back into Southeast Asia.

← 3. Indeed, non-government actors are well-positioned to assist with IWT cases due to the fact that that governments must compete with many different priorities whereas these specialized groups (many of which are composed of former law enforcement and environment officials) focus on conducting intelligence gathering and network analysis in a highly specific field of expertise.

← 4. The studies conducted in all the focus countries found that non-governmental bodies, in particular wildlife NGOs play a critical role in first co-ordinating among relevant bodies, secondly in providing subject matter expertise and intelligence, and third providing support for court cases that can be used for the successful prosecution of wildlife crimes.

← 5. Either directly or by inference (ASEAN-WEN, Freeland, 2016[6]).

← 6. Depending on the country, these stocks could be from pre-CITES convention “vintage” ivory stocks, or from local “beasts of burden” domesticated Asian elephants whose ivory can be commercially sold.

← 7. Cases here public officials have been arrested and charged in connection to acts of corruption, or where an official investigation has been opened.

← 8. Can include inferred definition of predicate offense

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2. Key Findings and Detailed Recommendations