Claim Your Role in Combating Illegal Wildlife Trade

The sustainability agenda has taken center stage around the world, in many instances surpassing the profit agenda, as people across the globe come to terms with their impact on our planet. The public and private sectors have begun to understand the financial flows associated with environmental crimes and pockets of success have been achieved, with sentences being handed down for financial crimes such as money laundering, alongside the sentences for the actual environmental crime.

Currently in the spotlight is illegal wildlife trade (IWT), which is estimated to account for $7 billion to $23 billion in trade per annum.1 The horrendous discovery of 24 rhino carcasses in the space of two weeks in South Africa last December2 is a stark reminder that we have a long way to go. The response to this tragedy by the private sector, nongovernmental organizations (NGOs), law enforcement (LE) and regulators—leading to 12 arrests and the seizure of 78 rhino horns in just under three months—testifies to the commitment to stop IWT.

But what can institutions do to set up a program to play their role in combating IWT? The following is a simple five-step model to get organizations out of the starting blocks.

Start a Discussion

In January 2020, Investec hosted The Royal Foundation’s United for Wildlife for the launch of their southern Africa chapter. Attendees included stakeholders from other financial institutions, LE, other agencies involved in conservation and conservationists from NGOs throughout southern Africa. The energy in the room was palpable and the momentum since that launch has been extraordinary.

At the same time, Investec arranged an internal staff discussion with a panel of experts on the topic of combating IWT, with some trepidation as to whether the room would fill. The room turned out to be packed with people from diverse teams in the organization who left enlightened and enthused about the role they could play in saving South Africa’s wildlife. These conversations set the attendees on a journey that is now nearly two years old, with a dedicated IWT team that is so passionate about the country’s heritage that they are doing most of the work in addition to their regular workload.

Top Tips:

  • Never fear that people will not be interested—you may be surprised about the number of people eager to play a role but unsure how to do so.
  • Do not limit yourself to picking only the usual suspects, like financial crime or transaction monitoring teams. Those less involved can often see the wood from the trees and bring a very fresh perspective.
  • Get senior management buy-in at the onset of your journey.

Look at Your Products and Services

Review your products and services with an IWT lens and be as critical as possible. Due to the nature of wildlife trafficking, much of the illicit activity is commingled with legitimate business activity. What may seem like an authentic transaction with one of your customers may turn out to be a convoluted transaction to use your products in the IWT value chain.

It is also not all about the finance sector. Entities in the transport sector, such as freight and courier companies, clearing agents and shipping companies, are being used by these criminals to move products transnationally. Train your staff to look out for suspicious activities. For example, a client shipping chocolates—conveniently wrapped in foil which reflects the imaging beams of airport baggage scanners—to a country known for consumption of IWT products should raise alarm bells, especially if the chocolates can be bought at any supermarket in that consumer country.

The renewed focus worldwide to extinguish this heinous crime means that there are plenty of organizations to call on for assistance

Naturally, one is tempted to think that the finance and transport sectors need to step up to the plate. But there are many other sectors being used, perhaps unknowingly, to help the IWT syndicates flourish, such as casinos, attorneys and professional advisors. Telecommunication companies can be used by IWT criminals to communicate with one another or make use of mobile money capabilities to move funds.

So, the question all corporations should be asking themselves is: “How can an actor in the IWT supply chain use my products or services in their pursuit of this crime, from the poaching of the animal to intermediating the sale, transport, transshipment and payments?” If there is a possibility, it is important to implement measures to prevent this from occurring or, at a minimum, to identify when someone attempts to do so.

Top Tips:

  • There is much research available publicly to inform your review of your products and services.
    — The Financial Action Task Force (FATF) produced its well-researched June 2020 paper titled “Money Laundering and the Illegal Wildlife Trade.”3
    — TRAFFIC publishes regular reports and case digests that speak to recent cases and general research. The papers published on interviews with those incarcerated for wildlife crimes in South African and Namibian prisons are particularly informative.4
    — Royal United Services Institute has conducted several projects on the topic of IWT and the organized crime nature thereof.5
  • Keep it current. Your measures to prevent or detect wildlife crimes need to evolve as the criminals change tactics. Information can become stale very quickly.

Fortunately, the vast amount of public research keeps up with this pace, so there is much information on which to draw.

Partner Up

The renewed focus worldwide to extinguish this heinous crime means that there are plenty of organizations to call on for assistance. Examples of partnerships that have worked in the South African context are:

  • The South African Anti-Money Laundering Integrated Taskforce was established in 2019. The partnership between the local financial intelligence unit, banks, regulators and other industry bodies published a paper on its research into the financial flows associated with wildlife crimes in South Africa. Similar public-private partnerships exist worldwide and may be a useful vessel in your country to conduct similar research.
  • The Royal Foundation’s United for Wildlife program runs two task forces: one for the financial sector and one for the transport sector. Membership is free and the benefits are vast.
  • There are a number of NGOs in most countries dedicated to conservation and working tirelessly to combat IWT. Partnering with these entities provides support to them and puts you closer to what is happening on the ground, enabling you to be more proactive.
  • Industry bodies and like-minded companies are also examples of partnerships that have and can work. There is no real competitive advantage in being better than your peers when it comes to combating IWT, as criminals will often move their activity to companies that offer the route of least resistance. Engaging with peers will not only create support but ensure cohesion in your industry’s response.

Top Tips:

  • Not all heroes wear capes. There are some organizations making massive strides to combat IWT, but there are also many smaller unsung heroes that can do with the support and, at the same time, provide valuable insight into the modus operandi of IWT perpetrators.
  • Prepare for the long game. Some partnerships take time, and one must be patient to see the results of the collaboration. Do not rush it.

Look with Specificity

Wildlife crimes can often be overlooked when using general typologies and rules. A dynamic combination of different factors will often yield better results. By way of example, frequent low-value cash deposits into an account may not attract much attention. However, low-value deposits in an area known for poaching (so-called “hot spots”) by someone employed by a national park should attract attention and warrant investigation.

It is therefore important to research locations, behaviors, occupations and industries that are typically associated with wildlife crimes. Well-researched typologies and parameters will hone your efforts and reduce the inefficiencies that come with finding the proverbial needle in the haystack.

Research should also be continuous and regularly updated or shared so that typologies and monitoring evolve as the criminals change their modus operandi.

Follow the Money

Far too often, investigations are abandoned at the first finding of a reportable crime. Wildlife trafficking is a transnational organized crime, and in many instances, following the source of a deposit or the destination of a payment can lead to the uncovering of wider groups and syndicates involved in IWT. This complexity means that no stone should be left unturned when conducting an IWT investigation, much like investigations into other predicate crimes. The transnational nature of IWT, however, means that one must be willing to reach further to find the true nodal point of a syndicate. Escalation to and collaboration with LE often enables this depth in an investigation.

One such example can be found in China, where authorities brought down one of the biggest ivory trafficking syndicates in 2020, leading to the arrest and conviction of 17 members of a group that collectively played a role in trafficking 22.22 tons of ivory, the equivalent of approximately 2,000 elephants.6 The Wildlife Justice Commission studied this case and published a case digest, “Bringing down the Dragon: An analysis of China’s largest ivory smuggling case,” which articulates the role of financial investigations and how the identification of even a small transaction can often lead to big insights.7

Upskill and Train Others

It is important to know that this is a journey and perhaps one that you will never finish. As these wildlife criminals change their course of action quickly, so must any IWT program adapt as quickly. It is therefore vital to continuously upskill your knowledge and scan resources that help inform emerging trends. An easy way to get started would be to try out ACAMS’ free online course, “Ending Illegal Wildlife Trade—A Comprehensive Overview,”8 available through

Create training and awareness programs in your organization that demonstrate an institutional commitment to playing a role in combating IWT. It should also enable your employees to be the first line of defense. For example, those engaging with clients, booking and analyzing financial information, or designing and reviewing products should know the red flags for IWT, especially if your organization works directly with or on the periphery of wildlife and wildlife products.

The most important message to convey to people in your organization is not to keep quiet when seeing something suspicious: If you see something, say something!

Gerald Byleveld, money laundering reporting officer, Investec Limited,

  1. Wolfgang Lehmacher, “Wildlife crime: a $23 billion trade that’s destroying our planet,” World Economic Forum, 2016,
  2. “DFFE notes incidences of rhino poaching in South Africa in December 2021,” Department of Forestry, Fisheries and the Environment, Republic of South Africa, December 14, 2021,
  3. “Money Laundering and the Illegal Wildlife Trade,” Financial Action Task Force, June 25, 2020,
  4. TRAFFIC homepage,
  5. “Projects,” Royal United Services Institute,
  6. “Bringing down the Dragon: An analysis of China’s largest ivory smuggling case,” Wildlife Justice Commission, February 2022,
  7. Ibid.
  8. Course: “Ending Illegal Wildlife Trade—A Comprehensive Overview,” ACAMS,

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