Wildlife Trafficking

Wildlife trafficking is an activity that generates illicit proceeds qualifying as a predicate offense for money laundering.

Traffickers use shell companies or front entities to conceal beneficial ownership and obscure the origin of wildlife trafficking proceeds. These opaque structures exploit vulnerabilities in customer due diligence, making it difficult to trace the true owners.

Proceeds are often commingled with legitimate trade or business revenues to mask their illicit origin. By integrating transactions into normal commercial flows, criminals exploit financial products and services designed for legitimate trade, making it harder to distinguish illicit funds.

Wildlife trafficking inherently relies on moving protected species and their proceeds across multiple borders, often targeting regions with weak AML enforcement or corrupt officials. This cross-border element is the primary vulnerability, as illicit funds can be laundered more easily when passing through jurisdictions with inconsistent regulations and oversight.

• Maintains databases of individuals in prominent public or political positions.
• Alerts financial institutions to heightened corruption risks, including potential collusion with wildlife trafficking networks.
• Enables closer scrutiny of transactions involving PEPs linked to wildlife transport permits or regulatory approvals.

• Aggregates negative media reports, lawsuit details, and legal actions involving individuals or entities.
• Identifies known or suspected involvement in wildlife trafficking, smuggling, or related illegal activities.
• Supports enhanced due diligence and ongoing monitoring of high-risk clients or transactions.

• Provides official logs of goods, shipments, and individuals crossing borders.
• Contains shipping routes, commodity details, and declarations that may reveal discrepancies or hidden wildlife products.
• Supports detection of fraudulent or incomplete documentation used to conceal illicit wildlife cargo.

• Documents items seized by customs or enforcement authorities, including wildlife products and derivatives.
• Provides details on parties involved and associated legal proceedings.
• Helps financial institutions detect connections between customers and seized assets or shipments.

• Captures detailed financial transaction data (e.g., timestamps, amounts, currencies, parties) across various channels.
• Enables identification of unusual or structured payment patterns indicative of layering or commingling proceeds generated from illicit wildlife trafficking.
• Supports tracing the flow of funds across accounts and institutions for investigative follow-up.

• Includes bills of lading, invoices, certificates of origin, and shipping logs for cross-border transactions.
• Allows verification of declared goods and detection of inconsistencies in shipping documents where wildlife products might be disguised.
• Supports investigation into potential trade-based money laundering schemes.

• Provides information on cross-border transactions and correspondent banking relationships.
• Reveals patterns of layered transfers across jurisdictions used to distance illicit wildlife proceeds from their origin.
• Facilitates the identification of high-risk corridors or account relationships indicative of laundering activity.

• Contains data on corporate structures, including registration details, shareholders, directors, and ultimate beneficial owners.
• Helps identify shell companies and undisclosed ownership ties often used to launder proceeds from wildlife trafficking.
• Facilitates linking questionable entities to known traffickers or high-risk networks.

Incorporate wildlife trafficking data into the evaluation of jurisdictional risks. Identify regions with systemic corruption, weak enforcement, or high wildlife trafficking incidence, and apply enhanced scrutiny or tighter controls for cross-border transactions involving those areas.

Apply deeper scrutiny to customers or counterparties involved in wildlife-related businesses, especially those operating in or sending funds to high-risk jurisdictions. Verify the authenticity of any wildlife permits or licenses, investigate known network connections (e.g., shell companies), and obtain senior management sign-off for accounts revealing indicators of illegal wildlife trade.

• Confirm each customer's claimed authority to trade in wildlife by verifying relevant licenses, such as CITES permits.
• Verify beneficial ownership.
• Match standard business operations to declared wildlife activities.
• Escalate accounts that hide or misrepresent their involvement in high-risk species trade.

Continuously track cross-border transactions, focusing on unusual payment flows to or from jurisdictions known for protected-species trafficking or referencing wildlife products. Flag repeated structured transfers below reporting thresholds and layered transactions that appear designed to conceal funds derived from illegal animal trade. Investigate anomalies tied to freight or logistics expenses that lack legitimate commercial justification.

Conduct rigorous due diligence and periodic reviews of intermediaries, freight forwarders, or logistics partners involved in transporting wildlife cargo to ensure their licensing and compliance with environmental and AML regulations. Investigate large or unexplained payments to unknown third parties within the wildlife supply chain.

Report large or threshold-based cash deposits originating from wildlife-related businesses, documenting the declared source of funds and intended usage. Pay extra attention to repetitive high-value deposits that are incongruent with the business’s legitimate wildlife trade or lack verifiable sales records.

Offer specialized courses that enable frontline and compliance staff to recognize patterns unique to wildlife trafficking, including suspicious documentation referencing endangered species, bribery indicators in transport chains, or recurrent shipments to high-risk habitats. Emphasize the correct escalation procedures for unusual wildlife-related transactions.

Categorize customers handling exotic or protected species, or operating in wildlife trafficking hotspots, as higher risk. Assign stricter transaction controls and monitoring thresholds to these segments. Perform more frequent account reviews to swiftly identify suspicious cross-border payments or sudden changes in transaction volumes.

Routinely cross-check customer and transaction details with external sources, such as news outlets, government registries, and NGO watchlists, to identify red flags related to wildlife trafficking. Validate permits against publicly available databases and investigate negative media or adverse reports that may indicate illegal wildlife trade.

Thoroughly scrutinize all trade documents related to wildlife cargo, verifying declared species, volumes, market values, and permit details. Identify anomalies in invoice pricing or inconsistent shipment records that might indicate falsified documentation. Escalate transactions involving endangered species or routes known for wildlife trafficking.

• Wildlife, including protected species or their parts, is an illicit commodity traded on black markets, generating unregulated proceeds.
• By transacting in these underground markets, traffickers convert illegal wildlife into monetary gains that can then be obscured and laundered through formal or informal channels.

• Criminals use bank accounts opened under shell or front companies to commingle illicit proceeds from wildlife trafficking with legitimate revenue, concealing their true origin.
• Funds are layered through multiple transfers across various domestic and offshore accounts, making it difficult for financial institutions to trace or detect the criminal source.

• Traffickers forge or alter bills of lading and other trade documents to disguise protected wildlife as ordinary cargo, facilitating trade-based money laundering.
• Over- or under-invoicing using these instruments allows criminals to shift value across borders under the appearance of normal commercial transactions.

• Wildlife traffickers rely on physical currency to pay poachers or suppliers in remote areas, entirely bypassing formal banking channels that might flag suspicious transactions.
• Cash also facilitates bribes to border or customs officials without leaving a paper trail, enabling traffickers to evade AML checks and regulatory scrutiny.

• By controlling the release of shipping documents until payment, traffickers mitigate the risk of early detection for illicit wildlife cargo.
• Collusion with or exploitation of counterparties allows the real merchandise to remain hidden behind routine trade settlement processes.

• Wildlife traffickers establish business accounts to commingle illicit proceeds with legitimate income, making activity appear routine.
• High transaction volumes and normal business operations mask the influx of illegal funds from wildlife sales.

• Criminals mislabel protected species as legitimate cargo or falsify shipping documents to conceal illicit wildlife shipments.
• The use of complex logistics networks with multiple transit points obscures true origins and destinations, hindering law enforcement detection.

• Traffickers forge or alter bills of lading, certificates of origin, and other paperwork to disguise illicit shipments as ordinary trade.
• Misrepresentation of cargo details complicates financial institutions’ efforts to identify and flag suspicious transactions tied to wildlife trafficking.

• Criminals manipulate trade finance instruments (e.g., letters of credit) to legitimize international payments for illegally sourced wildlife.
• Over- or under-invoicing disguises the true nature of shipments, undermining financial institutions’ ability to detect criminal proceeds.

• Specialized cross-border trade support can be exploited to navigate customs and regulatory requirements while concealing illicit wildlife.
• Free zone benefits and streamlined procedures reduce the financial footprint of suspicious cargo, helping to disguise illegal shipments.

• Traffickers open accounts in offshore jurisdictions to layer profits from wildlife trafficking away from stricter oversight.
• Reduced transparency and bank secrecy measures impede investigators’ ability to trace illicit funds tied to protected species trade.

• The formation and administration of shell or front companies enable traffickers to obscure the source of wildlife trafficking proceeds.
• Layering funds through these entities conceals beneficial ownership, frustrating AML investigations.

Wildlife traffickers generate illicit proceeds by illegally capturing, transporting, and selling protected species or their derivatives. They:

• Create or leverage complex arrangements (e.g., front entities or fraudulent invoices) to deposit and move funds, obscuring transaction origins.
• Exploit financial channels in multiple jurisdictions, making it difficult for financial institutions to trace or flag illegal proceeds.

Offshore financial institutions facilitate the movement and layering of wildlife trafficking proceeds by:

• Accepting deposits or transfers into jurisdictions with limited regulatory oversight or bank secrecy.
• Impeding financial institutions' ability to trace cross-border transactions and identify the ultimate beneficiaries.

Document forgers alter or fabricate shipping documents, permits, or wildlife trade licenses. They:

• Provide traffickers with the paperwork required to legitimize illicit shipments.
• Obscure cargo details and conceal the true nature and origin of protected species, hindering financial institutions from identifying suspicious trade transactions.

Shell or front companies enable wildlife traffickers to:

• Conceal beneficial ownership and commingle illicit wildlife proceeds with seemingly legitimate revenue.
• Layer funds across multiple accounts and entities, complicating financial institutions' due diligence and transaction monitoring efforts.

Shipping and logistics companies are exploited by traffickers who:

• Mislabel cargo and falsify documentation to transport protected species alongside legitimate freight.
• Integrate illicit shipments into normal logistical flows, making it harder for financial institutions to detect abnormal patterns in trade financing or payments.

Certain public officials are bribed or corrupted by wildlife traffickers to:

• Allow prohibited shipments or overlook regulatory breaches.
• Issue or approve falsified documentation or permits, giving a legitimate appearance to illicit cargo.

This corruption undermines standard checks in financial and customs processes, thwarting financial institutions' attempts to detect criminal proceeds tied to wildlife trafficking.