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The illegal wildlife trade is still one of the most profitable criminal enterprises

Given the astonishing global impact of the Covid-19 pandemic, the question must be asked – how did this happen? And how can we stop it from happening again? Tackling the illegal wildlife trade will be critical and companies across key sectors have an important role to play.

It is generally accepted that the first concentration of Covid-19 cases originated around a market in Wuhan, China. This “wet market” was one of many in the region selling a variety of live wild animals housed in cages in close proximity to slaughtered meat, birds, fish, and to the humans transporting, killing, and selling them. It provided ideal conditions for disease to spread between species. The exact mode of transmission of Covid-19 is unconfirmed, but bat, snake, and pangolin have all been suggested as the intermediary host for the disease before transmission to humans. 

In many Asian cultures, the consumption of exotic animals is reflective of status and wealth. Animal products are also commonly used in traditional Chinese medicine as well as in jewelry or ornaments. Given this demand, the farming of wild animals is a lucrative business that is commonly supplemented with illegal sales of wild animals. 

The United Nations estimates that global illegal wildlife trade is worth between $7 billion and $23 billion a year, making it one of the most profitable criminal enterprises. Wildlife crime has been linked to drug, human, and arms trafficking, as organized crime groups seek to exploit their established global transit networks. The trade drives corruption, damaging economies, and exacerbating poverty and violence. The risks are therefore not only to endangered species and the planet’s biodiversity, but to the rule of law, to economies and, as highlighted by this crisis, to our health. 

What has been done?  In February 2020, as a result of Covid-19, the Chinese government introduced emergency measures to limit the trade in wild animals for consumption, and there are indications that the ban could be enacted into law. But since much of this activity is already illegal, it is unlikely that such a law would eliminate the practice, but rather drive it further underground. There are many voices calling for a permanent and effective ban on wild animal trade. 

What more can be done? In the EU, environmental crime, including the illegal wildlife trade, is captured by the sixth Anti-Money Laundering Directive, due to become law across EU countries by December 2020, as a predicate offense to money laundering. The Financial Action Task Force (FATF) announced the illegal wildlife trade as a key priority under the current Chinese Presidency. We should expect to see more regulatory scrutiny of institutions that fail to take action and become unwitting facilitators of this activity. Financial services institutions should be considering illegal wildlife trade as part of their KYC procedures, and Financial Crime Compliance teams should become familiar with common red flags indicative of the activity. 

Companies in the global transportation sector need to also be mindful that their services could be misused by illicit actors and exploited through corruption and security loopholes to carry illegal wildlife products. 

Given the new public consciousness of the issue created by the pandemic, there is, at minimum, a significant reputational risk for companies who fail to prevent illegal wildlife trade. It is clearly now more important than ever that we take action to eliminate this illicit activity.


Sarah Wrigley, pictured above left, is a Director in the Forensic Accounting team based in FRA’s London office. She can be contacted here

Toby Duthie, above right,  is a Founding Partner of FRA and head of its UK and European offices. He can be contacted here

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1 Comment

  1. Wildlife trafficking is a serious social harm, and should indeed be an important component of AML. But the UN estimates – with a large range, which is good to see as any estimation without a large range is suspect – are of the turnover, not the profitability of wildlife trafficking. This also applies to other crime turonver data. We know almost nothing about how relatively profitable it is to primary offenders or to the laundering intermediaries compared with other crimes and licit activities.

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