Wildlife Money Trials Building Financial Investigations From Wildlife And Timber Trafficking Cases In The European Union

Insufficient use of financial investigations in wildlife trafficking can lead to booming illegal business

Wildlife and timber trafficking often involves transnational organised crime networks and generates significant illicit proceeds, billions each year. Despite the seriousness of this criminal activity, related

financial investigations and asset recovery approaches remain largely under-utilised in the EU, with investigations and prosecutions of wildlife trafficking still relying primarily on charges for poaching or trafficking. Wildlife criminals are, therefore, not punished for the financial crimes they have committed, and their criminal assets remain in their hands, allowing them to further invest in their illegal business.

Most wildlife traffickers are first and foremost interested in making money. It is the profit that drives, helps sustain and expand their business. We cannot win the fight against wildlife trafficking without targeting what is at the core of the motivation of traffickers.”

Emilie Van der Henst, Senior Manager Wildlife Trafficking at TRAFFIC and WWF

‘Follow the money’ approaches not only help identify the higher-level criminals within a network but also help estimate the amount of money generated by criminal activity, which can be the basis for asset recovery. Seizing the assets of criminals is key to weakening the lucrative smuggling business and preventing further business expansion.

Lack of knowledge in financial institutions leads to unnoticed suspicious financial transactions

The Wildlife Money Trails report highlights how financial institutions such as banks can be used by traffickers and can be exposed to money laundering, fraud, and facilitating organised crime.

Existing EU anti-money laundering directives place legal requirements on financial institutions to verify a customer’s identity, establish risk-based controls, and monitor transactions for unusual or suspicious behaviour or anomalies, which may indicate money laundering. In case of suspicious behaviour, banks have the duty to share so-called Suspicious Transaction Reports with the Financial Intelligence Unit (FIU) of the relevant country law enforcement agency. To our knowledge, very few Suspicious Transaction Reports are being shared with FIUs related to wildlife trafficking.

It appears wildlife trafficking is still not well-known to most banks in Europe; they have little information on how they can be exposed to this criminal activity, and it is often considered a low priority. We hope this report will support the financial sector and guide European law enforcement in ‘follow the money’ investigations.”

Emilie Van der Henst, Senior Manager Wildlife Trafficking at TRAFFIC and WWFThe report includes 16 case studies, of which 13 cases that include estimates of the value of the illegal activity; the combined value was EUR 18 million. The case studies come from law enforcement authorities in Belgium, Hungary, Netherlands, Portugal, Slovakia, Spain, and Sweden, as well as Europol related to a diverse range of species of timber, birds, reptiles, spiders, mammals and fish. The case studies illustrate some practical approaches to applying “follow the money” principles by law enforcement investigators.

In the EU Action Plan against Wildlife Trafficking launched in November 2022, the European Commission calls for systematically launching financial investigations in organised crime investigations and asset recovery procedures. The EU-funded UNITE project, which produced the Wildlife Money Trails report, aims to encourage law enforcement agencies to further use financial investigations in wildlife and timber trafficking, with the view to seize criminal assets and generate financial crime convictions. It also aims to engage the leadership of financial institutions based in Europe to look at money laundering risks linked to wildlife trafficking.