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Combatting illegal wildlife trade

Understanding the tremendous environmental and social impact of illegal wildlife trade, and how a financial institution can help in the combat against this illicit financing activity.

Biodiversity, which underpins healthy ecosystems critical to support all life on our planet, is being lost at 1,000 times the natural rate.1 To name a few examples, 47 African elephants are killed every day for their tusks, only roughly 100 Amur leopards remain in the wild, and orangutans who once thrived from China to southern Indonesia, are today only found on two islands.2

The issue of biodiversity loss and its impact on the environment is widely recognised and significant efforts have been made to protect endangered species, conserve wildlife and restore natural habitats. Amongst them, the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) was established in 1975, providing a global framework and legal procedure for the international trade in over 37,000 species of animals and plants to ensure that the trading of wildlife species does not threaten their survival.3 To date, the 184 member countries of CITES have made the trading of certain endangered species illegal under their jurisdictions.4

However, the illegal trading of wildlife remains a lucrative business which the World Wildlife Fund (WWF) estimates to be worth over £15 billion annually.5 The market is driven by high demand, is facilitated by international organised crime groups and is enabled by regional corruption. Examples of this illegal trade include the targeting of the elephant population for ivory in Gabon, the poaching of native tigers by foreign poachers for their skins in Bangladesh, and many more.6 Other than posing a direct threat to biodiversity the illegal wildlife trade also represents a significant public health risk. According to the World Health Organisation, some 60% of emerging infectious diseases are Zoonotic in nature in which viruses, bacteria, and pathogens are transmitted between animals and humans which the COVID-19 pandemic has demonstrated has a significant impact on global society.7 Furthermore, this activity damages the financial integrity from source to the destination of the trade.

Until recent years, most countries relied on arrests and seizures in combatting illegal wildlife trade and rarely focused their efforts on following the money or following the goods.8 This has not stopped the trade. To be more effective in tackling the trade in vulnerable and endangered species, it is vital that stakeholders at the national level and across the public, private and third sectors do more to collaborate with each other and to co-ordinate activity to prevent and disrupt this illegal trade, including a focus on following the money and intercepting the physical movements of illegal animal/plant products. The importance of collaboration is clear when you consider for example that:

  • The transport sector has visibility on goods transportation;
  • The financial sector has visibility on the financial flows;
  • Law enforcement has authority to make arrests and seizures; and
  • NGOs have the on the ground intelligence, as well as the capacity to research and investigate the illegal trade from an independent perspective, enabling them to provide essential insight.

As such, a collaborative information sharing culture and an ‘umbrella’ linking the key players is an important means to ‘make it impossible for traffickers to transport, finance or profit from illegal wildlife products’.9 This is the ambition and approach of United for Wildlife, an initiative led by the Royal Foundation of the Prince and Princess of Wales. To achieve this, United for Wildlife created and now operates two taskforces focusing on the transport and the financial sectors, and is establishing regional chapters where stakeholders including private sectors, law enforcement and NGOs collaborate to make a joint action plan. To find out more about United for Wildlife, please visit their website.

Such public-private partnerships have made a material difference to halting illegal wildlife trade, as seen in the successful arrests and convictions of Kromar, Ping Wu and their criminal syndicates, thanks to the South African Anti-Money Laundering Integrated Task Force (SAMLIT), the US Department of Fish and Wildlife Service and the Drug Enforcement Administration, as well as multiple financial institutions.10 11 Both cases were underpinned by information sharing to enable a quick response to disrupt this illicit activity.

Since June 2020, Deloitte has worked closely with United for Wildlife to help it achieve its ambition, particularly in the financial sector. We have provided support in the following areas and have noted that these actions can be taken by any financial institution who seeks to play in role in combatting illegal wildlife trade.

Understanding the risks associated with illegal wildlife trade

To effectively tackle the risk of processing illicit financial flows generated by illegal wildlife trade, a clear understanding of the trade itself and the characteristics associated with the typical actors and activities is required. The FATF Report on illegal wildlife trade published in 2020 recommended that financial institutions undertake a specific risk assessment.12 In partnership with a number of financial institutions, Deloitte supported the development of a specific illegal wildlife trade risk assessment methodology which can be used to support financial institutions in understanding their exposure to illegal wildlife trade, as well as integrating the methodology within their established risk assessment processes. This methodology and associated templates were provided by United for Wildlife to its taskforce members to support them in developing a better understanding of their risk exposure to illegal wildlife trade.

Joining forces globally to tackle all aspects of illegal wildlife trade

The geographic presence of illegal wildlife trade is generally classified into the categories of source, transit, and destination locations. However, the supply, production and sale can effectively happen everywhere under the disguise of international and domestic legal wildlife trading activities. For example, there are currently 112 jurisdictions associated with globally linked seizures according to the wildlife seizure dashboard.13 To help address the issue on this scale, Deloitte has supported United for Wildlife with the establishment and operation of regional chapters, leveraging Deloitte’s global network of member firms, our clients and contacts. Through the creation of a governance structure, regular discussions and events, these regional chapters connecting various stakeholders from the financial, technology and transport sectors, as well as NGOs and government agencies are making a stronger impact in areas previously under-represented. For example, the Hong Kong chapter and the Southeast Asia & Australasia chapter have pushed for changes in legislation to increase enforcement efforts in combatting illegal wildlife trade, such as classifying wildlife crimes as a serious crime, and imposing higher penalties.

As the combat against Illegal Wildlife Trading has received more focus and support across a wide range of geographies and sectors, a number of challenges remain from preventing the further loss of wildlife to detecting and acting against the illegal profits being generated. For example, there is currently no global database to follow up seizures; the exposure to illegal wildlife trade risk is not always clear to a financial institution; and more support is needed to turn arrests into prosecutions. With the significant environmental and societal impact of the crime, organisations should consider whether the risk of unknowingly facilitating illegal wildlife trade would hinder their ESG goals, and whether a more organised and aligned response, driven by awareness and technology, is needed, as for the wider economic crimes out there.

Our team is well placed to support in the identification of associated risk and reduction of exposure to funds generated from illegal wildlife trade. If you would like to discuss this topic in greater detail, please reach out to Andrew Robinson, Ryan Sutton, Zijin He, Minnie Clark, and Hannah Wurtzburg.



1Fauna and Flora International, About - Fauna & Flora International (

2WWF, Support WWF Today | For A Future Where People & Nature Thrive



5WWF, Stopping the Illegal Wildlife Trade | WWF

6C4ADS, Wildlife Seizure Dashboard

7FATF, Money-laundering-and-illegal-wildlife-trade.pdf (

8FATF, Money-laundering-and-illegal-wildlife-trade.pdf (

9UfW, About Us

10The US Department of Justice, Wildlife trafficker from Uganda Sentenced

11 Department of Forestry, Fisheries and the Environment, Republic of South Africa, Rhino Poaching in South Africa in 2021

12 FATF, Money Laundering and the Illegal Wildlife Trade, June 2020

13C4ADS, Wildlife Seizure Dashboard