World Wildlife Crime Report
Trafficking in protected species

Research

2020

UNITED NATIONS OFFICE ON DRUGS AND CRIME
ViennaWorld Wildlife Crime Report
Trafficking in protected species
2020

UNITED NATIONSNew York, 2020© United Nations, May 2020. All rights reserved, worldwide.
ISBN: 978-92-1-148349-9
eISBN: 978-92-1-005225-2
United Nations Publication, Sales No. E.20.XI.8
This publication may be reproduced in whole or in part and in any form
for educationalor non-profit purposes without special permission from the
copyright holder, provided acknowledgement of the source is made.
Suggested citation: UNODC, World Wildlife Crime Report 2020:
Trafficking in Protected Species
Comments on the report are welcome and can be sent to:unodcrab@un.org
DISCLAIMER
The content of this publication does not necessarily reflect the views
or policies of UNODC, Member States or contributory organizations,and nor does it imply any endorsement.
The designations employed and the presentation of material in thispublication do not imply the expression of any opinion whatsoeveron the part of the Secretariat of the United Nations concerning
the legal status of any country, territory, city or area, or of its authorities,
or concerning the delimitation of its frontiers or boundaries.
This publication has not been formally edited.
Photo source: Introduction (p. 29) © AdobeStock, rosewood (p. 37) © iStockphoto,elephant (p. 47) © Lucas Metz (unsplash), rhino (p. 60) © Fabrizio Frigeni (unsplash),pangolin (p. 65) © Wildlife Reserves Singapore, reptiles (p. 73) © Steven HWG(unsplash), big cats (p. 79) © Clovis Wood (unsplash), eels (p. 93) © iStockphoto,value chains (p. 107) © iStockphotoPreface
The heedless exploitation of natureby humans has led to unprecedented
biodiversity loss and a worsening climate
crisis. It is also a threat to human health,as highlighted by the COVID-19 pandemic. Three-quarters of all emerging
infectious diseases are zoonotic, according to the United Nations Environment
Programme, transferred from animals tohumans, facilitated by environmental
destruction and wildlife crime.
Links between the global health crisisand the illegal exploitation of wildlife
have been in the spotlight since it wassuggested that wet markets selling wildlife, in this case pangolins, could havefacilitated the transfer of COVID-19 tohumans. The spike in public awarenessof this connection has led to a push for
new bans on the sale of wild animals
for consumption.
It is against this backdrop that thesecond edition of the World Wildlife Crime Report is published by theUnited Nations Office on Drugs andCrime (UNODC).
The report shows wildlife crime to be abusiness that is global; lucrative, withhigh demand driving high prices; andextremely widespread. Nearly 6,000 different species of fauna and flora havebeen seized between 1999 and 2018,with nearly every country in the world
playing a role in the illicit wildlife trade.
The need to stop wildlife trafficking
has gained an increasingly prominentplace on the political agenda over the
past years. Since the publication of
UNODC’s first World Wildlife Crime
Report in 2016, regulation has increased
for several wildlife markets, includingthat for pangolin products.

International trade in all pangolin
species is now banned. Despite this,growing volumes are being seized eachyear. The present edition of the World
Wildlife Crime Report shows thatbetween 2014 and 2018, seizures of
pangolin scales increased tenfold.
Such developments point to the many
challenges which Governments face inpreventing and countering wildlife andforest crime.
The present report shows that regulations on wildlife crime can trigger
replacement effects, for example, geographic displacement of trade exploiting
legislative gaps between countries, ora shift from protected to alternative
species. Robust research and analysis,
as well as consistent legislation withincountries and across regions are essential to eliminate loopholes. Identifying
and addressing the vulnerabilities oflegal markets to infiltration by theillicit trade is also key to strengthening
the global regulatory system. Publicawareness of the scale and impact of
the threats posed by wildlife crime canhelp reduce demand for products of
the illegal wildlife trade and increase
support for action.

Putting an end to wildlife crime is an
essential part of building back betterfrom the COVID-19 crisis. As we prepare the road to recovery, we have thechance to reset our relationship withnature and lay the foundations of amore just and more resilient world –working together to eliminate wildlife
trafficking, prevent future pandemics
and put us back on track towards theSustainable Development Goals. I hopethat the second edition of the UNODCWorld Wildlife Crime Report will bea useful resource to all our stakeholders, contributing to new and sustained
action that can close gaps in awareness,knowledge, legislation, and resources for the sake of people and planet.

Ghada Waly
Executive Director
United Nations
Office on Drugs and Crime

Building upon UNODC’s research
and analysis work, the Office’s Global
Programme for Combating Wildlife and Forest Crime provides policy
guidance and technical assistance torequesting countries. UNODC draws
upon its role as guardian of the United
Nations Convention against Transnational Organized Crime and theUnited Nations Convention against
Corruption to build the capacities oflaw enforcement and criminal justiceinstitutions, and support the communities impacted by wildlife crime.

3

Table of contents
Preface		3

Table of Contents

5

Acknowledgements

6

Glossary7

Summary and overview

9

Policy implications

19

Chapter 1: Introduction

29

Chapter 2: Rosewood timber

37

Chapter 3: African elephant tusks and rhinoceros horns

47

Chapter 4: Pangolin scales

65

Chapter 5: Live reptiles

73

Chapter 6: Big cats

79

Chapter 7: European glass eels

93

Chapter 8: Value chains and illicit financial flows fromthe trade in ivory and rhinoceros horn

107

5

Acknowledgements
The World Wildlife Crime Report was prepared by the Research and Trend Analysis Branch, Division
for Policy Analysis and Public Affairs, United Nations Office on Drugs and Crime, under the supervisionof Jean-Luc Lemahieu, Director of the Division for Policy Analysis and Public Affairs, and Angela Me,
Chief of the Research and Trend Analysis Branch.
Content overview
Kristiina Kangaspunta
Angela Me
Anja Korenblik
Analysis and drafting
Ted Leggett
Julie Viollaz
Irmgard Zeiler
Tanya Shadbolt
Data management
Enrico Bisogno
Diana Camerini
Francesca Rosa
Lisa Weijler
Thematic research experts contributing to the report
Ekane Humphrey Anoah (pangolins)
Tanawat Likitkererat (World WISE)
James Liu (reptiles, tiger)
Rowan Martin (ivory)
Frances Maplesden (rosewood)
Joao Salguiero (ivory, pangolin)
Rebeca Sandoval (pangolins)
Florian Stein (eels)
Daniel Stiles (ivory, rhino, pangolin, tiger)
George Wittemyer (ivory)
Graphic design, cartography, and layout
Anja Korenblik
Suzanne Kunnen
Kristina Kuttnig
Maria Moser
Lorenz Perszyk
Editing
Raggie Johansen
Review and comments
The World Wildlife Crime Report 2020 benefited from the invaluable contributions by UNODC
colleagues in all divisions. Particularly, the support provided by the UNODC Global Programme
for Combating Wildlife and Forest Crime is gratefully acknowledged: Jorge Eduardo Rios,
Jenna Dawson-Faber, Giovanni Broussard, Olga Kuzmianok and Sinead Brophy.
Research for this Report benefited from the expertise and invaluable contribution by the Secretariatof the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).
Also, other partner members of the International Consortium on Combating Wildlife Crime (ICCWC),
the International Criminal Police Organization (INTERPOL), the World Bank and the World
Customs Organization (WCO), supported the production of the report.
The Research and Trend Analysis Branch acknowledges the invaluable contributions and advice
provided by the World Wildlife Crime Report Scientific Advisory Group: Debbie Banks,
Steven Broad, Colman O’Criodain, Ofir Drori, Juliana Machado Ferreira, Sofie Flensborg,
Pia Jonsson, Paula Kahumbu, Jennifer Mailley, Kelly Malsch, Martha Serrano Rivas, John Sellar,
Daniel Stiles, Kristof Titeca, and Ling Xu.
The preparation of this report benefited from the financial contributions of the United States of America,
the United Kingdom, Germany, Norway, France and the European Union.

6

Glossary
CEN

Customs Enforcement Network of the World Customs Organisation

CITES

Convention on International Trade in Endangered Species of Wild Fauna
and Flora. Also sometimes used to describe the international legal order thatflows from the Convention, or as shorthand for governance mechanisms or
the Secretariat of the Convention

CITES Parties
ICCWC
IUCN
IUCN/SSC/AfESG
Genus (plural, Genera)
Kosso
MIKE
Pangolin
PIKE
Range state
RosewoodStates that have joined CITES and agreed to be bound by the Convention
International Consortium on Combatting Wildlife Crime(includes CITES, INTERPOL, UNODC, World Bank, WCO)
International Union for the Conservation of Nature
IUCN Species Survival Commission African Elephant Specialist GroupA collection of species distinguished through common characteristics
Pterocarpus erinaceus, a fragrant hardwood marketed as “rosewood”
Monitoring the Illegal Killing of Elephants programme
Several species of scaly anteater found in Africa and Asia
Proportion of Illegally Killed Elephants
A country in the natural range of a species
Several species of trees with richly-hued hardwoods suitable for furniture
manufacture

Species

The basic taxonomic unit by which different types of wildlife are distinguished

Taxon (plural, Taxa)

A scientific grouping of organisms based on common characteristics.
For example, the designation “species” is a taxon, as are the designations “class”,“order”, and “genus”

TimberTons

Wood prepared in some way for human use

TRIDOM

Tri-National Dja-Odzala-Minkébé trans-border forest, the juncture between
Cameroon, Congo and Gabon

UNODC

United Nations Office on Drugs and Crime

USFWS-LEMISWCOWorld WISE

References to tons are to metric tons, unless otherwise stated

United States Forest and Wildlife Service Law Enforcement Management
Information System
World Customs Organization
UNODC World Wildlife Seizure database

7

SUMMARY AND OVERVIEW
Four years have passed since the first are many crimes affecting wildlife that
World Wildlife Crime Report was pub- have nothing to do with these species.
lished in 2016. In the interim, there For example:
have been significant changes in boththe policy environment and the illicit - -- the millions of species that are
not listed by CITES may bemarkets. If anything, trafficking ofillegally harvested and tradedwild fauna and flora has grown ininternationally, as is frequently
importance in the public consciousthe case in timber and fish trafness and has risen on the political
ficking;
agenda, as it becomes clear that wildlife crime has negative implications
for climate change, preservation of - -- CITES is limited to regulatinginternational trade, so the illegal
biodiversity, security and public
harvesting of wildlife, such as thehealth. In response, controls havepoaching of protected species,
tightened in a number of wildlife
does not fall within its scope if
markets since the first publication,
the product is not transported
including those for rosewood, ivory,
internationally;and pangolins.

wildlife crime. To better understandmarkets where illegal materials arefeeding legal industries, legal trade
data are used. In addition to thesecore data, additional research was performed for this report for a range of
species. Making use of this additional
research, other forms of illegal harvest and trade are considered where
this activity is relevant to the markets
examined. Consequently, for the purposes of this report, the term “wildlife
crime” refers to harvesting and tradecontrary to national law, particularly,
but not exclusively, the national laws
implemented in fulfilment of CITES
obligations. This includes offencesthat might not attract criminal sanctions in some parts of the world.

8,193

20,762

520

8,030

2015

12,93312,751

20132014

12,625

2012

13,492

11,785

9,513

9,182

8,423

8,233

2011

2002

5,735

3,592

2001

4,697

3,719

3,447

2000

3,317

1999

17,881

As in the previous Report, this edi- - -- domestic markets for wildlife
are also beyond its jurisdiction,
tion draws heavily on the seizure data
The World WISE Database illuswhatever the source of thecompiled in UNODC’s World WISE
trates the diversity of wildlife crime.
wildlife, so long as the products
database. This database has grown,
Nearly 6,000 species have been seized
concerned cannot be proven to
currently containing just under
between 1999-2018, including nothave crossed borders in contra180,000 seizures from 149 countries
only mammals but reptiles, corals,
vention of CITES rules.
and territories.1 Contributing to thisbirds, and fish. No single species is
growth is the new CITES illegal trade
responsible for more than 5 per centreporting requirement. Each October Thus, by focusing on CITES-related of the seizure incidents. Virtually
since 2017, CITES Parties have been seizures, the core data used in this every country in the world plays a role,required to submit data on all seizures report do not cover all aspects of and no single country is identified asof wildlife made in the previous year.
As an ICCWC partner, UNODC
has been maintaining these data andFig. 1 Number of seizures in World WISE by year
analysing them when permitted to
do so by the relevant CITES Party.2
25,000Thanks to this process, the UNODCWorld WISE database now has strong
20,000coverage for seizures that took placein 2016 and 2017. Seizure data for2018 have also been included for
15,000some countries, after their review.3
There are inherent limitations on the
10,000uses of seizure data, and not all seizure
data are of equal quality. With theselimitations in mind, World WISE is
5,000
used cautiously in this report.
2018*

2017

2016

2010

2009

2008

2007

2006

2005

2004

0
2003

The nature of this CITES-oriented
data source affects the scope of thisreport. CITES lays out rules for tradein over 36,000 protected species, andit requires its parties to penalise tradein violation of these rules. But there

Source: UNODC World WISE Database* A t the time the data processing for this report was finalized, the data collection for seizures made in 2018
was not yet complete.

9SUMMARY AND OVERVIEW

Fig. 2

Share of all seizure
incidents in WorldWISE by taxonomic
category, aggregated1999-2018
Other
5.7%

Boney fish
4.7%

Mammals
23.0%

Molluscs
7.9%
Birds
8.5%

Reptiles21.3%

Plants14.3%
Corals
14.6%

Source: UNODC World WISE Databasethe source of more than 9 per cent of
the total number of seized shipments
captured in the database. Suspectedtraffickers of some 150 citizenships
have been identified, illustrating
the fact that wildlife crime is truly aglobal issue.
A review of the data indicates thatillegal wildlife markets do not correspond neatly to biological categories.
Some markets make use of multiple
species. For example, there are many
tree species that are classified as “rosewood”, and collectors of rare reptiles
intentionally seek out multiple species.
In contrast, some species feed multiple distinct markets. For example,
pythons are illegally taken for theiruse live as pets, for their skins to makehandbags and shoes, for their meatas a food, and for their organs as a
traditional medicine. As a result, themarkets referred to in this report may

be comprised of multiple species orjust part of one particular species. For
the purposes of clarity and focus, they
may also be limited geographically.
Using the relative valuation approach(see Box 2), changes can be seen overtime in the shares of the total seizures that some key markets occupy.
Between 2009 and 2013, rosewood
was clearly dominant, rhino horns
and pangolins represented only 5.5
per cent and 4 per cent of the total
respectively, and agarwood also stoodat 4 per cent. But between 2014 and2018, rosewood’s dominance declined
as the market shifted to new species.
Both rhinos and pangolins compriseda much larger share of the total seizures than in the past, and agarwood
seizures experienced a sharp relative
decline.

Box 1: Seizures as part of the evidenceWORLD WILDLIFE CRIME REPORT 2020

Seizure data comprise an important partof the evidence presented in this Report.
Seizure data, though, can be difficult tointerpret in isolation and can lead tomisleading conclusions because they area mixed indicator, demonstrating boththe presence of a problem and the initiative of the relevant authorities inaddressing it. On their own, they cannot
be used to demonstrate the magnitude
and trend of the trafficking or shed muchlight on law enforcement capacity.
The value of seizure data comes not fromwhat they say about the country making
the seizure, but what they say about thewhole supply chain. Whether transported
by sea freight, air freight, personal courier, or post, it is often possible to determine where the contraband originated,transited, and was destined. Each seizure incident, therefore, has the potential to reflect on the entire trafficking
chain, including the countries where thecontraband went undetected.

10

In addition, a seizure allows a great dealof information to be harvested about theidentity and methods of the traffickers
when the confiscating authorities takethe initiative to record these details.
Aside from routes, the preferred methodsof conveyance and concealment can be
documented. The age, gender, and citizenships of those associated with the
shipment can be recorded, as well as thelaws used to charge them. Triangulatedwith other indicators such as price aswell as qualitative research, they canprovide a key data source for understanding the mechanics of wildlife crime.
The quality of seizure data recorded andreported by Member States, however,varies greatly in terms of completenessand coverage. Some seizure reports
leave out key data, such as the sourceand destination of the shipment. The
way products are classed and measured
varies greatly between jurisdictions, andconversion ratios are needed to amal-

gamate the diverse products seized into
comparable categories.
While seizures are an imperfect indicator, they have the potential to provide
important insights when aggregated in
sufficient volumes. They cannot be taken
at face value or interpreted mechanically, but they represent concrete evidence of criminal activity that is otherwise obscured from view.

Role of transnationalorganized crime
Some wildlife trafficking flows primarily feed illicit retail markets, whileothers feed into the licit trade. Legalindustries can be contaminated by
the introduction of illegal supply, andthis vulnerability must be assessedto understand the criminal market.
Each case study presented in thisreport lends special insights into theway wildlife trafficking is perpetrated,suggesting the drivers and dynamics
of the criminal trade.

Fig. 3

Share of type of wildlife among total seizures (aggregated on the basis of standard value*), 2009-2013

Tortoises and fresh
water turtles
0.9%
Corals
1.6%

Big cats
0.6%
Parrots
0.9%

Sturgeon
0.2%
Raptors
0.1%

Marine turtles
0.1%
Eels
0.1%

Agarwood
4.0%
Pangolins
4.0%
Other species
4.1%
Assorted reptiles
4.3%
Rhinos5.5%

Rosewood
40.7%

Illicit wildlife markets, and the traffickers that feed them, can be highly
specialised. With regard to destinaElephants
33.1%
tion markets, considerable attention
has been given to open street markets where a wide range of protected
species-products are often openly dis- Source: UNODC World WISE Databaseplayed. These markets are a reality, but * The distribution of seizures was calculated using a common metric based on the value of seizures. Over one million
declared import values were statistically assessed and each seizure assigned a monetary value based on this dataset.
they cannot account for the volumes
See the methodological annex of the report for more details.
of wildlife illegally harvested each year.
Based on the locations of the largest
seizures, border town bazaars and Fig. 4
Share of type of wildlife among total seizures (aggreback alleyways do not appear to begated on the basis of standard value*), 2014-2018
the venue where tons of fish, timber,and other wildlife products change
CoralsTortoises andParrots
Agarwood
hands. These volume commodities are
0.6%
fresh water turtles
0.6%
0.6%
usually marketed to specialists.
0.3%
Big cats
0.8%

Raptors
0.4%

Eels

With regard to trafficking, there have
0.2%
Sturgeonalso been seizures that suggest someMarine turtles
1.7%
0.1%
groups are involved in smuggling
Other species
multiple species. In just the last few
3.1%
years, detection of large quantities ofAssorted reptiles
ivory and pangolin scales in the same
3.6%
shipment indicate a clear confluence
Rhinosof these markets. But these are theRosewood
11.8%
31.7%
exception rather than the rule, and,based on available information in
Pangolins
World WISE, most shipments are
13.9%
of a single species. It is possible for
Elephants
the same trafficking group to move
30.6%
multiple commodities in separate
shipments, of course, but the relative
novelty of mixed shipments suggests
that, as with dealers in destination Source: UNODC World WISE Databasehe distribution of seizures was calculated using a common metric based on the value of seizures. Over one million
markets, traffickers appear to special- * Tdeclared
import values were statistically assessed and each seizure assigned a monetary value based on this dataset.
ise, trading in particular commodities
See the methodological annex of the report for more details.
where they know their buyers well.

11

SUMMARY AND OVERVIEWInformation on the linkages between species were put on CITES Appendix
licit and illicit trade is important for I in 2017, yet growing volumes aretargeting interventions to address the seized each year.
vulnerabilities of the licit trade andto strengthen the global regulatory In other cases, such as rosewood andsystem. In some case studies reviewed, European eels, a large share of the illeit appears that the legal and illegal gally acquired wildlife is ultimately
markets remain fairly distinct.
processed and sold in a legal market.
By introducing illegal products into
In other cases, the markets are entirely licit markets, traffickers have accessillegal. For example, rhino horns are to a much broader pool of potential
products without a legal international buyers. The commodities have accessmarket – zero trade is permitted for to legal demand, because the buyers
commercial purposes and there is no may be unaware of the illegal origin ofdomestic market in range states. Sim- the product. People buying rosewood
ilarly, there is no legal international furniture or eels may have no way tomarket for pangolin products since all ensure that the origin of this productBox 2: Valuation of wildlife seizures

WORLD WILDLIFE CRIME REPORT 2020

To prioritise the use of limited resources,
some quantification of the threats
posed by the various wildlife trafficking flows is necessary. Looking at the
number of times a particular species orregion is implicated can give some
general insights, but aggregating seizures is challenging because not all
seizures are equal. Some comprise
multiple container loads of illegal wildlife, while others involve a single itemin the hand baggage of a traveller.
Plumbing the depths of these datarequires an additional element, something that takes into account the scaleof the seizure. Once the relative significance of each seizure is weighed, arange of comparisons can be made. For
example, the most significant species intrade, from a criminal markets perspective, can be identified. Together, just a
few types of wildlife can account forjust under 90 per cent of the total.
Comparing and aggregating wildlife
seizures is complicated, however,
because of the variety of products
involved. For example, the seizure of abox of 10,000 dried seahorses is very
different in every respect from the seizure of a shipping container of illegally
harvested rosewood logs, or a suitcasewith three rhino horns. They cannot betreated as equivalent by simply counting the seizure incidents. The number

12of specimens cannot be counted: thewildlife is often processed before shipment, so the number of animals orplants involved is often unclear, and it
would be unreasonable to equate aseahorse with a rhinoceros. They also
cannot be compared on the basis ofweight, since the crude mass of thewildlife in no way captures its significance.
The importance ascribed to a wildlife
seizure depends on the purpose of theanalysis. Organized crime is crime committed for material gain, and the extent
of this gain is of great relevance fortraffickers. Thus, to capture the criminal significance of a wildlife seizure, it
makes sense to assign a monetary
value to it. To provide this valuation,over one million declared import values
were statistically assessed and each
seizure assigned a monetary value
based on this dataset. The valuation
process is fully explained in the online
methodological annex to this report.
These values have been used not as aproxy for the true black-market price,
but to act as a yardstick, giving a senseof the relative value of a seahorse to arhino horn to a rosewood log.

was legal. In these cases, supply-chain
security is of the essence in protecting
vulnerable species.
Organized crime groups are flexible
and can easily adapt to new restrictions, regulations and enforcement
measures that may reduce opportunities to maximize profits. There may be
many factors that make wildlife markets vulnerable to criminal infiltration.
Policies, capacities and regulatory
frameworks differ between countries,
prompting criminals to turn to places
where they can operate efficiently
with low risk of punishment.
Illicit wildlife markets are like otherillicit markets. With strong regulations and high demand, prices for the
products go up, which can increase
the profits of criminals. When efforts
to curb the illicit trade do not impact
both supply and demand, different
types of replacement effects can be
seen. Strong regulations in one place
combined with high levels of demandcan shift the criminal operations toless-regulated places or to the use of
substitute species.
From one country to another:geographic displacement
Combating wildlife and forest crime
has not usually been seen as a priority when addressing organized crime.
Legislation may be weak and the levelof detecting and addressing wildlife
crime may be very low because oflimited law enforcement capacity.
Criminals tend to exploit legislativeand enforcement gaps in countries
that are less capable of addressing them,with the result that wildlife crime isdisplaced to these countries. This is
the case, for example, with pangolinscale traders who choose to store theirstock in the Democratic Republicof the Congo as opposed to othersource countries due to a perceptionof lesser capacity for interdiction.

very large containerized shipments.
Unlike illicit drugs, timber is not soldin acknowledged illegal markets, butrather fed into legal industries where
its illegal origin is obscured. In fact,
as the first Report highlighted, timber
illegally harvested in one country
If the 2016 Report represented UNO- may be legal to import into another.
DC’s first global assessment of the Countries are not bound to enforce
state of wildlife crime, this edition the forestry laws of other countries.
represents a first assessment of trends. For this reason, both the legal trade
In several instances, these trends data and the seizure data need to be
have been dramatic. Several markets considered in assessing the illicit flow.
surveyed in the first report are also
reviewed in this Report, namely mar- Based on legal trade and seizure data,
kets for illicit rosewood, ivory, rhino the largest flow of illicitly harvested
horn, and pangolin scales. In addition, rosewood in the past four years is
this report includes discussion on a coming out of Africa. The rosewood
few new markets, including those for species featured in the last Report,
live reptiles, big cats, and European Pterocarpus erinaceus (known in Nigeeel. Some previously covered mar- ria as “kosso”), was listed on CITES
kets, such as reptile skins, live parrots Appendix II effective at the start ofFrom physical to online trade
and agarwood, are not continued in 2017. Remarkably, after this listing,
Like many markets, trade in wild- this report, due to a lack of available more rosewood was exported fromlife and wildlife products is moving new data.
Africa than ever before, but this time
online. For example, the illicit petwith CITES documentation. Nigeria
reptile trade increasingly involves
alone exported some 750,000 cubic
the use of social media platforms.
metres of rosewood in 2017, which is
Criminals can be quick in switching When traded internationally, timber equivalent to about four million trees,
online platforms whenever enforce- is a commodity sold and used in bulk, or over 30,000 shipping containers,
ment action is taken. This trade is and the seizure data are dominated by an average of almost 100 container
particularly difficult to address due
to its hidden nature, inconsistent
Volume of kosso logs (cubic metres) exported from
regulatory frameworks, and limited Fig. 5
specialised law enforcement capacities.
Nigeria and imported by Asian countries, 2008-2018
From one species to another:wildlife product replacement
Criminals can shift from protected
species to alternative species that havea similar value in destination markets. This sort of species replacement
is very common in wood markets,
where even experts can struggle todistinguish between timber of related
species. The dominant rosewood species has changed many times over theyears, shifting from Asian to African
species. Similarly, African pangolin
species were targeted after regulations tightened and populations were
overexploited in Asia. Leopard, jaguar
and lion bones have also emerged as
substitutes in the tiger bone trade. At
times, these substitutions are explicit,
but often the buyers are not aware thata new species has been introduced.

wild tiger populations but large captive populations strongly suggeststhat the illegal trade involves thesetiger facilities.

Case study markets

Rosewood(trade suspended October 2018)754,234

568,110

CITES Appendix II listing January 2017394,252

55,334

2018

2017

2016

2015

2014

2013

671

2012

2011

2010

2009

2008

486,389

392,384

cubic metres

From wild to captive: captive
breeding
800,000
When no viable wild population
exists, captive breeding has been
700,000
seen as an effective solution for the
600,000
preservation of species threatenedwith extinction, but captive breeding
500,000
can be exploited by organized crimegroups. Several countries allow cap400,000
tive breeding for commercial purposeswith the responsibility to ensure that
300,000
these businesses operate in line with
200,000
national regulations. There is evidence that criminals have used some
100,000
licensed breeding facilities to illegally18
216 34688
supply the illegal trade in exotic pets,
0luxury products and ingredients for
traditional medicine. For example,
detection of illegal tiger products incountries with little or no remaining Source: World Trade Atlas, UN Comtrade

13

SUMMARY AND OVERVIEW

With the imposition of controls on
Pterocarpus erinaceus, a number ofalternative African species suitableas rosewood substitutes have been
exploited. Some of these substitutes were listed by CITES in 2019.
Pterocarpus erinaceus itself has been
exploited as an alternative to depleted
Asian rosewoods. Even as CITES
listed the entire Dalbergia genus in
2016, alternative genera were being
targeted. Timber traders appear to becontinually searching for substitutespecies to exploit internationally, working both within and outside the law.

Ivory and rhino horncurrently paid for rhino horn in Asianmarkets are a fraction of those citedin the popular press. It had beensuggested that raw horn was worth
US$65,000 or even US$100,000 per
kilogram around 2014-2016, while
field monitoring suggests the 2019price was closer to US$16,000.

the associated decline in price indicates current supplies exceed demand.
Some very large seizures of both ivory
and rhino horn were made in 2019,
which is likely to be a record year once
all the data are in. Unless indicators
emerge of renewed poaching, thesource of this ivory was likely stockpiles, exported before prices decline
further still.

The simultaneous decline in poachingand prices suggests that these illicit
markets are contracting. It is possi- Seizure data also show a dramatic
ble that stockpiles are being tapped, reorientation in the routing of
reducing the need for poaching, but ivory. While East Africa (particularly

Ivory prices paid to poachers in Kenya and theUnited Republic of Tanzania, 2014-2018

Fig. 6
160

148

140
120
US$ per kg

loads exported per day. This continued apace in 2018. Because Nigeria
was unable to produce a scientificnon-detriment finding, a recommendation to suspend trade fromthe country was issued by CITES in
October 2018.

95

100

88

80

78.5
54.5

60

40
Perhaps the most revolutionary policy
40change in the past four years occurred20
in the trafficking of ivory, as several
0of the largest legal domestic markets
2014
2016
2018
were sharply restricted. Around the
Kenya
UnitedRepublicof
Tanzaniasame time, several indicators suggested the illicit market went into Source: UNODC fieldwork
sharp decline. The relation between
these two trends requires further
Number of whole pangolin equivalents seized andinvestigation, but it is possible that Fig. 7
the loss of the legal market undernumber of seizures annually, 2007-2018*mined investor confidence, flooding
the market with more ivory than
141.9
Number of seizures
required by retail demand.

*

14

*
71

2018

2017

2016

2015

2014

2013

2012

2011

2010

2009

2008

Data on poaching and trafficking
101.0* note: 2018 data collection is not yet complete
indicate that the ivory supply saw aresurgence around 2007 and grew
75.9
steadily until around 2011, declining
until 2016, and stabilizing at much
lower levels in the following two years.
Prices in both East Africa and Asia
35.8
appeared to have risen from 2007,
10.4
12.9
18.0
peaked around 2014, and to have
13.9
11.5
10.1
9.2
4.7
declined dramatically in the following
years. Similarly, rhino horn poach117
77
117
171
30
63
86
135
117
216
38
ing appears to have risen from 2007,
peaked in 2015, and declined every
year since that time, with prices also Source: UNODC World WISE Databasedeclining during this period. Prices * The specimen types included for this analysis are live, bodies, scales, meat, and trophies.
2007

WORLD WILDLIFE CRIME REPORT 2020

Number of whole pangolin live equivalents
seized (in thousands)

Mombasa, Kenya) was the primarysource of illicit shipments in the past,
Nigeria has become a dominant collection and transit point over the last
four years. Similarly, while China
dominated in the past, Viet Nam
has emerged as the primary destination of these shipments. In addition,
large mixed shipments of ivory andpangolin scales have risen in prominence, suggesting experienced ivory
traffickers are using their expertise to
move a rising illicit commodity

Fig. 8

Share of top ten CITES-listed live reptiles seized,
2007-2017*
Pig-nosed turtle
3%
Greek tortoise
6.1%
Black spotted turtle
7%

Yellow-spottedriver turtle
29.1%

Radiated
tortoise
8.2%
Russiantortoise
8.9% Asianbox turtle
11.2%

Pangolins
Between 2014 and 2018, seizures of
pangolin scales increased tenfold. The
reasons for this increase are unclear.
All species of pangolins were elevatedto CITES Appendix I in 2016, butthere was very little legal trade before
this time. While the main flow has
always been illegal, greater awarenessmay have produced a higher rate ofinterdiction as a growing number ofcustoms inspectors learn to recognise pangolin scales. Still, the sharp
and consistent increase in seizures ofscales year after year, as well as thegrowth in the size of the largest seizures, strongly suggest an increase in
the illicit flow. Attempts to farm pangolins for commercial purposes havefailed, and the loss of millions of wild
pangolins to illicit markets cannot besustained. Individual seizures made inrecent years have been comprised of
the scales of tens of thousands of pangolins, indicative of highly organizedcriminal operations.

False map turtle
2.9%
Mali uromastyx
2.3%

Indian star
tortoise
21.3%

Source: UNODC World WISE Database*** Includes bodies.
** The top 10 live reptile species seized represent 33% of all reptiles seized when looking
only at bodies and live specimens.

ivory, Viet Nam has become a conduit
for this larger market.

resulted in an abundance of “howto” videos to catch species, encouraging people living in the range area
to collect reptiles opportunisticallyfor secondary income. Middlemen
Reptile species are primarily traded and sellers then work through private
for décor or fashion, for food, tonics, Facebook groups and other social
or medicine and for the pet trade and media platforms to reach custombreeding. As the fashion industry has ers, with limited risk of being caught
increased its support for conserva- and easy opportunities to switch
tion and sustainable use, live reptile between platforms to dodge targeted
seizures meant for the pet trade are law enforcement efforts. Large repbecoming far more common than tile shows and outdoor markets act
seizures of reptile skins. This is espe- as rallying points for collectors andcially true for tortoises and freshwater dealers to build relationships and exeturtles, which constitute nine out of cute pre-arranged purchases.
the top 10 CITES-listed wild-sourced
live reptile species seized in the last
There has also been a shift in the nature ten years. These species are sourcedof pangolin seizures over time, away from a range of regions including All parts of the tiger are traded andfrom live and meat seizures (mainly South Asia, Central Asia, South-East used, for traditional medicine and forof Asian species) and towards Afri- Asia, East Africa and West Africa. East other purposes, but the bones are gencan pangolin scale seizures. Significant and Southeast Asia, followed by the erally most sought after. Consumer
meat seizures continue to be made in United States and Europe, are their demand has shifted in recent years
Asia, but most seizures in recent years main destinations.
with tiger product buyers purchasing
were of scales exported from Africa
these goods as a sign of wealth rather(especially Nigeria and the Demo- Tortoise and freshwater turtle are than for their health. The most popcratic Republic of the Congo) to Asia primarily trafficked in small batches ular bone-based products appear to(especially Viet Nam). Looking at a via air transport, in person or via be tiger wine and tiger glue/paste. A
broader range of time, China has been post, to limit death in transit. The large part of the trade has shifted tothe primary destination of pangolin advent of social media and YouTube online sales through social media andshipments, so it appears that, as with and other video sharing sites has messaging apps.

Reptile pets

Big cats

15

SUMMARY AND OVERVIEW

While the number of seizures oftigers and their parts remains small,that number has risen from 2007
to 2018. Thailand and India are themain source countries for these seizures, although sourcing from Nepal,
Bangladesh, and Bhutan is also ongoing. Given the large captive tiger
population in Thailand, which hasless than 200 wild specimens, most ofthese seizures likely involved farmed
animals. In contrast, seizures from
India, with the world’s largest wild
population, are likely from wild animals. Trafficking networks for tiger
products involve Chinese, Vietnamese, Indian, and Indonesian traders
who primarily sell the products toEstimated number of tigers (wild and captive) by selected
country, 2016 or most recent data

Fig. 97,000

Number of captive tigers

number of tigers

6,000

Number of wild tigers

4,000
3,000
2,000
1,000

a

ia

ric

th

er

Af

s

an

ica

O

O

er

ce

a

Am

er

ric

am

Af
h

ut

Ru

ss

O

th

So

Vi

et

N

R

n

PD

tio

La

o

pe

ra

ro

ia

n

Fe

de

sia
th

er

Eu

ia

ne

In

do

nd

th

er

As

a

la

di

ai

O

Un

O

ite

d

Th

In

at
St

Ch

in

a

es

0

Source: CITES

Fig. 10 Amount of glass eels seized (in kilogram), 2011-2018*
8,428

WORLD WILDLIFE CRIME REPORT 2020

kilograms of glass eels seized

8,000
7,000
5,800

6,000
5,000

4,499

4,000
2,964

3,000
2,000
1,000

1,887

1,895

2012

2013

1,620

246

0
2011

2014

2015

2016

Source: UNODC World WISE Database* The specimen types included in this analysis are live and fingerlings from the family Anguillidae.
Data from 2018 are preliminary.

16

2017

In addition to tiger products, products based on other big cat species
have been seen in the illicit market,
raising concern for those species.
These include clouded leopard, snow
leopard, jaguar, and lion parts, somepassed off as tiger products. African
lions appear to be the species of greatest concern, though, with current
interest in the bone trade spurring arise in the South African lion and tiger
breeding industry.

European eel

5,000

9,000

medicinal industries in China andmanufacturers or consumers in Viet
Nam and Thailand.

2018

Because eels have never been successfully bred in captivity, the productionof eel meat is a multi-billion-dollar
industry entirely reliant on wildcaught juveniles, known as “glasseels”. Demand for eel meat is especially strong in Asia. As with otherwild species consumed in growing
Asian economies, local populations ofeels have been overtaxed by growing
demand, leading to a global search
for alternate species. Eel meat is also
consumed in Europe, but declines in
European stocks, teamed with growing international demand, led to theprohibition of export of eel from theEuropean Union in 2010.
Since this time, the European authorities have detected organized criminal
operations trafficking European glass
eels to Asian farms. Because live
glass eels must be kept in controlled
conditions, these operations typically purchase European glass eels at
source and rapidly transport themby air courier or air freight to commercial growing ponds. Successfulinterdiction is likely to lead to the
exploitation of eel populations inparts of the world where there is lesscapacity to respond effectively.

Box 3: The role of bribes in the illicit wildlife trade
A common theme in the illicit trade ofivory and rhino horn (and more generally with all illicit wildlife trade) is corruption in the form of bribes. Corruption
has been found to be a critical enabler ofthe illicit wildlife trade, taking place atsourcing, transit and export stages, andinvolving public and private sector abuseof power and trust.a It can be ad hoc,
involving smaller amounts of money andlower-level officials, or systemic, involving
larger amounts of money, higher-level
officers, and generally pre-planned.b
The case of the Shuidong connection ,documented by the Environmental Investigation Agency, showed that bribes canmake up 4 – 10 per cent of the final(wholesale) sales value of ivory in Asia.
The overall bribes paid in that single
case amounted to US$90,000-210,000.
In 2012, along the Viet Nam-China
border, there was an estimated
US$18,000 to US$30,000 a day givenout in bribes to border officials to allow
ivory to cross borders illicitly.d Moreover,
several member states reported to theEastern and Southern Africa Anti-Money
Laundering Group (ESAAMLG) cases oflaw enforcement officials involved intrafficking.
cdefeating or obstructing the course ofjustice for failing or omitting to detectand stop the 18 rhino horns.
A court case documented that fraudulently acquired hunting permits wereused to divert rhino horns to markets in
the Lao People’s Democratic Republic
and Thailand. f ESAAMLG noted thatthe authorities issuing such hunting permits could be subjected to corruptive
practices.g
Corruption can thus occur at any level ofthe supply chain and involve many different actors. In 2018, the Organisation
for Economic Co-operation and Development (OECD, see note a) collected open
source data from four selected countries(Kenya, Uganda, United Republic ofFig. 11

Tanzania and Zambia) and identified therole of corrupt actors in reported cases,
concluding that corruption may go far
beyond lower-level police officers andpark rangers. In the cases analysed,
those involved in law enforcement operations (police, military, and customs)
were the government officials mostinvolved in corruptive practices. Officials
responsible for administration were also
involved but at a lower rate. Only asmall portion of corrupted officials
included park rangers (7 per cent).
An estimate of the overall volume ofbribes paid is beyond the scope of thisreport and the data available does not
permit it.

Government agency or role of actors found to becorrupt in available court cases
Customs/
border officer
6%

Other
5%

Foreign official/
diplomat7%

Police officer
32%

Elected official
7%

The Financial Intelligence Unit (FIU) of
Park ranger
Namibiae documented a case in which
7%
18 rhino horns weighing a total of 43
Administrative
Military
government
kilograms were found in the luggage of17%
officiala passenger who arrived from Namibia
19%
in South Africa and was about to board
a flight to Hong Kong, China. A Namibianpolice officer has been charged with Source: OECDa (based on the identifiable agency from open source data collection)aOrganisation for Economic Co-operation and Development (OECD),‘Strengthening Governance and Reducing Corruption Risks to Tackle Illegal
Wildlife Trade: Lessons from East andSouthern Africa’, Illicit Trade, 2018.
b Ibid.
c Environmental Investigation Agency(EIA), The Shuidong Connection:
Exposing the global hub of the illegal
ivory trade, 2017. See: SHUIDONG
CONNECTION BOX.

d Bennett, E. ‘Legal ivory trade in a
corrupt world and its impact in Africanelephant populations’. Conservation
Biology, 29(1), 54–60, 2014.
e Republic of Namibia Financial Intelligence Centre, Trends and typology
report No 1 of 2017: Rhino and elephantpoaching, illegal trade in related wildlife
products and associated money launderingin Namibia, 2017.

f

UNODC, Sharing Electronic Resourcesand Laws on Crime (SHERLOC), Case
Law Database, available at: sherloc.
unodc.org. Case number ZAFx008.
g Eastern and Southern Africa AntiMoney Laundering Group (ESAAMLG),
A Special Typology Report on Poaching
and illegal trade in wildlife and wildlife
products and associated money launderingin the ESAAMLG region, 2016.

17

SUMMARY AND OVERVIEW

Illicit financial flows
The oft-heard refrain “follow themoney” has been raised with regard
to wildlife crime, but there has been
little systematic assessment of how
much money is associated with illegal
wildlife markets and how this money
is distributed.

continuously monitor the situationand to provide insights on potential
weaknesses that allow for disrupting
illicit supply chains.

WORLD WILDLIFE CRIME REPORT 2020

The annual illicit income generated
from ivory and rhino horn trafficking
between 2016 and 2018 was estimated at US$400 (310 – 570) million
for ivory and US$230 (170 – 280)
Countering illicit financial flows has million for rhino horn trafficking.
been recognised in the Sustainable The largest shares of income are genDevelopment Goals under target erated at the retail level, where rhino
16.4.: “[b]y 2030, significantly reduce horn and ivory are processed andillicit financial flows and arms flows, sold to end consumers. The emergstrengthen the recovery and return ing illicit financial flows (volumeof stolen assets and combat all forms of cross-border transactions) couldof organised crime.” The estimates be – depending on how complex thepresented in this report provide an supply chains are – almost twice as
indication of the potential flows much, namely US$ 570 million forarising from the illegal trade in ivory and US$390 million for rhino
rhino horn and ivory and highlight horn. There is, however, a large range
the importance of systematic col- of possible scenarios.
lection of price and supply data to18

Endnotes
1 Further details on World WISE can befound in Chapter 1. Introduction.
2 Certain parties have submitted illegal
trade reports to the CITES Secretariat
but refused to let their data be used forresearch purposes by UNODC.
3 The annual data collection on AITRs was
still on-going when data processing for thepresent report had to be finalised. Therefore, data for 2018 should be used cautiously as they are not directly comparablewith those of previous years.

POLICY IMPLICATIONS
Wildlife crime involving organizedcriminal groups is serious crime.
No country is untouched by thiscrimes, which impacts biodiversity,
human health, national security
and socio-economic development,
and lines the pockets of organizedcriminal groups. The illegal trade inwildlife, which by definition does
not go through proper sanitary andphytosanitary controls, can potentially lead to the spread of zoonoses,
such as SARS-CoV-2 that caused the
COVID-19 pandemic. Addressing
the biodiversity crisis and its cascading effects cannot be done without
acknowledging the negative impact
caused by transnational organizedcrime and corruption, across theentire wildlife trafficking chain. As
each country may be a source, transit
and/or destination country, each has
a role to play in acting to prevent andaddress these crimes through disruption and deterrence. Wildlife crime,
like other organized crimes, must
be addressed through a balanced
approach that targets the complementary pillars of supply, demandand livelihoods.
A significant portion of this report isbased on seizure data collected froma wide range of countries. Poaching,trafficking and the illegal movementof large volumes of various protected
species and their products acrossnational, regional and international
borders continues, to a large extent,
unabated. In 2019 and in the firsthalf of 2020, several major seizuresof ivory, rhino horn, pangolin androsewood have been recorded. Therealso appears to be geographic consolidation of trafficking routes acrossseveral markets, with Nigeria emerging as a key source/transit country formany of the shipments noted above.
Similarly, Viet Nam has emerged as a
key destination country for shipmentsof ivory and pangolin scales, although
the domestic market for both commodities appears to be limited.

Also, the first clear and consistentlinkages between two major illicit
wildlife product markets – those for
African elephant ivory and for African
pangolin scales – have been documented, with a series of large-scale
seizures containing both specimens
in recent years.

The outstanding question is why morecountries are not using such tools to
address wildlife crime? The answer
likely lies in a combination of a lackof understanding of the nature ofthese crimes and their broader impact,
insufficient prioritization and/or alack of capacity or resources. Since
countries are at different stages ofDespite these large-scale seizures, the tackling the challenges of wildlife
number of investigations that follow crime and have differing capacities
them remains disproportionately low. to do so, the following chapter offers
The news is not all bad, however: suggestions for consideration by
several African and Asian countries Member States and the international
have secured a growing number of community towards preventing andconvictions for wildlife crime. For addressing wildlife crime, which canthis trend to continue, more political support their work towards achieving
commitment must be provided, and the Sustainable Development Agenda.
increased cooperation must occur to
disrupt criminal organizations.
The previous World Wildlife Crime
Report flagged the importance ofcountries undertaking an in-depth
assessment through the ICCWC
Wildlife and Forest Crime Analytic
Toolkit1 process to better understandtheir criminal justice and preventive
responses to wildlife and forest crime.
To date, 12 countries have completed
the Toolkit process, while 10 moreare underway; seven countries haveconducted the Indicator Framework2.
Both mechanisms allow for assessment of gaps in the national responseto these crimes and identify areas thatwould benefit from capacity building
and technical assistance. Common
insights from these processes include
the importance of having criminal
legislation that recognizes serious
wildlife crimes, and that capacity
gaps in knowledge and resources, aswell as a lack of mandate, can prevent
enforcement from taking place. Interagency coordination and international
cooperation are often cited as vital –but missing – keys to success.

Wildlife crime is serious,
organized crime

The objective of organized crime is togenerate profit; organized criminalgroups involve three or more people
working together for a period of time,with the aim of committing one ormore serious crimes in order to generate financial or material benefits, often
by providing illicit goods and services.
Transnational organized criminalgroups operate across borders; theirillegal behaviours include laundering
the proceeds of their crimes, corrupting officials or engaging in corrupt
acts, and actively working to obstructjustice. Such groups make use ofsophisticated, complex transportationand finance networks. This reportunderlines that most of these features
are present in the most serious formsof wildlife crime. The size and scaleof the illegal shipments documented
in this report require complex logistics and strong networks, suggesting
the organized nature of these crimes
and the involvement of a multitudeof individual stakeholders in the
trafficking.

Many tools to tackle serious andorganized crimes already exist, includ- Pursuant to UNTOC, ‘serious crime’ing the international legal frameworks refers to an offence punishable byprovided by UNTOC and UNCAC. a maximum penalty of at least four

19

POLICY IMPLICATIONS

years of imprisonment. By increasing the maximum penalties for themost serious types of wildlife offences,some countries have started to framethese offences as serious crimes intheir national legislation; as such,these crimes fall under the scope of
UNTOC, and therefore Parties canbenefit from the various tools forinternational cooperation containedin the Convention. Critically, countries should ensure that domestic
legislation and procedures allow theuse of alternate offences to pursue
wildlife crime, such as money-laundering, corruption, fraud and enablewildlife crime to be considered a
predicate offence for such crimes, toallow the use of the various tools to
address these.

have been made by Member States
to address wildlife crime and associated economic crime and corruption,
as well as to engage key stakeholders
and enhance international cooperation. The Sustainable Development
Agenda includes a variety of targets
associated with reducing wildlife
trafficking, notably 15.7 4, further, theinternational community has resolvedin a series of UN General Assembly
resolutions on tackling illicit wildlife
trade, in addition to those of theCommission on Crime Prevention
and Criminal Justice, CITES and
UNCAC, to work to end this scourge.
Combined with several national andregional strategies for addressing
wildlife crime, these statements andcommitments lay the political foundation to end wildlife crime. SuchIn addition to making illicit traf- commitments raise expectations forficking in protected species of wild action, and also provide the necesfauna and flora involving organized sary mandates for the international
criminal groups a serious crime in community to provide technical andnational legislation, illegal trade financial support to address wildlife
could be more easily targeted if each crime and its associated crimes.
country were to consider prohibiting,under national law, the entry, exit orin some cases, possession, of wildlife
products that were illegally obtainedin, or illegally traded from, anywhere
else in the world.3 Addressing vulnerabilities in legislation – both domestic This report indicates that corruption
and international – can help reduce exists across all stages of the wildlife
opportunities for trafficking.
supply chain and can facilitate the illegal trade of wildlife. This corruption
Further, consistency and harmoniza- manifests itself in various ways, rangtion of legislation within countries ing from officials receiving bribes andand across regions is critical to close colluding with criminals, to abuse ofloopholes and prevent displacement office and embezzlement of resourcesof crime to areas with lower penalties. allocated to wildlife management andThis could also improve cross-border protection. Bribes paid to officials
investigations and judicial cooperation. can make up a significant part of theoverall costs of wildlife trafficking; forexample, as noted in Chapter 8 onillicit financial flows, customs officers
may receive 4-10 per cent of the final
Galvanizing political will around the wholesale value of ivory.
issue of the seriousness of wildlife
crime has led to a series of high-level Criminals engage in corruption tointernational political events, like the create the veneer of legitimacy; as aLondon Conference of October 2018 result, illegal enterprises can be preand the first regional conference of the sented as legitimate sources of wildlife.
Americas on the illegal wildlife trade Corruption inhibits the ability ofin October 2019. Commitments honest public officials to fulfil their

Addressing corruption isfoundational to preventing
wildlife crimeWORLD WILDLIFE CRIME REPORT 2020

Political will can be harnessedto generate action

20

mandates, whether those be managing and protecting wildlife resources,
protecting borders, or managing andregulating markets for wildlife products. Corruption also interrupts thepath towards criminal justice, as theabsence of controls may result in evidence being lost or concealed, as wellas leaving witnesses, prosecutors andother judicial officers vulnerable tocorruption. Delays in expedient trial
processes may increase opportunities
for wrongdoing.
The international community has
recognized the importance of theissue. In 2016, at the 17th meetingof the Conference of the Parties to
CITES, a resolution5 was passed calling on Parties to take a broad range ofmeasures to prevent and combat corruption linked to the illegal wildlife
trade. In 2019, the 8th Conferenceof the States Parties to the UN Convention against Corruption adopted
a resolution,6 the first of its kind, on
preventing and addressing corruption
linked to crimes that have an impact
on the environment. The resolutions
recognize that corruption underpins
the illegal trade in natural resources,
constitutes a growing source of profits
for various criminal actors, and that
addressing this connection is vital totarget action to reduce illegal harvesting and trade and raise awareness ofthe detrimental effects of corruption.
These resolutions help create thepolicy environment in which to
deepen and strengthen the muchneeded practical work to combat
and prevent corruption linked towildlife management. Corruption
prevention and risk mitigation work
has commenced with wildlife, forest
and fisheries management authorities across Africa, South-East Asia andLatin America. These efforts need to
be strengthened and prioritized bymany more countries. To improve
results, it is necessary to support
leaders to put more transparent andaccountable processes and systems inplace, including oversight and auditing services and tools in government

decision making, conducting investigative units, such as Financial
anti-corruption risk assessments7 and Intelligence Units, customs, anti-corstrengthening integrity policies and ruption units, crime intelligence units,
frameworks across the entire crime forensic investigators, crime analysts
prevention and criminal justice chain. and others, seems to be the exception
rather than the rule.8
Many more instances of wildlife
crime and trafficking warrant being Good risk management practices
investigated and prosecuted as crimes that enable profiling and targetingof corruption, and the number of to detect and identify suspicious
associated financial investigations shipments and persons are crucial toneeds to be further increased. Such effectively addressing crime, includan approach not only provides inves- ing wildlife crime. As noted above,tigators with a wider range of powers however, detecting illegal wildlife
and techniques than may be available shipments and the associated seizures
under wildlife legislation, but may should, to the fullest extent possible,
well also offer a more extensive range be used as the starting point for furand severity of penalties. Investigating ther investigations. More must be
and prosecuting corruption and other done to go beyond seizures, to trace
economic crimes will help target more the ultimate beneficiaries of the trafsenior members of criminal groups ficking through robust investigations,and actual beneficiaries of wildlife including parallel financial investigacrime, and disrupt organized crimi- tions, that lead to viable court cases.
nal groups.
Capacity building from ‘crime scene
to court’ is critical to this end.

Enforcement must go
beyond seizures

As noted above, recognition of
wildlife crime as ‘serious crime’ in
relevant legislation is an importantfirst step, but this must be reflected
and reinforced throughout national
criminal justice systems. Legislation
can only have the desired impact if it
is effectively implemented, however;in many States, such implementationis still lacking, and combating wildlife
and forest crime has not been set asa priority for enforcement by policyand decision-makers. Criminals willcontinue to exploit legislative andenforcement loopholes, and where
weaknesses exist, the illegal trade will
be displaced to States less capable ofaddressing them. Many law enforcement agencies in source, transit anddestination States require additional
technical and financial assistance toaddress capacity gaps, including help
to better prevent, detect and investigate wildlife trafficking, and better
training and protocols on how tosecure and deal with specimens once
seized or confiscated. The support andengagement of specialized bodies and- -- Targeted enforcement approaches

may be required for different
species. As detailed in Chapter
8 on illicit financial flows, there
are distinct differences in supply
chains for different products; forexample, rhino horn poachers
are more organized than ivory
poachers. The differing degreeof professionalization of thesegroups – when indeed, they are
different groups – suggests thata more specialized law enforcement response is required against
rhino poachers, while elephantpoaching may be effectively
targeted through, amongst others,
community-based interventions.

- -- Specialized investigative tech-niques, such as controlled
deliveries, can be used to disrupt
and dismantle criminal organizations. Allowing a shipment toproceed to its final destination
allows law enforcement authorities to identify and address role
players across the entire tradechain, while also facilitating
a better understanding of themethods being used by criminal
networks. Controlled deliveries
should increasingly, and wheneverpossible, be considered as part of
wildlife crime investigations.
- -- Officials involved in building

cases often have limited training
on data management, intelligence analysis or other advanced
investigation methods andtechniques, which would greatly
enhance strategic and tacticaldecision-making. Improving
information analysis capacities
can provide authorities with
important data for cross-referencing information, identification of
resource needs, and exchange ofbest practices at the national andinternational levels.

- -- Science must be leveraged. To

this end, the use of forensic
science is critical, not only toidentify or verify species but
to deliver admissible evidence
that supports law enforcement
investigations and prosecutions.
Enhancing national laboratory
capacity to operate to internationally accepted standards is an
important goal. In the meantime,
countries should consider drawing upon the services of suitableinternational forensic providers
who are accredited and certified
to carry out wildlife forensic
analyses, mindful of issues ofadmissibility of evidence in certain jurisdictions. Portable labs
could also be considered, as these
could speed up turnaround timeand provide short-term national
solutions for some countries.

- -- Wildlife crime scenes can belocated anywhere from remoteareas to urban centres and border
posts. Responding to such
incidents can be complex andfirst responders must be properly
trained, as mistakes made at the
beginning of an investigation canjeopardize evidence and prevent
perpetrators from being brought

21

POLICY IMPLICATIONS

to justice. Robust chain-of-evidence/custody protocols forsamples that are collected to besent to forensic labs are vital toensure that the results of analyses will be admissible in court.

WORLD WILDLIFE CRIME REPORT 2020

- -- Wildlife is illegally traded in very

complex supply chains, which
can result in significant illicit
financial flows. Understanding the business practices ofcriminal operations, and how
licit businesses are exploited bycriminal groups, is essential incombating the crimes committed
by organized criminal groups.
Conducting parallel financial
investigations can identify theultimate beneficiaries of wildlife
trafficking and disrupt illegal
income streams. The money
should be followed in every
direction, not just towards profits
and assets. Organized criminalgroups spend money to commit
crimes (for example, by paying
for harvesting equipment (chainsaws, firearms, ammunition)),for transportation (for example,
plane tickets for couriers), toestablish front companies, etc.,
and these flows should also
be used as indicators to detect
potential illicit transactions andopportunities for disruption.
To this end, basic information
gleaned during law enforcement
processes, such as details of thebusiness structures and the financial transactions criminal groups
enter into, must be collected.
They should also be researchedfurther and built into typologies
to classify and outline criminal
operations and techniques. Suchtypologies should be frequently
updated, to allow all relevant
agencies with the potential tointervene in the money flow chain
to understand the potential vulnerabilities and what to look for.

- -- Even when follow-up inves-tigations to seizures may nottake place, it is important that22complex cases they should be involvedin the process as early as possible. If
investigations lead to prosecutions
and cases going to court, prosecutors
need to charge all possible infractions
linked to the case. For this to happen,
it is necessary that the investigating
officials correctly identify points toprove at the outset of an investigationand collect the necessary evidence tobuild a strong case. At the same time,prosecutors need to be aware of themulti-faceted nature of wildlife crime,
which can touch upon many different
pieces of legislation. Although there is
growing awareness of the importanceof having a strong legal framework
under which to lay charges, there
are still deficiencies in applying all
relevant provisions of the law andunderstanding the importance of
selecting the right charge to use. For
this, prosecutorial services should be
provided a continuum of capacity
building focusing on the codificationof the decision to charge, the practiceof written and continuous review, andthe use of ancillary legislation. This- -- Law enforcement would also bene- would have an added benefit of mitfit from strong partnerships withigating corruption risk by making theprivate sector service providers
decisions taken during a prosecution
whose infrastructure and protransparent and accountable.
cesses are used to facilitate illegal
trade, such as the transport andMany cases end in dismissal or
financial sectors, to help identify
acquittal because the initial charging
patterns, trends, and possible red
decision was made without enoughflags that could facilitate coordievidence present to successfully provenated action, combining forces
the charge and, in the absence of
to combat trafficking. Other pub- continuous review by the prosecutor,
lic-private partnerships that candifficulties such as witness attendbe beneficial include those thatance or questions over admissibility
supply software solutions, suchof evidence are not identified in time.
as to strengthen intelligence gath- Support to the prosecution services toering to inform decision-making
navigate existing law, such as using
or to provide various forensic
tailored reference guides for charges
services. All these mechanisms
to levy and points to prove that reflect
can build capacity, as suchthe broad range of criminal statutes
partnerships can put tools andand customs laws relevant to wildlife
information into the hands ofcrime, would be beneficial. Support
those who can make a difference.
should also be provided to prosecution services to identify areas thatwould benefit from legislative change,such as the power to appeal lenient
sentences.
Prosecutors are the gatekeepers of
the criminal justice system, and forrelevant agencies, at national,
regional and international levels,
receive and record the key facts
related to all seizures, as thesehave significant value for risk
assessment and profiling purposes, as well as for intelligence
analysis. Such disseminationof information/intelligence may
also provide insights to otherforms of crime and links to otherorganized criminal groups. For
example, the World Customs
Organization’s Customs Enforcement Network database is asource of intelligence for risk
assessments. Several networks,
both formal and informal,
already exist to share information,such as INTERPOL’s I 24/7,
WCO`s Environet, Wildlife
Enforcement Networks (WENs)
and various “Trade in Wildlife
Information eXchange (TWIX)”
networks like EU-TWIX,
SADC-TWIX and Africa-TWIX,
but they are often underutilized.

Prosecutorial support andengagement are critical

Equally important is the need forprosecutors to have effective casemanagement systems, preferablyelectronic. This allows for early
engagement with investigators andenables prosecution-guided investigations with enough time forprosecutors to review cases before
and after the charge. Prosecutors
require access to all documents relevant to the case in order to facilitate
efficient court proceedings. The
number of cases that are dismissed
as a result of basic case management
deficiencies are unacceptably high.
This not only demotivates the prosecutor and frustrates the judiciary,it also undermines the prosecutor/
investigator relationship and damages public confidence in the criminal
justice system.

and cooperation at all levels is not
the norm in many countries. There
continue to be structural and political challenges in many countries toestablishing inter-agency platforms
to apply a whole-of-government
approach. The need to clarify theroles and responsibilities of the various agencies mandated with wildlife
law enforcement continues to exist
in many countries; such clarification
would improve not only efficiency but
would better position entities to allow
for improved inter-agency coordination. There is an urgent need for atrans-disciplinary approach that ties
together law enforcement, wildlife
management authorities and otherrelevant authorities such as Financial
Intelligence Units, public health andsafety agencies, administrative andlocal authorities. Countries could
In addition to the benefit of elec- benefit from transnational organizedtronic case management systems, crime units or other agency coordinaprosecutors and judges often do not tion/technical working mechanisms,
have access to a centralized database including inter-agency platforms thatof previous wildlife crime cases to promote an integrated and multidishelp guide their decisions, which ciplinary response between decision
can result in lenient or inconsistent makers and technical officials at thesentencing. A further benefit of tech- federal and local levels.
nology can be harnessed to facilitate
expert testimony, notably in cases
where expertise may be limited. Using
technology as such would render the
court process more efficient and effective, notably when there is a need to
explain complexities and the impactof these crimes.
There is often a long chain of criminality between the site where an
animal or plant was illegally killed
or obtained, and its final destination.
As detailed throughout this report,
wildlife crime stretches over national
borders and across continents. While
There is often a lack of clarity con- decades of negotiations under CITES
cerning the roles, obligations and have contributed to reduce the grey
mandates of national agencies as to areas between legal and illegal trade
where wildlife crime “fits” in the of wildlife, cooperation to tackle thenational context. Increasingly, wildlife blackest end of the spectrum is still,
crime impacts on a variety of sectors however, in its infancy, as highlighted
and increasingly, cases of conver- by the rarity of prosecutions and congence with the trafficking of other victions that follow a seizure.
commodities are coming to light. As
such, national agencies should coop- As noted above, as more and moreerate, work collectively and share countries move towards punishing theinformation, but full integration illegal trade of wildlife with maximumInternational cooperation on
criminal matters related toillegal wildlife trade can thensupport national efforts

Inter-agency coordination on
wildlife crime is necessary at
the national level

penalties of at least four years imprisonment, this type of serious crime
falls under the scope of UNTOC andenables Member States to deploy thetools available in it against wildlife
crime. Parties should look more regularly at UNTOC as the legal basis forinternational cooperation, including
for mutual legal assistance (MLA),
extradition, joint investigations anduse of specialized investigative techniques such as controlled deliveries
and undercover operations for themost serious forms of wildlife crime.
UNTOC is a strong foundation for
MLA, which is a principle mechanism
used for international cooperation
towards investigating and prosecuting
serious crime types. Despite its importance to successful investigations andprosecutions, MLA is seldom usedin the wildlife crime arena, and theinternational community needs tobetter understand the challenges inusing MLA and increase its efforts tobuild capacity to promote this tool.
Outside UNTOC, States could also
look to use, if preferable, bilateral orregional mechanisms/agreements to
exchange information and facilitate
international cooperation on criminal
matters, including through networks
and information-sharing platforms
such as those noted previously.
Partnerships and other initiatives andnetworks play an important role insupporting the law enforcement community and in strengthening efforts toaddress transnational crimes such as
wildlife crime. For example, the International Consortium on Combating
Wildlife Crime (ICCWC) is a collaborative effort between the CITES
Secretariat, INTERPOL, UNODC,
the World Bank and World Customs
Organization (WCO). Coordinatedcapacity building and support atnational, regional and international
level and strengthened criminal
justice systems help to ensure thatperpetrators of serious wildlife crimes
face a formidable law enforcement
response.

23

POLICY IMPLICATIONS

Various networks to support different elements of the criminal justiceresponse also exist and can be thebasis for cooperation and joint investigations, such as WENs, anti-money
laundering and anti-corruption
networks and working groups, andforensics networks like the African
Wildlife Forensics Network andspecies identification databases, like
RhODIS9. Such regional and inter-regional mechanisms are platforms forcooperation and aim to combine
forces to disrupt and dismantle transnational organized criminal groups
and work to bring them to justice.

submission and quality of Annual Illegal Trade Reports (AITRs) by CITES
Parties to the CITES Secretariat. The
requirement for AITRs to be submitted was agreed at the 17th meetingof the Conference of the Parties to
CITES in 2016, and the first reports
were due in 2017. While this is a newrequirement, submission rates are still
relatively low and there remains significant room for improvement in
the submission of AITRs. Only 78
countries submitted AITRs at least
once between 2017 and June 202010
and, while these countries represent
some of the main source and destination countries for illegal wildlife
trade, it is important to obtain datafrom all Parties to identify emerging
trends, species or regions of concern.
Building the capacity of countries to
identify the species of seized speciData and evidence on criminal groups, mens and creating the infrastructure
prices, modus operandi and the to report the seizures in a standardcriminal justice response, and com- ized format is vital for monitoring andmensurate analysis, are the foundation research on the illegal trade.
of evidence-based policy making andprogramme development. Continu- While there is a gap in country-related
ing to conduct and provide financial data, the data historically collectedsupport for international research and often focused on charismatic species
analysis on wildlife crime, especially like elephants, while other trafficked
global analyses like the World Wild- species such as birds, reptiles, spiders
life Crime Report, is therefore vital and aquatic species have tended to go
to reducing illegal wildlife trafficking. under-documented, thus hampering
proper enforcement efforts. Without
The lack of the aforementioned data an even representation of the scope
severely hampers understanding of of the data – geographic and species
market dynamics and renders the – there is a risk of targeting enforceinterpretation of trends in seizure data ment efforts in the wrong place orquite difficult. There are significant towards the wrong species. Further,gaps in research and data on wildlife there is a need for additional analysis
crime in many countries; for exam- on the use of alternative species inple, the dearth of wildlife crime data some markets, such as leopard, jaguar
in Latin America leaves a vacuum in and lion as substitutes for the tiger
understanding the situation of wild- bone trade, or whether helmeted
life trafficking to and from the region. hornbill ivory is a replacement prodWhile officials in that region have uct for elephant ivory. A strong set of
taken steps to protect endangered data to make such insights is critical,
species like the jaguar, through their as there may be different responses
commitments to address the traffick- required depending on the market
ing, they need solid research, based on trend. Another data element that is
empirical data, to guide these well-in- required to consistently measure thetentioned and commendable steps.
illegal trade is systematic reportingon price data for a variety of illegal
Of particular importance to improve wildlife products, notably for lessdata and fill in the gaps is improved well-researched species. Some of theseWORLD WILDLIFE CRIME REPORT 2020

Research, data and monitoring require ongoing funding
and improvements

24

data needs could be met through partnerships and information exchanges
with other conservation and law
enforcement stakeholders, some ofwhich manage other wildlife crime
databases, as well as through web
scraping methodologies to supplement existing official data sources
with open source data.
Currently, the AITRs request somebasic criminal justice data fromenforcement agencies, but these data
could be expanded to include thecollection of more detailed data thatwould allow tracking cases throughthe criminal justice system to provide a basis from which to measuresuccesses in tackling the illegal trade.
Such data could also point to goodpractices that could be applied or
expanded upon in other contexts.
It is worth noting that the AITR does
not collect data on gender-related
matters: very little is known about
the specific roles of women and men
in wildlife crime, and more research
efforts should be placed on understanding the gender dynamics of theillegal wildlife trade. If enforcement
agents are making assumptions about
gendered aspects of wildlife crime,
they could be missing opportunities for seizures and arrests, and thepolicy and programming communities could be missing opportunities
to design tailored interventions thatwould foster sustainable success.
Lastly, while global research on
wildlife crime has mainly focusedon internationally protected species,
little comparative analysis is available
on wildlife crime affecting nationallyprotected species, including illegal
domestic trade. With criminals taking
advantage of any loophole, there is aneed to better understand the trafficking of non-CITES listed species
within and across borders to support
law enforcement and criminal justicepractitioners to define national andinternational tools that can protect
the biodiversity of each country from
criminal threats.

Addressing wildlife crime as
it moves to the Internet

countries and their enforcement agencies must ensure that their strategies,
tactics and activities do not alienate
Like many markets, trade in wild- such communities, but that theselife and wildlife products is moving communities are included as partners
online. Organized criminal groups are who can support and protect the habincreasingly using a range of online itat they share with wildlife.
platforms and technologies to facilitate the transnational trafficking of Beyond enforcement, investing inwildlife products. Member States and engaging local communities asshould develop the capacity of law partners has been effective in several
enforcement agencies to investigate areas. Success has been achieved as aonline sales of illegal wildlife, infil- result of tailored frameworks to fit thetrate existing online markets, collect nature of the challenges and opporrelevant evidence including using tunities, and due to fostering active
digital forensics, and develop enforce- participation of the local commument countermeasures. Monitoring nity members to become guardiansof online trade, and using available of wildlife. Successful initiatives havetechnology to track key hubs, pat- commonalities like shared manageterns and players involved in the ment rights and fair and equitable
illegal trade, is critical to disrupting benefit-sharing, such as in conservthe organizations exploiting online ancies that are managed directly by
platforms. These efforts must be local communities. Crucial is theflexible to enable law enforcement empowerment of those in the comto react quickly when, for example, munity, with support to build skills,
reptile traders switch to other online provide resources and incentives toplatforms after one platform cracks engage in stewardship or disincentives
down on illegal trade.
for illegal behaviour.

the international community must
look to foster small business enterprises and to promote various formsof sustainable livelihoods. National
agricultural and rural development
strategies must include communities vulnerable to the temptation topoach and take wildlife in an illegal
and unsustainable manner. There are
numerous best practices that can betaken from alternative development
programmes aimed at reducing theillicit cultivation of drug crops.

Several forms of legal and sustainablewildlife use can be important sourcesof income for families who live close
to global biodiversity hotspots. Sustainable livelihood initiatives must
go beyond eco-tourism, which has
proven to be vulnerable in the faceof travel restrictions associated with
the COVID-19 pandemic. Instead,future-proofing livelihoods that focus
on resiliency and can withstand the
myriad challenges posed by the
impact of climate change, pandemics and criminal exploitation must
be considered as part of any national
As both legal and illegal trade increas- Communities living in close proxim- strategy for tackling wildlife crime.
ingly use virtual means, partnerships ity to wildlife have been exploited by
between law enforcement and organized criminal groups, often as atechnology platform partners like result of a lack of legitimate income
Facebook, WhatsApp, Alibaba and earning opportunities. Building resilWeChat, amongst others, will be an ient and sustainable communities As reflected throughout this report,
important mechanism to prevent and is key to incorporating them into illicit markets for wildlife are not that
disrupt illegal trade. These platforms national efforts to end wildlife crime. different from other illicit markets. Ifshould support efforts to regularly This requires both establishing trust there are strong regulations in place,monitor specialist social media groups and confidence and ensuring that and high levels of demand, prices
and other online sales channels for communities benefit from the natural for the products go up. This, in turn,illegally-traded wildlife.
resources. An inequitable distribution increases the profits lining the pockets
of gains tends to generate marginali- of criminals offering these products
zation and a lack of trust, and a low illegally. If efforts to curb the traffickvaluation of wildlife by communities. ing do not impact the overall market
Governments should ensure that – both supply and demand - there
private sector entities, which often is often a replacement or ‘balloon’
Communities that live close to manage and operate tourism and effect, which displaces the trafficking
wildlife are key partners in tackling related industries, share the benefits to other products or locations. This
wildlife and forest crime. They can and income derived from such opera- phenomenon also exists in wildlife
play an essential role in preventing tions and respect the rights and voices markets, both geographically and interms of species. With strong regulacrime at source and form the so-called of community partners.
‘first line of defense.’ Community-led
tions in one place and the existence of
patrols and community-based crime Providing licit income generating high levels of demand, illicit markets
prevention initiatives can be vital opportunities for communities to supply that demand will move toextensions of national law enforce- living in, or adjacent to, areas of less-regulated places and/or towards
ment networks. As a matter of policy, wildlife is critical. Governments and substitute species.

Demand reduction is essential
to preventing wildlife crime

Improving local community
engagement and sustainable
livelihoods

25

POLICY IMPLICATIONSWORLD WILDLIFE CRIME REPORT 2020

Recent changes in the ivory market
show that efforts to impose strong
regulations, such as bans, to control
supply, while also tackling demandthrough demand reduction campaigns, can be effective. Looking at
the various bans on ivory that havebeen implemented in recent years,
these bans would not have had theimpact they had on the decline inpoaching for elephants had other,
commensurate, demand reduction
efforts not taken place. If demand forivory had stayed high because demand
reduction efforts had not been successful, the decline in poaching post-ban
would probably not have occurred.
Similar measures should be considered for any wildlife products where
there is no legal international market.
Recognizing that demand could be an
important driver of wildlife trafficking, addressing it is a core componentof reducing wildlife and forest crime.
There is no ‘one size fits all’ approach,and demand reduction initiatives
should be evidence-based, species-specific and country/community-specific.
Civil society plays an important role indemand reduction efforts, and manyorganizations have worked tirelessly
to raise awareness of wildlife crimeand conservation issues and to fundamentally change behavior in consumer
markets. Demand reduction actions
must be undertaken in parallel to law
enforcement and supply efforts, as wellas livelihoods initiatives, as success inpreventing wildlife crime can only
be achieved when all three areas are
addressed in parallel. Lessons learned
from research and previous campaigns
have demonstrated the importance ofdemand reduction initiatives foundedon culturally-sensitive, evidence-based
insights – rather than assumptions –into motivations for consumption toprovide targeted, effective interventions. Behavioral science has many
lessons that can be drawn upon, and
it is important to mainstream demand
reduction messages in culturally
appropriate communications targeting specific audiences and to reinforce
these messages over time. A strategic

26

approach needs to be developed totarget specific populations, notably
youth.

Addressing criminal
exploitation of captive
breeding facilities
Captive breeding is being exploitedby both criminals and unscrupulous
traders, and relevant countries needto do much more by way of enforcement or enactment of new laws toeffectively regulate captive breeding
facilities and ensure the legality of
their operations. While some of these
activities may be ‘legal’ in terms ofnational legislation or CITES, if theyalso support, prop up, permeate orotherwise aggravate wildlife crime andtrafficking, this must be addressed.
All countries that allow the breedingof CITES Appendix I species in privately-owned facilities for commercial
purposes bear the responsibility toensure that such businesses operate in line with CITES provisions
and implement high standards ofanimal welfare, public health safety
and legality. This report indicatesthat some licensed breeding facilities
have been used to illegally supply
demand for exotic pets, luxury products and ingredients for traditional
medicine. This is partly caused byconflicting and deficient legislationthat reduces the effectiveness of theinspection/regulatory mechanisms.
The delegation of licensing authority
to sub-national administrative structures also increases the opacity of theprocesses and the risk of corruption.
To address this, the following should
be considered:- -- Countries should adopt compre-

hensive provisions at national
and/or federal level to ensurethat laws and regulations on
possession, breeding and trading
are regularly updated, disseminated and consistently applied
throughout the territory.

- -- There is a need for greater

scrutiny of the risks and opportunities that are exploited bycriminal enterprises and criminal
networks to profit from thesefacilities.

- -- The process of issuing licenses

for these types of facilities should
be subject to multi-stakeholder
approval involving different
government departments, andanti-corruption protocols.

- -- Inspections of existing facilities

should be conducted by teams
focusing on a range of factors
including risks for human health,sanitary compliance, environmental/ecosystem implications,
integrity of the supply chain,
integrity of the business modeland animal welfare.

- -- Mechanisms should be devel-

oped to complement regulatory
inspections with law enforcement investigations that allow for
both civil and criminal justiceoversight and stricter regulation.

- -- Additional focus should be put

on traceability and proof of valid
captive breeding documentation
throughout the supply chain.

Strengthening supply
chain integrity
Organized criminal groups havedemonstrated their ability to exploit
weaknesses in complex supply chains.
As noted in the first World Wildlife
Crime Report, significant opportunities continue to exist for criminals
to launder illegally sourced wildlife through the legal supply chain.
Supply chain integrity could benefit
from making some parts of the tradetransaction process electronic, thereby
reducing opportunities for corruption,
which may also include exploring newtechnologies like blockchain. Moreneeds to be done to ensure efficient
controls are set in place to prevent
illegal trade without disrupting thelegal trade. The CITES community
has made strides towards strengthening the permits system, but theslow uptake by countries of an electronic permit system due to the highinstallation and maintenance costsmeans that gaps remain in which falsified documents and unscrupulous
actors can undermine the trade chain,making poorer countries particularly
vulnerable. CITES has supported
its Parties that expressed interest in
implementing the e-CITES permit
system11 and has worked to ensure
national systems remain robust andinteroperable. The integrity of the
CITES permit system is inherent topreventing illegal trade, and as mentioned above, reducing corruption
risk is critical.

controls in northern Uganda, theDemocratic Republic of the Congoand South Sudan to meet buyers andstockpile scales in countries where therule of law is weaker.

A similar form of displacement
occurs for the types of species trafficked. If enforcement efforts target
a particular species as a high priority,
poachers may adapt to traffic otherspecies, notably those of similar value
at destination markets, for which therisk of being caught is lower. Someof these shifts are also the result ofchanges in consumer preferences or
reductions in consumption because ofstrong enforcement. Recent seizuresof combined shipments of ivory andpangolin scales, as well as data gathered from poachers in Cameroon and
DNA tests could also be used at Uganda, suggested that ivory traffickvarious points in the supply chain ers are shifting to the pangolin scale
to ensure that species are accurately trade in response to the decline in the
declared. Regular audits can be con- ivory market.
ducted to monitor sources of supply,
and there are clear benefits to reduc- Available information further suggests
ing the gaps in collaboration between that authorities in some countries
actors at all stages of the supply chain, treat crimes involving some species,
including the private sector.
such as pangolins, as less serious thanother forms of poaching, such as elephant poaching for ivory. This resultsin the lack of enforcement action
This report has shown that offenders when some species are involved,
involved in wildlife crime, similar to which can be a driver for those species
those involved in other crimes, adapt to be specifically targeted by organtheir modus operandi to enforcement ized criminal groups. Given these
responses to avoid detection and displacement effects, law enforceto continue to operate. Offenders ment responses to wildlife crime
respond to increased enforcement in should anticipate and mitigate shifts
certain areas by shifting their opera- at both ends of the trafficking chain,tions to other geographic locations for changes in both geographical andwhere enforcement is less stringent. in species trends. Law enforcement
For example, as noted at the opening efforts should also be as versatile asof this chapter, since the last report, possible to allow for rapid changes in
Nigeria has emerged as a key source/ strategy as displacement occurs.
transit country for shipments of ivory,rosewood and pangolin scales, andViet Nam has become a major destination country for ivory and pangolin.
These patterns may be the result of The COVID-19 pandemic has highincreased enforcement in previous lighted that wildlife crime is a threatsource/transit/destination hubs, and not only to the environment and biotraffickers have sought weaker links diversity, but also to human health,
to exploit. Similarly, pangolin traf- economic development and security.
fickers take advantage of weak border Zoonotic diseases – those caused

Preventing displacementby pathogens that spread from animals to humans – represent up to 75
per cent of all emerging infectious
diseases. Trafficked wild species – pangolins, birds, turtles, tigers, bears andmany more – and the resulting products offered for human consumption,
by definition, escape any hygiene or
sanitary control, and therefore poseeven greater risks of infection. Whenwild animals are poached from theirnatural habitat, butchered and soldillegally, the potential for transmissionof zoonotic diseases is increased. The
One Health12 approach needs to beat the centre of any informed policy
involving the relationship between
humans and wildlife species. Use,consumption and trade of wildlife
species by humans need to be evaluated on the basis of scientific andfact-based information that puts
safety and prosperity for the planet
above the economic or commercial
value of these species. Stopping thetrafficking in wildlife species is a critical step not just to protect biodiversity
and the rule of law in line with the
Sustainable Development Goals, but
to help prevent future public healthemergencies.

Preventing and addressing
risks to human health

27

POLICY IMPLICATIONS

EndnotesWORLD WILDLIFE CRIME REPORT 2020

1 UNODC. (2012). Wildlife and forest
crime analytic toolkit. (Available at:https://www.unodc.org/documents/Wildlife/Toolkit_e.pdf ).
2 ICCWC. (2016). ICCWC Indicator
framework for combating wildlife andforest Crime. (Available at: https://www.
unodc.org/documents/Wildlife/Indicator_Framework_e.pdf ).
3 Examples of legislation can be found in
the UNODC Guide on Drafting Legislation to Combat Wildlife Crime on page
26. (Available at: https://www.unodc.org/
documents/Wildlife/Legislative_Guide.
pdf ).
4 Take urgent action to end poaching andtrafficking of protected species of floraand fauna and address both demand andsupply of illegal wildlife products.
5 Resolution Conf. 117.6 Prohibiting, preventing, detecting and countering corruption, which facilitates activities conductedin violation of the Convention. (Available
at: https://cites.org/sites/default/files/document/E-Res-17-06_0.pdf ).
6 Draft resolution to be recommended by
the Conference of the States Parties tothe United Nations Convention against
Corruption for adoption by the General
Assembly. (Available at: https://www.
unodc.org/documents/treaties/UNCAC/COSP/session8/Advance_unedited_resolutions_final.pdf ).

28

7 See, for example, UNODC. (2019). Scaling back corruption: A guide addressing
corruption for wildlife management
authorities. (Available at: https://www.
unodc.org/documents/corruption/Publications/2020/Scaling_back_corruption_
FINAL.pdf ).
8 See, for example, OECD. (2019). The illegal wildlife trade in Southeast Asia. (Available at: http://www.oecd.org/publications/
the-illegal-wildlife-trade-in-southeast-asia14fe3297-en.htm).
9 University of Pretoria. (2020). Rhino
DNA Index System (RhODIS). (Available
at: https://erhodis.org/).
10 The reported number refers to CITES
Parties that allowed the CITES Secretariat
to transmit AITRs to UNODC for the
purpose of updating the WorldWISE
Database and to conduct research on
wildlife crime.
11 See the CITES webpage on eCITES for
more information (Available at: https://cites.org/eng/prog/eCITES).
12 See the World Health Organization website for more information on the One
Health approach. (Available at: https://www.who.int/news-room/q-a-detail/onehealth).

1

INTRODUCTION

The second edition of the World Wildlife Crime Report takes stock of thepresent wildlife crime situation with afocus on illicit trafficking of protected
species of wild fauna and flora andprovides a broad assessment of thenature and extent of the problem at
the global level. It includes a quantitative market assessment and a series
of in-depth illicit trade case studies.
In addition, a discussion of the value
chains and illicit financial flows fromthe trade in ivory and rhino horn is
included. The report was conductedin cooperation with ICCWC partners.

criminal groups in broker countries,
neither the source nor the destinationof the wildlife, have consolidated control of multiple markets. The 2020
World Wildlife Crime Report tracks andsummarizes these trends.

attract criminal sanctions in someparts of the world.

Wildlife is protected internationallyby the Convention on International
Trade in Endangered Species of Wild
Fauna and Flora, known as CITES,The quantitative analysis is based on which provides a framework to protect
the updated World Wildlife Seizure certain species against over-exploitadatabase (World WISE), including tion through international trade. It
the latest seizure data provided to does not define wildlife crime as such,
the CITES Secretariat by its Parties but it strongly influences national
through the CITES annual illegal legislation on wildlife crime, andtrade reports. These data were circu- provides a means for international
lated to Member States by UNODC cooperation against trafficking. Parfor verification. While this database ties to CITES are required to “penalise”
This research was conducted in alone is not sufficient to describe the illegal trade, which may include theresponse to the United Nations Gen- nature and scope of illicit trafficking criminalization of serious offenses. It
eral Assembly Resolution on Tackling in wildlife on a global scale, it pro- is an agreement of remarkable power
Illicit Trafficking in Wildlife, adopted vides key indicators and a potential and scope.
in 2019. This resolution requested early warning mechanism. When
the United Nations Office on Drugs maintained and supplemented with CITES is so important because
and Crime, in close cooperation and a broader programme of research and wildlife protection laws are usuallycollaboration with Member States, to longitudinal assessments, it provides situated in broader national envicontinue the collection of informa- the international community with ronmental legislation. As a result,tion on patterns and flows of illicit the means to better understand and these laws focus on native species,
trafficking in wildlife and to report address the state of wildlife crime in and they do so in a wide variety of
the world.
thereon biennially.1
ways. Since wildlife populations are
dynamic, most wildlife related legisIf the 2016 World Wildlife Crime
lation leaves it to the executive branch
Report represented UNODC’s firstof the government to issue regulations
global assessment of the state of Providing a global assessment of determining when and how wildlife
wildlife crime, the 2020 edition of wildlife crime is challenging, because can be harvested. Species can be
this report represents a first assess- every country manages and protects added and removed from protected
ment of trends. In several instances, its wild terrestrial animals, fish, trees, species lists, licenses issued allowing
these trends have been dramatic. The and other flora in different ways the legal taking of wildlife, and quotas
poaching of both elephants and rhi- and wildlife, fisheries and forestry established to ensure sustainability. As
noceroses has declined since 2011 regulations evolve as new risks and a result, the domestic legality of any
and 2015 respectively, as have the priorities for countries emerge. There given wildlife product is a matter of
prices paid for tusks and horns. In is no universal treaty defining wildlife considerable complexity.
contrast, the amount of pangolin crime, therefore there is no universallyscales seized has increased 10-fold in accepted definition of the term. For The national lists of protected species
just five years, and new markets, such the purposes of this report, the term may be limited to native species andas the trafficking of European glass “wildlife crime” refers to harvesting there may be no basis in nationaleels, have emerged. For the first time, and trade contrary to national law, law to challenge the import or salea consistent pattern of large ship- particularly, but not exclusively, the of questionable wildlife products thatments of unrelated wildlife products national laws implemented in ful- are not covered by national legislation.
– elephant ivory and pangolin scales filment of CITES obligations. This Even if the law allows the seizure of– has emerged. In addition, organized includes offences that might not wildlife taken or exported contrary

What is wildlife crime?

29

INTRODUCTION

to the laws and regulations of othercountries, proving this illegality canbe challenging. Few countries havethe capacity to keep track of the complex and changing world of foreign
wildlife regulation, or to gather evidence on offences committed on theother side of the world.
CITES allows countries to reciprocally protect one another’s species
against overexploitation according to a common set of rules. The
system works through a series of
permits and certificates relating tothree international protected species
lists, the CITES Appendices. International trade in CITES-listed wildlife without the appropriate permits
and certificates appears to be the most

The CITES Appendices
CITES works by subjecting international
trade in specimens of selected species
to certain controls. All import, export,
re-export and introduction from the seaof species covered by the Convention
has to be authorized through a licensing system. Each Party to the Convention must designate one or moreManagement Authorities in charge ofadministering that licensing systemand one or more Scientific Authorities
to advise them on the effects of tradeon the status of the species.
The species covered by CITES are listed
in three Appendices, according to thedegree of protection they need.

WORLD WILDLIFE CRIME REPORT 2020

Appendices I and II

Appendix I includes species threatenedwith extinction. Trade in specimens ofthese species is permitted only in
exceptional circumstances. Appendix II
includes species not necessarily threatened with extinction, but in which trademust be controlled in order to avoid
utilization incompatible with their survival.
The Conference of the Parties (CoP),
which is the supreme decision-making
body of the Convention and comprises

30

commonly detected transnational
violation of the Convention, sometimes involving organized crime andserious wildlife offences.

the international rules that wildlife
traffickers seek to circumvent. Whilecertain species may be afforded different levels of regulation even within
the borders of a single country, theAs mentioned, CITES requires Parties CITES appendices contain a list of
to “penalise” violations of the agree- species for which the international
ment.2 CITES violations are punished community has agreed common
in different ways and degrees depend- rules and standards to regulate theiring the seriousness of the infraction trade and transboundary movement.
and the different national legal CITES does not address all aspects
systems. Some countries are more of wildlife crime, but it is the single
inclined to sanction with a fine, while most coherent approach to a topic ofin others, offenders can be sentenced considerable international complexity.
to more than four years in prison.
Furthermore, as a multilateral agreeCITES is an agreement that regulates ment combining trade and wildlife
international trade in specimens of provisions, CITES has a powerful
species of wild fauna and flora, with compliance mechanism: complianceconservation aims. CITES defines measures may be recommended
against non-compliant Parties. Depending on the nature of the compliancemeasures agreed by the governing
body of CITES, all other CITES
Parties may agree not to trade with
the non-compliant Party, either in
all its Parties, has agreed in Resolution
particular species, or in any CITESConf. 9.24 (Rev. CoP17) on a set oflisted species. Since many CITES
biological and trade criteria to deterlistings are broad (to cover look-alikemine whether a species should bespecies), such trade suspensions can
included in Appendix I or II. At eachhave serious economic consequences.

regular meeting of the CoP, Parties
submit proposals based on those criteria to amend these two Appendices.
Those amendment proposals are discussed and if no consensus can befound, submitted to a vote. The Convention also allows for amendments bya postal procedure between meetings of
the CoP (see Article XV, paragraph 2, of
the Convention), but this procedure israrely used.

Appendix III

This Appendix contains species that areprotected in at least one country, which
has asked other CITES Parties for assistance in controlling the trade. Changes
to Appendix III follow a distinct procedure from changes to Appendices I andII, as each Party is entitled to submit
unilateral requests to include or withdraw species from it.aa

See the CITES web page “How CITES
works” for further information.
(Available at: https://cites.org/eng/disc/
how.php).

The scope of CITES is limited tointernational trade, and purely domestic behaviour is the responsibility of
the Parties. States have the sovereign
right to manage CITES-listed species
within their borders in accordancewith the principles of internationallaw, so long as the specimen does not
move internationally. This effectively
means that access, sourcing, acquisition, possession, transport, poachingand domestic trade (legal or illegal)
are matters for national governments
to regulate under their national legislation. Because CITES addresses
international trade, most CITES-related enforcement takes place at portsof entry, and not in domestic markets.
The origin of non-indigenous wildlife sold domestically could always be
queried, but proving it was illegallyimported would be difficult in somelegal systems, especially for species
in Appendices II and III for which

1
contraband including those officiallyreported by CITES Parties in fulfilment of their reporting obligations.
Reference is made to other violationsof domestic law in specific case studies where appropriate. Although thisapproach does not encompass all that
could be defined as “wildlife crime”,
it does highlight those aspects most
likely to constitute transnationalorganized crime, and the areas whereinternational cooperation is most vital.

Wildlife crime
as transnationalorganized crime

In contrast to markets on which there
is a complete prohibition, wildlife
trafficking may involve goods thatcan be legal or illegal, dependingon when, where, and how they wereacquired. Like firearms, pharmaceuticals, or antiquities, the legality of thisacquisition is demonstrated througha licensing system. Since an official
document can transform millionsof dollars of suspected contraband
into millions of dollars of legitimate
merchandise, a proportion of the“trafficking” of these goods may belaundered and proceed through thefront door, with documents provided
through fraud, forgery, or corruption.

Introduction

trade is allowed. The upshot of all
this is that most CITES enforcement
occurs when the wildlife is moving
between countries, which meansthat an important part of CITES
enforcement is conducted by nationalcustoms agents responsible for controlling trade at borders. However, thepolice, rangers, prosecutors, judiciaryand wildlife authorities have a significant role to play before and after thedetection of any alleged infraction.

Domestic wildlife law enforcement
is conducted by a wider range ofnational and local agencies. The topics
of logging and fishing in particular
are often regulated by distinct bodies
of law, with their own enforcement In some cases, illegal wildlife trade Aside from evading interdiction, illebodies. Environment, health, agri- can be seen as a form of organ- gally sourced goods laundered using
culture, development, and commerce ized crime and the involvement of fraudulent documents can be introministries may be involved in regulat- organized criminal groups in trans- duced into legitimate commercial
ing use of land and the marketing of national organized wildlife trafficking channels, availing themselves of legal
wild species products. Responsibility is evident.3 The United Nations demand. In this way, illegally sourced
for many forms of environmental Convention against Transnational timber, fish, and other wildlife prodenforcement may be devolved to pro- Organized Crime defines an “organ- ucts find their way into mainstream
vincial or even municipal authorities. ized criminal group” as:retail outlets, and consumers who
would never knowingly purchase
Even on a national basis, communication between these actors may … a structured group of three or more contraband may nonetheless do so.
be limited. Finally, many wildlife persons, existing for a period of time Transnational trade has grown at acrimes may be prosecuted under and acting in concert with the aim of rate greater than the ability of thenon-specialised legislation, such as committing one or more serious crimes international community to regulate
laws pertaining to fraud or perjury. or offences established in accordance it, allowing a wide range of illicit merGiven the diverse ways that the crime with this Convention, in order to obtain, chandise to be laundered through a
can be approached and prosecuted, directly or indirectly, a financial or other series of holding companies and offfew countries have the capacity to material benefit…
shore accounts. Wildlife products arecomprehensively add up all detected
no different, and the need for strict
wildlife offences.
The Convention goes on to explain regulation and supply chain security
that a “serious crime” is a crime pun- is key to protecting threatened species.
Thus, CITES provides another useful ishable by four years or more in prison
function: it defines a meaningful and that a “structured group” need
sub-set of wildlife offences for ana- not have “formally defined roles forlytic purposes. It captures on a global its members, continuity of its mem4
list the species about which, based bership or a developed structure.”
on international agreement, there
is reason to be concerned. Without In other words, organized crime To better understand wildlife crime,
this agreement, it is impossible to rec- is not just about rigid mafia-type UNODC established the World
oncile the national categorisations of groups. Any pattern of profit-moti- WISE Database - a global data reposprotected species.
vated, serious criminal activity is con- itory of wildlife seizure incidents
sidered organized crime, and nearly – on the occasion of the first WorldFor these reasons, this report focuses all transnational wildlife trafficking Wildlife Crime Report. At the time,on CITES listed species, although fulfils these criteria, provided the it was partly based on the existingother species are discussed where penalties in the relevant countries are international mechanism for reportrelevant. As will be explained below, sufficiently high (that is, in excess of ing wildlife seizure data that alreadythe seminal data source on which it four or more years in prison).
existed: the Annual and Biennial
is based are the seizures of wildlife
Reports submitted by CITES parties.

The World Wildlife
Seizures (World WISE)
database31

INTRODUCTION

WORLD WILDLIFE CRIME REPORT 2020

As member of the International
Consortium on Combating Wildlife
Crime (ICCWC), UNODC received
these data from the CITES Secretariat
to create the World WISE database
and to use for research purposes.5

World WISE’s annual coverage of
wildlife seizures is not consistent,
however. The first report, launchedin May 2016, was based on data
through 2014. After the completionof the Report, work on World WISE
was suspended until early 2017. At
In 2016, CITES passed Resolu- the same time, the CITES Biennial
tion Conf. 11.17 (Rev. CoP18) on Report had been discontinued andNational Reports urging “all Parties to the new Illegal Trade Report, inausubmit their annual reports required gurated in 2016, had not yet been
under the provisions of Article VIII, initiated. As a result, the years 2014
paragraph 7 (a), by 31 October fol- and 2015 are relatively data deficient.
lowing the year for which they are
due and in accordance with the most Currently, the seizures included inrecent version of the Guidelines for the database come from the following
the preparation and submission of sources as portrayed in Fig. 1. Where
CITES annual reports distributed by necessary, seizure data from NGO
the Secretariat, as may be amended sources, reviewed by Member States,with the concurrence of the Standing have been added to World WISE toCommittee.”6
provide a more complete picture. Further information can be found in the
Since 2016, the Annual Illegal Trade methodological annex on the individReports (AITRs) are a crucial source ual data sources for each species.
of data for the database.7 As ICCWC
partners, UNODC has been main- The data reporting countries represent
taining these data and including them most of the main source and destinain the World WISE analysis, when tion countries for the most valuable
permitted to do so by the relevant and commonly trafficked wildlife,
CITES Party. For reporting years and therefore provide a robust and2016-2018, UNODC received over representative picture of global wild42,600 seizure records8 from the life trafficking trends. A number ofAnnual Illegal Trade Reports,9 involv- source regions, though, are weak, paring around 1,500 species in various ticularly South America and Africa.
product formats, from live animals The data collection effort required
to medicinal products containing to produce World WISE suggested
animal parts.
that many countries lack the capacity to collect national wildlife seizure
The current release of the World WISE data, either due to legal issues, lack of
Database – which is the basis of this communication between government
report – includes nearly 180,000 sei- agencies, or federal/state conflicts.
zures from 149 countries with almost These counties may require future
6,000 species represented in the ille- technical assistance to fulfil their
gal trade, with seizures dating from CITES reporting obligations.
1999 to 2018.10 Most of the analysis
in this report is based on data from World WISE remains one of the larg2005 to 2018. The database holds est official seizure databases available
almost 155,000 seizures from 146 on wildlife crime and the main toolcountries for this period. Apart from for the Secretariat of the Convention
the AITRs, a number of additional for the International Trade in Endandata sources (including, among other gered Species (CITES) to review thesources, WCO-CEN, EU-TWIX and illegal wildlife trade patterns at the
USFWS-LEMIS) were used to create global level.
a unique collection of data on the
In addition to this quantitative data,
illegal wildlife trade.
the report also relies on qualitative

32

Fig. 1

Share of data sourcesin World WISE,
2008-2018

WCO-CEN
1.7%
NGO and othermedia sources
2.8%
Other
national
reports
6.2%

Other regional
bodies and operations
1.4%
UNODC
Fieldwork
0.1%

CITES
32.9%

EU - TWIX
22.1%

USFWS - LEMIS
32.8%

Source: UNODC World WISE Database

Fig. 2

Share of regionalsources of seizures
in World WISE

Latin America
and the Caribbean
3.9%

Africa
1.9%

Asia
10.0%
North
America
38.5%

Oceania22.4%
Europe23.2%

Source: UNODC World WISE Databasedata from fieldwork to put thosenumbers in context based on thesituation on the ground where thesepoaching and seizure incidents aretaking place. This sort of “on the
ground” research is key to helping
law enforcement respond to wildlife
threats in real-time and adjust theirapproach as new wildlife crime trends
that emerge and are sometimes yet
to be seen in the larger-scale seizure

INTRODUCTION

Wildlife trafficking and COVID-19
While there are many factors that havecontributed to the spread of zoonotic
diseases, including social, environmental and economic developments such asurbanization, increasing human population density, climate change, and theincrease in speed of trade and travel,
large-scale wildlife trafficking anddeforestation are among these key factors. More frequent human-wildlife
interactions increase the probability oftransmission of animal-borne pathogens
to human beings, and illegally sourced
wildlife, traded in a clandestine way,
escapes any sanitary control and exposes
humans to the transmission of new
viruses and other pathogens. Without
human interference through capturing,slaughtering, selling, trafficking, trading
and consuming of wildlife, the evolution
The COVID-19 pandemic and the vast and transmission of the coronavirus that
subsequent harms to human and eco- causes COVID-19 would have been
nomic well-being have starkly illustrated highly unlikely.
the potential global impact of zoonotic
diseases, for which wildlife trade – both The impacts of the COVID-19 pandemic
legal and illegal - is a potential vector. on practices of poaching, wildlife trafUNODC and its partners are dedicated to ficking and wildlife consumption are notunderstanding the nexus between wild- yet clear. While global travel restrictions
life trafficking and risks associated with and other factors will have an impact on
zoonotic diseases, while recognizing the scale, transportation methods andthat there remain substantial uncertain- overall mode of operations of organizedcriminal groups plying this trade, it isties relating to this area.
highly likely that wildlife trafficking will
According to the World Health Organiza- not have substantially decreased. Whiletion, around 75 per cent of new or there may be some short-term disrupemerging infectious diseases that have tions, buyers and sellers will likely reoraffected humans over the past three dec- ganize and increase focus on online
ades originate in animals.a While the trade channels and related mechanisms.
understanding of both the disease and In addition, increased poaching due tothe origin of the virus that causes it are declines in tourism and its associatedevolving rapidly, COVID-19 is likely revenue and increases in subsistencelinked to a pathogen found in wild bats poaching are realistic risks. Park andthat is suspected to have passed to protected area closures and a decreasein patrols by rangers have already conhumans, possibly via an intermediary.

WORLD WILDLIFE CRIME REPORT 2020

Given the extensive impact of the COVID-19
pandemic on human health, the global
economy and national security, understanding the nature of zoonotic diseases
and the risks they pose – and how toprevent them - has become one of themost critical questions facing governments today. The data collection andanalysis for this report was completed
prior to the COVID -19 pandemic. While
the patterns and trends depicted in thereport reflect only those pre-pandemic,
they offer an overview of the seriousnessof wildlife crime and suggest implications
for policy and programmatic responsethat reflect the importance of addressing
and preventing wildlife trafficking asimportant avenues to reducing the risk of
future zoonotic pandemics.

34

tributed to increased poaching activities
in some countries. Further, wildlife products may be touted as ‘cures’ for COVID-19,
notably bear bile b and various plant
species c used in Traditional Chinese
Medicine.
It is still too early to observe clear trends
and changes related to wildlife trafficking due to the pandemic, but lockdown
measures taken by governments haveforced organized criminal groups toadapt and quickly change their dynamics. Those changes might result in illicit
markets going even deeper underground,
additional risks for corruption, and shifts
in market and transportation methodologies in the longer term.
UNODC, alongside its partners, will
focus on analysing trends in wildlife
trafficking and providing Member Stateswith tools to address demand; tostrengthen their law enforcement andjudicial response to address wildlife
forest and fisheries crime; and to create
sustainable alternative livelihoods for
those involved in poaching and the illegal trade.
a World Health Organization. Zoonotic
disease: emerging public health threatsin the Region. (Available at: http://www.
emro.who.int/about-who/rc61/zoonotic-diseases.html).
b Fobar, R. (March 25, 2020). China
promotes bear bile as coronavirus
treatment, alarming wildlife advocates.
National Geographic. (Available at:https://www.nationalgeographic.com/
animals/2020/03/chinese-government-promotes-bear-bile-as-coronavirus-covid19-treatment/).
c TRAFFIC. (April 7, 2020). COVID19 - The role of wild plants in healthtreatment and why sustainability of theirtrade matters. (Available at: https://www.
traffic.org/news/covid-19-the-role-ofwild-plants-in-health-treatment/).

Combining national reports and otherdata sources from 149 countries andterritories presented a number ofmethodological challenges, which are
discussed in the online methodological supplement to this report. One
issue that deserves discussion is theneed to convert seizures to common
units, at least within specific markets.
For example, timber seizures may bereported in terms of log or container
counts, weight, or volume. They may
also involve different sorts of commodities, including logs, sawn wood,and other products. For each species,
the academic and trade literature
were consulted to provide conversion formulas. These conversions are
discussed further in the case study
chapters that comprise the bulk ofthis report.

By analysing the records submitted,
it is possible to determine the sorts
of information parties gather in thenormal course of business. For example, most of the seizures reported
contained information about thesource of the shipment (71 per cent)and the destination of the shipment(76 per cent). Much less often, however, did the seizure data include
information on the countries transited before the seizure (3 per cent).
Many countries gave more detailed
information as to the exact location
where the seizure was made – thisinformation could be used to create
maps of vulnerable locations – but
since this information was available
for less than half the seizures, it is not
fully utilised in this report.
For further information on the WorldWISE database, please refer to thefirst edition of the World Wildlife
Crime Report published by UNODC
in 2016.

Endnotes

Introduction

data. Further details on the specificfieldwork conducted and the qualitative data collected can be found in
the species chapters as well as in themethodological annex.

1

1 A/RES/73/343.
2 The CITES agreement requires (Article
VIII, Section 1) “The Parties shall takeappropriate measures to enforce the provisions of the present Convention and toprohibit trade in specimens in violation
thereof. These shall include measures:(a) to penalize trade in, or possession of,such specimens, or both; and (b) to provide for the confiscation or return to
the State of export of such specimens.”
https://www.cites.org/eng/disc/text.php.
3 See the cases on wildlife, forest and fisheries crime combined with participationin an organized criminal group in the
UNODC SHERLOC Case Law Database,https://sherloc.unodc.org/cld/v3/sherloc/
cldb/#/crime-type.
4 For a complete description of the databaseand its creation, please refer to the firstedition of the World Wildlife Crime
Report published in 2016 (https://www.
unodc.org/unodc/en/data-and-analysis/
wildlife.html).
5 This cooperation is in line with the
ICCWC Strategic Mission 2014-2016
and the ICCWC Strategic Programme
2016-2020. See https://cites.org/eng/
prog/iccwc.php/Strategy.
6 Conf. 11.17 (Rev. CoP18).
7 The AITR requirement was introduced at
CoP17, and to date reports covering datafor 2016-2018 were due. Some Parties
however also provided data from previous
years in their submissions so AITR data
included in World WISE covers years
2013-2018 depending on the country.
8 In order to produce a comprehensive andvalid database, data collected from different sources have been processed to avoid
the inclusion of duplicate records. Whenthe same seizure event was reported bymore than one source, only one iteration
has been retained in World WISE. For thisreason, not all AITR seizure records havebeen incorporated in the World WISE
Database and for some countries (forexample EU Member States), alternative
official data sources (like EU-TWIX) havebeen used.
9 This release of World WISE does notinclude all 2018 AITRs received because
the data collection for 2018 was notcomplete when the data processing for theWorld WISE dataset had to be closed tocomplete the analysis for the current report.
10 As of November 2019, the time at whichanalysis for this report was initiated.

35

2

ROSEWOOD TIMBER

Map 1

Trafficking flow map - Rosewood (2015-2018)*

Main trafficking flows basedon adjusted seizures
High volume flow

Low volume flow
Seized mass equivalent (tons)
1000
750
500
250
100
<50

Trafficking role
Source of shipment
Transit or destinationof shipment

Sources: World WISE Database.

Source: UNODC World WISE Database *The year 2018 is based on partial data.

The boundaries and names shown and the designations used on this map do not imply official endorsement or acceptance by the United Nations.

The boundaries and names shown and the designations used on this map do not imply official endorsement or acceptance by the United Nations.
A dispute exists between the Governments of Argentina and the United Kingdom of Great Britain and Northern Ireland concerning sovereignty over the Falkland Islands (Malvinas).

“Rosewood” is a trade term for a wide In order to understand the illegal
range of tropical hardwoods, not a trade in rosewood and associatedbotanical category. It appears that fraudulent practices, it is important
illegal rosewood and other tropical to understand the legal market andhardwood timber is entering some value chain. The following description
legal industry supply chains, includ- of legal trade does not imply that all
ing the international wood furniture this trade is illegal. Global imports
trade. Demand for tropical hardwood of tropical hardwood logs totalled 18
timber has grown greatly in the last million cubic meters in 2018, valued
two decades, and where trade asso- at over three billion US dollars.1 Some
ciated with this demand is not well 82 per cent of the value of this importregulated, it can be incompatible demand came from industries basedwith the survival of these species and in China, which currently lead thethe forests that contain them. Both world in furniture manufacture.2
local and international controls have Up to one-fifth of these imports
been gradually put in place to counter include timber species described asover-exploitation, yet key operators “rosewood”.3
constantly adapt their tactics to circumvent these controls.

Fig. 1

India
370

Imports of “tropicalwood in the rough”(US$ millions) in
2018
Others
259

China
2,803

Source: ITC Trade Map

37

ROSEWOOD TIMBER

Because there is no universal definition of “rosewood”, there are no
global statistics on the rosewood
market – in most national systems,
and imports are typically registeredas tropical hardwood “not elsewhere
specified”. While traditional rosewoods have many uses,4 as a practicalmatter today most of the trade refers
to tropical hardwoods suitable formaking traditional furniture in the
Asian style, typically referred to as
hongmu.5 Most of these rosewood species used for hongmu come from theDalbergia and Pterocarpus genera,6 but
a growing number of species, including those from other genera, appear tohave become integrated into the trade.
In the past, CITES Parties haveacknowledged that “rosewood timber
species” is a common commercialname that encompasses hundreds ofspecies within around nine genera oftree species in trade.7 Table 1 shows
rosewood species currently listed in
CITES Appendices.

Share of the volume of rosewood log imports to China
by regional source, 2008-2018

Fig. 2
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%

Latin America

Africa

2018

2017

2016

2015

2014

2013

2012

2011

2010

2009

2008

0%

Asia-PacificSource: World Trade AtlasWORLD WILDLIFE CRIME REPORT 2020

Table 1

38

Over the last decade, the share of totalrosewood imports to China comingfrom Africa has steadily increased(Figure 2), with a portion of thisshare suspected to have been illegallysourced in or exported from Africa.
As this demand has grown, manysource countries have taken measures
to ensure their exports are sustainable,
including restrictions on harvesting orexporting rosewood species and banson log exports (roundwood exportbans). There is evidence to suggestthat in some countries illegal tradeemerged circumventing these controls.9 The international community
has also intervened and placed many
species under CITES control. Amongthe most notable include the listing ofDalbergia nigra on Appendix I in 1992,
the listing of Pterocarpus santalinus on
Appendix II in 2007, and the listing

CITES listed tree-species in international trade under the name “rosewood”

APPENDIXTAXA

I

Dalbergia nigra
Dalbergia spp. #15 (except forthe species listed in Appendix I)
Guibourtia demeusei #15
Guibourtia pellegriniana #15
Guibourtia tessmannii #15
Paubrasilia echinata #10
Platymiscium parviflorum #4
Pterocarpus erinaceus
Pterocarpus santalinus #7
Pterocarpus tinctorius #6
Senna meridionalis

II

Traditionally, hongmu furniture wasconstructed from species found incountries of Eastern and Southern
Asia. Economic and population
growth in the region led to greater
demand for these products relative tothe natural supply. Over time, Asian
species of rosewood became overexploited.8 This pushed rosewood
traders to look farther afield for supplies of Dalbergia and Pterocarpus
species, to places where the species
were not yet protected by national
or international legislation.

DATE OF ORIGINAL LISTING
IN THE APPENDICESDATE OF LAST AMENDMENT
TO THE LISTING

11.06.92

N/A

12.06.13

26.11.19

02.01.17
02.01.17
02.01.17
13.09.07
01.07.75
09.05.16
16.02.95
26.11.19
12.06.13

26.11.19
26.11.19
26.11.19
N/A
26.11.19
02.01.17
13.09.07
N/A
N/A

Up until 2013, one of the more prominent non-Asian sources for rosewood
was Madagascar, where at least 48 species of Dalbergia are known to occur(of which 47 are endemic).11 Since
the 1980s, recognizing that it is losing
its unique wild areas at a rapid pace,
Madagascar has implemented a seriesof export bans and logging prohibitions that were later suspended or
rescinded.12 After the CITES listingin 2013,13 there followed a seriesof seizures enforcing these controls,
including the 2014 seizure of 3,000
tons of Malagasy rosewood by Singapore. A recommendation to suspend
trade in species of Dalbergia from
Madagascar was made by the CITESStanding Committee in 2016 andremains in place.14
The last WWCR focused on anotherpart of the continent: West Africa.
From around 2011, great volumesof a particular species were exported
from different countries in this region:
Pterocarpus erinaceus, known in Nigeria as “kosso”.15 Kosso was not listedon the CITES Appendices at the time,
but its export was often occurring inviolation of a range of national laws
and regulations. Kosso is the only species recognised as rosewood in Asia
that grows in West Africa, so any
Asian imports of rosewood from West
Africa are highly likely to be kosso.16
Because the species was not placed on
Appendix II until 2017, prior to its
CITES-listing it could be imported
by destination countries withouta CITES permit. This resulted inimports taking place despite the factthat harvesting in some cases had
been illegal or that exports were incontravention of national laws. As alegal import, these flows were captured in the national import statisticsof the destination countries, and they
showed the rise of kosso to dominate
rosewood imports.17

The CITES Appendix II listingof Pterocarpus erinaceus in 201718
required all exporting countries to certify that the trade was legal in origin
and would not negatively impact
the survival of the species. According to CITES trade data,19 CITES
Parties reported importing over
825,000 cubic metres of kosso logs in2017. This is equivalent to about four
million trees.20 Based on these data,
Nigeria was the exporter of 58 percent of the volume that year (Figure 3).
Some 99 per cent of the CITES
reported kosso exports in 2017 were
imported by China.21

words, CITES certificates were being
issued without any evidence that thetrade would not be harmful to thesurvival of the species, which is thepoint of certification. The CITES Secretariat described this trade as “lawful
but awful” and in October 2018 theFig. 3Rosewood timberof all Dalbergia species of Madagascar in 2013. Due to the difficulties of
distinguishing Dalbergia species, theentire genus was listed in 2016, withthe listing taking effect in 2017.10

2

Distribution of CITES
regulated imports ofkosso* logs (cubic
metres) by exporting
country, 2017

Mali
50,083

Benin
19,962Burkina
Faso
68

Another way to look at this flow isthrough trade data based on the Har- Sierra Leone
55,119monised System (HS). Based on these
data, it is estimated that Asian countries imported about 1.4 million cubic
Ghana
metres of rosewood (presumably
93,215
Nigeria
kosso) from West African countries
475,101
in 2017, of which 58 per cent came
Gambiafrom Nigeria. This represents the larg132,121
est volume of kosso ever imported andan increase of over one-third for Nigeria over the previous year (Figure 5).
In the previous World Wildlife Crime
Report, the flow of kosso from West Source: CITES Trade Database* Pterocarpus erinaceus
Africa to Asia was described as illegally sourced, since most of the source
Distribution of Asian
countries had imposed domestic laws Fig. 4
on harvest or export that were viocountries imports oflated when the product was exported
kosso logs from Westin contravention of those laws. In
Africa (cubic metres)
2017, some of this flow was accomby exporting country,
panied by CITES certificates, despite
the fact that in some countries these2017
laws were still in place. For example,
Mali
Othersthese included a timber export ban
68,08545,279Sierra22
Leone
in Nigeria. The volume of the trade
was so large that it prompted a mis- 69,067
sion by the CITES Secretariat to visit
Nigeria in May 2018, to evaluate thebasis for these permits.
Gambia209,291

The mission found that the timber
Nigeria
754,234
might have been obtained in accordGhana
ance with national law but it was not
230,691
in accordance with the Convention.
The CITES Secretariat pointed to theabsence of recent scientific studies toestimate the level of sustainable harvest that could be authorized. In other Source: World Trade Atlas, UN Comtrade

39

ROSEWOOD TIMBER

Standing Committee recommended species is found in this region. Rather sanders”, terms that normally applythat Parties suspend trade in this spe- it appears these are exports of Ptero- to Pterocarpus santalinus, an estabcies with Nigeria.23
carpus tinctorius, known as “mukula” lished rosewood endemic to Southin Central Africa. Mukula is not Eastern India.28 Mukula also appears
CITES recommended that West and among the species on the Chinese to be sold as “Zambian blood roseCentral African states with domestic rosewood trade standard, but it bears wood”29 or “dye red sandalwood”.30
legislation in place prohibiting the a strong resemblance to other African Other African genera of the Fabaceae
export of timber and timber prod- Pterocarpus species. It was listed on family, such as Guibourtia, known as
ucts, establish a voluntary ‘zero export CITES Appendix II in 2019 because, “bubinga” in Central Africa, may also
quota’ for kosso.24 Also, at its 70th as the proposal justified:be feeding into the illegal rosewood
meeting , the CITES’ Standing Comtrade, and several species were listed
mittee requested the CITES Plants
While Pterocarpus tinctorius isin Appendix II, effective in 2017.31
Committee to consider the inclusion
not on the official hongmu list, it
Bubinga is not listed as rosewoodof kosso from all range States in thehas achieved market demand duein the Chinese trade standard,32 but,
25
according to the Proposal for the listReview of Significant Trade process.
to its lookalike characteristics. Chiing of these species:
nese buyers in Zambia reported to
CIFOR interviewers that an early
Alongside this trade, the smuggling ofkosso continues. In 2017, Singapore
boom in P. tinctorius (beginning
The woods of the different Bubinga
seized over 1,000 tons of kosso coming
in 2010) was actually due to its
species, the aesthetic qualities ofwhich are close to those of thefrom Guinea-Bissau on its way tobeing used as a false rosewood:
Viet Nam without CITES documenshipments were sent through interAsian rosewood species which aretation.26 At the same time, it appears
mediary traders and nations to Vietmost highly prized in the Hongmu
other species are being drawn into
Nam and the Philippines, wheretradition, have gradually become
the illegal rosewood trade. National
it was mixed with Pterocarpus
established as the first-choice alternative for this burgeoning sector.33
trade data show that the Democratic
santalinus (red sandalwood) andRepublic of the Congo, the Congo,
sold onto the Chinese furniture
According to World WISE, in 2019,and Mozambique are major suppliers
market.27
of logs classified as “rosewood”, but
300 containers of bubinga werethese are unlikely to be kosso, or any There appears to be a tendency to refer seized in Gabon. Another 74 tons
other rosewood species in the trade to a number of African Pterocarpus were seized by China at Hong Kong,standard, because no recognised species as “red sandalwood” or “red China, coming from Gabon.34 It is
possible that other species or genera
will become informally integrated
into the trade in ways that are not
Fig. 5 Volume of kosso logs (cubic metres) exported from
captured in the national or internaNigeria and imported by Asian countries, 2008-2018tional statistics.

(trade suspended October 2018)

800,000

Sourcing

754,234

700,000
568,110486,389

392,384

500,000

394,252

400,000
300,000
200,000
100,000

40

2012

2018

2011

2017

2010

Source: World Trade Atlas, UN Comtrade

2016

671

2015

88

2014

346

2013

216

2009

0

55,33418

2008

WORLD WILDLIFE CRIME REPORT 2020

cubic meters

600,000

Much of the following discussion isbased on qualitative fieldwork conducted by UNODC in nine West
African countries35 in two periods: 75
interviews conducted over a periodof six months spanning 2014-2015
and 46 interviews conducted overa period of two months in 2018.
These interviews included seniornational governmental officials, local
authorities, border guards and port
administrators, as well as traders andothers active in the legal and illegal
market. In addition, a range of site
visits were conducted, including both
harvest areas and timber markets. This
fieldwork took place in the context of

Fig. 6Rosewood timber

and then quickly rescindedagain afterwards.47 According
to the Ministry of Finance, by
raising the tariff on exports from
US$1,500 to US$2,500 per container, the total amount realised
from timber export between October 2018 and March 2019 was$16.5 million,48 suggesting that
6,600 containers of timber were
exported in those six months.
Comparing data on exports asreflected in the CITES Trade Database49 with national import data,
it appears that considerably more
kosso was reported as imports than
was reported as having CITES export
permits issued, according to available
export data for 2017. Trade data rarely
line up neatly, and part of these differences may be due to delays between
the year the permit was issued andwhen the export occurred, but thevolumes involved are significant insome cases.
The fact that these four countries(Nigeria, Gambia, Ghana, and Sierra
Leone) are currently exporting large
volumes of rosewood does not mean
the rosewood they are exporting camefrom within their counties. Interviews
with traders indicate that Nigerian
exports are supplemented by wood

Asian country imports of kosso logs (cubic metres)by exporting country, 2008-2018

1,600,000
1,400,000
1,200,000
1,000,000
800,000
600,000
400,000
200,000
2018

2017

2016

2015

2014

2013

2012

0
2011

estimating the rate of extraction
between 2004 and 2013 found,“The current level of exploitationis unsustainable…”41 Exports
from Ghana have more thandoubled since that time. The
government of Ghana has imposed and withdrawn bans on
harvesting and export of rosewood several times since 2011,
and, in April of 2019, a total ban
on harvesting, processing andexport of rosewood was imposed
to “eliminate illegal activities thatwere endangering the species,
especially in northern Ghana”,
although the Ministry of Lands
and Natural Resources has
indicated that ‘salvage permits’would be issued for rosewood
log stocks.42 On 26 August
2019, the Ghanaian government
established the Committee toInvestigate Allegation of Corruption in Rosewood Trade in
Ghana.43

country that has increased exports of kosso since the CITES
Appendix II listing in 2017, with
export volumes tripling between
2017 and 2018, despite periodic
export bans that year. In 2018,the longstanding log export ban
was temporarily lifted, and thismay have fuelled the surge inexports. The ban was reinstatedby the President on 4 April 2018,as part of his first act in office46

2010- -- In Ghana, an academic study- -- Like Nigeria, Sierra Leone is a

2009

Aside from Nigeria, the other countries in the region responsible forthe largest share of recorded exportsof kosso are Ghana and Gambia.
These three countries were collectively responsible for 85 per cent of
the volume traded in 2017.40 In 2018,
Sierra Leone also emerged as a top
exporter (Figure 6).

plies of [kosso] are suspected to
be exhausted from Gambia…”44
Despite this fact, Gambia continues to be a major exporter,
second only to Nigeria globallyin 2017 according to the CITES
Trade data. A 2019 Wildlife
Crime Threat Assessment Reporton West and Central Africa45
commissioned by the CITES
Secretariat, and prepared by
UNODC states, that in the caseof the Gambia illegal exports ofrosewood are estimated to be
worth about half of the country’s
total exports, about 10 per centof its GDP, and more than 20
times the budget of the Ministry of Environment, Climate
Change and Natural Resources.

2008

Kosso (Pterocarpus erinaceus) is foundmainly in West Africa and somenorthern parts of Central Africa.36
Often growing in arid areas withsparse forest cover, it is nitrogen
fixing, fire resistant, and a source ofanimal fodder.37 One of the cheapest
rosewoods,38 its ecosystem value asa species seems to exceed its export
value. According to the International
Union for the Conservation of Nature(IUCN), it is classified in 2018 as“endangered” with a decreasing population trend.39- -- According to the IUCN, “Sup-cubic meters

long-term ethnographic research on
the illegal timber trade in this region.

2

Nigeria

Ghana

Sierra Leone

Mali

GambiaCongo

DRC

GuineaGuinea-Bissau

Others

Source: World Trade Atlas, UN Comtrade41

ROSEWOOD TIMBER

from Cameroon.50 In Gambia, forestry officials interviewed estimatedthat nearly all the rosewood exported
comes from the Casamance area of
Senegal.51 According to traders interviewed, exports from Ghana appear tobe supplemented by illegal imports
from Burkina Faso.52 Under CITES,
however, this trade between Africancountries would require export permits, and the subsequent re-export
would require a designated re-export
permit. In other words, under the
CITES implementation laws of allthese countries, all this trade would
be illegal because the required permits
were not issued.

Recent interviews with kosso trad- source kosso, paying them a nominal
ers in West Africa suggested some of fee for the service.58 These leaders in
the rosewood being exported from turn recruit other community heads
West Africa was coming from outside to promote logging. Designatedthe recognised range of the species, depots are established in the periphincluding from the Democratic ery of a forested area and a “depot
Republic of the Congo along the chairman” is assigned.
Angolan border. It seems likely thata closely related species is being traded Local people are then recruited to findas kosso. The most likely candidate prime trees and local labour employed
is Pterocarpus tinctorius, or “mukula”, to extract them, often for very low
as it is known in Zambia. In 2018, wages. Typical labour costs citedresearchers estimated that mukula was were US$8.28 per log cut to chainbeing extracted from Zambia at a rate saw operators; US$ 5.52 per log toof 110,000 cubic metres per annum, “pushers” who manually transport thewith estimated bribes paid to state log from the felling site to the depot;
officials of about US$1.7 million.56
and US$1.38 per log to loaders, whowork in teams of five or six and divide
These are not the only countries The interface between kosso export- this fee among them. This labour isthat appear to be exporting more ers and illegal loggers appears to be generally conducted without safetyrosewood than their known stocks professional timber traders, many of equipment.
would allow. For example, kosso has whom have moved between countries
been a protected species in Mali since to pursue supplies. Fieldwork con- Transport of illegally obtained logs
1995. The country has been targeted ducted by UNODC in Nigeria give from the depots by land is generally
by rosewood traffickers since at least some idea of how this might be taking not a problem, although truckers
200353 and has very few forested areas place more generally.57 Traders inter- are subject to roadside “taxes” fromremaining.54 Nonetheless, according viewed often came from a logging various dubious local authorities.
to harmonised system trade data, it area and had the logistical capac- During interviews, traders showedmanaged to export over 80,000 cubic ity to move the wood to the major handfuls of printed receipts frommetres of rosewood in 2018, which cities. These traders “empower” (or these bodies that they had paid. As therepresents about half a million trees.55 “activate”) local community leaders to more accessible kosso stocks become
depleted, a seasonality in exports canbe seen in some countries, with a dip
Fig. 7 Volume of kosso log import permits and volume ofduring the rainy season when roads
kosso logs* imported by Asian countries based on trade to remote areas become impassable.

statistics in 2017 (cubic metres) by exporting country

800

754

CITES

thousands of cubic meters

WORLD WILDLIFE CRIME REPORT 2020

700

Comtrade

600
500

475

400
300
209

200

132

100

231
93

55 69

50

68

20 30

14

Benin

Guinea0
Nigeria

GambiaGhana

SierraLeone

Mali

Source: CITES Trade Database, UN Comtrade* That is, estimated volume of logs classified as rosewood from West Africa,
which would almost certainly be kosso logs or logs passed off as kosso.

42

Trafficking
CITES-regulated wood from Africa,
Asia and Latin America continues tobe seized and CITES continues tomonitor both illegal and legal trade.
For example, in November 2018,
CITES suspended commercial tradein the genus Dalbergia from Lao People’s Democratic Republic (Lao PDR),
including finished products, such as
carvings and furniture. The suspension will remain “until Lao PDR
makes scientifically based non-detriment findings for trade in the relevant
species, including D. cochinchinensis
and D. oliveri in the country to thesatisfaction of the CITES Secretariat.”59 However, since 2015, most of
the rosewood imported by China

Fig. 8Inspection Unit has only one officer
designated to inspect the loads leaving the two ports in Lagos (Apapa
and Tin Can Island, which are situated about one half hour drive apart)and two officers in Port Harcourt.
Interviews with officials in the ports
indicated that timber loads were neverunloaded, even in cases where irregularities were suspected; scanners wereused for imports only; and that there
was very little space or scope to detain
shipments for further inquiry. Apapa
Port, for example, is owned by a private company (APM), and charges
the government a daily rate for the
storage of containers. As a result,interviews suggested that questionable shipments are generally returnedto the shippers rather than seized.

Rosewood timber

Logs of illegal origin may be consolidated in transit countries, so theorigin and species of the wood canbe concealed. On arrival in the destination countries, illicit shipments
Due in part to the bulk of the product, are laundered into mainstream timberoverseas shipments of logs are gener- markets. The buyers of this wood may
ally containerized. Seizures recorded in be unaware that the product they are
the World WISE database show that purchasing was illegally harvested orlogs may be concealed behind worked traded.
planks or species may be intermixed
or mislabelled, but this is generally The World WISE seizure data sugthe extent of physical concealment.60 gest that China and Viet Nam are
Planks may be used at the mouth of the main destinations for traffickeda container to conceal whole logs in rosewood, and three-quarters of all
countries with a roundwood export the logs seized globally (where theban. For example, Benin is one of two destination was known) were on theirexporting countries of sawn rosewood way to one of the two countries. The
to China in the region,61 and inter- United Arab Emirates has also been
views conducted by UNODC in the the destination of a number of signifcountry in 201462 found that kosso icant seizures, as has Malaysia.
planks were frequently used at themouth of a container to conceal logs In most countries, the sheer volume
within. Interviews with officials in of the trade makes comprehensive
the region in 2014 and 2018 showed inspection impossible. If Nigeriathat countries rarely have the capacity exported around 750,000 cubic
to unload or scan departing timber metres of kosso in 2017 (Figure 5),
containers to verify the contents, so that is equivalent to nearly 40,000
loading the outer third of the con- containers of wood, or over 100
tainer with planks allows good cover containers per day.63 According tofor illegal log exports.
interviews conducted by UNODC
in Nigeria in 2018, the Forestry

came from Africa, much of it illegallysourced. For this reason, this chapter
focuses primarily on the flow fromAfrica and African rosewoods.

2

According to interviews with timbertraders in the region, corruption is an
issue throughout the trafficking chain,from the bribes paid to local authorities to the road taxes and the bribes at
ports. Multiple layers of overlapping
bureaucracy in some countries further
complicate the issue. In Nigeria, forexample, federal authorities such as
Customs, the National Park Service,
the national police, the National

Percentage distribution of seizures of Dalbergia and Pterocarpus by reported countryof destination (in mass equivalent), 2005-2017
Domestic
1.3%

of which domestic

Liberia
1.1%

Excluding seizures withunknown destination

Indonesia
Other
0.9%
2.7%

Malaysia
3.8%
Domestic
1.8%

United ArabEmirates
8.0%

China
32.3%

China
17.9%

Indonesia
Other
1.2%
3.7%

Malaysia
5.3%
United ArabEmirates
11.2%

Viet Nam
21.3%
India
82.1%

Liberia
1.5%

Unknown
28.7%

China
45.4%
Viet Nam
29.9%

Source: UNODC World WISE Database

43

ROSEWOOD TIMBER

Agricultural Quarantine Service,
the National Environmental Standards and Regulations Enforcement
Agency, and the Forestry Departmentof the Ministry of Environment all
have some responsibility for timber
enforcement with varying mandates
and capacities, but most of the regulation takes place at the state level.
In addition, falsified CITES permits
have been reported by senior officials
interviewed by UNODC in 2018.

billion in exports in 2016, 59 percent of the global total. Rosewoodcomprised about 20 per cent of thevalue of log imports in 2017, basedon import declarations, most of whichwere destined for Hunagpu (Guangdong) and Shanghai ports.64- -- According to media sources, itappears housing investment has
slowed,68 resulting in a decline
in consumer spending on new
furniture.

- -- On the high end, the govern-

ment has spoken out againstconspicuous consumption andanti-corruption efforts havelooked critically at spending on
luxury goods.69

However, in response to rising manufacturing costs in China, furnitureproduction has been relocating toViet Nam, where costs are lower.65
Viet Nam exported more than US$3
In response to illegal logging, many billion in tropical hardwood furniture - -- It also appears that demand in2014 was buoyed by speculation,
countries have seized wood and pre- in 2016, while three other South-Eastand that the drop in 2015
vented the export of privately held Asian countries combined (Indonesia,
was the result of oversupply andtimber stocks. The result is the accu- Malaysia, and Thailand) exported
market correction.70
mulation of stockpiles of considerable a similar amount. In addition tovalue in poor countries, degrading China, the United States of America,
through exposure and held in place European Union countries and Japan In response, China’s rosewood
only through the power of local law are destinations for wood furniture furniture industry has undergone
enforcement.
exports.66 To feed this growing indus- considerable structural change andtry, imports of tropical hardwood logs rationalisation in response to overcaIt appears that the primary illegal from Africa (including rosewood) have pacity, changing consumer demand,
exporters of rosewood from Africa increased by a factor of 10 since 2010 rising raw material and production
are Asian expatriate traders. UNODC (Figure 9).
costs, and increases in compliancecosts associated with legality andfield observations show these traders
conducting their business illegally are Based on a market analyst’s report environmental controls.71
in for the long term. For example, the commissioned by UNODC,67 Chisame traders known for their involve- nese demand for rosewood furniture In light of the new peak in imports
ment in illegal activities in 2014 can appears to have dropped since 2014 from Africa in 2017 (see Figure 6
be seen today in Guinea-Bissau. They due to a number of factors:
above), the market is likely far fromexhausted.
are mostly found in the urban export
areas in West Africa, as risks in thesource areas are high. For example,
they were frequently targeted for
kidnapping by local gangs during theearly years of rosewood exploitation Fig. 9
Imports of African logs (cubic metres) by Viet Nam,in Nigeria, according to interviews
2008-2018with officials in the region conducted
1,800,000
in 2014.
1,500,000

1,200,000
Most of the tropical hardwood logs ininternational trade today are destined
900,000
for Asia’s massive furniture industry.
China alone produced over 44 per
600,000
cent of the value of world tropical
hardwood furniture in 2016, valued
300,000
at about US$20 billion. Due to protections afforded forests in China, this0
industry was based almost entirelyon imported logs. The country has
also dominated exports of tropical
hardwood furniture, topping US$11 Source: COMTRADE

44

2018

2017

2016

2015

2014

2013

2012

2011

2010

2009

2008

cubic meters

WORLD WILDLIFE CRIME REPORT 2020

Destination markets

2

1 Based on UN Comtrade data as captured
by ITC Trade Map, Tropical wood in therough, commodity HS code 440349 (2017revision).
2 Ibid.
3 This chapter draws on the Harmonised
System (HS) classification of trade data,
captured in UN COMTRADE andnational statistics. These data can beaccessed through databases such as theInternational Trade Centre’s Trade Mapor commercial providers such as Trade
Atlas. These data indicate that for China,
rosewood (defined in Chinese National
Standard 2017 and captured in China
in HS code 44034980 ‘Tropical Rosewoodin the rough’) comprised 13% of all tropical hardwood log imports by weight and20% by value in 2018.
4 For example, Dalbergia species are usedin the manufacture of musical instruments, but the CITES Conference of
the Parties (CoP) 18 in 2019 found thatcommercial and non-commercial trade inmusical instruments was not detrimental
to the species and these instruments were
excepted from the listing.
5 红木 Hongmu (red wood) refers to justone of several sets of species that are usedin traditional furniture manufacture, andother terms are used to refer to different
groups of species. In China , the best definition of ‘rosewood’ comes from the species included in Chinese National Standard
for Legal Marketing Purposes (GB/T
18107-2017, effective 1 July 2018): Pterocarpus santalinus, Pterocarpus dalbergioides,
Pterocarpus erinaceus, Pterocarpus indicus,
Pterocarpus macrocarpus, Pterocarpus marsupium, Dalbergia odorifera, Dalbergia
cultrata, Dalbergia latifolia, Dalbergia melanoxylon, Dalbergia nigra, Dalbergia spruceana, Dalbergia stevensonii, Dalbergia louvelii,
Dalbergia cearensis, Dalbergia bariensis, Dalbergia cochinchinensis, Dalbergia frutescens
var. Tomentosa, Dalbergia granadillo, Dalbergia oliveri, Dalbergia retusa, Millettia
laurentii, Millettia leucantha, Senna siamea,
Diospyros ebenum, Dalbergia crassiflora, Dalbergia celebica, Dalbergia philippensis, andDalbergia pilosanthera. Many species usedin hongmu are also sought after by makers
of other fine wood products, such as musical instruments, but, based on import statistics for protected species, the quantities
used are much smaller.
6 The Dalbergia and Pterocarpus species comprise 25 of the 29 recognized species above.
7 CITES CoP 18, Working document 74(2019), Species specific matters: rosewood
timber species [leguminosae (fabaceae)].
8 See, for example, CITES CoP17 Prop.55(2016); available at: https://cites.org/sites/
default/files/eng/cop/17/prop/060216/
E-CoP17-Prop-55.pdf
9 CITES CoP16 (2013) Prop. 60, p. 6 and
CITES CoP17 (2016) Prop.55, p. 10.
10 CITES CoP17 Prop. 54 (2016): Include
13 timber species of genus Dalbergia (native
to Mexico and Central America) in Appendix II); CITES CoP17 Prop. 55 (2016):
Include the genus Dalbergia in CITES
Appendix II with exception to the species
included in Appendix I.
11 Waeber, P., Schuurman, D., Ramamonjisoa, B., Langrand, M., Barber, C., Innes,

J., Lowry, P. and Wilmé, L., ‘Uplisting ofMalagasy precious woods critical for theirsurvival’. Biological Conservation, Vol 235,
2019, pp 89-92; CITES, Sixty-fifth meeting of the Standing Committee, A preliminary Dalbergia checklist for Madagascar for
CITES, SC65 Inf. 21, 2014.
12 Ibid.
13 CITES CoP16 Prop. 63 (2013), Inclusionof the populations of Madagascar in Appendix II, and limited to logs, sawn wood andveneer sheets by an annotation.
14 CITES Notification to the Parties No.
2018/007, 15 January 2018.
15 Pterocarpus erinaceus is also known as vène
in the Francophone countries, pau desangue in Guinea-Bissau, krayie/kpatro in
Ghana, and keno in the Gambia.
16 Of the 29 species recognised under the2017 China trade standard, only one grows
in West Africa: kosso. The other species arefound in South-East Asia, Central America
or Madagascar. It is theoretically possiblethat species from these other regions could
be trans-shipped via West Africa, though
this would make little commercial sense.
17 See UNODC, World Wildlife Crime Report:
Trafficking in Protected Species, 2016,
Chapter 3.
18 According to CITES CoP17 Prop. 57(2016), “The last few years have seen adramatic increase in trade of Pterocarpus
erinaceus timber, in response to risingdemand in Asia for rosewood furniture andincreasing scarcity of other officially recognized ‘rosewood’ species.” Before this, it
was placed on Appendix III at the requestof Senegal. See CITES, Notification to theParties, 2016/008 (February 2016), available at: https://cites.org/sites/default/files/
notif/E-Notif-2016-008.pdf.
19 Since the CITES listing only took effect in2017, this is the first year CITES data are
available. UNEP-WCMC (Comps.) 2019,
Full CITES Trade Database Download, Version 2019.2; available at: trade.cites.org.
20 As discussed below, a cubic meter of kosso
is estimated to weigh on average roughly
one metric ton, each log weighs about
200 kg, and each log is equated to one tree,so 825,000 metric tons divided by 200 kg
gives an estimate of 4,125,000 trees.
21 Viet Nam reported importing 17 cubic
meters (out of 825,000).
22 Nigeria Customs Service, Export Prohibition List, item 2 (of 8) is “Timber (roughor sawn)” (available at:https://customs.gov.
ng/?page_id=3079).
23 CITES, Seventieth Meeting of the Standing Committee, SC70 Doc.27.3.5 (2018),
Application of Article XIII in Nigeria.
24 Decision 18.88, paragraph 6, recommendation q), on “Controlling trade in specimensof Pterocarpus erinaceus”. See: Recommendations to Parties in West and Central Africa
for consideration in their implementation of
measures and activities to address wildlife
crime affecting the two subregions, available
at: https://cites.org/sites/default/files/
eng/prog/enforcement/CoP18_Doc_34_
Annex2_EN.pdf.
25 CITES, Seventieth Meeting of the Standing Committee, SC70, Summary Record,para. 27.3.5 1. d) (2018). Available at:

Rosewood timber

Endnotes
https://cites.org/sites/default/files/eng/com/
sc/70/exsum/E-SC70-SR.pdf.
26 World WISE.
27 CITES CoP18 Prop.54 (2019), Consideration of proposals for amendment of appendices I and II.
28 See, for example, http://chinatimber.org/
price/69232.html. Chinatimber.org is atimber network with 160,000 registeredmembers. It was founded in 2009 by
Dongguan Xingye International Logistics
City Co., Ltd.
29 “赞比亚血檀原木”, https://www.1688.
com/jiage/-D4DEB1C8D1C7D1AACCB4D4ADC4BE.html
30 “将染料紫檀”, http://chinatimber.org/
price/69423.html (see also prior note on
chinatimber.org).
31 CITES CoP17 Prop. 56 (2016), Consideration of proposals for amendment ofappendices I and II. Guibourtia demeusei,
Guibourtia pellegriniana, and Guibourtia
tessmannii were included in Appendix II.
Other CITES listed species that could possibly be used as rosewood include Paubrasilia echinate and Platymiscium parviflorum.
32 红木 Hongmu (red wood) refers to justone of several sets of species that are usedin traditional furniture manufacture, andother terms are used to refer to different
groups of species. Given the distributionof the market, the best definition of ‘rosewood’ are the species included in Chinese
National Standard for Legal Marketing
Purposes (GB/T 18107-2017, effective 1
July 2018): Pterocarpus santalinus, Pterocarpus dalbergioides, Pterocarpus erinaceus,
Pterocarpus indicus, Pterocarpus macrocarpus, Pterocarpus marsupium, Dalbergia
odorifera, Dalbergia cultrata, Dalbergia
latifolia, Dalbergia melanoxylon, Dalbergia nigra, Dalbergia spruceana, Dalbergia
stevensonii, Dalbergia louvelii, Dalbergia
cearensis, Dalbergia bariensis, Dalbergia
cochinchinensis, Dalbergia frutescens var.
Tomentosa, Dalbergia granadillo, Dalbergia
oliveri, Dalbergia retusa, Millettia laurentii,
Millettia leucantha, Senna siamea, Diospyros
ebenum, Dalbergia crassiflora, Dalbergiacelebica, Dalbergia philippensis, and Dalbergia pilosanthera. Many species used in
hongmu are also sought after by makers ofother fine wood products, such as musicalinstruments, but, based on import statistics
for protected species, the quantities used
are much smaller.
33 Ibid.
34 Hong Kong Customs. (11 June, 2019).
“Hong Kong Customs seizes suspectedscheduled Guibourtia species wood logs.”(Available at: https://www.customs.gov.hk/
en/publication_press/press/index_id_2585.
html).
35 Benin, Burkina Faso, Gambia, Ghana,
Guinea-Bissau, Mali, Nigeria, Senegal andTogo.
36 According to the IUCN, its range includes
Benin, Burkina Faso, Cameroon, Central
African Republic, Côte d’Ivoire, Gabon,
Gambia, Ghana, Guinea, Guinea-Bissau,
Mali, Niger, Nigeria, Senegal, Sierra Leone
and Togo. Barstow, M., ’Pterocarpus erinaceus‘, The IUCN Red List of Threatened
Species 2018: e.T62027797A62027800.
37 Ibid.

45

WORLD WILDLIFE CRIME REPORT 2020

ROSEWOOD TIMBER

38 See Table 1 in Ted Leggett, ‘The rapid riseof rosewood trafficking in West Africa’.
Forum on Crime and Society, Vol 9, Nos 1
and 2, 2018, p 71.
39 See IUCN 2019 op cit.
40 CITES CoP 18, Working document 34(CoP18 Doc. 34; 2019), Wildlife crime
enforcement support in West and Central
Africa.
41 Dumenu, W.K and Bandoh, W.N.
‘Exploitation of African Rosewood (Pterocarpus erinaceus) in Ghana: A situation
analysis’, Ghana Journal of Forestry, Vol. 32,
pp. 1-15, 2016.
42 International Tropical Timber Organization(ITTO), Tropical Timber Market Report,
Vol. 23, No. 6, 16-31 March 2019.
43 Ghana, Ministry of Lands and Natural
Resources, Lands and Natural Resources
Minister investigate alleged corruption inrosewood, news story (posted on the Ministry’s website www.mlnr.gov.gh), 28 August
2019.
44 Barstow, M., ’Pterocarpus erinaceus‘,The IUCN Red List of Threatened Species
2018: e.T62027797A62027800. Available at: http://dx.doi.org/10.2305/IUCN.
UK.2018-2.RLTS.T62027797A62027800.
en. Downloaded on 18 September 2019.
45 CITES CoP 18, Working document 34(CoP18 Doc. 34; 2019), Wildlife crime
enforcement support in West and Central
Africa.
46 President Julius Maada Bio, Executive
Order No 1, 9 April 2018.
47 International Tropical Timber Organization(ITTO), Tropical Timber Market Report,
Vol. 22, No. 16, 16-31 August 2018.
48 Sierra Leone, Ministry of Finance, 2018
Annual Review (available at: https://mof.
gov.sl/wp-content/uploads/2019/07/
FIRST-Year-Achievements-of-MoF-underthe-New-Direction.pdf ).
49 Available at: https://trade.cites.org/.
50 Based on interviews with traders conductedin Nigeria in 2018. See Methodological
Annex for details.
51 Based on interviews conducted in theGambia in 2018. The exception being one
senior Forestry official, who estimated that
only 60% of the Gambia’s exports camefrom the Casamance. See Methodological
Annex for details.
52 Based on interviews in Burkina Faso in
2014. See Methodological Annex for
details.
53 Based on interviews with forestry officials
and traders in Mali in 2015. See Methodological Annex for details.
54 As of 2015, only 4% of the territory ofMali was forested, according to the WorldBank’s World Development Indicators(https://databank.worldbank.org/source/
world-development-indicators). See Methodological Annex for details.
55 Depending on its moisture content, kosso
has a density close to water (around 800890 kg per m3), so one cubic meter isaround one metric ton. Standard kosso
logs are about 2.1 meters in length andof varying circumference, but on average
about 200 kg, or one-fifth of a cubic meter.

46

In most cases, one kosso log represents one
entire tree, so 80,000 m3 * 5 = 400,000
trees.
56 Cerutti, P., Gumbo, D., Moombe, K.,
Schoneveld, G., Nasi, R., Bourland, N.
and Weng, X., Informality, global capital,rural development and the environment:
Mukula (rosewood) trade between China andZambia, International Institute for Environment and Development, (London) andCenter for International Forestry Research,(Lusaka), 2018.
57 Based on fieldwork conducted in Nigeria
in 2018. See Methodological Annex for
details.
58 Prices cited in interviews include US$138
to US$193 for a district head and only
US$28 to US$55 for a village head as aone-off fee.
59 CITES, Countries currently subject to a
recommendation to suspend trade, online
running list, available at: https://www.cites.
org/eng/resources/ref/suspend.php. See
CITES, Seventy-first Meeting of the Standing Committee, SC71, Summary Record,
p. 4, para. 10.1.a) (2019); available at:https://cites.org/sites/default/files/eng/com/
sc/71/exsum/E-SC71-SR.pdf. Also, forexample, according to COMTRADE data,
the Lao People‘s Democratic Republic supplied about 9% of China’s rosewood log
imports in 2017, down from about 25%
in 2014. A significant increase in imports
from Myanmar occurred in anticipation ofa log export ban, which was implemented
in April 2014. See UNODC, Criminal
justice response to wildlife and forest crimein Myanmar, UNODC Regional Office forSoutheast Asia and the Pacific, Bangkok,
2015. In 2017, import demand was stimulated by a total ban on commercial logging
in national forests in China. See the statement of the Director of the State Forestry
Administration, Zhao Shucon, ‘State
Forestry Administration: Strictly protect
all natural forests’ (available at: http://news.
sciencenet.cn/htmlnews/2015/2/313822.
shtm). Production in 2018 was interrupted
by the introduction of stricter environmental controls, which impacted wood processing industries. These include the rolloutof the People’s Republic of China Water
Pollution Prevention and Control Law(available at: http://www.gov.cn/flfg/200802/28/content_905050.htm) and theLaw of the People’s Republic of China on
Prevention and Control of Atmospheric
Pollution (available at: http://www.npc.gov.
cn/zgrdw/npc/zfjc/zfjcelys/2018-07/09/
content_2057589.htm).
60 Some rosewood concealed in cover loads
has been observed, however. For example,
World WISE contains a seizure in which
the Gambia detained containers in July
2018 where P. erinaceus logs were concealed behind a load of plastic waste.
61 According to national trade statistics, withthe other being Nigeria, which only began
exporting sawn rosewood in 2014 but was
the leading exporter in 2017.
62 See the Methodological Annex of the
UNODC World Wildlife Crime Report
2016.
63 Based on a conservative estimate of 20
cubic meters per container.

64 Based on data from the World Trade Atlas.
65 Russell, T., ‘The Vietnam connection’,Furniture Today, 7 October 2019.
66 Based on UN Comtrade data (https://
comtrade.un.org/).
67 See Methodological Annex for details.
68 Based on data from the National Bureauof Statistics of China, as cited in Yu, X.,‘China’s real estate market expected toadjust in H2‘, China Daily, 26 June 2019.
69 See, for example, Xi Jinping, Eight-point
Regulation of the Centre (中央八项规定),4 December 2012, which admonishes party
leaders to “practice thrift”.
70 International Tropical Timber Organization (ITTO), Analysis of trade trends for
CITES-listed tree species and the impact on
Chinese SMEs, Project Technical Report,
Research Institute of Forestry Information
and Policy, Chinese Academy of Forestry(unpublished report), 2018.
71 Based on market analysts’ report commissioned by UNODC. See Methodological
Annex for details.

3

AFRICAN ELEPHANT TUSKS
AND RHINOCEROS HORNS
Trafficking flow map - Elephant ivory (2014-2018)*

Map 1

Main trafficking flows basedon adjusted seizures
High volume flow

Low volume flow
Seized mass equivalent (tons)
15
9
3
<1

Trafficking Role
Source of shipment
Transit or destinationof shipment

Source: UNODC World WISE Database *The year 2018 is based on partial data.
The boundaries and names shown and the designations used on this map do not imply official endorsement or acceptance by the United Nations. The final status of Jammu and Kashmir has not
yet been agreed upon by the parties. Final boundary between the Republic of Sudan and the Republic of South Sudan has not yet been determined. A dispute exists between the Governmentsof Argentina and the United Kingdom of Great Britain and Northern Ireland concerning sovereignty over the Falkland Islands (Malvinas).

In the last World Wildlife Crime
Report, elephant ivory and rhino
horns were discussed separately. Ivory
was discussed under the heading of“art, décor, and jewellery” and as aninvestment commodity. Rhino horn
was classified as a traditional medicine, although it was already apparent
at that time that it had also becomea status item. In the last four years,
the evidence has mounted that rhino
horn is being sold for its artistic andinvestment value, so it is similar toivory in this respect. The two commodities are sourced from different
regions in Africa but require similar skills and equipment to procure.
They also share many commonalities
in their primary destination markets.
For these reasons, the two species are
considered together here.

The poaching of both elephants andrhinos appears to be in decline, as
do the markets generally. For ivory,
a downward trend since 2011 can beseen in the best available indicatorsof poaching, smuggling, and price.
A similar, but more recent, trend
can be seen with rhino horn poaching and prices, although seizures ofrhino horns have continuously risen.
A 2019 surge in very large seizures ofboth commodities may be related tothe unloading of stocks in response to
declining prices. This chapter reviews
the data and discusses some explanations for these trends.

African elephant ivory
Ivory comes from elephants, particularly African elephants.1 There are atleast two different ways to estimate
the number of elephants poached in
Africa, and thus the size of the illicit
ivory supply entering the market
annually. Elephant population estimates can be compared across timeand poaching data can be modelled
to estimate the number of elephants
illegally killed:- -- Population estimates can be com-pared between two assessment
dates; after accounting for natural growth rate and taking into
consideration other factors that
may lead to unexpected mortality(such as drought), unexplained
declines could be attributed topoaching.
- -- Detections of elephant poaching
can be compared to detections

47

AFRICAN ELEPHANT TUSKS AND RHINOCEROS HORNS

of elephants who died of othercauses; based on natural mortality rates, the share of natural
deaths detected can be estimated,
and this share used to estimate
the number of poaching deaths
that occurred.2

How many elephants
are being lost?
Elephant populations are studied bymany independent scientists, and theresults of these studies are compiled
and analysed by the African ElephantSpecialist Group (AfESG) of theInternational Union for the Conservation of Nature (IUCN). In addition
to the regular scientific efforts, a
concentrated study was conductedon savannah elephant populations
using aerial surveys in 18 range
states in 2015, dubbed “the Great
Elephant Census”.3 The results ofthese surveys were integrated into the
IUCN African Elephant Status Report2016 (AESR 2016).4 The AESR 2016
reports a strong decline in elephantpopulations based on estimates madein 2006 and 2015 (Figures 1 and 2).
The AESR 2016 estimated that there
were just over 400,000 elephants inthe areas surveyed5 and over 100,000
in the areas not systematically sur-Fig. 1

While not all the missing elephants
were poached, available data showthat poaching over the last decade
undoubtedly accounts for a significant portion of the elephants killed,8
potentially resulting in some one
thousand metric tons of illegal ivory
over the decade, or an average ofabout 100 tons per year.9 Evidence
discussed below suggests that theactual amount of poaching varied
greatly between years, so in someyears more than 10,000 were lost, andin some, less. This average only gives
a sense of the order of magnitude of
the illicit ivory supply entering themarket in recent years.

Estimated number of elephants
residing in African countries in 2006
(556,973 elephants)10

Congo
17,349South Africa
17,847

Botswana
154,658

Kenya
24,669Gabon
26,980Zimbabwe
91,449Fig. 2

Over half of this continental decline
can be attributed to losses in the
United Republic of Tanzania, where
the estimated population declined
from 135,853 in 2006 to 50,433 in
2015.12 The elephant populationsin the Selous and Ruaha reserves in
Tanzania alone declined by nearly
75,000 elephants between 2006
and 2013. Since 2015, Tanzania has
increased its efforts against poaching
and trafficking, supported by NGOs.
These efforts include actions undertaken through its National Ivory
Action Plan (NIAP),13 as well as theundertaking of the ICCWC Analytic
Toolkit on Wildlife and Forest Crime.
Early indications are that this work is
having some effect.
Other areas where the IUCN noted
negative population trends associated with poaching included Gabon,
Congo and Cameroon (home tothe so-called TRIDOM range), as
well as northern Mozambique (theNiassa range along the border with
the United Republic of Tanzania
and the Selous reserve) and parts of
Kenya. Serious long-term declines
were also noted in the populationsof Central Africa14 as well as partsof Southern Africa (parts of Zimbabwe, Angola, and, to a lesser extent,

Estimated number of elephants
residing in African countries in 2015
(413,242 elephants)11
Mozambique
10,884

Others80,722

Zambia22,510WORLD WILDLIFE CRIME REPORT 2020

veyed,6 which combined cover 62
per cent of the known and possible
elephant range. The AESR compared
their 2015 figures to similar estimates
made for 2006 and found that there
had been a net decline in elephantpopulations of about 111,000 elephants in the areas comparably
surveyed in the intervening years.7
This decline suggests that unexplained
losses not only offset expected natural population growth (which would
have left the population unchanged)
but also reduced the continental elephant population by an average ofabout 10,000 elephants per year.

United Republicof Tanzania
135,853South Africa
18,841
Zambia21,96748

Botswana
131,626

Namibia
22,754
Kenya
22,809
United Republicof Tanzania
50,433

Source: IUCN 2007

Others51,298Source: IUCN 2016

Zimbabwe
82,630Fig. 3

PIKE score for Africa, 2003-2018

CASE STUDY: African elephant tusks and rhinoceros horns

Zambia), which were attributed inpart to poaching.15

3

0.9

How many elephants
are poached?
Another way of estimating the numberof elephants poached (and thus theillegal ivory supply) is to extrapolate
from elephant carcass data. Trends inelephant poaching are monitored by
the CITES program “Monitoring the
Illegal Killing of Elephants” (MIKE).
Based on a network of over 60 sentinel sites, participating rangers report
the number of dead elephants theydetect and the share of these deadelephants that appear to have been
illegally killed. According to CITES,
the designated MIKE sites in Africa
hold an estimated 30 – 40 per centof the African elephant population.18
The “share of the detected elephantcarcasses that have been illegallykilled” is known as the Proportionof Illegally Killed Elephants (PIKE),
and it is calculated at the subregionaland continental levels, adjusted forsample variation.19 Since 2002, over
22,000 elephant carcasses have been
so categorized, with between 1,000
and 2,000 observations per year
between 2007 and 2018. Detectionsof both elephant carcasses and illegallykilled elephants peaked in 2012, but
the PIKE score was highest in 2011.
Since then, it has declined every year
until 2018, during which it increased
by about 0.6 per cent.20

2018

2017

2016

2015

2014

2013

2012

2011

2010

2009

2008

2007

2006

2005

2004

2003

PIKE socre

0.8
These national population trends
0.7
resonate with the findings of DNA
0.6
research conducted on 28 major ivory
0.5
seizures between 2010 and 2016.16
0.4
The majority of the seizures were0.3
traced back to two broad elephant0.2
populations: one extending from
0.1
central Tanzania to northern Mozam0
bique (including Selous and Ruaha),and one centred on the TRIDOM
area (north-east Gabon, north-west
Upper confidence interval
Congo, and south-east Cameroon).17
PIKE estimate
They also align with the trafficking
Lower confidence intervaldata, discussed below, which indicate
East African (Mombasa) and West Source: CITES MIKE
African (Lagos) hubs for illicit trade.

Box 1: Assumptions and limitations in thepoaching-based estimate of illegal ivory supply
presented in this report
Like any estimate of the size of ahidden population, the estimate of thenumber of illegally killed elephantspresented in this chapter is based on
certain assumptions and limitations.
The reliability of the estimates is sub-ject to the validity of these assumptions which concern the demography ofelephants, the nature of the carcass
survey, and the selection of the sites
for observation:

The baseline death and birth rates are derived
from a few, increasing populations
It is assumed that the age structure does not
impact on elephant survival or reproduction
Demographic

No effect of ecologically good or bad years inelephant mortality is taken into accountNo feedback from illegal killing is included in
the model
Density dependent effects are not taken into
account
It is assumed there is no bias in the detectionof natural versus illegally killed carcasses

Carcass survey

Patrol effort consistency across time is assumed
It is assumed that the patrol effort is spatiallyrepresentative of elephant distribution

Site selection

It is assumed that sites are representative of
poaching levels in the region
No ecological differences between sites aretaken into account49

AFRICAN ELEPHANT TUSKS AND RHINOCEROS HORNS

If elephants dying of natural causes
and elephants poached are equally
likely to be detected, it is possible touse the PIKE scores, estimates of natural mortality, and population figures
to estimate the number of elephants
poached. Crudely put, the ratio of the
proportion of the carcasses illegallykilled to the proportion that died ofother causes can act as a multiplierto the natural rate of mortality in theelephant population. This provides anestimate of the poaching rate, as longthese data are robust to the model
assumptions (Box 1). This estimatedpoaching rate can then be multipliedby the population size to estimate theactual number of poached animals.21
This approach has been applied in thepast to generate poaching estimates
between 2010 and 201222 and was extended to 2018 using updated population and PIKE data (Figure 4). Theseestimates suggest some 157,000 elephants were poached between 2010
and 2018, or an average of about
17,000 elephants per year.23 Theyshow a declining trend in poaching
since 2011, rising again slightly in2017 and 2018 (Figure 4).

intensity of poaching, not the volume While not directly relevant for estiof poaching. A relatively low PIKE mation purposes, aerial surveys, suchscore in a large population could pro- as those conducted during the Greatduce more illicit ivory than a high Elephant Census, can provide another
PIKE score in a small population. indicator of poaching intensity: theAccording to the PIKE-based analysis “carcass ratio”. The total number ofconducted for this report, Southern elephants detected (live and dead) can
Africa, despite its low PIKE scores, was be compared to the number of carresponsible for the largest share of the casses observed. A “carcass ratio” of lesselephants poached between 2010 and than 8 per cent is said to be indicative
2018. Oddly, this composition is not of growing elephant populations.27
reflected in the population data, the Whether these elephants died of natuforensic data, or the trafficking data, ral causes or were poached is impossible
which indicate an Eastern African to determine from the air, and environsource as predominant in recent years. mental conditions can affect the rate
at which carcasses disappear. Still, theThere could be several reasons for this stark variation between countries withinconsistency. It could be an issue of regard to the share of dead elephants
data quality for one or more of the detected in aerial surveys gives someconsidered indicators. It is also pos- indication of the variation in threats
sible that some parts of Southern faced across the continent, and highAfrica, with its large elephant pop- shares of dead elephants relative toulations, have been an unrecognised live elephants in Cameroon (83 persource of elephant ivory. The low cent),28 Mozambique (32 per cent),
PIKE values and, therefore, low Angola (30 per cent) and the United
estimated rate of poaching in many Republic of Tanzania (26 per cent)Southern African populations may show higher mortality risk in thesebe sustainable, meaning the level of areas. High carcass ratios, possibly
poaching does not drive a population indicating high poaching levels, were
decline. For instance, using the mod- found in the northern section of Tsavo
elled demographic rates, it would be East National Park, Kenya (52 perThis analysis shows that the intensity expected that the poaching of up to cent carcass ratio), Niassa Nationalof the poaching must be differentiated 4,000 elephants annually in northern Reserve, Mozambique (42 per cent),
from the amount of illicit ivory pro- Botswana would not cause a decline and Rungwa Game Reserve, Tanzania
duced. The PIKE score measures the in the size of the population.24(36 per cent), areas also highlighted by
the forensic data.29

Fig. 4

Estimated annual numbers of illegally killed elephants
in Central, Eastern and Southern Africa (median figures)

35,00030,00025,000WORLD WILDLIFE CRIME REPORT 2020

20,00010,87011,1406,703

13,374 11,137
6,764

6,203

Eastern
37%

7,011
5,737

2,537
4,277

1,728

3,169

5,936

6,477

3,247

4,383

4,337

3,320

4,062

2,906

1,918

2,063

1,569

2010

2011

2012

2013

2014

2015

2016

2017

2018

Source: UNODC25

50

Central
18%

6,659

6,496

5,000
0

Shares of estimatedpoached elephants in
Africa, by subregion,
2010-201812,827

15,00010,000Fig. 5CentralSouthern

Eastern

Southern
45%

Source: UNODC26

Trafficking

Cameroon
Mozambique
AngolaUnited Republic of Tanzania
Chad
Kenya
Mali
Other West Africa
Zimbabwe
Botswana
ZambiaMalawi
Democratic Republic of Congo
UgandaEthiopia

CASE STUDY: African elephant tusks and rhinoceros horns

Based on both population modelling31
and the PIKE estimate, it appears
that the illegal ivory supply has been
declining since 2011. If demand isconstant or growing, then a decline insupply would normally result in a risein prices. But despite indications thatthe supply of ivory is declining, theprice of ivory in Africa also appears tohave declined since 2014. UNODC
fieldwork conducted in 2018 in
Kenya and the United Republic of
Tanzania found that poachers werebeing paid between half and one-thirdof the price they were paid in 2014
(Figure 7). Reports from the field evensuggested that some poachers were
holding onto their tusks in hopes thatthe price would eventually rise.32

Estimated share of observed elephants that were deadin 2015 surveys (carcass ratio)

Fig. 6

83.4
31.6
30
26.4
17.4
13
10
9.4
7.8
6.9
4.5
2
1.4
0.5
0.2
0

10

20

30

40

50

60

70

80

90

Share of detected elephants that were dead (%)

Source: Great Elephant Census30

Ivory prices paid to poachers in Kenya and United
Republic of Tanzania, 2014-2018 (US$/kilogram)

Fig. 7
160

148

140
120
US$ per kg

Looking at both population-based
and poaching data-based estimates,
it appears that between 10,000 (population loss average) and 17,000(poaching estimate average) elephants
were poached per year between 2006
and 2018, producing potentiallybetween 100 tons and 170 tons ofillicit ivory on average per year.

3

95

100

88

80

78.5
54.5

60

40

40

40
30
20
10

2017

2015

2013

2011

2009

2007

2005

2003

2001

1999

1997

1995

1993

1991

0
1989

The official CITES data on elephantivory seizures are maintained by
TRAFFIC in the Elephant Trade
Information System (ETIS). Theseraw data show the total annual weightof seizures reported to ETIS began
to decline in 2013 and the numberof seizures declined after 2011.33
The trend parallels the decline seen

Estimated wieght of ETIS ivory
seizures (MT)Trafficking patterns can be detected
20
through seizure records, but these do0
not give an accurate representation of
2014
2016
2018
the volume of the trafficking because
Kenya
United Republic of Tanzania
it is not clear what share of the con- Source: UNODC fieldwork
traband flow is being seized, and thisshare can vary from year to year. This
Fig. 8 Estimated weight of ETIS-recorded ivory seizures,is particularly true with ivory seizures,
1989-2017 (tons)
where the total volume seized regu80
larly doubles or halves year-on-year
70(Figure 8). Nonetheless, long term
trends can be triangulated with other60
trend data to give an indication of50
market dynamics.

Source: ETIS.34

51

AFRICAN ELEPHANT TUSKS AND RHINOCEROS HORNS

in the poaching data: both indicatethat ivory trafficking grew between
2007 and around 2011-2013 and has
experienced an overall decline sincethat time.

destination markets for raw ivory do
exist outside South-East Asia andChina,36 it appears that almost all
the illicit tusks detected are boundfor this region.

If, as suggested above, an average
about 100 tons to 170 tons of illicit
ivory per year were generated between
2010 and 2018, the ETIS seizure
figures suggest a high rate of interdiction: 17 to 35 per cent on average
across the decade.35

Analysis using the latest data showsa different picture in the identified
destination of illegal ivory shipments
to that in the previous World Wildlife

Crime Report, with a growing role forcountries like Viet Nam and Cambodia. For example, using data up to2015, Viet Nam was the destinationof about 3 per cent of total weightof ivory interdicted, but using recent
data (2015-2019), the share has
increased to 34 per cent. Recently,
almost all the major seizures recordedin World WISE were destined for Viet

Weight of elephant tusk seizures and total number of
seizures captured in World WISE, 2005-2018 (tons)

2017

2016

2015

2014

2013

2012

2011

2010

2009

2008

2007

2006

2005

36.6
Number of whole
While it lacks the long time series,
elephant tusk seizures
World WISE contains a comparable
Weight of seized whole
number of ivory seizures to ETIS inelephant tusks (in tons)
29.0
recent years. Looking just at tusks, the27.1
trend between 2007 and 2017 is sim26.2
22.2
ilar to the ETIS raw data (Figure 9),with sharp growth between 2009 and17.92013 and an uneven decline since
16.7
16.4
then. Based on World WISE records
of some 1,262 African elephant tusk
12.5
11.4
seizures where an alleged destination
was known, between 2005-2017,
0.3
168
1.1
China and South-East Asia were
113 116 113 129 132 120 135
55
51
49
the destination of 90 per cent of
35
28
0.7
these shipments by weight (Figure10). However, some of the countries
listed as destinations in World WISE
for illicit ivory shipments are highly Source: UNODC World WISE Databaselikely to be transit countries. While * The year 2018 is based on partial data.

9.8

33

2018*

Fig. 9Fig. 10 Share of reported national destination of ivory tusk seizures,(total reported seizures 104 tons), 2015-201937
Malaysia
1%
Singapore1%
Nigeria2%

of which domestic

WORLD WILDLIFE CRIME REPORT 2020

Cameroon
2%
Namibia
2%
Kenya
9%

Malawi2%South
Africa1%

Domestic
1%
Other
3%

Cambodia10%
Viet Nam
34%

China
32%

Dem.
Republic of
the Congo
52%

Source: UNODC World WISE Database

52

Kenya
1%

excluding unknown
Malaysia
2%
Singapore2%
Nigeria
2%

Kenya
1%

Cambodia
12%

Unknown
20%
China
27%

China
34%

Domestic
1%
Other
4%

Viet Nam
42%

Just five large scale seizures made in
2019, totalling over 30 tons,39 would
make it a record year in terms of seizures, contradicting the downward
seizure trend seen since 2014. Sincepoaching levels appear to be down,
this suggests either improved interdiction (a higher share of the ivory
flow being captured) or sourcing fromstockpiles (not from recent illegal
killings).
Forensic research suggests that a limited number of criminal groups may
be responsible for a large share of theivory seized (and, possibly, trafficked).
This conclusion was reached by linking
ivory shipments to a common trafficking organization when DNA fromthe same elephant was found in two
seizures. A large share of the seizures
tested could be thus linked together,suggesting as few as three or four
major criminal groups were involvedin the bulk of the trafficking.40
Another trafficking trend of note is thegrowth of mixed seizures containing

Fig. 11both ivory and pangolin scales, often
in large volumes. For example, on 21
July 2019, the government of Singapore seized almost 12 tons of pangolinscales alongside almost nine metrictons of ivory – remarkably large
quantities of both commodities – ina container coming from the Democratic Republic of the Congo on its
way to Viet Nam, declared as timber.
Wildlife seizures containing productsof multiple species are fairly rare in
World WISE, so this recent trend
is worthy of attention. It is possiblethat ivory traffickers, facing declining demand, are taking advantage of
their established networks to movea commodity for which demand is
growing: pangolin scales. The 2019
West and Central Africa Wildlife Crime
Threat Assessment noted that interviewed poachers knew that hunting
pangolins was illegal, but they felt thisoffence was taken less seriously thanelephant poaching.41

3

with only 3 per cent being foundduring routine inspections (Figure 11).
This highlights the importance ofintelligence-driven approaches andrisk management practices in ivory
interdiction. Countries that seize alot of ivory do so because they haveinvested in finding it. Based onrecords involving the seizure of 144
tons of ivory tusks, China (specifically the Kwai Chung area of HongKong) and Viet Nam (specificallyHai Phong) lead the world in ivory
seizures, followed by Port Klang in
Malaysia and Mombasa in Kenya.

CASE STUDY: African elephant tusks and rhinoceros horns

Nam and Cambodia, although data
in World WISE for 2018 and 2019
do not have the same coverage asprevious years.
38

Based on those cases where the exact
location of the seizure was specified,most of the tusks were seized at seaports, although private houses andairports were also frequent sites oftusk seizures. The majority of thetusks were found hidden in freight,
although not all were concealed. Most
seizures involving shipping containers
do not present immediate opportuBased on an analysis of 265 cases of nities for arrests but, based on 221
ivory tusk seizures (accounting for 72 cases where arrests were reported intons of ivory), made in 41 countries42 connection with the seizures, Chi(where the reason for the seizure was nese nationals were most frequently
reported), it appears that the vast arrested, followed by Zimbabwean,majority were made due to investi- Nigerian, Zambian, and Vietnamese
gations, risk-assessments, and tip-offs, nationals (Figure 12).

Share of the most frequent method of detection in ivory tusk seizures(in mass equivalent), 2004-201843
excluding unknown
method of detection

Intelligence /Investigation
14.9%

Unknown
68.8%

Third-party information
5.7%
Risk assessment
4.7%
Scanning images
3.2%
Routine1.0%
Sniffer dog
0.9%
Other
0.8%

Sniffer dog
3%Routine
3%

Other
3%

Scanning images
10%
Risk
assessment
15%Intelligence /Investigation
48%

Third-party
information18%

Source: UNODC World WISE Database

53

AFRICAN ELEPHANT TUSKS AND RHINOCEROS HORNS

Fig. 12 Citizenship of persons arrested in connection with ivory tusk seizures, 2009-201844
excluding unknown
nationality of offenders

Zimbabwe
3% Nigeria
3%

China
8%

Unknown
64%

Other
24%

Zambia3%
Viet Nam
2%
United Republicof Tanzania
2%
France
2%

Other
24%
Angola
4%
Kenya
4%
India
5%
France6%
United Republicof Tanzania
6%

China
22%
Zimbabwe
8%
Nigeria8%

Viet Nam
6%

Zambia7%

Source: UNODC World WISE DatabaseWORLD WILDLIFE CRIME REPORT 2020

Destination markets

interested in the raw material than theart or jewellery that could be madeNumerous reports on Asian markets from it. Large carved art-pieces were
have indicated a decline in the price also prominent in the Chinese marketof illicit raw ivory tusks after 2014. at this time. However, a 2017 survey
This trend parallels the decline in price of 22 cities in China found that 90
paid in Africa. Based on observational per cent of the illegal ivory objects
studies, prices in China almost tri- offered for sale were small items, pripled between 2010 and 2014, only marily jewellery.48 This suggests thatto drop below their 2010 levels by interest in buying raw ivory or large
2018 (Figure 13). This declining artworks for their investment value
trend was also reflected in price data has declined, leaving only the retailgathered by the Chinese police in 50 market for trinkets. Of course, large
law enforcement operations between investors in raw ivory were unlikely to2015 and 2017 (Figure 14). These buy from visible retail establishments
trends in China were paralleled by a even during peak demand, but the
decline seen by the Wildlife Justice decline in visible high-value items is
Commission in 22 undercover price a significant indicator of the health of
quotations in Viet Nam. The 2018 the market. It is also possible that sales
price observed in China (by TRAF- have moved online, but physical marFIC) and Viet Nam (by WJC) are kets remain important in this market.
very similar, and both are similar to Recent surveys in China suggest only
the price in 2010.
a small share of ivory buyers (17 percent in 2018) bought ivory online,
Another indicator of the decline of the with most buying it in person either
ivory market comes from studies on in China or while overseas.49
the type of objects being offered forsale in markets in South-East Asia and The situation in South-East Asia
China. Surveys conducted around appears to be similar. Today, the2014 in China noted the sudden ivory markets in Viet Nam and Thaipresence of whole polished tusks in land seem largely limited to bangles,
urban markets. The last World Wild- amulets, and other jewellery. A 2018
life Crime Report suggested that these survey of 60 online sellers and 852
were marketed to speculators more physical outlets in 13 locations in Viet54

Nam found that 90 per cent of over
10,000 items reviewed were jewellery,and only the top 1 per cent werepriced over US$200.50 The numberof items viewed was fewer than a lessextensive survey conducted in 2015,
which also noted the lack of expensive items in the market.51 A 2016
survey of ivory markets in Bangkok
found the number of objects observed
for sale dropped sharply over an
18-month period between the end of2014 and mid-2016 (Figure). Some
86 per cent of the objects observed
were jewellery, and only 4 per centwere carved ivory, with the numberof carved ivory objects dropping from
614 in December 2014 to just 10 in
May 2016.52
In Japan, which retains a legal domestic ivory market, most (80 per cent)ivory is used to produce hanko nameseals,53 though ivory is also worked
into jewellery and other finishedproducts often targeted at an international tourist clientele.54 A surveyof Japan’s physical ivory market andauctions in 2018 found a strong
reduction in the number of wholetusks offered for sale.55
Thus, surveys conducted in the largest
known ivory markets globally seemFig. 13 Wholesale prices for illegal ivory in China, selected years(US$/kilogram)

CASE STUDY: African elephant tusks and rhinoceros horns

to reflect a move toward a smaller
number of smaller objects, consistent with an overall reduction in thevolume of ivory available.

3

2500
2,100

Trend analysis

2000
US$ per kg

The downward trend in supply and1500
price is likely due to some combina1,100
tion of several factors. As discussed
1000
above, and average of around 100
750728
to 200 tons of ivory had been enter500
ing the market annually since 2007.
Ivory is a durable good, so unless themarket continued to expand, at some02010 (STE)2014 (STE)2015 (STE)2018 (TRAFFIC)
point supply would exceed demand.
45
The exact point when this occurred Source: Various sources.
is unclear but was likely sometime
between 2011 and 2015, and prices
Fig. 14 Illegal raw ivory tusk price in China, 2015-2017
fell as the market adjusted.

(US$/kilogram)

3000
2,610
2500
2000
US$/kg

The timing of this over-supply could
have been influenced by a number offactors, including declining demand.
One factor that surely affecteddemand was a radical change in thelegal regime in some of the key legal
ivory markets.

2,030

1500
1000

1,015

US$/kgIn December 2015, two of the largest ivory consumer markets globally500– China and the United States ofAmerica – publicly committed to0closing their legal domestic markets
2015
2016
2017
for ivory in the future.56 Since theSource: Chinese law enforcement, as reported by TRAFFIC.46
publication of the last World Wildlife
Crime Report, this promise has beenenacted in law in both countries. On
Fig. 15 Wholesale prices for illegal ivory in Viet Nam,
6 June 2016, the relevant rules under
2015-2018 (US$/kilogram)the United States Endangered Species
Act were revised, prohibiting import,
1400
1,316
export, and interstate trade of Afri1200
can elephant ivory, with very limited
exceptions.57 On 30 December 2016,
1000887
the Chinese government announced
its decision to end the commercial
800
713
660
processing and sale of ivory by the600
end of 2017.58 In 2018, the Hong
Kong Special Administrative Region
400of China also announced the imple200
mentation of a three-step plan tophase out the trade in elephant ivory
0by the end of 2021, and to impose
2015 (n=10)
2016 (n=4)
2017 (n=8)
2018 (n=9)
heavier penalties to enhance detern = number of observations
rence of the illicit trade in endangered
Source: Wildlife Justice Commission.47
species.59

55

AFRICAN ELEPHANT TUSKS AND RHINOCEROS HORNSWORLD WILDLIFE CRIME REPORT 2020

These restrictions in the legal market
may have had an impact on the illegal
one. Targeted surveys conducted in2017 and 2018 in China found thatmany consumers have lost interest inivory.63 Even among those open to
the purchase of ivory, the share that
had purchased in the previous year
declined. Some respondents said theysaw owning ivory as shameful after
the ban. In other words, the closingof the legal ivory market changed theway people view ivory as a product.
Despite this shift, the survey found acontingent of die-hard ivory buyers,
primarily affluent men who travelledabroad frequently and purchased theivory while overseas.64 In this way,tightened controls in China likely
had the unintended consequence of
displacing ivory markets into neighbouring countries.
It may be that speculation, not retaildemand, was driving the poaching
since 2007, as suggested by the previous World Wildlife Crime Report.
Of course, by its nature, speculation
is not directly tied to retail demand.
The price of gold, for example, is notdetermined by trends in the retail jewellery market. But ivory’s value as aninvestment may have declined relative56

to competing investment vehicles dueto the tighter controls.
Once large investors began to sell, thecascading flood of ivory could havepushed the price for poached ivory
down. One problem with the ideathat tightened legal market controls
undermined demand is the timing of
the decline. These policy innovations
only started in 2015. The data presented above suggest that poachinghas been declining since 2011 andprice has been declining since 2014.
It may be that while poaching peakedin 2011, ivory trafficking only peakedin 2013 as suggested by seizure data
or in 2015, as suggested by modelled
ETIS data.
It is also possible that, as researchers have suggested,65 prices began
to drop in anticipation of the legal
market ban. If the speculators knew
in advance that market restrictions
were forthcoming, they could havestarted dumping their ivory stocks
in response. Buyers for this surplus
could have been those who weredirectly involved in producing ivory
artefacts: the carving factories. Thesebuyers know what retail ivory objects
can be sold for, so the price they wereMay.16Apr.16

Mar.16

Jan.16

Feb.16

Dec.15

Nov.15

Oct.15

Sep.15

Aug.15

Jul.15

Jun.15

May.15Apr.15Mar.15

Feb.15Jan.15

Dec.14

In addition, Thailand has taken
Fig. 16 Number of carved ivory objects identified in Bangkok,
significant measures to criminalize
December 2014-May 2016
the trade of African elephant ivory.
700
Thailand initiated a series of reforms
614
at the beginning of 2015, including600
the listing of African elephants on
the national protected species list,
500
mandatory countrywide registrationof privately-owned ivory objects and400
several other measures.60 In response,343
300
some 40,000 people registered over
200 tons of ivory with the national200
152 140authorities, underscoring the impor144
tance of Thailand as an important
81 67
65
100
60
32
ivory market. Significant reduction in
30 10
15
1 11 2 15
ivory for sale in the domestic market
0
was observed in 2016.61 While not aban on domestic sales, these measuresappear to have dramatically reduced
the visible retailing of ivory in Bang- Source: TRAFFIC
kok.62willing to pay would be much lower
than the speculative price paid in
2014. Thus, the illicit market wholesale price as reported by market
observers in 2018 is about the sameas that observed before the boom in
2010: about US$750 per kilogram.66
Based on just the five major seizures
cited above, it appears the global
seizure trend will reverse in 2019.
Poaching data for 2019 are not yet
available but would have to reverse
starkly to match the seizure trend.
Unless evidence of renewed poaching emerges, this suggests either anincrease in interdiction rate or the useof stocks rather than freshly poachedelephants.

CASE STUDY: African elephant tusks and rhinoceros horns3
Box 2. Helmeted hornbill ivory: “Red ivory”
Despite its CITES Appendix I listing since1975, escalating demand for hornbill
ivory in recent years has contributed tothe up-listing of the Helmeted hornbill(Rhinoplax vigil) from a “Threatened”
IUCN Red list status in 2012 to a “Critically Endangered” status in 2015.a Also
known as red ivory, golden jade, or“ho-ting,” the hornbill’s casque haslong been considered a natural ivory
substitute.b Unlike elephant, hippo andwalrus ivory, which are dentine material, the casque of the helmeted hornbill
is made of solid keratin.c The casque isorange-yellow in its raw appearancewith a thin red outer layer on the upper
portion, which may disappear once polished.d It is softer than elephant ivory
and relatively easy to carve.e
After being listed on CITES Appendix I,
the international market for helmeteda BirdLife International. Rhinoplax vigil.
The IUCN Red List of Threatened Species 2018: e.T22682464A134206677(2018).
b Liang, J., Li, H., Lu, T., Zhang, J., Shen,
M. & Zhou, J., ‘Identification characteristics of natural and imitation hornbill
ivory’, J. Gemmology 34: 42–49, 2014;
Espinoza, E. O. and Mann, M.-J., Identification guide for ivory and ivory substitutes.
Geneva, Switzerland: CITES Secretariat,
1999; Kane, R.E., ‘Hornbill ivory’, Gems
and Gemology, pp. 96-97, 1981.
c Kane (1981); Liang et al. (2014) ibid.;
CITES CoP 17, Doc. 69, Illegal trade in
the Helmeted Hornbill (Rhinoplax vigil),
2016.

hornbill ivory all but collapsed, with relatively low volumes of illegal tradeoccurring until sometime around theearly 2010s. Hornbill ivory is reportedly
worth five times that of black-market
elephant ivory by weight f During 59
separate events between 2010 to 2017,
2,878 casques, worth US$3 million
were seized.g
Most seizures occurred in Indonesia (arange State) and China (a destination
market), peaking in 2012 and 2013.h
Between 2014 and 2016, Indonesia
reported at least 48 poaching cases in
Sumatra (primarily in Leuser and Bukit
Barisan Selatan National Parks)i and by
2016, Indonesian authorities had confiscated 1,398 casques in 25 seizures.j
Poachers in Indonesia have confirmed
the existence of organized crime networks in the trade, also targeting otherg Jain, A., Lee, J. G. H., Chao, N., Lees,
C., Orenstein, R., Strang,e B. C., Chang,
S. C. L., Marthy, W., Yeap, C. A., Hadiprakarsa, Y. Y. and Rao, M. (Eds), Helmeted
Hornbill (Rhinoplax vigil): Status Review,
Range-wide Conservation Strategy andAction Plan (2018-2027). IUCN Species
Survival Commission Hornbill Specialist
Group. 2018.
h Jain et al. (2018); Beastall, C., Shepherd,
C.R., Hadipraksarsa, Y. and Martyr,D., ‘Trade in the Helmeted Hornbill
Rhinoplax vigil: the ‘ivory hornbill’’,Bird Conservation International 26(2):137–146, 2016.

e Liang et al. (2014); CITES (2016).

i CITES, 69th meeting of the Standing
Committee (SC69), Document 61 (Rev.
1), Species specific matters. Illegal trade in
the helmeted hornbill (Rhinoplax vigil):
Report of the Secretariat, 2017.

f Environmental Investigation Agency,
Seeing ‘red’ – the often-hidden colourof wildlife contraband, 2015 (available
at: https://eia-international.org/news/
seeing-red-the-often-hidden-colour-ofwildlife-contraband/).

j CITES (2017); Indonesia Ministry ofEnvironment (Kementerian Lingkungan
Hidup dan Kehutanan), Strategi dan
Rencana Aksi Konservasi Rangkong Gading(Rhinoplax vigil) Indonesia 2018-2028,
Jakarta, Indonesia: KLHK (available

d Liang et al. (2014); Kane (1981).

species such as tigers and pangolins. k
There have also been reports of seizuresin Malaysia and Thailand.l The seizureof 72 helmeted hornbill casques at
Soekarno Hatta Airport (Jakarta) in July
2019 highlights that illegal trade is still
occurring.m
There are still many unknowns about
the illegal trade in helmeted hornbill. Of
special importance given current ivory
poaching trends, is whether and how
much a decline in ivory supply could
lead poachers to source helmeted hornbill as a possible replacement product,whether consumers would accept such achange, and if non-wild sources could
meet a possible shifted demand to thissubstitute.

at: http://ksdae.menlhk.go.id/assets/publikasi/SRAK%20Rangkong%20
Gading_Published.pdf ).
k Beastall et al. (2016).
l Jain et al. (2018).
m Indonesia Ministry of Environment andForestry (KLHK), KLHK Gagalkan
Penyelundupan 72 Paruh Burung
Rangkong ke Hongkong. [In Indonesian]. Press release. Nomor: SP. 261/
HUMAS/PP/HMS.3/7/2019 (available
at: http://ppid.menlhk.go.id/siaran_pers/
browse/1997#).

57

AFRICAN ELEPHANT TUSKS AND RHINOCEROS HORNS

Endnotes
1 This chapter focuses on African speciesof elephants and rhinoceros, although
there are Asian species of both animals.
Although Asian elephants and rhinos arealso subject to poaching, seizures indicatethat the illegal trade is presently dominated by the flow from Africa to Asia. For
the purposes of precision and simplicity,
the chapter focuses on this dominant flow.
2 There are about half a million Africanelephants left and every year some of themdie of natural causes. Due to its recognizedvalue, their ivory is usually stockpiled by
the state. Ivory is a durable good and canlast for centuries, so stockpiles naturally
accumulate. Since international trade inivory is not allowed for CITES parties,
these stockpiles can be a source of illegal
supply. In addition, every year thousandsof elephants are illegally killed for theirivory. Since it is this killing that is ofconcern to conservationists, this chapter
focuses on the illegal ivory supply fromelephants that have been poached.
3 Chase, M., Schlossberg, S., Griffin, C.,
Bouché, P., Djene, S., Elkan, P., Ferreira,S., Grossman, F., Kohi, E., Landen, K.,
Omondi, P., Peltier, A., Selier, S. and Sutcliffe, R., ‘Continent-wide survey reveals
massive decline in African savannah elephants’. Peer J, Vol. 4, No. 2354, 2016.
4 Thouless, C., Dublin, H., Blanc, J., Skinner, D., Daniel, T., Taylor, R., Maisels, F.,
Frederick H. and Bouché, P., African Elephant Status Report 2016: an update fromthe African Elephant Database, Occasional
Paper Series of the IUCN Species Survival
Commission, No. 60 IUCN/SSC Africa
Elephant Specialist Group, IUCN, 2016.
5 415,428 ± 20,111. See IUCN 2016, op.
cit. p. 29. These estimates are based on
the latest population surveys available inthe scientific literature, extensively vetted
for reliability by the top authorities in
the field, and therefore represent the best
available data on elephant populations.
6 117,127 to 135,384, ibid.
7 The report notes that some new populations were found in areas surveyed for the
first time, reducing the difference between
two estimated number of elephants basedon surveys to about 93,000.

WORLD WILDLIFE CRIME REPORT 2020

8 CITES SC69 Annex document, p. 15.
9 There is a great need for an updated
estimate of the amount of ivory carriedby each elephant, which could be done
through the centralized ivory stockpile
databases held by several Member States.
Although several figures have been used,
the traditional yield has been estimated at
1.8 tusks per elephant and about 5.5 kg
per tusk, resulting in an average of about
10 kg ivory per elephant. See Martin, R.,
Cumming, D., Craig, G., Gibson, D. andPeake, D., Decision-Making Mechanisms
and Necessary Conditions for a Future Tradein African Elephant ivory: Final Report(CITES SC62 Doc. 46.4 Annex A),
24 May 2012, p. 16.
10 Combined “definite” and “probable”
estimates; does not include “possible”
or “speculative” estimates.

58

11 Does not include guesses or uncertainty
range.
12 IUCN 2016 op. cit. p.3.
13 Such as the development of a National
Anti-Poaching Strategy, the creation of a
National Taskforce on Anti-Poaching, anincrease in intelligence-led investigations,increased prosecution, and steep sentences
for wildlife trafficking. Tanzania exited
the NIAP process in 2019. See CITES,
71st meeting of the Standing Committee(SC71), Document 11, Annex 1: National
Ivory Action Plan (NIAP) process: Implementation of Step 1 of the Guidelines to
the NIAP process - Identification of Parties to participate in the NIAP process.
14 Chad, Central African Republic, theDemocratic Republic of the Congo andEquatorial Guinea.
15 IUCN 2016, op. cit. Parts of this region
were also seriously affected by drought
during this period.
16 According to CITES Resolution Conf.
10.10, Trade in elephant specimens, all ivory
seizures over 500 kg should be submitted
to forensic analysis but it appears that only
20% to 25% have been.
17 Wasser, S., Brown, L., Mailand, C.,
Mondol, S., Clark, W., Laurie, C. andWeir, B., ‘Genetic assignment of large
seizures of elephant ivory reveals Africa’s
major poaching hotspots’, Science, Vol.
349 No. 6243, 2015. In TRIDOM, areas
affected include the Minkébé National
Park in Gabon, the Mengame Wildlife
Sanctuary, the Abong-Mbang Forest
Reserve, Bénoué National Park, Bouba
Ndjidah National Park, Faro National
Park, and the Yoko area in Cameroon.
Using Cameroon as an example, theMengame Wildlife Sanctuary was estimated in 2003 to have more than 1,000
elephants; the 2011 revision was 10. In
addition, poaching around 2012 appears
to have virtually wiped out the savanna
elephant populations of northern Cameroon. Reserves that had previously held
elephants with a zero population estimate
in 2016 include Abong-Mbang Forest
Reserve, Bénoué National Park, Bouba
Ndjidah National Park, Faro National
Park, and the Yoko area. See IUCN 2007
and IUCN 2016 op. cit.
18 CITES CoP18 Doc.69.2 (2019), Species
specific matters: Elephants (Elephantidaespp.), Report on Monitoring the Illegal Killing of Elephants (MIKE).
19 See online data repository, which contains
R script for analyses of data from theMonitoring the Illegal Killing of Elephants(MIKE) Programme to produce outputs
for reports to CITES (https://github.com/
CITES-MIKE/MIKE-LSMEANS).
20 That is, from a revised PIKE of 0.52948
in 2017 to 0.53544 in 2018, for an
increase of 0.00596. However, 2018 also
had the smallest overall carcass countsince 2010: 1314, compared to an averageof 1780 between 2011 and 2017.
21 The method used here is explained indetail in the Methodological Annex.

22 Wittemyer, G., Northrup, J. M., Blanc, J.,
Douglas-Hamilton, I., Omondi, P. and
Burnham, K. P., ‘Ivory poaching drives
decline in African elephants’, Proceedings of
the National Academy of Sciences, Vol. 111,
No. 36, 2014.
23 Wittemyer, G., ‘Revisiting estimates ofelephant poaching across Africa’, Working
Paper prepared for UNODC, 2018. Available in the online Methodological Annex.
24 Wittemyer, G., 2020, in litt.
25 Analysis performed by George Wittemyer
for UNODC (full paper available in the
Methodological Annex). PIKE data from
West Africa were insufficient for an estimate to be produced. Based on estimatedpoaching of over 150,000 elephants.
26 Ibid.
27 Chase, M., Schlossberg, S., Griffin, C.,
Bouché, P., Djene, S., Elkan, P., Ferreira,S., Grossman, F., Kohi, E., Landen, K.,
Omondi, P., Peltier, A., Selier, S. andSutcliffe, R., ‘Continent-wide survey
reveals massive decline in African savannah elephants’. Peer J, Vol. 4, No. 2354,
2016. See also Douglas-Hamilton, I. andBurrill, A., ‘Using Elephant Carcass Ratios
to Determine Population Trends’. African
Wildlife: Research and Management, 1991,
pp. 98—105.
28 This very high share was based on a verysmall observed elephant population (148).
Most of Cameroon’s elephants are forest
elephants, which are difficult to view fromthe air.
29 Chase et al. 2016, op. cit.
30 Ibid.
31 Martin, R., Cumming, D., Craig, G.,
Gibson, D. and Peake, D., Decision-Making Mechanisms and Necessary Conditions
for a Future Trade in African Elephantivory: Final Report (CITES SC62 Doc.
46.4 Annex A), 24 May 2012, p. 16.
32 UNODC fieldwork conducted in 2018 in
Kenya and the United Republic of Tanzania. See online Methodological Annex for
details.
33 In addition to these raw data, ETIS
models intended to address bias found alater peak, in 2015. See CITES CoP18
Doc.69.3 (2019), Species specific matters:
Elephants (Elephantidae spp.), Report on the
Elephant Trade Information System (ETIS).
34 Milliken, T., Underwood, F., Burn, R. andSangalakula, L., The Elephant Trade Information System (ETIS) and the Illicit Tradein Ivory: A report to the 18th meeting of theConference of the Parties to CITES, CoP18
Doc. 69.3 (Rev. 1) Annex 1, December
2018.
35 Interdiction rate is usually estimated at
the level of 10-15 per cent. To get lower
interdiction rates with the same seizure
estimates, the total amount of new illegal ivory generated would need to be
increased, either by increang the yield
per animal above 10 kg or increasing thenumber of animals poached above 20,000.
It is also possible that seizures are exaggerated by incorrect weight imputation.

36 The “other” countries indicated include
Kenya, Philippines, Sudan, United ArabEmirates, France and the United States.
37 The data for 2018 and 2019 are notcomplete.
38 For example, in December 2018, Cambodian customs seized 1,026 tusks (3.2 MT)at the Phnom Penh port in a shipping
container from Mozambique that wasnever claimed. In January 2019, 2.1 MTof tusks were seized by China at Hong
Kong, China, coming from Nigeria on
their way to Viet Nam, alongside 8.2
MT of pangolin scales. Also that month,
Uganda seized 3.3 MT of ivory alongsidepangolin scales crossing into South Sudan
on its way to Viet Nam, arresting two
Vietnamese nationals. In March 2019,
9.1 MT ivory were seized by Viet Nam
coming from the Democratic Republicof the Congo, one of the largest ivory
seizures ever made. In April, the Mozambican tax authorities seized 867 pieces ofivory weighing 3.4 MT in a container ofplastic waste destined for Cambodia. In
July 2019, 8.8 MT of ivory was seized bySingapore coming from the Democratic
Republic of the Congo to Viet Nam(alongside 11.9 MT of pangolin scales).
Large amounts of ivory continue to be
seized in China, such as the March seizureof 7.48 MT ivory by Chinese authorities
in the village of Gaogou, Anhui, from agroup that smuggled from Nigeria.
39 Ibid.
40 Wasser, S., Torkelson, A., Winters, M.,
Horeaux, Y., Tucker, S., Otiende, M.,
Sitam, F., Buckleton, J. and Weir, B.,‘Combating transnational organized crimeby linking multiple large ivory seizures tothe same dealer’, Science Advances, Vol 4,
no. 9, eaat0625, 2018.
41 See CITES CoP 18, Doc. 34 (2019),
Interpretation and implementation matters:
General compliance and enforcement:
Wildlife crime enforcement and support inWest and Central Africa.
42 Out of 1,176 ivory tusk seizures in WorldWISE.
43 2018 data are not complete.
44 2018 data are not complete.
45 “STE” stands for “Save the Elephants” andrefers to surveys conducted by Vigne andMartin. Martin, E. and Vigne, L., The
Ivory Dynasty: A Report on the Soaring
Demand for Elephant and Mammoth Ivory
in Southern China, Elephant Family, The
Aspinall Foundation and Columbus Zoo
and Aquarium, 2011; Vigne, L. andMartin, E., China faces a conservation
challenge: The expanding elephant andmammoth ivory trade in Beijing andShanghai, Nairobi: Save the Elephants andAspinall Foundation, 2014; Vigne, L. andMartin, E., Decline in the Legal Ivory Tradein China in Anticipation of a Ban, Nairobi:
Save the Elephants, 2017. Yu Xiao, China’s
Ivory Market after the Ivory Trade Ban in
2018, Beijing: TRAFFIC, 2018.
46 Yuankun Zhao et al 2018 op cit
47 Data transmitted directly from WJC, 19
April 2019.

48 Yuankun et al 2017 op cit.
49 Meijer, W., Scheer, S., Whan, E., Yang, C.
and Kritski, E., Demand under the Ban –China Ivory Consumption Research Post-ban
2018, Beijing: TRAFFIC and WWF, 2018.
50 Nguyen, M. D. T., Indenbaum, R. A. andWillemsen, M., From Tusk to Trinket:
Persistent illegal ivory markets in Viet Nam.
Ha Noi: TRAFFIC, 2018.

CASE STUDY: African elephant tusks and rhinoceros horns

3
63 Meijer, W., Scheer, S., Whan, E., Yang, C.
and Kritski, E., Demand under the Ban –China Ivory Consumption Research Post-ban
2018, Beijing: TRAFFIC and WWF, 2018.
64 Ibid.
65 Vigne and Martin 2017, op cit.
66 See the price trend discussion above.

51 Vigne and Martin observed 16,099 ivory
items at 242 open outlets in six locations.
See Vigne and Martin 2016, op cit.
52 Krishnasamy, K., Milliken, T. and
Savini, C., In Transition: Bangkok’s Ivory
Market – An 18-month survey of Bangkok’sivory market. TRAFFIC, Southeast Asia
Regional Office, Petaling Jaya, Selangor,
Malaysia, 2016.
53 Martin, E. and Stiles, D., The Ivory Markets of East Asia, Save the Elephants, 2003.
54 Kitade, T. and Nishino, R., Ivory Towers:
An assessment of Japan’s ivory trade anddomestic market, TRAFFIC, Tokyo, Japan,
2017.
55 Kitade, T. and Nishino, R., Slow Progress:
A Reassessment of Japan’s Ivory Market
in 2018, TRAFFIC, Tokyo, Japan, 2018.
According to data from Japan’s Ministry ofEnvironment, as of the end of 2019, Japan
had a registered stockpile of 181 metrictons of whole tusks and an additional 68.7
metric tons of cut pieces of raw ivory.
56 The White House, Office of the Press
Secretary, Fact sheet: President Xi Jinping’s
State Visit to the United States, 25 September 2015; State Council of China, Noticeof the General Office of the State Council
on Orderly Stopping Commercial Processing
and Sales of Ivory and Products, Notice 103
of 2016, 30 December 2016 (available
at: http://www.gov.cn/zhengce/content/2016-12/30/content_5155017.htm).
57 50 CFR Part 17, “Endangered and Threatened Wildlife and Plants; Revision of theSection 4(d) Rule for the African Elephant(Loxodonta africana); Final Rule”. Federal
Register, Vol. 81, No. 108, Monday, June 6,
2016.
58 State Council of China, Notice of theGeneral Office of the State Council on theOrderly Stopping of Commercial Processing
and Sales of Ivory and Products, Notice 103
of 2016, 30 December 2016.
59 CITES, Notification to the parties, No.
2018/057, China: Stricter domestic measures on ivory trade in Hong Kong Special
Administrative Region, China, 1 June 2018(available at: https://www.cites.org/sites/
default/files/notif/E-Notif-2018-057.pdf ).
60 See Annex 1 to document SC66 Doc. 29(Rev. 1) pg. 29 and 30: https://cites.org/
sites/default/files/eng/com/sc/66/E-SC6629-Rev1.pdf.
61 CITES, 69th meeting of the Standing
Committee (SC69), Document 29.3,
paras. 122-127: National ivory action plansprocess: report of the Secretariat.
62 Krishnasamy, Milliken and Savini, 2016,
op cit.

59

AFRICAN ELEPHANT TUSKS AND RHINOCEROS HORNS

Map 2

Trafficking flow
map - African rhinoceros horns (2014-2018)*
Trafficking flow map – Elephant Rhinocerotidae (2014–2018)

Main trafficking flows basedon adjusted seizures
High volume flow

Low volume flow
Live equivalents (Heads) - Seizures
200
100
50
25
<5

Trafficking Role
Source of shipment
Transit or destinationof shipment

Sources: World WISE Database.

Source: UNODC World WISE Database *The year 2018 is based on partial data.

* The boundaries and names shown and the designations used on this map do not imply official endorsement or acceptance by the United Nations.

The boundaries and names shown and the designations used on this map do not imply official endorsement or acceptance by the United Nations.
A dispute exists between the Governments of Argentina and the United Kingdom of Great Britain and Northern Ireland concerning sovereignty over the Falkland Islands (Malvinas).

Rhinoceros horn

reserves.3 These operations have Anecdotal data gathered on prices
weathered a decline in the price of paid to poachers historically in Kenya,
African rhinos differ from African a live rhino by two-thirds between the United Republic of Tanzania andelephants in that there are far fewer 2007 and 2018.4 While legal prices South Africa in 2018 were erratic andof them, and they are far more con- have declined, the threat of poaching showed no clear trend. The consensus
centrated geographically.1 For every has imposed substantial security costs among experts interviewed, however,remaining African rhino (about for rhino ranchers.5 In this way, the25,000 of them) there are perhaps 20 illegal trade poses an additional threat
Fig. 17 Estimated numbers
African elephants, and while it takes to rhino populations: it threatens tofive countries to comprise three-quar- make these private holdings unsusof rhinoceroses byters of the remaining elephants, 75 tainable.
country in 2017
per cent of the remaining rhinos can
Botswana
be found in just one: South Africa.
Others502
Zimbabwe
South Africa has been so successful
412
887
in breeding rhinos that it has man- Similar to ivory, there have recently Kenya
aged to export 538 live rhinos since been indications of a decline in the 1,258
2014, feeding growing wild and cap- market for rhino horn, as both supply
tive populations in other countries. (poaching) and price indicators are
Namibia
Drought and poaching have caused declining. South Africa, which expe2,832
South Africa’s rhino population to rienced 86 per cent of the recorded
decline since 2012, however, driving poaching incidents between 2006
South Africa
down the overall continental popu- and 2017, has seen a declining trend
17,671
lation.2
in its poaching numbers every year
since 2014. In 2019, the number ofAround 7,500, or over 40 per cent, poaching incidents decreased to 594,
of South African rhinos are privately the lowest level since 2011.
owned by ranchers and private game
Source: IUCNWORLD WILDLIFE CRIME REPORT 2020

Poaching

60

Trafficking

Fig. 18 Number of poaching incidents in Africa, 2006-2019

CASE STUDY: African elephant tusks and rhinoceros horns

was that the price increased dramatically between 2013 and 2014 andhad declined since then (Figure 19).

3

1600
1400

2018

2017

2016

2015

2014

2013

2012

2011

2010

2009

2008

2007

2006

2019

1200

World WISE shows a strongly increas1000
ing trend in the number and weight ofrhino horns seized, from 16 seizures in800
2008 to 105 in 2017 (Figure 20). This
600
trend stands in contrast to the declining number of poaching incidents and400
suggests increased enforcement has
200
resulted in a higher share of the illicit
7
flow being captured or that some of0
the horn being seized is flowing fromeither public or private stockpiles.
Based on World WISE data between
South Africa
Zimbabwe
Namibia
Kenya
Others
2014 and 2019 where the final desKnight) and South African Department of Environment,
tination was known,8 accounting for Source: IUCN (Emslie andForestry, and Fisheries.6
about two tons of horn, more than
three-quarters of the weight of horn
was destined for China and Viet Nam. Fig. 19 Reported prices paid for rhino horns to poachers(Figure 21). Many of the seizures
in East and Southern Africa, 2010-2018
made in South Africa were domestic;
8000
6,987
the intended destination of this horn7000
was unknown.
6000

2019*

2018*

2017

2016

2015

2014

2013

2012

2011

2010

2009

2008

US$/kg4,808
Because rhino horn is relatively por5000
table and value intensive, the vast
4000
majority is trafficked by air in luggage
2,699
3000
and personal carry-on (sometimes
wrapped in tinfoil) and is seized at air2000
1,152
1,121
ports with a relatively large number of739
1000
seizures involving arrests. According0
to World WISE data for the period
2010
2012
2013
2014
2016
2018
2010 to 2017, Chinese (including 24
suspects in 2017 alone), Vietnamese, Source: UNODC fieldwork
Indian, and South African nationals
are most commonly implicated inFig. 20 Kilograms of horn seized, 2008-2019
rhinoceros horn smuggling. Most of
1,085.0
the Chinese suspects were arrested in
Number of whole rhino horn seizures
970.5
China or South Africa; most of the
Weight of whole rhino horn seized (in kilograms)
Vietnamese in Viet Nam or Mozam762.3
bique. All the Indians arrested werearrested in India, but it is unclear
740.0
539.7
whether the horn they were carrying
412.4
was of African or Indian origin. All
326.7
340.5
305.5
the South Africans associated with
214.4
seizures recorded in World WISE 126.5 91.6
105
69
63
59
49
47
45
40
35
were arrested in their home country,
16
10
18
although, according to the CITES
Secretariat, in April 2019 a South
African national was arrested in Viet
Nam and 13 rhino horns confiscated. Source: UNODC World WISE Database
Maputo (in the suburb of Matola and * The years 2018 and 2019 are based on partial data.

61

AFRICAN ELEPHANT TUSKS AND RHINOCEROS HORNS

Fig. 21 Reported national destination of rhino horn seizures by weight, 2002-2019
Thailand1.4%
Malaysia
2.2%

Other
6.0%

Excluding seizures with unknown destinations

Thailand
3.1%

China
17.8%
Unknown
53.7%

Malaysia
4.7%

Viet Nam
18.8%

Other
13.0%
Viet Nam
40.7%
China
38.5%

Source: UNODC World WISE Databaseat Maputo International Airport), If the 600 rhinos poached in South
Fig. 22 Number of people
Johannesburg and Hanoi are the three Africa in 2019 all bore five kilograms
arrested for rhino
places where the most rhino horn has of horn, then about three tons wouldhorn trafficking
been seized.
have generated that year, and moreby citizenship,
than one-sixth of that total wouldMore recent seizures found inhave been seized in just the five sei2010-2017
World WISE include the following:zures detailed above. Just like ivory,
Nepal
Zambiathe conclusion is that either the rate10
9
of interdiction has gone up or that a Mozambique- -- On 20 August 2018, 116 kg of
Kenya
rhino horn en route to Viet Nam non-poaching source of rhino horn
5
17South Africa
were seized in Malaysia.
must be feeding the market, such as
28
stockpiles.
- -- In January 2019, 116 kg of rhino
horn en route to Dubai wereIndia
50
seized in South Africa.
Based on trafficking data, mostUnknown
Viet Namrhino horn is destined for the con279- -- On 8 February 2019, 21 rhino
65
sumer markets in China and Viethorns coming from South Africa
ChinaNam. Recent market surveys haveand en route to Viet Nam were81
seized in Istanbul, Turkey.
shown that, similar to ivory, demand
for rhino horn in Viet Nam often
involves Chinese nationals seeking to- -- On 14 February 2019, 40 kg ofrhino horn coming from Southmove the product to China. These
Source: UNODC World WISE Database
Africa and en route to Viet Nam
surveys indicate a growing demand
was seized in Hong Kong, China. for rhino horn jewellery and décor
items, including traditional libation
bowls, rather than medicine. Also
- -- On 5 April 20 19, 82.5 kg rhino
horn from South Africa and en
similar to elephant ivory, the prices
route to Malaysia were seized in
paid for rhino horn appear to be inHong Kong, China.
decline in Viet Nam since around2014 or 2015.10
Since most of these seizures took
place in the first quarter of 2019 andamounted to almost 500 kg, the year
is on track to be another record year
for rhino horn seizures.9 At the sametime, poaching is clearly declining.

WORLD WILDLIFE CRIME REPORT 2020

Destination markets

62

Fig. 23 Average wholesale prices of whole rhino horn observedin markets in Viet Nam, 2015-2017

CASE STUDY: African elephant tusks and rhinoceros horns

Analysis3

US$/kg

It is too soon to confirm a decline
30,000in the rhino horn market. Like ivory,
25,617
declines in new supply (poaching)
25,000seem to be teamed with declines
19,505in price in the destination markets.
18,881
20,000
Unlike ivory, seizures show a clear
15,000and consistent upward trend. This
could be due to improvements in
10,000
the rate of interdiction or a genuine
increase in the flow. If the flow has
5,000
increased as poaching has decreased,0
this could suggest the new supply is2015 (n=3)
2016 (n=11)
2017 (n=6)
coming from existing stocks. Many ofthese stockpiles are in private hands
Source: Wildlife Justice Commission11
and can be sold in some range states.
‘n’ refers to the number of market observations in each year factored into this average price
Sellers may be motivated by declining
prices and possibly declining interest.

Endnotes
1 There are two species of African rhinos,
white and black. White rhinos carry morehorn than black rhinos: 5.88 kg of horn
per white rhino versus 2.65 kg for blackrhinos. See Pienaar, D. J., Hall-Martin,A .
J. and Hitchins, P. M., ‘Horn growth rates
of free-ranging white and black rhinoceros’,
Koedoe, Vol 34, No 2, 1991, pp. 97-105.
But no distinction is made between thetwo species by horn traffickers and thespecies is rarely identified in the seizure
records. For these reasons, no distinction
is made between the two species in thischapter.
2 This includes 18,067 white rhinos (86%of which are found in South Africa)and 5,495 black rhinos (37% of which
are found in South Africa and 34% in
Namibia) as of 2017. Other countries
with significant rhino populations include
Kenya (1,258 rhinos), Zimbabwe (887rhinos) and Botswana (502 rhinos). Lesser
populations are found in Eswatini, Malawi,
Mozambique, Rwanda, Uganda, United
Republic of Tanzania and Zambia. See
CITES CoP18, Doc. 83.1, Annex 2, p. 2
(2019), Species specific matters: Rhinoceroses(Rhinocerotidae spp.), Report of the Standing
Committee and the Secretariat.

3 Nearly half (49.3%) of the continental
white rhino population is now privately
owned.
4 CITES CoP18, Doc. 83.1, p. 9 and Annex2, p. 5 (2019), Species specific matters: Rhinoceroses (Rhinocerotidae spp.), Report of theStanding Committee and the Secretariat.
5 For example, South Africa’s largest private
rhino breeder has posted his accounts
on-line reporting that security alone wascosting US$400,000 per month. Save the
Rhino, World’s largest ‘rhino farm’ at risk ofcollapse, 19 June 2018 (available at: https://www.savetherhino.org/thorny-issues/rhinofarm-at-risk-of-collapse/).
6 CITES CoP18, Doc. 83.1, p. 7. Data
from 2018 include projected values for“other” countries. South African data for2019 were announced on 3 February 2020
(South Africa, Department of Environment, Forestry and Fisheries, Departmentof Environment, Forestry and Fisheries reportback on rhino poaching in South Africa in
2019, press release, 3 February 2020.) Estimates for other countries are not available,
although media reports suggest poachingin Botswana has increased.

7 See para. 27 in CITES CoP18, Doc. 83.1
(2019), Species specific matters: Rhinoceroses(Rhinocerotidae spp.), Report of the Standing
Committee and the Secretariat for morediscussion of this trend.
8 Out of 350 rhino horn seizures.
9 Media reports suggest this trend continued through the first half of the year. For
example, on 13 April 2019, 167 rhino
horns sourced from a private stockpile
and destined for South-East Asian markets
were seized in South Africa. On 17 June
2019, 246 kg of rhino horn were seized ona ship in coastal waters of Guangdong. On
25 July 2019, 55 rhino horns weighing
125 kg were seized at Noi Bai International Airport in Viet Nam.
10 Stoner, S., Verheij, P. and Jun Wu, M.,
Black Business: Illegal Rhino Horn Trade
Dynamics in Nhi Khe, Viet Nam from a
Criminal Perspective, A Case Study, Wildlife
Justice Commission, 2017.
11 Ibid.

63

4

PANGOLIN SCALES

Trafficking flow map - Pangolin scales (2007-2018)*

Map 1

Main trafficking flows basedon adjusted seizures
High volume flow

Low volume flow
Seized live equivalent(thousand heads)
200
150
100

50
25
<10

Trafficking role
Source of shipment
Transit or destinationof shipment

Sources: UNODC World WISE Database *The year 2018 is based on partial data.
The boundaries and names shown and the designations used on this map do not imply official endorsement or acceptance by the United Nations.
A dispute exists between the Governments of Argentina and the United Kingdom of Great Britain and Northern Ireland concerning sovereignty over the Falkland Islands (Malvinas).

*

141.9

Number of seizures

Number of whole pangolin live equivalents
seized (in thousands)
101.0

75.9

12.9

86

117

135

117

77

2011

2012

2013

2014

63

117

171

216

71

2018*

30

2017

38

13.9

2016

10.1

2015

9.2

2009

10.4

11.5

2008

18.0

2010

35.8

4.7

There are eight species of pangolin:
four found in Asia and four found in
Africa. They have traditionally been
consumed in both regions, but only
recently have the two markets met.

Number of whole pangolin equivalents3 seized andnumber of seizures annually, 2007-2018

Fig. 1

2007

Pangolins are reclusive nocturnal creatures and the only mammal wholly
covered in scales. They remain elusive, with researchers having limited
knowledge of their ecology, yet they
are now arguably the most heavily trafficked wild mammal in theworld.1 There has been a sustained
increase in seizures of the species since2014 (Figure 1). Due largely to their
exploitation in illegal trade, all species of pangolin were transferred fromCITES Appendix II to Appendix I at
the CITES Conference of the Parties
in 2016.2

Source: UNODC World WISE Database* The year 2018 is based on partial data.

Live, bodies, scales, meat and trophies

65

PANGOLIN SCALES

Fig. 2All eight species of pangolins are
believed to be in decline,8 but sinceexact population counts are unavailable, it is difficult to determine theconservation impact of the illegal
trade.9 The sheer volume of seizures,
though, suggests unsustainable harvesting, a hypothesis corroborated byhunters interviewed by UNODC in
Uganda and Cameroon in 2018, whoreported that pangolins are becoming
harder to find.10*The year 2018 is based on partial data.

- -- The increase started in 2015,

two years before the listing tookeffect.

WORLD WILDLIFE CRIME REPORT 2020

- -- The size of individual seizures has

increased, alongside the increasein overall seizure quantity.

- -- Before the Appendix I listing, theamount of pangolins seized wasmuch larger than the legal trade,
implying that the industries
where pangolins are used havelong drawn on illegal sources.

100%
80%
60%
40%

Bodies

Live

2017

2016

2015

2014

2013

2012

2011

2010

2009

2008

2007

0%

2018*

20%

Scales

Source: UNODC World WISE Database

Kilograms of pangolin scales legally traded,2013-2017 (importer reported quantities)

Fig. 314,00012,000kilograms of scales

Since 2014, there has been a 10-foldincrease in the number of whole
pangolin equivalents seized globally.
The inclusion of all pangolin species
on Appendix I in 2016 likely hadsome role in this trend, especiallyas it increased awareness, but there
are several reasons why the listing is
unlikely to be solely responsible forthe increase:66

Shares of whole pangolin live equivalents
seized globally by product type, 2007-2018

Today, demand for pangolins in Asia
is being supplied by pangolins fromAfrica. In both regions, pangolins are
killed for their meat4 and their scales,
which have been used medicinally.5
Pangolin products have been usedin traditional Chinese medicine forthousands of years to treat a wide
range of ailments. The scales are said
to promote blood circulation andincrease lactation in pregnant women,
while the meat is used as a tonic.6
They are also used as medicine in
Africa. In Nigeria, for example, pangolin parts are used to treat a wide
range of physical and psychologicalconditions.7

10,000
8,000
6,000
4,000
2,000
0
2013

2014

2015

2016

2017

Burundi

DRC

Congo

Togo

UgandaSource: CITES Trade Database
Sizable shipments of whole (oftenlive) pangolins have been seized in
Asia, but most of the largest recent
seizures have involved pangolin scales
sourced from Africa. Prior to 2009,
the international trade involved
mostly pangolin meat and scales,
sourced in Asia (Figure 2).11 The reasons for the shift to African sources is
unclear, but may be due to declining
Asian populations. There have beenvery few seizures of pangolin meatfrom Africa. The reasons for this arealso unclear, but almost all the WorldWISE pangolin seizures coming fromAfrica have been comprised of scales.

Most of the large African scale shipments originated in West and Central
Africa,12 where three out of the four
African pangolin species are found.13
Four pangolin species are also foundin South-East, South and East Asia.
Most of the trade for all species is destined for East and South-East Asian
countries.14 Before 2016, the largest
seizures intercepted amounted to lessthan 10,000 live pangolin equivalents.
In 2019, the three major seizures
made by Singapore were equivalent
to more than twice that number.

4

Demand for pangolin meat persists,
but it appears to be satisfied regionally.
For example, Malaysian authorities
raided two illegal high-volume pangolin meat facilities in February 2019,confiscating 29.8 tons of pangolins in
the form of live and frozen animals,
including frozen meat.16 Intercontinental meat seizures, though, remainrare, and the short geographic distance of trafficking may be one reason
why meat seizures are not detected
at the same level as scale seizures inrecent years. Based on World WISE
data, meat seizures represented 15
per cent of pangolin seizures in
2015, compared to only 1-2 per centof pangolin seizures from 2016 to2018. There were 4,355 live pangolinequivalents’ worth of meat seized in2018, out of 187,256 live pangolinequivalents seized overall that year.17
There is some debate as to how muchof the large increase in scale trafficking could be coming from stockpiles
that existed prior to pangolins’ CITES
Appendix I listing, and therefore,
how much poaching is taking place.
Nineteen countries have declared
pangolin scale stockpiles to CITES.18
China reports regularly releasing thesestockpiled scales for domestic use by
designated hospitals and manufacturers of patented Chinese medicines.19
The volume of declared stockpiles insource and destination countries is far
smaller than the tens of thousands ofwhole pangolin equivalents seizedover the past decade (Figure 3). It istherefore unlikely that leakage fromdeclared government stockpiles contributes significantly to the illegal
trade; most sourcing is likely comingfrom the wild and most from African source countries, and not fromstockpiles.
The magnitude of the illegal trade based on seizure records - suggeststhat this wild sourcing is unsustainable. Breeding of pangolins in captivity
at commercial scale is currently notpossible. Highly specialized diets
combined with extreme sensitivity
to capture-induced stress mean that
pangolins fare poorly in captivity.
Pangolins generally give birth toone cub at a time20 with gestation
periods that range from about 65 to
370 days.21 Only a few births havebeen reported in captivity, with highinfant mortality rates.22 At present,
sourcing from captive-bred populations does not seem to be possible tomeet demand and/or replace the wild
population of pangolins harvested byhunters.
Given that the scales from one pangolin weigh anywhere between 0.36
to 3.60 kg,23 multi-ton seizures ofscales represent far larger numbers of
pangolins killed than meat shipmentsof a similar weight. Estimates of how
many pangolins have been illegally
traded in recent years are difficult to
calculate given that:

Africa produced an average of 500
grams of scales, the 185 tons of scales
seized between 2014 and 2018 would
represent about 370,000 pangolinequivalents.

Sourcing
In 2000, zero export quotas were
established for Asian pangolin species whose populations were seriously
depleted from the skin and meat
trade.24 These zero quotas may havecontributed to the decline in the skintrade,25 but despite population depletion, sourcing from South-East Asia
(primarily from Indonesia, Malaysia
and Thailand) continued in large
quantities until 2013, at which point
it dropped off significantly.
Based on World WISE seizure data,
it appears that, starting in 2013, thesource of seized pangolins shifted to
the African continent, primarily toWest and Central Africa. Seizures weremade first on shipments coming from
Cameroon, then Nigeria, and then (in2016) from the Democratic Republic of the Congo (Figure 4). Other
source countries mentioned by pangolin traders during fieldwork include
the Central African Republic, Congo,
Gabon and Uganda. Recent large seizures in Côte d’Ivoire involve Guinea
and Liberia as additional source countries for trafficked pangolins.26- -- incomplete seizure records that

Nigeria, Uganda and the Democratic Republic of the Congo act astransit countries and logistical hubs
for pangolin and wildlife trafficking more generally. Illegal pangolintrade in Nigeria seems to have grownsignificantly in recent years, and thecountry was the reported provenanceof at least 51 tons of pangolin scales
seized in 2019 (Figure 5)

According to pangolin hunters andtraders interviewed by UNODC
in Cameroon and Uganda, giant
pangolins are relatively rare. If eachpangolin killed for illegal trade in

Based on UNODC fieldwork in
Cameroon and Uganda in 2018, itappears that the initial hunting of
pangolins for the trade is done by
local community members. Wealthier local traders and intermediaries
then consolidate their catch into- -- seizures represent only a small

fraction of the animals killed;- -- size and weight of scales vary

between species; andmake it difficult to know what
species was seized.

Pangolin scales

In 2000, CITES Parties adopted azero-export quota for wild-caught
Asian pangolins traded for primarily
commercial purposes. The legal tradein African pangolin species was rare
until about 2014.15 Between 2013 to2017 (when the up-listing of all pangolin species to Appendix I came into
force), the amount of pangolin scales
legally imported went from almost
zero to nearly 13 tons, with four
countries being responsible for thebulk of the shipments: Burundi, theDemocratic Republic of the Congo,
Congo (Brazzaville) and Uganda(Figure 3). China was the importerof 99 per cent of this volume.

67

PANGOLIN SCALES

Fig. 4

Shares of global pangolin scale seizures by reported
source of shipment, 2015-2018

100%
80%
60%
40%
20%

2018*

2017

2016

2015

0%

Nigeria
Cameroon
Malaysia, Viet Nam and Indonesia
Other

Democratic Republic of the Congo
Ghana
Domestic

Source: UNODC World WISE Database* The year 2018 is based on partial data.

Fig. 5

Pangolin scale shipments involving Nigeria as a sourceor destination, 2015-2019 (tons)

60
51
tons of pangolin scales

50
40
27

30
20
9

8

10
2

2019

2018

2017

2016

2015

0

WORLD WILDLIFE CRIME REPORT 2020

Source: UNODC World WISE Database and CITES
bulk batches and transport them tourban centres where they are trafficked onward by Asian expatriates.27
In some locations, it is not unusual
for a large number of members of acommunity to be involved in hunting
pangolins, often in addition to theirmain job as farmers.28 As a result,
there are large numbers of suppliers
dispersed throughout rural areas.
These suppliers seem to be primarily
part-timers.

68Entering the illicit trade chain is easy.
Without the need for the heavy guns
and specialized equipment requiredfor big game hunting, anyone canparticipate. UNODC fieldwork in
Cameroon found that prospective
new entrants only need supplies
costing US$3 to US$5, with hunters making anywhere from US$ 8 to
US$ 13 for a small live pangolin and
US$ 25 to US$ 30 for a large one. In
Uganda, hunters report being able tocatch anywhere from one to 20 pangolins per day.29
Hunters in Uganda track the animals
and set traps while hunters in Cameroon use wire traps or hunting dogs.
Pangolins, once dead, are immersedin hot water or fire and descaled witha knife. The scales are then dried in
the sun in centralized ‘drying camps’
set up by hunters in the forest. Some
hunters reported keeping the meatto eat. In Cameroon, scales werealso recovered from open bushmeat
markets in the region or from restaurants selling the meat. According
to UNODC fieldwork, most people
seem to understand that pangolins canbe sold for profit, which encourages
local hunters to catch them wheneverpossible. Most hunters and even traders interviewed knew very little about
the animal itself and had radically different and often misguided ideas ofwhat consumers used the animals for,including making bullet-proof vests
out of their scales. Local traders andintermediaries consolidate scales until
at least 10 kg are ready for transit tourban centres. These operators – someof whom are women - tend to be local
residents. They are in contact withinternational traffickers, who sometimes pay for their services by wiretransfer.
The first buyers are often small
business owners, local authorities
or transportation workers that haveenough cash to buy stock from local
hunters and pay for transit to urban
areas. In fieldwork in Cameroon and
Uganda, it was reported that Congolese and Nigerian citizens act as
traders and intermediaries.30 In theurban areas, the goods are sold tointernational traffickers, primarily
Chinese, but also some Nigerians andVietnamese.31
International traffickers tend to be
individuals with enough wealth andpolitical connections to ensure protection from the authorities. These
include high-level government officials and wealthy business people but

TRADER

INTERMEDIARY

TRAFFICKER

US$ 2.5 - 9/kg scales
US$ 4 -14 per live
pangolin

US$ 13-40/kg scales(consolidate to 10 kg)

US$ 135 commission perdelivery (10 -16 sacks,
50 kg each)No data available

Supplies: US$ 3 to 5
per hunter (or per
pangolin?)

Storage: US$ 40 per month
Car to city: US$ 100-134
No data available
Driver: US$ 27
Bribes: US$ 27 -100

Pangolin scales

HUNTER
IncomeActors involved in pangolin scale trafficking and their costs and income (Uganda)

Costs

Table 1

4

No data available

Source: UNODC fieldwork
can also be foreign workers based in
the country for development projects.
The number of actors involved in the
trafficking from source to destination
ranges from five to more than 15
people, with prices paid to each actor
increasing the closer one gets to theconsumer. For example, in Uganda,
traders who consolidate scales are paid
quadruple the price per kg than that
paid to the hunters.
Traders order pangolin scales by thekg, with a preference for the large
scales from giant pangolins, Manis
gigantea, which hunters report
are harder to find. Several huntersdescribed traders seeking them out
and requesting they switch to hunting pangolin rather than other species.
Table 1 provides an overview of theactors involved in the trafficking of
pangolin scales from source to theinternational trafficker in major urban
centres. It includes associated costs
along the way, where known, using
data collected through field interviewsin Uganda as an example.32

Trafficking
Trafficking is done by sea, air andland, and parcel post is also sometimes used. Shipments may not bewell concealed, but they have beenfound under frozen meat and ice,33
hidden in logs using candle wax34 andstuffed inside steel barrels of othergoods.35 Large illegal consignments ofpangolin scales in shipping containers
are either misdeclared or concealed
under ‘cover loads’ such as plastic
waste. International seizures haveshown that traffickers are using thesame techniques repeatedly, including regular air shipments of relatively
small amounts of scales. For example,
authorities in the Netherlands haverepeatedly seized similarly packaged
consignments of about 20 kg of scales
from Nigeria in parcel post. Malaysia
also seized a series of similarly packed
shipments in air cargo from Ghana
in 2017.36 Some are even smuggled
in luggage37 and sent via parcel post
declared as wood chips or other commodities.
Traders reported that pangolin traffickers often use the same routes toexport and import pangolin scales
as they do ivory.38 A third of hunters
and traders interviewed in Uganda
reported that traffickers take advantage of the weak border controls
and security challenges in northern
Uganda, Democratic Republic of theCongo and South Sudan to offload
the scales they collected, sometimes
concealing themselves as impoverished locals to avoid detection at
known checkpoints.39 Traders andtraffickers also store stockpiles ofscales in countries where the ruleof law is weaker and wildlife crime
enforcement limited before moving
the scales for immediate sale to buyers
in more high-risk locations.
The development of logging operations in previously wild areas, bringing
with it an influx of people and infrastructure like roads, facilitates hunters’
access to wild pangolin populations,making areas near logging operations
particularly vulnerable to pangolinpoaching. In fact, two-thirds of theinterviewees in Cameroon notedthat traders often transport scales tolarger cities on logging trucks, withthe scales concealed as wood chips
or foodstuffs.40 A third of the tradersinterviewed in Uganda mentioned
using motorbikes for local transport,
although several choose “fancier”
vehicles that belong to official organizations when possible to limit the
chances that they will be searched.
Very large individual seizures in 2019show that Nigeria is the primary pointof export of pangolin shipments,
while Viet Nam has emerged as theprimary destination (Table 2). In
October 2019, the Chinese government announced having seized 23
tons of pangolin scales in China in aseries of operations. These shipments
were coming from Nigeria via the
Republic of Korea.41
Ivory traffickers appear to be involvedin the pangolin scale trade, oftentransporting shipments of ivory andpangolin specimens together. Recent
large seizures of pangolin scales areoften mixed shipments of both pangolin scales and ivory.
The interviewed hunters also seemto be of the view that authorities
consider crimes associated with pangolins as less serious than other formsof poaching, for example elephantpoaching. Fear of enforcement action
did not appear to play much of a rolein their decision-making.
Currently, the market for ivory appears
to be in decline, while, according tointerviews with hunters in Cameroon and Uganda, pangolin prices

69

PANGOLIN SCALES

Table 2

Notable pangolin seizures in 2019DATE

VOLUME OF PANGOLIN SCALESSEIZED (TONS)REPORTEDORIGINSEIZING
COUNTRYREPORTEDDESTINATION

January

1.4 (with 100 kg ivory)

Nigeria

Viet Nam–

January

8.3 (with 2.1 tons ivory)

Nigeria

China (HongKong SAR)

Viet Nam

March

8.3

Nigeria

Viet Nam

April

12.9 (with 175 kg ivory)

Nigeria

Singapore

Viet Nam

April

12.8

Nigeria

Singapore

Viet NamApril

4 (with 3.4 tons ivory)

Democratic Republicof the Congo

Viet Nam

–

May

5.3

Nigeria

Viet Nam–

July

11.9 (with 8.8 tons ivory)

Singapore

Viet Nam

July

1.2

Turkey–October

1.5–

Nigeria

Malaysia

December

1.7 (with 330 kg ivory)

Nigeria

Viet Nam–

Democratic Republicof the Congo
Democratic Republicof the Congo

Source: CITES
have been going up since 2017.42
UNODC fieldwork in Cameroon
and Uganda suggests that some ivory
traders may be entering the pangolinscale trade in response to lower risk.
For example, hunters interviewed in
Uganda reported that while they used
coded language to discuss transactions
involving ivory and rhino horn overthe phone, they did not feel the needto take such measures when tradingin pangolin products and openly discussed the number of kg of pangolinscales that they wanted to buy or sell.
If those involved in the ivory trade
are now selling pangolin scales, thiswould imply that the pangolin trade
can now build on the supply chainof the well-established ivory market.

WORLD WILDLIFE CRIME REPORT 2020

DemandBased on seizures, most pangolin scales
are destined for traditional medicine
use in China, followed by other Southeast Asian countries. Some 71 per centof seizures of whole pangolin equivalents recorded in World WISE between
2007 and 2018, where the destination
was known, were destined for China,
with 19 per cent bound for Viet Nam

70(Figure 6). As noted above, this routing
seems to have changed dramatically in
2019, where all the major seizures weredestined for Viet Nam.
In China, the cities of Fangchengang,
Guangzhou and Kunming are key
nodes for pangolin trafficking according to a 2016 study of 206 Chinese
seizures.43 In a survey of five major
Chinese cities in 2012, Guangzhou
residents reported the highest rates
of wildlife consumption for food andas ingredients for traditional medicine.44 Consumer surveys in 2018 of
1,800 people living in Chinese cities
with active markets for wildlife products (Beijing, Guangzhou, Harbin,
Kunming, Nanning and Shanghai,)support the increased demand argument, especially for scales.45 The
number of people who reported they
had bought pangolin products in thelast 12 months increased by 12 percent from previous studies in both
Beijing and Shanghai and remained
stable in Kunming and Nanning
while decreasing only slightly inGuangzhou and Harbin (4 and 3
per cent, respectively). Some 68 percent of that group reported that they

intended to rebuy pangolin productsin the future, suggesting that there isa stable base of buyers46 regardless of
campaigns against the practice. The
government announcement in August
2019 that pangolin products would
no longer be covered by China’s state
insurance funds could reduce purchases overall.47
A 2018 survey of 1,500 wildlife
product consumers in key Vietnamese cities (Can Tho, Da Nang, Hai
Phong, Hanoi and Ho Chi Minh
City) found similar results and consumer profiles for pangolin scales andpowder.48 About 60 per cent of thesampled buyers who bought pangolinproducts in the last 12 months and54 per cent of all buyers of pangolin products surveyed indicated thatthey would purchase these again,
suggesting a strong continuing consumer demand.49 In addition, 52 percent of these buyers, who mostly buy
from private sellers, reported making
an unplanned purchase of pangolinproducts influenced by the seller’s recommendation. This suggests that sales
pressure drives about half of consumerpurchases.

4

Destinations of seizures in whole pangolin equivalents,* 2007-2018
Malaysia
0.7%
Domestic
1.8%
Lao People'sDem. Rep.
2.2%

Dem. Rep. of
the Congo
0.6%
Nigeria
0.5%
Other
1.6%

China
50.4%
Unknown
28.9%

excluding unknown
Dem. Rep. of
Nigeria
the Congo
0.9%
0.7%

Malaysia
1.0%
Domestic
2.5%
Lao People'sDem. Rep.
3.1%

Viet Nam
13.3%

Pangolin scales

Fig. 6

Other
2.3%

Viet Nam
18.7%
China
70.9%

Source: UNODC World WISE Database* Includes seizures of live pangolins, bodies, and scales.

Endnotes
1 Challender, D. W. S., Waterman, C.
and Baillie, J. E. M., Scaling up pangolinconservation, IUCN SSC Pangolin Specialist Group Conservation Action Plan,
Zoological Society of London, 2014.
2 In 1975, all four Asian pangolins species,
including M. crassicaudata, M. culionensis,
M. javanica and M. pentadactyla were
included in CITES Appendix II and one
African species (M. temminckii ) was listed
in Appendix I. In 1995, all species of pangolins (including the African species) were
included in Appendix II under the species
listing Manis spp. In 2000, there was a
proposal to transfer M. crassicaudata, M.
javanica and M. pentadactyla to Appendix
I. However, the proposal was not accepted,
noting that the species were at that time
under the Review of Significant Trade process. Following this process, a zero annual
export quota for specimens removed fromthe wild and traded for primarily commercial purposes was established for all Asian
pangolin species. In 2016, all eight species(Asian and African) were transferred toAppendix I.
3 The figure refers to seizures of pangolinbodies, scales, meat, trophies as well aslive pangolins. For conversion factors, see
Annex 1 of Challender, D. and Waterman,
C., Implementation of CITES Decisions
17.239b) and 17.240 on pangolins (Manisspp.)., Cambridge: IUCN, 2017. Where
the species is not specified in the seizures,the conversion factor of 360 grams of scale
per pangolin (recommended by Challenderand Waterman) is adopted for cases where
Asian countries are reported as origin,whereas the conversion factor of 500 grams
is adopted for the cases originating fromAfrican countries (UNODC Fieldwork).
In cases of unknown origin, the conversion

factor adopted is the average of the above
conversion factors, that is 430 grams.
These estimates should be regarded asliberal when taken on an annual basis, but
consistent across time.
4 Krishnasamy, K. and Shepherd, C.R., ‘Seizures of African pangolin scales in Malaysia
in 2017’, TRAFFIC Bulletin, 29(2), 52-55,
2017.
5 Challender, Waterman and Baillie 2014,
op. cit.
6 Hua, L. et al., ‘Captive breeding of pangolins: Current status, problems, and future
prospects’, ZooKeys, 507, 99-114, 2015.
7 Soewu, D.A. and Ayodele I.A., ‘Utilisationof pangolin (Manis sps) in traditional
Yorubic medicine in Ijebu Province, Ogun
State, Nigeria’, Journal of Ethnobiology &Ethnomedicine, 5, 39, 2009; Soewu, D.A.
& Adekanola, T.A., ‘Traditional-medical
knowledge and perception of pangolins(Manis sps) among the Awori People,
Southwestern Nigeria’, Journal of Ethnobiology & Ethnomedicine, 7, 25-36, 2011.
8 Challender, Waterman and Baillie 2014,
op. cit.
9 CITES SC69 Doc 57; IUCN, The IUCN
red list of threatened species, Version 2019-2,
see: http://www.iucnredlist.org, accessed on
30 August 2019.
10 UNODC fieldwork in 2018, see Methodological Annex for details.
11 Annex 1 of Challender, D. and Waterman,
C., Implementation of CITES Decisions
17.239b) and 17.240 on pangolins (Manisspp.)., IUCN, 2017.
12 UNODC, West and Central Africa Transnational Organized Crime Threat Assessment,
2018.

13 The fourth species, Temmick’s groundpangolin, is found primarily in East,
Central, and Southern Africa. IUCN SSC
Pangolin Specialist Group, The status, trade,and conservation of pangolins (Manis spp.),
Information document for the 17th meetingof the conference of the Parties to CITES(CoP17 Inf.59), CITES, 2016.
14 See, for example, Annex 1 of Challender,
D. and Waterman, C., Implementation of
CITES Decisions 17.239b) and 17.240 on
pangolins (Manis spp.), IUCN, 2017.
15 UNODC, West and Central Africa Transnational Organized Crime Threat Assessment,
2018.
16 Papachristou, L., ‘TRAFFIC: 30 Tonnesof Rare Pangolin Meat Seized in Malaysia’,
Organized Crime and Corruption Reporting
Project, 15 February 2019.
17 World WISE. See note 4 above for conversion factors.
18 In response to Notifications to the Parties
No. 2017/035 and 2014/059 , as included
in table 13 in Annex 1 of Challender,
D. and Waterman, C., Implementation of
CITES Decisions 17.239b) and 17.240 on
pangolins (Manis spp.), IUCN, 2017.
19 Challender, D. and Waterman, C., Implementation of CITES Decisions 17.239b) and17.240 on pangolins (Manis spp.), IUCN,
2017.
20 Hua, L. et al. (2015).
21 This range is very approximate and debatedby contradicting studies. Research is stillongoing to get more exact figures. See, f.ex.
Hua et al. 2015, op. cit.; Chin, S.C. et al.,‘Monitoring the gestation period of rescued
Formosan pangolin (Manis pentadactyla)
with progesterone radioimmunoassay’, Zoo
Biology, 31, 479-489, 2011;Yang, C.W.

71

PANGOLIN SCALESWORLD WILDLIFE CRIME REPORT 2020

et al., ‘History and dietary husbandry of
pangolins in captivity’, Zoo Biology, 26,
223–230, 2007.
22 Hua et al. 2015, op. cit.; World Association of Zoos and Aquariums (WAZA),WAZA statement in response to the pangolintrade crisis, September 20, 2016.
23 Challender and Waterman 2017, op cit.;Zhou, Z.M. et al., ‘Allometry of scales in
Chinese pangolins (Manis pentadactyla) and
Malayan pangolins (Manis javanica) andapplication on judicial expertise’, ZoologicalResearch, 33, 271-275, 2012; Challender,
D.W.S. et al., ‘Understanding markets
to conserve trade-threatened species in
CITES’, Biological Conservation, 187, 249259, 2015.
24 UNODC, World Wildlife Crime Report,
2016.
25 UNODC, World Wildlife Crime Report,
2016.
26 UNODC, West and Central Africa Transnational Organized Crime Threat Assessment,
2018.
27 UNODC fieldwork.
28 Despite heavy community involvement in
the pangolin trade, there are certain communities, like the Lugave Clan in Uganda’s
Mukono District, that protect pangolin
populations (in this case because the species is their totem animal).
29 Hunters operating near national parks
reported the highest per day catches.
30 UNODC fieldwork.
31 UNODC fieldwork.
32 Note that prices for 1 kg of pangolin scales
are on the low side in Uganda with hunters
in Cameroon reporting being paid anywhere from US$6 to 23 per kilo (with thehighest prices near major cities).
33 Osborne, S., ‘Record haul of pangolinscales seized along with hundreds of ivory
tusks in Hong Kong’, The Independent, 2February 2019.
34 Delegation of the European Union to theAfrican Union, ‘3.2 tons of ivory and 423
Kg of pangolin scales seized thanks tosupport of EU Wildlife Conservation programme’, 2 April 2019.
35 Doom, J., ‘7.5 tons of ivory, pangolinscales seized in Viet Nam’, ABC News, 14
June 2019.
36 CITES, Wildlife crime enforcement support
in West and Central Africa, CoP18, Doc34(available at: https://cites.org/sites/default/

72

files/eng/cop/18/doc/E-CoP18-034.pdf ).
37 TRAFFIC, ‘Ivory processing workshop
found in Angola following airport rhino
horn seizure’, 28 August 2018.
38 UNODC fieldwork; Osborne, S. 2019,
op.cit.
39 UNODC fieldwork.
40 Also confirmed by research from the first
UNODC World Wildlife Crime Report(2016).
41 China Daily, Smuggled pangolin scales
seized in joint operation, 12 December
2019 (available at: http://www.china.org.
cn/china/2019-12/12/content_75505980.
htm).
42 UNODC fieldwork in 2018.
43 Cheng, W., Xing, S. and Bonebrake, T. C.,‘Recent pangolin seizures in China reveal
priority areas for intervention’. Conservation Letters, 10(6), 757-764, 2017.
44 Zhang, L. and Yin, F., ‘Wildlife consumption and conservation awareness in China:
a long way to go’, Biodiversity and Conservation, 23, 2371-2381, 2014.
45 De Guzman, E., ‘Research study on consumer demand for elephant, pangolin,rhino and tiger parts and products in
China’, USAID Wildlife Asia, 2018.
46 Primarily males in their 30s and early 40s
with high levels of income and education,and frequent travel outside the country.
47 Bale, R., ‘Pangolin scale medicines nolonger covered by Chinese insurance’,
National Geographic: Wildlife Watch, 29
August 2019.
48 USAID Viet Nam, ‘Research Study on
Consumer Demand for Elephant, Rhino
and Pangolin Parts and Products in
Viet Nam’, research study submitted by
GlobeScan, 2018.
49 Supporting documents provided withrequests for CITES listing upgrades for
multiple pangolin species suggest thatdemand remains strong and is driving these
species to extinction as demand outpaces
the number of individuals available for
consumption (CITES CoP17 Prop. 9).

5LIVE REPTILES

Map 1

Trafficking flow map - Reptilia (2007-2018)*

Main trafficking flows basedon adjusted seizures
High volume flow

Low volume flow
Seized live equivalent(thousand heads)
15
10
5
1
<1

Trafficking Role
Source of shipment
Transit or destinationof shipment

Source: UNODC World WISE Database *The year 2018 is based on partial data.
The boundaries and names shown and the designations used on this map do not imply official endorsement or acceptance by the United Nations.
A dispute exists between the Governments of Argentina and the United Kingdom of Great Britain and Northern Ireland concerning sovereignty over the Falkland Islands (Malvinas).

In the last World Wildlife Crime Report,
several species of reptiles appeared
among the most trafficked species
in the world, including crocodilians,
lizards, snakes, tortoises and freshwater turtles.1 The same species remain
prominent in the analysis conducted
for this report. The three largest markets for illegally traded reptiles thatappear in the seizure records are:- -- Reptile skin or shells used in

the décor or fashion industries;- -- Reptile meat organs, or venom

consumed as a food, tonic ormedicine;- -- Live reptiles used as pets, forzoos, or breeding.

The last World Wildlife Crime Reportfocused on the illegal skin trade,highlighting the ways that unregulated collection of wild pythons andboas can introduce illegally caught
skins into the legal fashion industry.
Since 2016, however, according to the
CITES Secretariat, fashion brands,
designers and department stores
have expanded their support to reptile conservation programmes aroundthe world. While small leather items(such as handbags, wallets, belts, andshoes) continue to be the single largest category of reptile products seized,
the number of live reptiles seized iscomparable to the number of reptile
skins from crocodilians, snakes, andlizards seized, and live reptile seized.2

Because the smuggling of live reptiles often results in high mortality
rates, seizures involving live reptiles
or whole reptile bodies3 are includedin the analysis below as “live reptile
equivalents.” In addition, species
known to be widely used for theirmeat or skin or widely farmed were
excluded,4 so the analysis below
focuses on wild-sourced species thatare likely to be traded as pets oramong reptile collectors and breeders.
According to World WISE, nine outof the top ten CITES-listed wildsourced live reptile species seized inrecent years, based on a head count,
were tortoises and freshwater turtles(Figure 1).5 Consequently, this chapter
pays particular attention to the illegal
trade in live turtles and tortoises.673

LIVE REPTILES

The majority of the live reptiles seized(70 per cent) were listed on Appendix II of CITES, with 18 per centon Appendix I and 4 per cent on
Appendix III. The remaining live reptiles seized for CITES violations were
not identified down to a taxonomic
level that allowed for an exact appendix listing classification.7 The top 10
CITES-listed live reptile species seized,

Share of broad reptile
groups in total numberof live reptile
equivalents seized,
2007-2017*

Fig. 1

excluding food species, are indicatedin the table 1 below, along with their
Appendix listing and IUCN status.
In addition to World WISE data, thechapter uses qualitative data based ona series of 30 interviews with reptile
experts and people involved in the live
reptile trade during 2019.14

Fig. 2

Live reptiles detected in illegal international trade come from several
different parts of the world, includingSouth Asia, Central Asia, South-East
Asia, East Africa and West Africa.
Based on World WISE seizure data,
India is the leading national source of
seizures and is the source of a variety

Share of top ten CITES-listed live reptiles seized,
2007-2017

Unspecified
reptiles0.5%

Crocodilians
7.6%

Sourcing

False map turtle
2.9%
Mali uromastyx
2.3%

Pig-nosed turtle
3%
Greek tortoise
6.1%
Black spotted turtle
7%

Lizards
17.8%

Turtles andtortoises
47.4%

Radiated
tortoise
8.2%
Russiantortoise
8.9% Asianbox turtle
11.2%

Snakes26.7%

Source: UNODC World WISE Database

Source: UNODC World WISE Database*Includes live specimens and bodies. Based on 6,015
seizure events.

* Includes bodies.
** The top ten live reptile species seized represent 33% of all reptiles
seized when looking only at bodies and live specimens.

Fig. 3

India
13.3%

Domestic
19.1%

WORLD WILDLIFE CRIME REPORT 2020

Indian star
tortoise
21.3%

Share of source countries for the top ten live reptile species seized,* 2007-2017
Other
5.7%

Unknown
38.3%

Madagascar
5.5%*Excluding food species. Includes bodies.

Other
9.3%

Pakistan
2.9%
Mali
2.6%
United Statesof America
2.1%

Thailand
1.5%

Source: UNODC World WISE Database

Excluding seizures withunknown origin

Uzbekistan
7.4%

Bangladesh
1.5%

74

Yellow-spottedriver turtle
29.1%

Domestic
30.9%

India
21.5%
Uzbekistan
12.1%

Thailand
2.4%
Bangladesh
2.5%

Mali
4.2%

United States of America
3.4%

Madagascar
8.9%
Pakistan
4.7%

Top ten seized reptile species for the live trade, 2007-2017

TOP 10 CITES-LISTEDSPECIES SEIZEDCOMMON NAMESOF SPECIESIUCN RED LISTSTATUS 8

POPULATIONTREND 9

Podocnemis unifilis(Appendix II)

Yellow-spottedriver turtle10

Vulnerable

Unknown

Geochelone elegans (II)Indian star tortoise

Vulnerable

Decreasing

Cuora spp. (II)11

Asian box turtle

Endangered or
critically endangered12

Decreasing for three
species and unknown
for all others13

Testudo horsfieldii (II)Russian tortoise

Vulnerable

Unknown

Astrochelys radiata (I)Radiated tortoise

Critically endangered

Decreasing

Geoclemys hamiltonii (I)Black pond turtle/
Indian spotted pond turtle

Endangered

Decreasing

Testudo graeca (II)Greek tortoise

Vulnerable

Unknown

Carettochelys insculpta (II)Pig-nosed turtle

Endangered

Decreasing

Graptemys pseudogeographica (III)

False map turtle

Least concern

Unknown

Uromastyx dispar (II)Mali uromastyx––

Live Reptiles

Table 1

5

* Excluding food species, including bodies.

of species, most notably the Indianstar tortoise (Geochelone elegans).
Uzbekistan appears prominently
due to the indigenous Russian tortoise (Testudo horsfieldii). Madagascar
is seen as the source of seizures of atleast 30 species of reptiles, but mostprominently the radiated tortoise(Astrochelys radiata). The black pond
turtle (Geoclemys hamiltonii) is seizedfrom a wide range of source countries,
including India, Indonesia, Malaysia,
Pakistan and Thailand.

their homes until middlemen cometo collect them. They may also breed
and grow-out reptiles.

At this early point in the trafficking
chain, prices paid are often very low.
For example, illegal market prices
for turtles in the Philippines range
from US$1-15 per turtle at the source.
These are sold for 10 to 100 times thatat the retail level. Radiated tortoises(Astrochelys radiata) from Madagascar
are sold for US$2-10 at source, while
they are sold to the end consumer for
The wide range of seizure source loca- US$1,000-2,000 (for a one- to threetions makes it difficult to generalize year-old animal, depending on theabout the means of collection. Based colour).16
on interviews with international reptile traders,15 poachers collect animals Interviews with reptile traders aroundby hand or with snares, pitfall traps, the world suggested that contrabandfishing line or funnel traps, and some- reptiles may be laundered throughtimes specialized hunting dogs. The captive breeding operations. Interadvent of YouTube and other video national traders say that somesharing sites has resulted in an abun- suppliers will illegally source gravid
dance of “how to” videos promoting females from the wild, so that they
the best ways to catch certain species, lay their eggs at their farm, and theyespecially in South-East Asia. Most then declare the offspring to be cappoachers living in the range area tive-bred. “Niche” species, with verycollect reptiles opportunistically for specific or lesser-known ecologies,
secondary income and keep them at diets and behaviours that make themdifficult or costly to breed in captivity, are typical targets for this sort oflaundering.17

Trafficking
The intention of this kind of wildlife
trafficking is to get the animals toarrive alive at their final destination.
To reduce mortality rates due to suffocation, dehydration, starvation orotherwise, most international trafficking of live reptiles occurs by air: 56
per cent of the live reptile seizure incidents in World WISE that included
transport information involved airtransport.
According to interviews with reptile
dealers around the world, turtles andtortoises are a good product to sellbecause they tend to sell for higher
prices than other reptiles and survive
transportation well, providing higher
profit margins. Some turtle and tortoise species are valuable enough to
air courier, making use of carry-on
or checked luggage. Some experts
interviewed reported cases involving

75

LIVE REPTILES

airport personnel facilitating thetrafficking of ploughshare tortoises(Astrochelys yniphora), for example.18
Use of air freight also appears to
be on the rise as well as the use of
express mail using devised packaging
and techniques that allow live reptiles
to be posted to buyers. Mail and air
courier seizures have increased morethan any other means of trafficking
documented in World WISE in recent
years, each more than doubling from2016 to 2017.
Small-scale seizures of less than 15
reptiles per shipment accounted
for 80 per cent of seizures in World
WISE. For these small-scale seizures,the 15 most valuable species seized
represented only 9 per cent of shipments; the large majority of shipments
were of less valuable species. Many
seizures of tortoises and freshwater
turtles seem to involve small numbersof animals carried or kept as personal
pets or souvenirs. Trends in the illegal trade in tortoises and freshwater
turtles, though, do differ geographically, with a relatively large number of
seizures in Europe and North America involving smaller quantities of
specimens per event, whilst a smaller
number of seizures in Asia resulted inFig. 4

Based on seizures, Asia is the main destination (or possible transit destination)
for the illegal live reptile trade. East andSouth-East Asia, followed by the UnitedStates of America and Europe, are themain destinations for tortoise and freshwater turtle species.21 Trafficking routes
are in constant flux with traffickers
seeking out emerging transit opportunities and concentrating their activities
in major air transit hubs.22 These hubs
provide more direct flight options that
reduce the transit time necessary to get
trafficked live reptiles to their destination, limiting deaths in transit. The
trafficking flow map at the beginningof the chapter provides an overview ofsome of the current trafficking routes.
Private Facebook groups and othersocial media platforms are in somecases the dominant sales points. For
example, in Indonesia, according to

China
16.2%

Excluding seizures with unknown
destination/transit
Malaysia
6.0%

Other
8.9%

United States
5.8%

Unknown
37.2%

Domestic
26.3%

Sri Lanka
3.6%
Domestic
16.5%

Russian Federation
3.0%
Thailand
2.8%
United Kingdom
1.8%France1.5%

Source: UNODC World WISE Database* Excluding food species. Includes bodies.

76

interviews with experts in the trade,many physical markets have closed
in favour of online sales, as these
reduce overhead costs and often
receive less official scrutiny. When
online sales points are detected bylaw enforcement, traffickers simply
switch platforms. Facebook, in May
2019, added a functionality to its siteenabling the public to report illegal
wildlife trade, and subsequently shut
down various Indonesian Facebook
groups. In response, traffickers moved
to other platforms, such as vk.com or
mewe.com, even keeping the samegroup names they had on Facebook.
WhatsApp groups have also been used
to traffic reptiles since the Facebook
crackdown. These groups are smaller
than those from Facebook because
WhatsApp limits the number ofpeople that can join groups. Perhaps
partly as a result, these splinteredgroups have become more specialized,with some focusing on specific species.
Some groups also moved to Telegram,which has no group member limit. In
some cases, these moves have madeillegal activity more difficult to detectbecause they make use of encoded private messaging applications.

Share of the most reported final destination or transit countries for the top ten
live reptile species seized,* 2007-2017
Other
5.6%

WORLD WILDLIFE CRIME REPORT 2020

much greater quantities of specimens
seized.19 A smaller number of seizuresof large to very large shipments (thatis several hundred or thousands oflive specimens) have also been documented, suggesting the involvementof well-organized criminal networks,
consisting of collectors, local traders,
wholesalers, exporters and importers.20

France2.3%
United Kingdom
2.9%
Thailand
4.4%

RussianFederation
4.8%

China
25.8%
Malaysia
9.6%
United Statesof America
9.2%
Sri Lanka
5.7%

5In September 2019, Austrian customs
at Vienna International Airport intercepted an Austrian national living in
the Philippines with a suitcase filledwith 43 venomous snakes and 45
other reptiles.24 His plan was to crossare illegal to trade in the back of theirstalls or have local suppliers nearby
who can deliver rapidly if interested
international collectors visit.28 To
evade law enforcement, some dealers at the Mercado de Peces, also in
Mexico, suggested collectors comeback on the weekend for sales of illegal
wildlife because less law enforcement
agents are on duty then.29

Live Reptiles

This rise in online markets allows the open border between Austria andhobbyists, and not only traders, to Germany and sell the animals at Terimport and breed on a small scale raristika Hamm, a quarterly trade fairand sell directly to other hobbyists, that claims to be the largest of its sort
both to supplement their income in the world.25
and fund their hobby. In doing sothey cut out the middleman and the Dealers at shows find different ways
overhead costs involved in brick and of circumventing legislation and bansmortar operations. Private sellers are on selling protected species. Theseless exposed to law enforcement and include laundering the animals as
specialized shipping services make it captive bred, marking animals thateasy to ship from home.
are illegal to trade as “display only” inorder to ensure dealers are officiallyIn addition to these virtual meeting acting within the law. Dealers can also
places, large reptile shows often act label animals as being sold for “scias rallying points for collectors and entific or educational purposes only”
dealers to build relationships and in order, for example, to bypass legtrade merchandise. Sales of illegally islation preventing commercial trade
imported reptiles at such shows are in turtle specimens smaller than 4generally pre-arranged via social inches (10.2 cm).26 After some scanmedia and private messaging so dals, most of the larger reptile shows
the dealer can meet buyers outside in recent times have stricter controls
the show to avoid law enforcement to prevent these kinds of operations. A
scrutiny as well as avoid the risk of greater focus on traceability and proof
returning with unsold trafficked ani- of valid captive breeding claims would
mals.23
also help prevent these abuses.
Street markets, both permanent andtemporary, are also a common place
to obtain illegal reptiles based on
seasonal availability. At the Mercado
Sonora in Mexico,27 reptile dealers
sometimes keep native animals that

77

LIVE REPTILES

EndnotesWORLD WILDLIFE CRIME REPORT 2020

1 See figure 3 on the share of type of wildlife
among total seizures (aggregated on thebasis of standard value) 2005-2016 on
page 16 of the first World Wildlife Crime
Report published by UNODC in 2016.
Included in these most trafficked species
are various species of python, boa, monitor, alligator, crocodile, and caiman, as
well as turtles and tortoises.
2 Small leather products made of reptile
skin are very common (more than 13,000
seizures) but two-thirds of these wereof one or two items (such as two shoes).
These seizures may be related to tourists
or others who inadvertently travel internationally with products made of protected
reptile skins, rather than the actions oftraffickers. Reptile skin seizures are sometimes reported by weight or another unit
(as are live reptiles less commonly), but
based on those seizures in which a countis given, there were 386,156 reptile skins
seized in World WISE, compared to316,393 live reptiles. World WISE contains 5,699 seizures of live reptiles (99.2%
in which a count is given), compared to
1,644 seizures of reptile skins (98% inwhich a count is given).
3 Note that the World WISE databaseseparates taxidermy specimens fromdead bodies so the whole reptile bodies
mentioned here are not meant for thetaxidermy market.
4 Looking at the volume of all reptile species
seized, the top species illegally tradedinclude a number that are primarily consumed for meat or the skin trade and/or are heavily farmed with little need
for wild-sourcing or conservation protection. They include, for example, thegreen iguana (Iguana iguana) and the ballpython (Python regius), both of which
are heavily farmed and in the top ten
species for the legal reptile commercial
trade based on number of live specimens,
according to the CITES Trade Database.
Also excluded are Varanus nebulosus(clouded monitor), Varanus bengalensis(bengal monitor), and Ptyas mucosus(oriental rat snake), excluded because they
are primarily traded for the skin trade.
Amyda cartilaginea (Asiatic softshell turtle),
Mauremys reevesi (Chinese pond turtle),
Testudo hermanni (Hermann’s tortoise),and Naja atra (Chinese cobra) areprimarily consumed for their meat (aswell as for traditional Chinese medicine
for Chinese cobra), so were also removed.
These species are not, first and foremost,traded for the live pet trade and havetherefore been removed from the analysis.

78

5 The exception being the Mali uromastyx
lizard (Uromastyx dispar).
6 All analyses nevertheless include all
reptile types.
7 30% of reptiles seized had no CITES
listing information and were excluded
from this analysis.
8 The Red List of the International Union
for the Conservation of Nature (IUCN)
is a compilation of research about plant
and animal species put together on a
voluntary basis by interested scientists.
This compilation involves the assignmentof a threat status, from “least threatened”
and “critically endangered” which is updated periodically, as well as an assessmentof the population trend.
9 International Union for the Conservationof Nature (IUCN), The IUCN Red List of
Threatened Species, Version 2019-3 (available at: http://www.iucnredlist.org).
10 The yellow-spotted river turtle suffers fromoverfishing (partly as fisheries bycatch)and habitat loss in addition to harvestingfor the pet trade. Its conservation status isunclear. Poaching in the wild for the pet
trade is a major contributor to the decline
in population numbers, so it was includedin this list.
11 Cuora spp. is left at the genus level inthis table because most seizures did not
identify the specimen seized down to thespecies level. Cuora amboinensis, though,is number 14 in the top 15 seized reptile
species for the live trade by count. The
other reptiles in this top 15 seized were allidentified down to the species level.
12 Except for the Southeast Asian box turtle(Cuora amboinensis) which is listed as vulnerable.
13 Decreasing for Cuora picturata (Southern
Viet Nam box turtle), Cuora galbinifrons(Indochinese box turtle), Cuora yunnanensis (Yunnan box turtle) and Cuora bourreti (Bourret’s box turtle). Unspecified
for Cuora trifasciata (golden coin turtle),
Cuora mouhotii (keeled box turtle), Cuora
flavomarginata (yellow-margined box
turtle), Cuora zhoui (Zhou’s box turtle),
Cuora mccordi (McCord’s box turtle),
Cuora amboinensis (Southeast Asian box
turtle), Cuora aurocapitata (Yellow-headed
box turtle) and Cuora pani (Pan’s box
turtle).
14 See the Methodological Annex for details.
15 UNODC fieldwork, see Methodological
Annex.
16 UNODC fieldwork.

17 Ibid.
18 UNODC fieldwork.
19 See CITES CoP 17, Doc. 73, Annex 2(2016), Species specific matters: Tortoises
and freshwater turtles (testudines spp.).
20 See CITES CoP 17, Doc. 73, Annex 2(2016), Species specific matters: Tortoises
and freshwater turtles (testudines spp.).
21 66% of the seizure incidents in WorldWISE reported origin while 74% included
destination.
22 UNODC fieldwork.
23 UNODC fieldwork.
24 Federal Ministry of Finance of the Republic of Austria. (September 16, 2019).
43 poison snakes and another 45 reptiles
seized by Austrian customs. Vienna, Austria: Federal Ministry of Finance of the
Republic of Austria. See, for example,’43 Giftschlangen und 45 weitere Reptilien
auf Flughafen Wien sichergestellt’, Der
Standard, 12 September 2019.
25 For more information about the trade fair,see: http://www.terraristikahamm.de/content/index.php.
26 UNODC fieldwork.
27 Sellers also sell reptiles along the highways
in Mexico, especially those with highnational tourist traffic.
28 UNODC fieldwork.
29 Ibid.

6

BIG CATS(Figure 1).7 It is estimated that there
are up to three times as many tigers
in captivity (estimated at 12,574),8
91 per cent of which are held in 716
facilities in seven countries for whichdata are available: China, the UnitedStates of America, Thailand, Lao
People’s Democratic Republic, India,
Viet Nam and South Africa (see Table
1). Some of these facilities appear to
supply domestic tiger product markets, and some appear to be the sourceof illegal international trade.

international trade in their parts andvoted for “trade”, in the context of
this Decision to refer to domestic aswell as international trade.12 Captive
breeding of tigers is occurring in several range and non-range States, with
the United States, South Africa andCzechia having many captive tigers.
Many captive breeding facilities
appear to be operated in a mannerthat would not seem to align with thisCITES Decision (14.69).13 Breedingof tigers for commercial purposesis thus contrary to this Decision,
Captive breeding of Appendix I although this alone may be perfectly
species, such as tigers, for the inter- legal in some countries according tonational commercial trade of these domestic legislation.14 Some tiger
captive-bred species and their parts, range countries have legal provisions
is permitted but strictly regulated that permit domestic trade under aunder CITES9 and can only be car- permit system.15 Some non-range
ried out by facilities registered with states, meanwhile, simply do not
Tigers – and tiger products – have the CITES Secretariat.10 There are no have regulations regarding non-native
been traded continuously since antiq- captive tiger facilities registered under species. Regulations vary widely inuity. They have been traded live, as this system.11 In 2007, however, the what they allow and how and if they
pets. Their skin, claws, and teeth have Conference of the Parties agreed in are applied. Trading these products
been and are still used ornamentally. Decision 14.69 that tigers should not across borders, however, is contrary
Various parts, including their bones, be bred for the purpose of commercial to CITES under national CITES
have and continue to be used in tonics
and medicines in East Asia. While in Fig. 1
Estimates of wild tiger populations in 2015,
1994, a TRAFFIC report concluded
selected countries
that the most serious threat to the
2,500
tiger’s survival was the trade in parts
3
for medicine, more recent reviews
2,000
have shown that tiger parts (such asmeat) and other products (such as
1,500
bone wine or glue), are now less consumed for medicinal purposes and
1,000
more as exotic luxury products andtonics.4 Poaching for these uses is the500
greatest threat to tigers across their
5range. In addition, tigers have a long0
history of being hunted due to conLow-end estimate
High-end estimate
flicts with humans and livestock. As a
3,855 (Total)
4,982 (Total)
result, they have disappeared from 90
Russian Federation
India
Indonesia
per cent of their original habitat range.6
Estimated number of wild tigers

With the exception of the African lion,
all big cat species are listed in CITES
Appendix I, meaning internationalcommercial trade in these species
is illegal except under a few narrowconditions.1 This chapter focuses on
the illegal market for tiger products,
specifically bone products, but also
touches on the markets for products
from other species of big cats, likelion and jaguar, some of which areused in ways similar to, in place of,or sold as, tiger products. The focus
on bone products stems from the factthat almost two-thirds of tiger seizure incidents in World WISE from1999-2018 corresponded to either
tiger bone products or tiger medicinal products, which themselves areprimarily made from bone.2

In 2016, there were an estimated
3,855 to 4,982 tigers in the wild, mostof which are found in eight countries

Malaysia
Bangladesh

Thailand
Bhutan

Nepal
Others

Source: CITES, citing WWF and Goodrich et al 2015** CITES CoP18, Doc. 71.1, p. 13 (2019), Species specific matters: Asian big cats (Felidae spp.): Report of the Secretariat.

79

BIG CATS

implementation laws. It is this trafficking as well as the trafficking ofwild tigers that are the subject of thischapter.

in the world, followed by the UnitedStates, India, and Thailand. The Russian Federation, which does not havea large captive population, has thesixth largest tiger population in theworld. The top eight countries holdabout 90 per cent of the remaining
tigers on earth (Figure 2). All ofthem, except the United States andSouth Africa have some indigenous
tiger populations. According to theWorld Wildlife Fund, tiger ownershipin the United States appears to belightly regulated22 as many tigers are
privately owned, as pets or in small,unlicensed menageries,23 with some
anecdotal evidence of trafficking toSouth-East Asia.24 This is not to suggest that captive tigers do or do nothave any conservation value per se but
rather to point out that these countries with high levels of both wild anddomestic tigers are potential sourcesof tigers for the illegal trade becauseof existing tiger “supply.”

Fieldwork conducted by UNODC
in 2019 suggests that some of thedata on captive breeding operations
obtained through studies commissioned by CITES (Table 1) may havechanged over time and suffered fromincomplete reporting. For example,
it appears that in 2016, there werean estimated 53717- 700 tigers in
captivity in the Lao People’s Democratic Republic,18 with a decline in2017 following the disappearanceof 300 tigers from just one facility.19
By 2017 the number of captive tiger
facilities in the Lao People’s Democratic Republic had increased fromthree to four, and by 2018 there weremore than 600 tigers in six facilities
in the country. Likewise, UNODC
fieldwork documented over 450 tigers
in South Africa in 2019.20 Numbers
in some countries are more difficult toassess because record-keeping is spotty
and non-centralised or some tigers are Assessing the illegal supply of tiger
being held in facilities that are unregis- products is complicated by the fact
tered or not open to the public.21
that the species is used in so many
forms and that seizures are only a parWhen all sources of tigers are com- tial picture of the trade since there
bined (wild and captive), China likely can be no seizures in countries withhas the largest number of living tigers out adequate laws and enforcement

Sourcing

Table 1

Seizures of live tigers, tiger bodies,rugs, skins, skulls, skeletons and trophies can be most easily analysed so
as to represent equivalent numbersof individual tigers involved.26 Whilethe number of animals reflected inseizures of tiger products in thesecategories in World WISE is relatively small (913 in 1,032 seizures
over 12 years),27 based on just theseproducts, the amount seized appears
to be rising between 2007 and 2018
(Figure 4). This number should moreover be understood in the context
of a small global tiger population

Estimated number of facilities holding tigers and the number of tigers held in theseven countries with the greatest captive tiger populations up to early 2018

COUNTRY

WORLD WILDLIFE CRIME REPORT 2020

capacity and limited seizures incountries with weak governance and/or high levels of corruption. Nevertheless, seizures do provide someinsight into illegal tiger trafficking
when properly contextualized. WorldWISE contains 1,032 seizure records
for tigers from 2007-2018 where thetype of product was specified. Of
these, 40 per cent involve medicinal
products reportedly containing tiger
parts. Since these seizures were usually
made on the basis of labelling, notforensic analysis, it is unclear how
many individual tigers were used in
the manufacturing of these products,
if any.25 All other types of tiger products account for the remaining 60 per
cent of all seized items (Figure 3).

China
United States
ThailandLao People’s
Democratic Republic
India
Viet NamSouth Africa
61 other countries
TOTAL

NUMBER OF TIGERS
LEFT IN THE WILD 16

NUMBER OF
FACILITIESNUMBER OF TIGERS
HELD IN FACILITIES>7
Not indigenous
189-252

210
355
46

6,057
2,729
1,595

2

4

380

2,226
<5
Not indigenous
–
–

48
13
36
326
1,038

309
186
186
1132
12,574

Source: CITES** CITES Seventieth meeting of the Standing Committee, Review of facilities keeping Asian big cats (Felidae ssp.) in captivity, SC70, Doc. 51, Annex 2 (Rev. 1).

80

Fig. 37,000
Number of captive tigers

number of tigers

6,000

Share of tiger seizures
by type of product2007-2018*

Skulls2%
Bones
5%

Number of wild tigers

5,000

Other
8%

Derivatives
5%

4,000
3,000

Claws
6%

2,000

Live
6%

Medicinals
40%

Teeth
7% Bodies

1,000

8%

Ch
ite ina
d
St
at
es
In
d
Th ia
ai
O lan
th
d
er
As
In
La
ia
d
o
Pe
O one
op
sia
Ru thele's ssia r Eu
De
ro
n
F
p
m
oc ede e
ra
ra
tic
ti
Re on
pu
bl
ic
Vi
et
So N
ut am
h
O
Af
th
ri
er
Am ca
er
ic
O as
ce
O
an
th
er ia
Af
ric
a

0

Un

Big Cats

Estimated number of tigers (wild and captive) by selected
country, 2016 or most recent data*

Fig. 2

6

Skins
13%

Source: UNODC World WISE Database* The year 2018 is based on partial data.

Source: CITES.

* F or countries where the number of wild tigers is estimated as a range, a midpoint figure was used for this graph. See:
CITES CoP18, Doc. 71.1., p. 13 (2019), Species specific matters: Asian big cats (Felidae spp.): Report of the Secretariat.

While some research has asserted
that tiger products sourced fromwild individuals are preferred by

240
200
160
120
80

2018*

2017

2015

2014

2013

2012

2011

2010

2009

0

2016**

40

2008

Thailand has one of the largest captive tiger populations, but fewer than
200 wild tigers, so most of theseseizures since 2007 likely involved
captive-sourced animals. The Tiger
Temple case is one notorious example.30 In India, the opposite is true,
with the world’s largest wild population and a small captive population
with no indicators to suspect captive
specimens in trade,31 the seized products are more likely from wild animals.

280

2007

Looking only at products that convert readily to whole equivalents, itappears from the World WISE data
covering 2007-2018 that Thailand
and India are the main source
countries of shipments seized in international trade, together representing
82 per cent of the total whole tiger
equivalents seized where the origin
was known (Figure 5).

Number of whole tiger equivalents seized based on reported
seizures of products that can easily be converted into an
equivalent number of individuals, 2007-2018*

Fig. 4

Tigers live equivalentof 3,855-4,892.28 It should also be
noted that these seizure data may not
be complete, particularly for 2018.29

Source: World WISE.
* I ncluded are bodies, live animals, rugs, skeletons, skins, skulls, and trophies. Teeth and claws
are excluded. The year 2018 is based on partial data.
** 2016 includes an outlier of considerable size, the Tiger Temple case that occurred in Thailand.

consumers over those from captive
animals because they are thought
to be more powerful with more
effective medicinal properties,32 it isalmost impossible for consumers todifferentiate between wild and captive animals. Given the current useof other species in products purporting to be tiger, the first concern for

consumers is likely whether the product is genuine tiger.33 This is part of
the reason why, for example, wholetiger cubs have been found in large,transparent bottles or jars: they offer
proof that the wine contains genuine
tiger.34
In addition to tiger products, products containing body parts of other81

BIG CATS

Share of reported origin countries for whole tiger equivalents seized globally, 2007-2018*

Fig. 5

Excluding seizures with unknown
country of origin
China
1.2%
Malaysia
1.8%

Lao People's
Democratic Republic
1.2%
Other
8.5%

RussianFederation
1.2%
Indonesia
2.1%

Domestic
0.8%
Other
4.7%
Excluding outlier**

India
3.4%

Domestic
2.1%
RussianFederation
3.3%
Indonesia
5.7%

Thailand
24.5%
India
9.3%

Thailand
66.9%

Unknown
63.4%

Lao People's
Democratic
Republic
3.2%
China
3.2%

Other
22.5%

Thailand*
12.9%
India
24.4%

WORLD WILDLIFE CRIME REPORT 2020

Indonesia
Malaysia
15.0%
4.7%
Domestic
5.5%
Russian Federation
8.7%
Source: UNODC World WISE Database* Included are bodies, live animals, rugs, skeletons, skins, skulls, and trophies. Teeth and claws are excluded. The year 2018 is based on partial data.
** The Tiger Temple case that accounts on its own for 207 tigers (live equivalent) and clearly represents an outlier has been removed, the resulting chart showsthat the prominent role of Thailand as a source of illegally traded tiger products is driven by this one single seizure incident of considerable size.

big cat species have been recorded in Chinese medicine is not specific andillegal trade, including leopards, snow could refer to three species (leopard,
leopards, clouded leopards, jaguars, snow leopard, and clouded leopard),
and lions. Some of these products it remains difficult to parse out the
could be passed off as tiger products, involvement of each in illegal or evenparticularly bones, teeth, and claws, legal trade.41
although some of these species arealso illegally traded to consumers As for jaguar, the IUCN Red List
seeking these species specifically. assessment group noted in 2018,
Leopard bone was officially recog- “jaguars are starting to be considnised as a substitute for tiger bone in ered a replacement for tiger bone
China in 1993, when domestic trade for traditional medicine purposes byin tiger parts was prohibited.35 Later, the increasing Asian community inin 2006, the hunting of wild leopards Latin America.”42 The CITES Secrewas prohibited, as was the purchase of tariat also has plans to commission abones except from official stockpiles.36 study on the illegal trade in jaguars as
In addition to being used in place of it becomes a concern for the species’
tiger bones in traditional medicinal survival.43 Jaguar parts appear to bepreparations,37 leopard bone products entering the trade when jaguars areare openly marketed as containing killed as menaces to humans and liveleopard, including in a tonic product stock (see box on jaguar canine trade
known as Hongmao Yaojiu.38
below). World WISE contains recordsof only 121 seizures of jaguar parts
Data on the use of snow leopard as a (excluding medicines and derivatives)
possible supplemental species to tiger from 1999 to 2018, including skins or
is limited. One case of snow leopard skin pieces (32 per cent of jaguar parts
use in Asian medicines was detected seizures), teeth (18 per cent), and live
through DNA analysis in 2015.39 animals (13 per cent).
Snow leopard claws and canines
have more recently been advertised
as medicine to cure heart and bloodvessel ailments.40 Given that the termfor “leopard” used in traditional82

As a supplement to the tiger bone
supply, African lions appear to be
the species of greatest concern (seebox 2 below). Nevertheless, greater
insight into actual substitution trends
between different big cat products isneeded to determine its importanceas a threat.

Trafficking
There are only 155 cases recorded in
World WISE where the citizenshipof the tiger traffickers was identified,but of these, 29 per cent were Chinese, 18 per cent Indian, 14 per centVietnamese and 8 per cent Indonesian. Research conducted for CITES
suggests the trafficking networks fortiger products involve Chinese andVietnamese traders who sell the products to medicinal industries in China,
casino towns bordering China in the
Lao People’s Democratic Republic
or Myanmar, urban markets in the
Lao People’s Democratic Republic,
and manufacturers in Viet Nam, or
directly to consumers.69 They linksuppliers in source countries, bothpoachers and farms, with retailers in
consumer countries. Supply chainsconverge to some extent with traders
moving wild and captive-bred tigers

Big Cats6
Box 1: Jaguar canines
Although jaguars (Panthera onca) aremainly killed in retaliation for conflictwith humans and their livestock, 44
poaching for jaguar parts is a concern
across the range states of Latin America(including Belize, Brazil, Costa Rica,
Honduras, Panama, Peru and Suriname).45
Despite being listed on CITES Appendix
I since 1975, jaguar parts have enteredillegal trade,46 and this appears to be
an increasing problem. 47 While necklaces and keychains made of canines
are found in local markets in source
countries, local traders have reported
increased interest in jaguar parts(including canines) from Asian citizens.48 Recognizing the issue in 2018,
the Chinese consulate in Santa Cruz
(Plurinational State of Bolivia) and theChinese embassy in Suriname issued
advisories, warning Chinese citizens inthese countries that jaguar trafficking isstrictly forbidden.49

Seizures of canines en route to Asia 50
began as early as 2012-2014.51 From
January 2012 to March 2018, over
1,900 jaguar canines were reported
seized.52 34 per cent of these incidents
were linked with China and these seizures were 14-fold larger than thosemeant for the domestic market. The
majority of these canines were seized in
the Plurinational State of Bolivia. 53
Many Bolivian seizures involved postal
trafficking, with some seizures made inpersonal luggage at airports. 54 It is
unclear whether the seized canines originated from Bolivia, or if they were
smuggled into Bolivia from neighbouring countries.
In July 2019, representatives fromjaguar range states met in Santa Cruz,
Bolivia, at a regional seminar on wildlife trafficking. There, they signed adeclaration recognizing the jaguar as
an integral part of the ecosystem, andthat its protection was a regionaland African lion through their net- Democratic Republic to Viet Nam
works.70 Two trafficking routes for and China74. The South-East Asiantigers that have been identified are:routes are used to transport captive
and wild tigers.75 Captive tigers in
China and Viet Nam are used for- -- A trans-Himalayan routesourcing primarily from wild
illegal domestic consumption.76
populations in South Asia;71 and- -- Multiple South-East Asian routes Of those seizure cases where the destithrough the Mekong Delta
nation was reported (54 cases, 16 permaking use of captive, as well ascent of seizures over the period 2007wild, tigers.72
2018), the most common reported
destinations were China, Thailand,Some border areas in South Asia and Viet Nam, which together were
have been identified as hotspots for believed to be the destinations fortiger trafficking based on high seizure more than half of the whole tiger
rates recorded there.73 From South equivalents seized.
Asia parts move across the borders ofIndia and Nepal into China, and via
the northeast India route to Myanmar. Tiger parts from South Asia All parts of the tiger are traded andand South-East Asia, including from used, for traditional medicine and forIndonesia move through Myanmar to other purposes, but the bones are genChina. Tiger parts are also trafficked erally most sought after.77 The tiger’s
via Myanmar to China via Lao Peo- strength and power are said to be theple’s Democratic Republic. Tiger parts reason for its medical properties, withfrom Indonesia, Malaysia, Thailand the bones believed to promote healing
may be trafficked via Lao People’s of bone, joint, and ligament issues

Destination markets

responsibility. 55 The signatories proposed the jaguar as the emblem of thefight again wildlife and forest crime.
They highlighted that wildlife trafficking
should be considered a serious transnational organized crime that affects sustainable development, communities,
and security, and that sharing information, strengthening enforcement capacity, and regional cooperation are criticalto halting the trafficking. Like the firstregional conference of the Americas onillegal wildlife trade that took place inLima, Peru in October 2019, suchregional commitments to address thepoaching and trafficking of protected
species raise awareness of the seriousness of these crimes and their wideranging impact.

and reduce inflammation.78 Tiger
bone is used in a variety of forms
depending on the location. It issoaked in wine to make tiger wine,
boiled down to make glue or cake,and ground into powder for use inpills, plasters, and other manufactured medicinal products.79 Of these,tiger wine and tiger glue (also known
as cao, in Vietnamese, and gao, in
Chinese) are believed to be the mostsought-after products.80
Tiger bone is traditionally cleaned andfried in oil or vinegar to remove all
flesh and cartilage. It is then groundinto powder and mixed with herbs
to make pills or added to camphor
and menthol to make tiger balm.81
Reported wholesale prices for tiger
bone in South-East Asia ranged
from US$1,200 per kg in 1994, to
US$1,250-3,750 per kg in 2007, toUS$2,260 per kg as of 2014, but
prices vary significantly based on
the source of information used.82
For example, Chinese court records

83BIG CATS

Box 2: South African lion bones
Sport hunting of lions has been a mainstay of some South African private gamereserves for decades. In 1977, African
lions were listed on Appendix II, so
international trade in all lions requires
CITES documentation. As late as 2000,
more than 90 per cent of legally
exported lion trophies worldwide werewild-sourced according to the CITES
Trade Database, 56 but concern aboutwild sourcing as well as the profitabilityof farming other big cats led gameranchers to breed lions for theirreserves. 57 Captive lion populations
made possible the hunting of farmed
and released animals. By 2015, thetotal number of lion trophies exported
had doubled, but 93 per cent of thesetrophies came from farmed animals.58

WORLD WILDLIFE CRIME REPORT 2020

Around 2007, further scrutiny of theadverse effects of trophy hunting on lion
conservation and restrictions on trophy
exports put pressure on game ranchers
to find new outlets for their stock,
including the international sale of lionbones as a supplement to tiger bones inthe trade. These restrictions culminatedin the 2016 United States trophy importban, which significantly affected thesport hunting business in South Africa. A
survey of South African lion breeders
carried out in 2017 revealed that 79 percent of respondents were affected by theUnited States trophy hunting import ban,and that 21 per cent of the respondents
had decided to compensate by focusing
on the lion bone trade. When asked
what they would do if the United States
ban was to remain in place, 52 per centof respondents said they would instead
focus on the lion bone trade.59

considered a substitute for tiger bone oran additional possible ingredient for
medicinal use.61

Thailand), presumably for the creation of products like bone glue
(Figure 6).65

Small scale breeding of tigers has
existed in South Africa since the 1990s,62
but the interest in the bone trade has
spurred growth in this industry.63 The
current tally is 72 facilities with over
450 captive tigers recorded in South
Africa, compared to 363 lion breeding
facilities with over 7,000 captive lions.64

Between 2007 and 2017, about half
the legal live trade, over 80 per cent of
the trophies, and virtually all the skeletons, bones, and bodies of lions were
exported from South Africa.

UNODC fieldwork in South Africa suggests that exporters sometimes illegallycombine tiger bones with lion bone
Lion appears to be the main supplemen- exports, the two being difficult to distintal species for tiger bone at this point guish. Examples of illegal trade in tiger
because there is a plentiful supply from bone from South Africa to Asia haveSouth Africa. According to the CITES been detected. There have also been
Trade Database between 2010 and instances where tiger and lion bone
2018, most legal lion exports fall into coming from legal captive-breeding
facilities in South Africa have been
three categories:
seizedin connection with the same
… Live animals, which are shipped toorganized
criminal group.66
virtually every country in the world,
mostly for circuses and zoos;
A recent CITES study also found indica… Hunting trophies, which are also tions that much of the lion bone legally
exported to many countries, but imported into South-East Asia was thenparticularly to the United States likely being illegally re-exported inter(up until the 2016 ban) and nationally. The same study reported
multiple court cases relating to “tiger
Europe; and,bones” seized from illegal trade in… Skeletons, bones, and bodies which China, which, when tested, turned out toare exported in commercial trade to be lion bones.67 Chinese court records
Southeast Asia (Lao People’s Dem- suggest that lion bones sold as tiger
ocratic Republic, Viet Nam and fetch similar prices.68

Fig. 6

Number of lion skeletons legally exported from South
Africa by importing country (exporter reported data),
2009-2017*

1,600
1,400
1,200

It appears that the first evidence of lionbone use in the production of products 1,000
marketed for medicinal use or tonics in
800
China was found in 2005, when lion
600
bone was listed as an ingredient in
400“bone strengthening wine.”60 It is unclear
whether the consumer was meant to200
notice this change in bone type, given
0that the wine bottle was in the shape of
2009
2010
2011
2012
2013
2014
2015
2016
2017
a tiger and the name of the product
Lao
People's
Democratic
Republic
Thailand
Viet
Nam
Other
remained similar to tiger bone wine,
despite the ingredients listing lion Source: CITES Trade Database.
bone. There is also some debate as to * The drop in exports in 2017 is linked to the South African government setting a quota of 800 skeletons,
whether and/or how much lion bone is but questions remain as to the exact volume of bones exported.

84

Share of reported destination countries for whole tiger equivalents
seized globally, 2007-2018*
Viet Nam
1.1%

France0.9%

Domestic
0.8%

Excluding seizures with unknown
country of destination

Other
3.5%

Thailand
1.8%
China
4.7%

Big Cats

Fig. 7

6

United States ofAmerica
3.5%

Other
20.6%

Lao People's
Democratic Republic
3.5%
Unknown
87.3%

Domestic
6.0%

China
37.1%

Thailand
13.8%
France
6.9%

Viet Nam
8.6%

Source: UNODC World WISE Database* Includes live, bodies, rugs, skins, skulls, skeletons, and trophies. The year 2018 is based on partial data.

indicate prices of about US$1,400 per
kg in 2015 closer to the retail endof the trafficking chain.83 There arethought to be cultural preferences
for certain tiger bone products: useof tiger bone wine is more commonly
associated with Chinese culture, while
use of tiger glue is associated with
Vietnamese culture.84
Tiger wine is produced in several
ways. The Hunan Sanhong Pharmaceutical Company describes one
procedure where tiger bone is crushed
into powder and mixed with sorghum
liquor.85 Other methods include soaking tiger bones in alcohol to produce
tiger stock rather than mixing crushedbone (bones are used for a maximumof three batches in this case). Tiger
wine is sold in East and South-East
Asia for an average of about US$80
for a bottle aged three years, US$155
for six years, and upward of US$290
for an eight-year wine.86 In venues
where tiger wine is consumed for prestige, bottles can range in price from
US$500 to over US$1,000 per bottle.
Tiger glue is a concentrated productmanufactured by boiling the bones
for three to seven days, producing a
red-brown substance that is poured
into a frame to make a gelatinous cakeand cut into bars of approximately

100 grams for sale.87 It is often groundinto powder or scrapings and consumed with alcohol. Tiger glue bars,
weighing about 100 grams, are sold in
Viet Nam for about US$1,000 each.88

law is said to be under review thatwould require all tigers to be registered, with the government surveying
all tiger facilities.93 The result of thesecontrols is that few pharmacies, traditional medicine shops, or wildlife
China is the largest of the three desti- markets now openly carry tiger prodnation markets identified on the basis ucts in Viet Nam.
of seizure records (Figure 7). China
implemented a ban on all domestic The same is happening in Thailand.94
trade of tiger bone in 1993.89 China’s Tiger glue is sold behind closed doors
national medicine standard for using through acquaintances, only to betiger bone in prepared Chinese med- discovered during investigations andicine was annulled, but leopard seizures.95 A large part of the trade,bone was permitted as a substitute.90 though, including the tiger wine andRecently, new regulations concern- live trade, has shifted to online sales
ing tigers have been issued.91 Despite through social media and messagthese regulations, some illegal trade ing apps, like Facebook, Instagram,
continues, as tiger products repeat- Weibo, Taobao, WhatsApp and We
edly appear in seizure cases. But more Chat.96
evidence is needed to understand themagnitude of this trade given the lim- Consumer demand profiles for tiger
ited number of seizure cases where the products have started to change, anddestination is known (16 per cent of new forms of demand are emerging.
seizures).
Instead of health, wealth is becoming
the primary motivation of consumers.
Vietnamese law and regulations allow The switch is from tiger meat and tiger
internal trade in wild or captive-bred wine being consumed only as healthbig cats with a permit from designated products to now also being consumed
authorities (the Provincial People’s as exotic luxury products that demonCommittee, which then reports to strate affluence.97
the Ministry of Agriculture and Rural
Development).92 Based on interviews In Viet Nam, gifts of tiger products
in 2019 in Viet Nam, it appears no were made to obtain respect frompermits have yet been granted. A new others. 71 per cent of those who

85BIG CATS

Box 3: Captive breeding facilities in the United States
Around the world, facilities are established to deal with captive populationsof endangered species for a variety ofreasons, including research, conservation, and entertainment. In the UnitedStates, privately-owned commercial
entertainment facilities (parks, zoos) inseveral states have engaged in breeding
and crossbreeding of big cats, and some
generate over US$1 million per year
while providing opportunities for visitors
to take photos when petting and feeding
cubs.a The presence of cubs is a fundamental ingredient for the commercial
success of these facilities, but also posesa considerable challenge because cubs
are no longer suitable for petting after
age two to three months. To reduce thecosts of maintaining adult tigers, manyare sold, sometimes on the black market
to collectors, unaccredited zoos, or are
killed by their owners.b

the resolution of trade issues. Violationsof AWA are generally handled throughcivil litigation.d The Endangered Species
Act (ESA) does prohibit the sale acrossstates or the international import/exportof listed species and their parts, without
a valid ESA permit or registration under
the Captive-Bred Wildlife Programme.e
Furthermore, the Lacey Act prohibits theimport, export, inter-state commerceand sale of fish, wildlife and plants
taken in violation of international laws
or laws in the country of origin.

The United States Fish and Wildlife Service (USFWS) is responsible for theenforcement of both the ESA and Lacey
Act (in cooperation with other agencies),and it can press criminal charges against
those who violate these laws. The current legislative system makes it difficult
to address crimes related to possession,
captive breeding, and transport of exotic
In the United States, there is no federal wildlife. The agency responsible for thelaw that prohibits the possession and inspections of these wildlife facilities,
sale of big cats and exotic petsc, includ- the USDA, has a clear focus on animal
ing tigers ( Panthera tigris ) and lions welfare rather than on crime investiga( Panthera leo, Panthera leo melano- tions, f while at the same time, thechaita ). The Animal and Plant Health agency responsible for wildlife crime
Inspection Service (APHIS) under the investigations – USFWS – is not signifDepartment of Agriculture (USDA) icantly involved in zoo and other animal
administers the Animal Welfare Act commercial entertainment facility(AWA) by conducting routine, unan- inspections as the possession of exotic
nounced inspections of all entities that species does not fall under its remit.
are registered or licensed under the Recent media coverage about one of theAWA. The focus of these inspections is most popular exotic animal attractions
on the prevention or cessation of inhu- in the United States – the Greatermane treatment of animals, as well asaWORLD WILDLIFE CRIME REPORT 2020

b
c

86

Guynup, S. (2019). Captive tigers in
the U.S. outnumber those in the wild.
It’s a problem. National Geographic Society. (Available at: https://www.nationalgeographic.com/animals/2019/11/
tigers-in-the-united-states-outnumberthose-in-the-wild-feature/).
Ibid.
While there is no federal law, 36 states
ban the ownership of tigers as pets,
but it is possible to obtain a license
for breeders and exhibitors to transfer
and keep big cats. Four states have nolaws on ownership at all, while tenothers require permits. Licenses to run
establishments that own these animals
are issued by Government authorities,
often with requirements for regularinspections to ensure compliance withanimal welfare standards, regulations
for obtaining and disposing of animals, and sanitary and public healthstandards to, for example, avoid diseasetransmission (including zoonoses). See
National Geographic map on state lawsdef

on keeping big cats as pets retrieved
from https://www.nationalgeographic.
com/animals/2019/11/map-shows-tiger-trade-in-united-states-feature/.
U.S. Department of Agriculture. What
we do. (Available at: https://www.usda.
gov/our-agency/about-usda).
United States Fish and Wildlife Service.
Press release: U.S. Fish and Wildlife
Service Strengthens Protections for
Captive Tigers under the Endangered
Species Act (5 April 2016), (available at:https://www.fws.gov/news/ShowNews.
cfm?ref=u.s.-fish-and-wildlife-servicestrengthens-protections-for-captive-tigers-&_ID=35543).
U.S. House of Representatives, 116th
Congress, 1st Session, Report 116107. Agriculture, Rural Development,
Food and Drug Administration, andRelated Agencies Appropriations Bill,
2020. Pg. 28. (Available at: https://www.
congress.gov/ 116/crpt/hrpt107/CRPT116hrpt107.pdf ).

Wynnewood Animal Park (or G.W. Exotic)
in Oklahoma – re-ignited the debate
about the effectiveness of this existing
regulatory system. The attraction owner
was convicted on eight counts of violating the Lacey Act for falsifying wildlife
records and nine counts of violating the
ESA in 2019. g The wildlife offences
included the killing of five tigers, thesale or offer for sale of five tiger cubs ininterstate commerce, and false documentation hiding the sale of nine lions,
three tigers and one lemur. Thesecharges were secondary, however, to themurder-for-hire charges that triggered
the prosecution. They were also limited
to a timeframe spanning only twomonths in 2017 when the facility has
been in operation since 1997 and underinvestigation for the past 10 years,
including for the death of 23 tiger cubsin 2010.
The Big Cat Public Safety Acth has been
introduced in both houses of the UnitedStates Congress. The Act would create an
overarching federal law on ownership of
big cats as pets and would ban public
handling (including cub petting) andprohibit breeding that did not fall under
specifically managed Species Survival
Plani conservation breeding programs.j It
is currently being considered by theUnited States Congress to help control
the possible exploitation of big cat
breeding facilities by organized crimeand other black market actors.

g

h

i

j

U.S. Department of Justice. U.S.
Attorney’s Office, Western District ofOklahoma. Press release. “Joe Exotic”
Sentenced to 22 Years for Murder-Forhire and for Violating the Lacey Act andEndangered Species Act. (22 January2020). (Available at: https://www.
justice.gov/usao-wdok/pr/joe-exoticsentenced-22-years-murder-hire-andviolating-lacey-act-and-endangered).
United States Congress, 116th Congress, 2d Session, H.R. 1380, Report116-430. (Available at: https://www.
congress.gov/bill/116th-congress/housebill/1380/text).
Association of Zoos and Aquariums.
Species Survival Plan Programs. (Available at: https://www.aza.org/species-survival-plan-programs).
Norton, Kara Jamie. (6 April 2020).
The Truth about “Tiger King” and Catsin Captivity. (Available at: https://www.
pbs.org/wnet/nature/blog/the-truthabout-tiger-king-and-cats-in-captivity/).

Table 2

Thai consumers, on the other hand,tended to buy tiger products for
spiritual reasons and because they
believed these products would provide protection (86 per cent),101 withless than half of consumers buying forstatus reasons. These purchases weremainly in the form of spiritual items
and amulets, oftentimes blessed by a
Buddhist monk, despite a strict 2014
prohibition against the use of tiger

parts in amulets from the Sangha
Supreme Council, the governing bodyof the Buddhist order of Thailand.102
This prohibition is in keeping withthe fact that tiger products are notformally included in the Thai traditional medicine practice.103

Big Cats

used tiger products purchased themfor medicinal uses (83 per cent ofpurchases were for tiger glue).98 Purchasers reported buying primarily
for themselves or for close family
in equal proportion, purchasing forfamily members to gain their respect.99
There was also a recent trend toward
using big cat tooth and claw jewellery
among young men, sometimes madeof other species than tiger.100

6

Tiger body parts utilized for healing and preventive medicine in Asia

TIGER DERIVATIVE
Bone plasters
Bone wine
Bone gelatine “cake”/”glue”(cao in Viet Nam)
Penis
Fat
Skins
Claws
Teeth
Whiskers
Eyeballs
Nose
Tail
Brain
Lung
TestesBlood
Bile
StomachGallstones
Meat
Paws
Hair

EXAMPLE USES
Aches and pain, bone and joint conditions (for example, arthritis, rheumatism),
replenish calcium, anti-inflammatory, treat osteoporosis
Aches and pain, bone and joint conditions (for example, arthritis, rheumatism),
replenish calcium, anti-inflammatory, treat osteoporosis, increase sexual
capacity, paralysis
Give strength, arthritis
Increase sexual performance, treat impotence
Vomiting, dog bites, bleeding haemorrhoids, scalp ailments in children
Clothing, magical amulet, trophies, decoration, treat mental illness
Magical amulet, jewellery to ward off common cold
Magical amulet, rabies, asthma, sores on the penis, diabetes
Tooth ache
Epilepsy, malaria, nervousness of fever in children, convulsions, cataract
Epilepsy, children’s convulsions
Skin disease
Decrease laziness, heal pimples
Relieve cancer
Tuberculosis of lymph nodes
Strengthening the constitution and willpower
Convulsions in children
Calming upset stomachs
Weak or watering eyes, abscesses on the hand
Nausea, malaria, improving vitality, tonifying the stomach and spleen
Arthritis, improve general health
Drives away centipedes when burnt

Source: CITES SC70 Doc. 54.1, Annex

87

BIG CATS

Box 4: Cheetahs
Cheetahs (Acinonyx jubatus) are highly
sought-after luxury pets, popular in the
Arabian Peninsula. Despite being listed
on CITES Appendix I since 1975,a seizures of trafficked cheetahs do occur.
World WISE data includes only 19 seizures from 2005-2019, amounting to
65 live seized cheetahs. To account for alack of data, seizure data provided by
the Cheetah Conservation Fund havebeen added to these World WISE seizures. Together, these data provide amore complete picture of the live cheetah trade: 144 live cheetah seizuresfrom 2005 to 2019, accounting for 213
live seized cheetahs.b These numbers do
not include domestic seizures or seizures
for the skin trade, which are some of theadditional threats to the species. The
main countries of origin for these shipments (known in 62 per cent of cases),
were Ethiopia (67 cheetahs) and Somalia (32 cheetahs). The destination for 69
per cent of the seized cheetahs wasabWORLD WILDLIFE CRIME REPORT 2020

c

d

88

Commercial trade in wild cheetahs has
been prohibited since 1975; however,there is an annual export quota inplace for three countries pertaining totrophies and live trade (5 from Botswana, 50 from Namibia and 150 from
Zimbabwe). See CITES Appendix I(available at: https://www.cites.org/eng/
app/appendices.php); UNEP-WCMC,The Species+ website (available at: www.
speciesplus.net).
World WISE data were supplemented
with seizure records provided by the
Cheetah Conservation Fund (CCF).
Only verified seizures with animals
recorded present at CCF safehouses
where included in the analysis. Animals
that died during confiscation and onroute to a safehouse were included.
The source country was known for
71% of these seizures (155 cheetahs)
and the destination was known only
for 18% (38 cheetahs).
Tricorache, P., Nowell, K., Wirth, G.
Mitchell, N., Boast, L.K. and Marker,
L. (2018). Pets and pelts: understanding and combating poaching and trafficking in cheetahs. In. L. Marker, L.K.
Boast & A. Schmidt-Küntzel (Eds.),
Biodiversity of the World: Cheetahs:
Biology and Conservation (pp. 191 –
203). San Diego: Elsevier.
Durant, S., Mitchell, N., Ipavec, A.,
and Groom, R., Acinonyx jubatus. The
IUCN Red List of Threatened Species

unknown, but it is worth noting that ofthese seizures, Somalia (including
Somaliland) seized 111 cheetahs andthe United Arab Emirates seized 53
between 2005 and 2019.
Prices for a live cheetah on the black
market can reach up to US$15,000,
which is 50 times what illegal traders in
Africa receive (anywhere from US$200
to 300).c The survival rate of cheetahs,
both adults and cubs, in the illegal tradeis quite low, between 30 to 52 per cent.d
Juvenile mortality is even higher, as
many as five out of six cubs taken fromthe wild will die before they reach their
final destinatione and many kept as pets
will die due to the fact that most owners
do not know how to properly care forthem, generating an ongoing demand
for new individuals.f Given the ongoingrisks to cheetahs from habitat loss,
human-wildlife conflict, and poaching,
and their significant decline in popula-efg

2015: e.T219A50649567 (2015)(available at: https://www.iucnredlist.
org/species/219/50649567); CITES.
(2014). Interpretation and implementation of the Convention Species
trade and conservation. Illegal Tradein Cheetahs (Acinonyx jubatus). Submitted by the Secretariat. Sixty-fifth
meeting of the Standing Committee
Geneva (Switzerland), 7-11 July 2014.
SC65 Doc. 39 (Rev. 2). Retrieved from:https://cites.org/sites/default/files/eng/com/sc/65/E-SC65-39.pdf
Ferard, E., ‘The success of cheetahs
as pets is threatening the survival of
the species,’ (unofficial translationfrom the French original) Geo, January
2019 (available at: https://www.geo.fr/
environnement/le-succes-des-guepardscomme-animal-de-compagnie-menacelavenir-de-lespece-194274).
Durant et al. 2015, op. cit; Tricorache
et al. 2018, op. cit.
Durant et al., ‘The global decline ofcheetah Acinonyx jubatus and what itmeans for conservation’, Proceedings of
the National Academy of Sciences of theUnited States of America, 114(3), 528533, 2017; Durant, S., Mitchell, N.,
Ipavec, A., and Groom, R., Acinonyx
jubatus. The IUCN Red List of Threatened Species 2015: e.T219A50649567(2015) (available at: https://www.iucnredlist.org/species/219/50649567).

tion from an estimated 14,000 in 1975
to 7,100 in 2016, the illegal trade is asignificant threat.g
At the 70th meeting of the CITES Standing Committee in 2018, Ethiopian,Kenyan and Yemeni authorities notedhthat the illegal trade spans a far wider
range of countries and that its volume islargely underestimated, posing a significant threat to wild populations. i In
2014, experts suspected that someSouth African breeding facilities werelaundering wild-sourced cheetahs as
captive-bred.j In 2016, CITES recognizedthat South African breeding operations
had made significant strides in improving regulations, including requiring
parental DNA as proof of captive-breeding for specimens to be exported as captive-bred. Since then seizures continue tosuggest ongoing illegal trade but data is
scarce on its extent and modus operandi.

h

i

j

CITES Seventieth meeting of theStanding Committee (SC70), Inf. 44,
Supplemental information on illegal
trade in cheetah (acinonyx jubatus),
2018.
CITES (2018a). Report by Kristin
Nowell, CAT, & IUCN SSC Cat
Specialist Group. Implementation of
CITES Decision 17.228: Review of
implementation of
Resolution Conf. 12.5 (Rev. CoP17)
on Conservation of and Trade in Tigers
and Other Appendix-I Asian Big Cats.
Report for the 70th meeting of the
CITES Standing Committee, Sochi,
Russia, October 1-5, 2018; CITES
SC70 Doc 54.1 Annex.
CITES, Interpretation and implementation of the Convention Species trade andconservation: Illegal Trade in Cheetahs(Acinonyx jubatus), SC65 Doc. 39(Rev. 2). (available at: https://cites.
org/sites/default/files/eng/com/sc/65/
E-SC65-39.pdf ); Durant et al. 2015,
op. cit; Marnewick, K., Beckhelling,A., Cilliers, D., Lane, E., Mills, G.,
Herring, K., Caldwell, P., Hall, R., andMeintjes, S., ‘The status of the cheetah in South Africa’, Cat News Special
Issue 3, 22-31, 2007; Klein, R., ‘Status
report for the cheetah in Botswana, Cat
News Special Issue 3, 14–21, 2007.

6

1

2

3

4

5

6
7

8

9

That is, all species of the genus Panthera
including tigers, Asian lions, leopards,
clouded leopards, and snow leopards.
Most Panthera species were placed on
Appendix I in 1975, the exceptions being
lions (Panthera leo) and one subspecies oftiger (Siberian tiger, Panthera tigris tigris,formerly Panthera tigris altaica), which
was later included in 1987. Asian lions(Panthera leo persica) were up-listed to
CITES Appendix I in 1977. Currently
African lions (Panthera leo leo) remain on
CITES Appendix II with an annotation.
CITES also noted the importance ofthe skin trade for tigers, although WorldWISE data does not reflect this. See:
See CITES, Sixty-fifth meeting of theStanding Committee, Interpretationand imple­mentation of the Convention:
Species trade and conservation: Asian big
cats, SC65, Doc. 3, (available at https://cites.org/sites/default/files/eng/com/
sc/65/E-SC65-38.pdf ).
Mulliken, T. and Haywood, M., ‘Recent
data on trade in rhino and tiger products,
1988-1992’, TRAFFIC Bulletin, 14 (3),pp. 99-106, 1994.
CITES, Sixty-fifth meeting of the Standing Committee, Interpretation and implementation of the Convention: Species tradeand conservation: Asian big cats, SC65,
Doc. 38, para. 6.; CITES CoP18, Doc.
71.1., p. 13 (2019), Species specific matters: Asian big cats (Felidae spp.): Report of
the Secretariat.
Goodrich, J., et al., Panthera tigris, The
IUCN Red List of Threatened Species 2015:
e.T15955A50659951 (2015). (Available
at: http://dx.doi.org/10.2305/IUCN.
UK.2015-2.RLTS.T15955A50659951.en).
Ibid.
CITES Seventieth meeting of the Standing Committee, Species specific matters:
Asian big cats (felidae spp.): Report of theSecretariat, SC70, Doc. 51, Annex 4.
CITES Seventieth meeting of the Standing Committee, Review of facilities keeping
Asian big cats (Felidae ssp.) in captivity,
SC70, Doc. 51, Annex 2 (Rev. 1) (available at: https://cites.org/sites/default/files/
eng/com/sc/70/E-SC70-51-A2-R1.pdf ).
In accordance with CITES, Appendix
I animal species bred in captivity forcommercial purposes shall be deemed
to be specimens of species included inAppendix II (see Article VII, paragraph
4, of the Convention). Therefore, tradingin captive bred Appendix I species, suchas big cats, is permitted under CITES. In
2007, however, the CITES Conferenceof the Parties decided that tigers should
not be bred for the purpose of trade in
their parts and derivatives. CITES Decision 14.69, on captive-bred and ranchedspecimens, was directed to the Parties,
especially Appendix I Asian big cat range
States, and reads as follows, “Parties withintensive operations breeding tigers on acommercial scale shall implement measures to restrict the captive population toa level supportive only to conserving wild
tigers; tigers should not be bred for tradein their parts and derivatives.” Violationof this directive does not carry criminal
penalties unless supported by national
legislation. Decision 14.69 is still valid.

10 CITES. Registration of operations thatbreed Appendix-I animal species in captivity
for commercial purposes, Conf. 12.10 (Rev.
CoP15) (available at: https://cites.org/
sites/default/files/document/E-Res-1210-R15.pdf ); CITES Sixty-fifth meetingof the Standing Committee, Review of
implementation of resolution conf. 12.5
(rev COP16) on conservation of and tradein tigers and other appendix-I Asian big cat
species, SC65, Doc. 38, Annex 1, (available at: https://cites.org/sites/default/files/
eng/com/sc/65/E-SC65-38-A01_0.pdf ).
11 Ibid.
12 CITES Fourteenth Meeting of the Conference of the Parties, Summary recordof the 14th session of Committee II, CoP14
Com. II Rep. 14 (Rev. 1), (available at:https://www.cites.org/sites/default/files/
eng/cop/14/rep/E14-Com-II-Rep-14.
pdf ).
13 The CITES Secretariat refers to this misalignment in CITES SC70 Doc. 51 andagain in CITES CoP18 Doc 71.1.
14 Wildlife crime related to CITES tradeviolation is clearly defined by CITES
requirements, but outside trade violations, wildlife crime varies from country
to country and some actions involving
wildlife may be a criminal offence in one
country but not in another. CITES Decision 14.69, on captive-bred and ranchedspecimens, was directed to the Parties,
especially Appendix-I Asian big cat range
States, and reads as follows, “Parties withintensive operations breeding tigers on acommercial scale shall implement measures to restrict the captive population toa level supportive only to conserving wild
tigers; tigers should not be bred for tradein their parts and derivatives.” Violationof this directive does not carry penalties
unless national legislation specificallycriminalizes it.
15 See annex 5 of https://cites.org/
sites/default/files/eng/cop/18/doc/ECoP18-071-01.pdf, paragraph 2 commencing “Legislation and administrative
regulations are in place to regulate themanagement of those facilities and thetrade in those big cats, their products andderivatives originated from them.”
16 Ibid.
17 CITES Secretariat. 2017. Application of
Article XIII in the Lao People’s Democratic Republic. SC69 Doc.29.2.1 (page5-6). (Available at: https://cites.org/sites/
default/files/eng/com/sc/69/ESC69-2902-01.pdf; Wildlife Justice Commission(WJC). 2016. Operation Ambush.
Available at: https://wildlifejustice.org/
wp-ontent/uploads/2016/10/WJCAmbush-Briefing_Public.pdf ).
18 Reference from the intervention of thedelegation of Lao People’s Democratic
Republic at the 17th CoP to CITES,
2016.
19 CITES Secretariat. 2017. Applicationof Article XIII in the Lao People’s Democratic Republic. SC69 Doc.29.2.1
20 UNODC fieldwork, see Methodological
Annex.
21 See Methodological Annex for details.
This lack of regulation increases the riskthat organized crime can profit from the

Big Cats

Endnotes
captive tiger trade as noted by the U.S.
Department of the Treasury when they
sanctioned the Zhao Wei Transnational
Criminal Organization. See U.S. Department of the Treasury. (January 30, 2018).
Treasury sanctions the Zhao Wei Transnational Criminal Organization. (Available
at: https://home.treasury.gov/news/
press-releases/sm0272).
22 Prior to 2016, regulations did not protect
or regulate ownership of hybrid tiger
species, but the United States Fish andWildlife Service has now tightened theseregulations and hybrids must now be
registered as well. U.S. Fish & Wildlife
Service. Questions and answers U.S. captive-bred inter-subspecific crossed or generictigers final rule, (available at:https://www.
fws.gov/home/feature/2016/pdfs/GenericTiger-Final-Rule-FAQs.pdf ”.
23 World Wildlife Fund (WWF), More
Tigers in American Backyards than in theWild, 29 July 2014. (Available at:https://www.worldwildlife.org/stories/
more-tigers-in-american-backyards-thanin-the-wild#).
24 For instance, a resident of New York in2018 admitted during court proceedings
having purchased and exported from theUnited States to Thailand an assortmentof endangered species parts corresponding to a market value of US$150,000(Department of Justice, US Attorney
General Office. 1 August 2018. New YorkMan Sentenced To Prison For Trafficking In
Endangered Lion And Tiger Parts).
25 For example, World WISE contains
seizures of a product known as “Jian Bu
Hu Qian Wan”, which contains nine
ingredients, including “Os Tigris,” aimed
at treating a wide range of maladies. It is
unclear what portion of these seizures istiger bone. Forensic tests of natural supplements in the West have often foundlittle or none of the active ingredientclaimed. See, for example, Newmaster,S. G., Grguric, M., Shanmughanandhan,D., Ramalingam, S. and Ragupathy, S.,‘DNA barcoding detects contaminationand substitution in North American
herbal products’, BMC Medicine, Vol. 11,
p. 222, 2013.
26 Each live tiger, body, skin, skull, skeleton, and trophy was counted as one
tiger. In World WISE, seizures marked
are skeletons are meant to be wholeskeletons meaning that adding skulls inthis analysis is unlikely to double count.
Furthermore, skull seizures make up only
a fraction of cases limiting any risks frompossible double counting. While double
counting with skins and skeletons is also
possible, World WISE data appears tounder-represent skins compared to otherpublic data sources, meaning this possible
duplication would also be limited.
27 Data from EIA’s database of tiger seizures
were included in this sample if cases met
the following criteria: confirmed seizures
with a specific date and location.
28 CITES Seventieth meeting of the Standing Committee, Species specific matters:
Asian big cats (felidae spp.): Report of theSecretariat, SC70, Doc. 51, Annex 4.
29 Other sources report a higher number ofseized tigers over the same period. (See,89

WORLD WILDLIFE CRIME REPORT 2020

BIG CATS

among others, TRAFFIC. 2019. Skin
and Bones: Unresolved. An analysis oftiger seizures from 2000-2018. Available
from: https://www.traffic.org/publications/reports/skin-and-bones-unresolved/;
https://eia-international.org/wildlife/
wildlife-trade-maps/illegal-trade-seizuresasian-big-cats/).
30 CITES. (2019). Species specific matters
Asian big cats (Felidae spp.) Report of theSecretariat. Eighteenth meeting of the Conference of the Parties Colombo (Sri Lanka),
23 May – 3 June 2019. CoP18 Doc. 71.1.
Annex 4. Available at: https://cites.org/
sites/default/files/eng/cop/18/doc/ECoP18-071-01.pdf.
31 According to CITES Seventieth meetingof the Standing Committee, Review offacilities keeping Asian big cats (Felidaessp.) in captivity, SC70, Doc. 51, Annex 2(Rev. 1), there are 309 tigers in captivity
in India.
32 Taweekan, J. and De Guzman, E.,
Consumer research findings on ivory andtiger products in Thailand, info sheet,
USAID, 2018 (available at: https://www.
usaidwildlifeasia.org/resources/reports/
infosheet-thailand-ivory-and-tiger_
4june2018_eng_final.pdf/view).
33 UNODC field work, see Methodological
Annex.
34 UNODC fieldwork, see Methodological
Annex.
35 CITES CoP 14, Doc. 52, Annex 1,
Report on implementing resolution
Conf.12.5 of CITES: Asian big cats, 2007.
36 China State Food and Drug Administration (SFDA), ’Notification on the
management of the use of leopard bones’,
State Food and Drug Administration note
[2006] No. 118, 2006.
37 China Medicinal Science and Technology
Publishing House. 2020. Pharmacopoeiaof the People’s Republic of China, 2020
edition, part 1.
38 CITES (2018a). Report by Kristin
Nowell, CAT and IUCN SSC Cat Specialist Group. Implementation of CITES
Decision 17.228: Review of implementation of Resolution Conf. 12.5 (rev.
CoP17) on Conservation of and Trade in
Tigers and Other Appendix-I Asian Big
Cats. Report for the 70th meeting of
the CITES Standing Committee, Sochi,
Russia, 1-5 October 2018.
39 Coghlan, M.L., Maker, G., Crighton, E.,
Haile, J., Murray, D.C., White, N.E.,
Byard, R.W., Bellgard, M.I. , Mullaney, I.,
Trengove, R., Allcock, R.J.N. ,Nash, C.,
Hoban, C., Jarrett, K., Edwards, R., Musgrave, I.F., and Bunce, M., ’Combined
DNA, toxicological and heavy metal
analyses provides an auditing toolkit toimprove pharmacovigilance of traditional
Chinese medicine (TCM)’, Scientific
Reports, 5(1), pp. 1-9, 2015.
40 Nowell, K., Li, J., Paltsyn, M., Sharma,
R.K. (2016, October). An ounce ofprevention: Snow leopard crime revisited.
TRAFFIC: Cambridge, UK.
41 Theile, S., Fading footsteps: The killing andtrade of snow leopards, TRAFFIC International, 2003; Nowell, K. and Xu, Ling,
Taming the tiger trade: China’s markets forwild and captive tiger products since the901993 domestic trade ban, TRAFFIC East
Asia, 2007.
42 Quigley, H., Foster, R., Petracca, L.,
Payan, E., Salom, R. and Harmsen, B., Panthera onca (errata version
published in 2018), The IUCN Red
List of Threatened Species 2017:
e.T15953A123791436 (Available at:https://dx.doi.org/10.2305/IUCN.UK.
2017-3.RLTS.T15953A50658693.en).
43 CITES decision 18.251. (Available at:https://cites.org/eng/dec/valid17/82250).
44 Adrian Reuter, Leonardo Maffei, John
Polisar, and Jeremy Radachowsky, Jaguar
Hunting and Trafficking in Mesoamerica:
Recent observations. New York: Wildlife
Conservation Society, 2018. Data fromthree countries (Belize, Costa Rica, andPanama) in this study, though, did suggest that a formal international trade may
be emerging.
45 Reuter et al (2018); Berton (2018);
Verheij, P. (2019). An assessment of
wildlife poaching and trafficking in
Bolivia and Suriname. Amsterdam,
Netherlands: IUCN.
46 Reuter et al (2018); Verheij, P. (2019).
47 Morcatty et al (2020). Illegal trade inwild cats and its link to Chinese-led
development in Central and SouthAmerica. Conservation Biology, doi:
10.1111/cobi.13498.
48 Reuter at al (2018).
49 Embassy of the People’s Republic ofChina in the Republic of Suriname.
(2018). Remind Chinese citizens in
Suzhou not to buy or carry wild animal
products such as tiger teeth (Panthera).
(Available from: www.sr.chineseembassy.
org/chn/lsfw/GY216/t1537671.htm);
Consulate General of the People’s Republic of China in Santa Cruz. (2018).
Santa Cruz’s overseas Chinese community
issued a joint statement on the suspectedillegal sale of wild protected animal
products such as jaguars. (Available from:http://santacruz.chineseconsulate.org/
chn/lgdt/t1540116.htm).
50 With a known final destination in Asia as
declared by seizing authorities.
51 Morcatty et al (2020); Verheij, P. (2019).
52 Morcatty et al (2020).
53 The two largest seizures occurred at a
private residence of a Chinese nationalin December 2014 (300 teeth and otherwildlife products) (Ministerio de Medio
Ambiente y Agua (MMAyA). (July 3,2019). Aprehenden a sentenciado por
tráfico ilegal de colmillos de jaguar y lo
trasladan a la cárcel de Mocovi. (Available
from: https://www.mmaya.gob.bo/index.
php/noticias/Aprehenden-a-sentenciadopor-trfico-ilegal-de-colmillos-de-jaguar-ylo-trasladan-a-la-crcel-de-Mocovi-,2413.
html); Choque M. (2015). Mercado
negrode colmillos (Fangs black market).
La Razón. (Available from: http://
www.la-razon.com/suple-mentos/
informe/Mercado-negro-colmillos-informe_0_2254574635.html) and from a
restaurant with owners of Chinese origin
in February 2018 (185 canines, 8 molars,
2 claws and 3 skins) (MMAYA, 2018).
The largest airport seizures occurredin August 2014 at El Alto Airport in

Bolivia (8 packages containing 60 loose
canines, 40 canine necklaces and 2 jars
with canines) on route to China (Verheij,2019) and in 2015 at Beijing CapitalInternational Airport in China (119Jaguar canines and 13 claws) (Beijing
Morning Post, 2015; Verheij, 2019).
Beijing Morning Post. (2015). Man
returned to China with more than 100
American leopard teeth. Beijing Morning
Post. Available from: https://new.qq.com/
cmsn/20160221/20160221001007.
54 Navia (2018); Verheij (2019).
55 Manifiesto “Alianza contra el trafico ilegaldel jaguar.” Signed by the representativesof Argentina, Bolivia, Costa Rica, Ecuador, Paraguay, and Peru with observers
from CITES, UNODC, and INTERPOL on July 25, 2019.
56 CITES Seventieth Meeting of the Standing Committee, Species specific matters:
African lion (Panthera leo): Report of theSecretariat and the animals committee,
SC70 Doc. 54.1, Annex, 2018.
57 Williams, V.L. and ‘t Sas-Rolfes, M.
J., ’Born captive: A survey of the lion
breeding, keeping and hunting industries in South Africa’, PLoS ONE, 14(5),e0217409, 2019.
58 CITES Seventieth Meeting of the Standing Committee, Species specific matters:
African lion (Panthera leo): Report of theSecretariat and the animals committee,
SC70 Doc. 54.1, Annex, 2018.
59 Williams, V.L. and t’ Sas-Rolfes, M.,
South African lion bone trade: A collaborative lion bone research project (Interim
Report 1), South African National Biodiversity Institute, 2017 (available at:https://conservationaction.co.za/wpcontent/uploads/2018/07/2017_InterimReport-1.pdf ).
60 Nowell, K. and Xu, Ling, Taming the tiger
trade: China’s markets for wild and captive
tiger products since the 1993 domestic tradeban, TRAFFIC East Asia, 2007.
61 CITES Seventieth Meeting of the Standing Committee, Species specific matters:
African lion (Panthera leo): Report of theSecretariat and the animals committee,
SC70 Doc. 54.1, 2018.
62 Environmental Investigation Agency(EIA)/Wildlife Protection Society ofIndia (WPSI), Skinning the cat: crimeand politics of the big cat skin trade, 2006;
Nowell, K., Far from a cure: The tiger
trade revisited, TRAFFIC, 2000; Nowell,K. and Xu, Ling, Taming the tiger trade:
China’s markets for wild and captive tiger
products since the 1993 domestic trade ban,
TRAFFIC East Asia, 2007.
63 UNODC fieldwork, see Methodological
Annex.
64 According to the CITES Management
Authority of South Africa as of March
2019.
65 A mismatch exists between reported
export and import records, suggesting a
discrepancy in the recording and possibly
illegality in the legal trade.
66 According to the CITES Management
Authority of South Africa as of March
2019. Also, Bloch, S., ’Alleged key player
in lion bone syndicate in court afterhanding himself over to police’, News24,
27 November 2018.
67 CITES. (2018). African lion (Pantheraleo) - Report of the Secretariat and the Animals Committee. CITES SC70 Doc. 54.1.
68 A 2016 case of lion bone sold as tiger
quoted a price of US$1500 per kg oflion bone (closer to the retail end of thetrafficking chain) compared to genuine
tiger bone sold for US$1400 per kg in2015. China Court Record. 2018. Hekou
Yao Autonomous County People’s Court,
Yunnan Province (2018). First instancejudgment in the case of illegal purchase,transport and sale of precious and endangered wild animals and the products ofprecious and endangered wild animals by
He Jianming and Liang Dilong; China
Judgements Online. 2016. First instancejudgment in the case of illegal purchase,transport and sale of precious and endangered wild animals and the products ofprecious and endangered wild animals
by Zhao Lei and Lao Tongzai. Available
at: http://wenshu.court.gov.cn/content/
content?DocID=369fb126-5e8d-42b0-95
32-5d73f3fc44bf.
69 CITES (2018a). Report by Kristin
Nowell, CAT and IUCN SSC Cat Specialist Group. Implementation of CITES
Decision 17.228: Review of implementation of Resolution Conf. 12.5 (rev.
CoP17) on Conservation of and Trade in
Tigers and Other Appendix-I Asian Big
Cats. Report for the 70th meeting of
the CITES Standing Committee, Sochi,
Russia, 1-5 October 2018.
70 According to the CITES Management
Authority of South Africa as of March
2019. Also, Bloch, S. (2018).
71 Environmental Investigation Agency(EIA), Key features of the Asian Big Cat(ABC) skin and bone trade in China in
2005-2011, November 2011. Discussion
with EIA in late 2019 verified that thisroute is still active.
72 CITES (2018a). Report by Kristin
Nowell, CAT and IUCN SSC Cat Specialist Group. Implementation of CITES
Decision 17.228: Review of implementation of Resolution Conf. 12.5 (rev.
CoP17) on Conservation of and Trade in
Tigers and Other Appendix-I Asian Big
Cats. Report for the 70th meeting of
the CITES Standing Committee, Sochi,
Russia, 1-5 October 2018.
73 Krishnasamy, K. and Stoner, S., Reduced
to skin and bones re-examined: An analysis
of Tiger seizures from 13 range countries
from 2000-2015, TRAFFIC Southeast
Asia Regional Office, 2016.
74 See Figure 22, page 41, of CITES Sixty-fifth meeting of the Standing Committee, Review of implementation of resolution
conf. 12.5 (rev COP16) on conservationof and trade in tigers and other appendix-I
Asian big cat species, SC65, Doc. 38,
Annex 1, (available at: https://cites.org/
sites/default/files/eng/com/sc/65/E-SC6538-A01_0.pdf ).
75 CITES (2018a). Report by Kristin
Nowell, CAT and IUCN SSC Cat Specialist Group. Implementation of CITES
Decision 17.228: Review of implementation of Resolution Conf. 12.5 (rev.
CoP17) on Conservation of and Trade in

Tigers and Other Appendix-I Asian Big
Cats. Report for the 70th meeting of
the CITES Standing Committee, Sochi,
Russia, 1-5 October 2018.
76 CITES (2018a). Report by Kristin
Nowell, CAT and IUCN SSC Cat Specialist Group. Implementation of CITES
Decision 17.228: Review of implementation of Resolution Conf. 12.5 (rev.
CoP17) on Conservation of and Trade in
Tigers and Other Appendix-I Asian Big
Cats. Report for the 70th meeting of
the CITES Standing Committee, Sochi,
Russia, 1-5 October 2018.
77 CITES CoP18, Doc. 71.1., (2019),
Species specific mat­ters: Asian big cats
(Felidae spp.): Report of the Secretariat.
78 Ellis, R., Tiger bone and rhino horn: The
destruction of wildlife for traditional Chinese medicine, Island Press, 2005.
79 Mills, J.A. and Jackson, P., Killed for acure: A review of the worldwide trade intiger bone, TRAFFIC International, 1994;
Nowell, K., Far from a cure: The tiger
trade revisited, TRAFFIC, 2000; Krishnasamy, K. and Stoner, S., Reduced to skinand bones re-examined: An analysis of Tiger
seizures from 13 range countries from 20002015, TRAFFIC Southeast Asia Regional
Office, 2016.
80 CITES Seventieth Meeting of the Standing Committee, Species specific matters:
Asian big cats (Felidae spp.): Report of
the Secretariat, SC70 Doc. 51, Annex 4,
2018.
81 UNODC fieldwork, see Methodological
Annex for details.
82 Ibid.
83 China Judgements Online. 2016. First
instance judgment in the case of illegal
purchase, transport and sale of preciousand endangered wild animals and the
products of precious and endangered wild
animals by Zhao Lei and Lao Tongzai.
(Available at: http://wenshu.court.gov.cn/
content/content?DocID=369fb126-5e8d42b0-9532-5d73f3fc44bf ).
84 CITES Seventieth Meeting of the Standing Committee, Species specific matters:
Asian big cats (Felidae spp.): Report of
the Secretariat, SC70 Doc. 51, Annex 4,
2018; SC70 Doc. 54.1.
85 Hanun Sanhong Pharmaceutical Company Limited, Hanun Sanhong Pharmaceutical Company Limited “True Tiger
Wine” Project: Feasibility Studies Report,
December 2005 (available at: https://eia-international.org/wp-content/uploads/
Sanhong-Real-Tiger-Wine-FeasibilityReport_Eng1.pdf ).
86 UNODC fieldwork, see Methodological
Annex for details.
87 UNODC fieldwork, see Methodological
Annex for details; Krishnasamy, K. andStoner, S., Reduced to skin and bones
re-examined: An analysis of Tiger seizuresfrom 13 range countries from 2000-2015,
TRAFFIC Southeast Asia Regional Office,2016; Nowell, K., Far from a cure: The
tiger trade revisited, TRAFFIC, 2000.
88 UNODC fieldwork, see Methodological
Annex for details.
89 China State Council, Circular of theState Council on banning the trade of

Big Cats

6
rhinoceros horn and tiger bone, 29 May
1993, (Available at: https://sherloc.unodc.
org/res/cld/document/circular-of-thestate-council-on-banning-the-trade-ofrhinoceros-horn-and-tiger-bone_html/
Circular_of_the_State_Council_on_Banning_the_Trade_of_Rhinoceros_Horn_
and_Tiger_Bone.pdf ). See also CITES,
Decisions of the Standing Committee on
Rhinoceroses and Tiger, No. 738, 20 April
1993 (Available at: https://cites.org/sites/
default/files/eng/notif/1993/738.txt).
90 CITES CoP 14, Doc. 52, Annex
1, Report on implementing resolution
Conf.12.5 of CITES: Asian big cats, 2007.
91 Chinese State Council. (October 29,2018). Strict control notice on the operation and utilization of rhino and tiger
and their products. No. 36. (Available
at: http://www.gov.cn/zhengce/content/2018-10/29/content_5335423.htm).
92 Decrees 32/2006, 82/2006 and 160/2013
have governed all aspects of big cat
possession, breeding, trading and law
enforcement in Viet Nam.
93 UNODC fieldwork, see Methodological
Annex for details.
94 UNODC fieldwork in Viet Nam and,Thailand.
95 UNODC fieldwork, see Methodological
Annex for details; Krishnasamy, K. andStoner, S., Reduced to skin and bones
re-examined: An analysis of Tiger seizuresfrom 13 range countries from 2000-2015,
TRAFFIC Southeast Asia Regional Office,2016; CITES SC70 Doc 51 Annex 4.
96 UNODC fieldwork, see Methodological
Annex for details; Indenbaum, R. A., ‘A
rapid assessment of the tiger trade inViet Nam’, TRAFFIC Bulletin, 30(1),pp. 33-36, 2008; International Fund forAnimal Welfare (IFAW), Disrupt: Wildlife
cybercrime - uncovering the scale of online
wildlife trade, 2018; IFAW, Wanted - deador alive: Exposing online wildlife trade,2014.
97 CITES Sixty-fifth meeting of the Standing Committee, Interpretation and implementation of the Convention: Species tradeand conservation: Asian big cats, SC65,
Doc. 38, 2014.
98 TRAFFIC, Tiger product consumers:
Suggested demand reduction messaging,
TRAFFIC Viet Nam Office, July 2019(available at: https://www.traffic.org/site/
assets/files/12254/tiger-product-consumers-web.pdf ).
99 TRAFFIC, Tiger product consumers:
Suggested demand reduction messaging,
TRAFFIC Viet Nam Office, July 2019(available at: https://www.traffic.org/site/
assets/files/12254/tiger-product-consumers-web.pdf ).
100 UNODC fieldwork, see Methodological
Annex for details.
101 Taweekan, J. and De Guzman, E.,
Consumer research findings on ivory andtiger products in Thailand, info sheet,
USAID, 2018 (available at: https://www.
usaidwildlifeasia.org/resources/reports/
infosheet-thailand-ivory-and-tiger_
4june2018_eng_final.pdf/view).
102 UNODC fieldwork; Chokevivat, V. and
Chuthaputti, A., The role of Thai tradi-

91

BIG CATSWORLD WILDLIFE CRIME REPORT 2020

tional medicine in health promotion, Global
Conference on Health Promotion,
Thailand Ministry of Public Health, 2005;
CITES CoP18, Doc. 71.1. (2019), Species
specific matters: Asian big cats
(Felidae spp.): Report of the Secretariat.
103 Chokevivat, V. and Chuthaputti, A., Therole of Thai traditional medicine in healthpromotion, Global Conference on Health
Promotion, Thailand Ministry of Public
Health, 2005.

92

7

EUROPEAN GLASS EELS

Trafficking flow map - European glass eels (2007-2018)*

Map 1

Main trafficking flows basedon adjusted seizures
High volume flow

Low volume flow
Seized live equivalent(million heads)
15
10
5
<1

Trafficking role
Source of shipment
Transit or destinationof shipment

Source: UNODC World WISE Database *The year 2018 is based on partial data.
The boundaries and names shown and the designations used on this map do not imply official endorsement or acceptance by the United Nations.
A dispute exists between the Governments of Argentina and the United Kingdom of Great Britain and Northern Ireland concerning sovereignty over the Falkland Islands (Malvinas).

On 28 October 2019, French customs
officers at Charles de Gaulle Airport
arrested two people on their way to
Kunming, China, because they had
300,000 live glass eels1 in their luggage. Contained in water-filled plasticbags kept cool by frozen water bottles, this contraband weighed 91 kg
and was worth over 100,000 euros.
What these “fish mules” were doing
was illegal because, following a significant decline in the wild population,
European eel (Anguilla anguilla) was
listed in Appendix II of CITES in2009, and the European Union (EU)placed a ban on the import and exportof these eels in 2010. This seizure
represents just one small portion ofa large-scale illicit flow involving
many tons of live, critically endangered European eels smuggled from
Europe to Asia every year.

The first World Wildlife Crime Reportfocused on a different market: illegal
sturgeon caviar. The illicit caviar
market, however, appears to be in
decline. In the 1990s and early 2000s,
seizures of hundreds of kg were made.
While a few large seizures continue tobe made, 2 the volumes seized haveplummeted in recent years. For example, in 2001, over six tons of caviar
were seized, which is more than all thecaviar seized between 2003 and 2017.
While poaching continues in both the
Caspian and Black Sea regions, itappears that the value of the illicit
market has declined over the last two
decades.

The first World Wildlife Crime Reportconcluded that the decline of caviar
trafficking was attributable to twothings: the growth of farmed sturgeon
as a viable alternative and the decline
in wild Caspian sturgeon populations.
While poaching of sturgeon continues
to pose a threat to the remaining wild
population, most of this contrabandappears to be consumed in source
country markets, as very little is seizedinternationally. As a result, this reportfocuses on a different marine species,
European glass eels, where the alternative of captive breeding is not available.

93EUROPEAN GLASS EELSFreshwater eels are one of the mostwidespread marine genera and arepart of the national cuisine in countries around the world. European
eels, like most sturgeons, are diadromous, which means they spend partof their life cycle in saltwater and partin freshwater. While sturgeons spend
most of their lives in saltwater andreturn to the freshwater to breed, eels

do it the other way around, spending most of their lives in rivers andstreams and returning to sea to mate.
Scientists believe that both Europeanand American eel (Anguilla rostrata)
breed in the Sargasso Sea, a calm areaof the North Atlantic bordered byocean currents and home to a characteristic seaweed.3 While this breeding
has never been witnessed, captured

Weight equivalent of European eels seized and numberof European eel seizures (live, fingerlings), 2011-2018*

Fig. 1

6,867.6

Number of eel seizures
Weight of eels seized (in kg)

4,523.7
4,054.5

2,427.0111

2,481.7
66

1,259.0

64

410.1

122.9
2

4

5

2011

2012

2013

13

9

2014

2015

2016

2017

2018*

Source: UNODC World WISE Database* The year 2018 is based on partial data. It is therefore not directly comparable to data from other years.

European eel produced (aquaculture and capture
fisheries) in Europe, 1990-2017

Fig. 220,00017,500metric tons

12,50010,000
7,500
5,000
2,500

Source: FAO

94

2016

2014

2012

2010

2008

2006

2004

2002

2000

1998

1996

1994

1992

0
1990

WORLD WILDLIFE CRIME REPORT 2020

15,000larvae grow increasingly larger radiating from the Sargasso Sea toward theUnited States and European coastlines.4
After riding the Gulf Stream to theEuropean and North African estuaries
over the course of a year or longer, thearriving larvae have matured to theglass eel stage, reaching between six
and eight centimetres in length. Thesejuveniles, referred to as “glass eels”
due to their transparent appearance,
are needed for aquaculture because
adult European eels have never beensuccessfully bred in captivity. Thismeans that, unlike sturgeon caviar,
demand for wild caught eels cannot
be replaced by captive breeding.
And since populations of Japaneseeel (Anguilla japonica), American eel
and European eel are in steep decline,
some of the multi-billion-dollar5 eel
industry appears to have become reliant on poaching.

The legal global eel
marketEel products are legally produced andconsumed in countries around theworld. This legal market is relevant toa discussion of eel trafficking, because
it is largely fed by aquaculture producers who may receive some of theirglass eel stock from illegal sources.
Unlike contraband like street drugs,
there is no back-alley black market
for eel meat products. Rather, similar to some other wildlife products,
legitimate products can be tainted
by illegitimate sources of supply. The
following section describes the parameters and trends of this legal market
and the role European glass eels haveplayed in it.
Adult eels may be caught from rivers
for consumption, but most eels consumed today come from aquaculture.
In 2017, FAO statistics showed thatover 96 per cent of the global eel
supply was from aquaculture.6 As
explained later in this chapter, someof these farming operations make useof illegally taken glass eels.

- -- Anguilla japonica (Japanese eel),8- -- Anguilla rostrata (American eel),9- -- Anguilla bicolor (shortfin eel),10

and- -- Anguilla anguilla (European eel).

According to the IUCN, shortfin
eels are classified as “Near Threatened”, with an uncertain population
trend.11 Both Japanese and Americaneels are “Endangered”, European eelsare ”Critically Endangered”, and all
three species have a declining population trend.12 However, only European
eel is CITES-listed (Appendix II as
of 2009) and, in 2010, the European Union banned all European eel
imports and exports. While sourcing
and trading of other eel species could
be contrary to national fisheries laws,
only European eels are subject tointernational controls, and so they
are the focus of this chapter.

For more than 50 years, stock abundance and fishing yield of Europeaneels have declined by about 5 per centannually, to less than 10 per cent of
their historical levels today.14 In the
1980s, official glass eel catch figures
for Europe exceeded 3,000 tons per
year, but between 2010 and 2016, theofficial catch was less than 60 tons.15
This decline is due to a number offactors, not just overexploitation,16
but the species has been deemed too
vulnerable for international commercial trade from the European Union.
National trade data show that France,
Spain, Portugal and the United Kingdom hosted the primary fisheries forglass eels in the past, and a different
group of countries (particularly the
Netherlands, Denmark and Germany)
grew the glass eels to maturity andprocessed the meat. Today, the Portuguese fishery is strongly restricted,
so most of the legal glass eel catch inEurope comes from the other three
countries:- -- In Spain, the situation is compli-

cated by the fact that the coastal
areas have autonomous status,
so the fishery is regulated locallywith no national quota, and recreational fishing of glass eels for
personal consumption is allowed
in some areas.17

Only the import and export of European eel are banned in the European
Union.13 Production of eel in the EU
for European consumption continues, although at greatly reduced levels
compared to 30 years ago (Figure 2).

Fig. 3

Live eel imports in2018 by importing
region (US$ millions)- -- In France, a national quota is set

CASE STUDY: European glass eels

There are many species of freshwatereel (of the genus Anguilla), but it
appears that just four provide mostof the glass eels for eel aquaculture:7

7(just under 65 tons for 20172018), which is the sum of local
quotas and includes glass eels set
aside for restocking.18- -- In the United Kingdom, there isno national quota, but fishing islimited to the use of hand nets
by a small number of fishers(about 300) operating during a
constrained season in a limited
geographic area.19
The volumes legally fished for Europe
appear to be less than those illegally
exported for aquaculture. Global seizures alone can represent more than
10 per cent of the French national
quota, and have trended upward since2011, the year after the eel export ban
was put in place (Figure 1). Based on
World WISE data, Spain, France andPortugal appear to be the source ofmost of glass eels seized today. Seizure data also show the destinationof these glass eels is also the region
with the highest legal production:
Asia. In 2017, 96 per cent of global
aquaculture eel production took placein Asia.20
Traditionally, Asian eel production
was based on Japanese eel, but
declines in catches have forced theindustry to import glass eels of other

Juvenile eels (Anguilla japonica) legally caught
in Japan (tons), 1957-2017

Fig. 4250

Rest of the world
35
Europe43
Metric tons

200
150
100
50

Source: UN Comtrade

2017

2012

2007

2002

1997

1992

1987

1982

1977

1972

1967

1962

0
1957

Asia
674

Source: Japan Fisheries Agency

95

EUROPEAN GLASS EELS

species. Based on UN Comtradedata, 89 per cent of the world’s live
eel imports (including glass eels) weremade by Asian countries in 2018, particularly Japan, the Republic of Korea
and China (Figure 3). Japan was theleading importer, importing virtually
all its live eels from China.

species of the glass eels on which thisproduction is based has varied overtime. Until exports from the European Union were banned in 2010,
most of the Chinese eel production
was based on European eel (78 percent in 2008-9, see Figure 6). Since
then, there have been limited CITES
certified exports of live European eel
from North Africa, which is within

the range of the European eel but outside the EU export restrictions.
The 2010 EU export restriction triggered a rush for glass eels from othersources. Based on UN Comtrade
import data, it appears that demand
for Chinese aquaculture was satisfied by imports from Malaysia andthe Philippines (presumably shortfin

Metric tons

Nowhere are eels more important asa food source than in Japan, where
unagi kabayaki is popular year-round,
Imports of glass eels into legal aquaculture ponds in
but traditionally eaten by everyone Fig. 6
on the Midsummer Day of the Ox.
China (tons), 2008-2016
Fisheries catches of Japanese eels
(Anguilla japonica) have been steadily
80declining since the 1960s (Figure 4)
70
due to a variety of factors, including
over-exploitation.21 The species has
60
been classified as “Endangered” on
50
the IUCN Red List since 2014.22
Parallel to this decline, export of40
European eels to East Asia began to30
rise steeply in the 1970s.23 According to the CITES Trade database, in20
2009,24 Japan imported 96 per cent of10
the legally traded European eel meat.25
While Japan dominates imports,
0
China dominates aquaculture produc2008-9 2009-10 2010-11 2011-12 2012-13 2013-14 2014-15 2015-16
tion. In 2017, 85 per cent of global
Japanese
European
AmericanShortfineel production by weight occurred in
China (Figure 5). The combination of Source: CITES

Imports of glass eels
into legal aquaculture
ponds in China (tons),
2008-2016

Fig. 5

Legal imports of live glass eels to China by exporting
country (US$ millions), 2001-2018

Fig. 7
25

Japan
8%

Others0%

US$ (millions)

20
Republic of
Korea
4%
Europe3%

15

10Source: FAO

96

2018

2017

2016

2015

2014

2013

2012

2011

2010

2009

2008

2007

2006

2005

2004

2003

0
2002

China
85%

2001

WORLD WILDLIFE CRIME REPORT 2020

5France, Spain, and United Kingdom

Philippines and Malaysia

United States and Canada

Others

Source: UN Comtrade

- -- commercial fishers who catchglass eels for the legal market andknowingly or unknowingly supply
illegal exporters (diversion);- -- poachers, who fish clandestinely
with the intent to supply theillegal market.

For example, European investigations
uncovered a Spanish eel trader who
was working with a Greek eel farm toillegally export large (800 kg) shipments of glass eels to China. The eelswere illegally taken in Spain, transported in trucks to Barcelona, andthen by ferry to Italy and onwards
to Greece, where the legal eel farm
was located.29 This ostensibly legal
farming operation gave cover to both
illegal fishing and illegal export.

CASE STUDY: European glass eelseel) initially, but increasingly from theUnited States and Canada (presumably American eel) (Figure 7). The
shift in demand outside Europe canbe seen, for example, in export dataon American glass eels. In the stateof Maine, the catch quadrupled as
prices increased twenty-fold in three
years, from just under US$100 per
pound (454 g)26 in 2009 to just under
US$2,000 per pound in 2012. The
increase in both price and volume
caused a sharp increase in the total
market size in 2012 (Figure 8). In
2018, renewed demand for American
eel was seen, albeit at lower prices, suggesting a competing source of supply.

7

Established eel traders have beenfound to be involved in illegal exports,
so any commercial fisherman selling
glass eels to a trader could unwittingly
be complicit in illegal exports. Commercial traders can also be involved In parallel, there are also networks
in acquiring glass eels illegally and of poachers who acquire their glassthen further exporting them illegally. eels clandestinely. Based on their

2016

2018

2014

2016

2014

2008

2008

2012

2006

2006

2010

2004

2004

2002

2000

1998

1996

1994

US$ millions

Recorded value of the legal American glass eel fishery
Despite population declines and fluc- Fig. 8
tuations in the source of glass eels,(Anguilla rostrata) in the state of Maine (US$ millions),
global eel production has remained
1994-2018
remarkably consistent over the45
years, driven by rising production in40
China (Figure 9). Although the 201035
ban on exports from the European
Union did cause a slight decline in30
eel production until 2013, produc25
tion again increased after that time,20
reaching a new high in 2016 (Figure
159). Since the total value of recorded
glass eel imports (of all species) by
10
China have declined by half since5
the CITES listing of European eel in02009 (Figure 10),27 it remains unclear
how production is being maintained.
Data on the species input for Chineseaquaculture shows a different pattern Source: Source: State of Maine Department of Marine Resourcesin the sourcing after 2009 (Figure6), with increasing reliance on theFig. 9 Legal aquaculture eel production in China andendangered American eel. Despite
the world (tons), 1996-2016
its “Endangered” status, American
glass eel can still be legally exported
300
without CITES certification.
200

World

2010

2002

2000

1996

2012

EU Trade Ban

150

Based on World WISE data, it
100
appears that it is in the traditionalsource countries that much of the50
illegal glass eel supply originates.
According to high ranking wildlife law
0
enforcement officials interviewed in2018,28 there are two main sources ofEuropean glass eels illegally traffickedinternationally:
Source: FAO

1998

Sourcing

Metric tons

250

China

97

EUROPEAN GLASS EELS

The poachers receive between 180
and 400 euros per kg from buyers,thus receiving up to 400 euro pernight. Some poachers keep tanks intheir homes and sell to buyers fromtheir front door. In some instances,buyers travel to the harvest locations
and consolidate the output of manypoachers, paying cash on the spot.32

Fig. 11

2017

2016

2015

2014

2013

2012

2011

2010

2009

2008

2007

2006

2005

2004

2003

2002

2001

Kilograms of glass eelsknowledge of the timing and loca- Fig. 10 Glass eels (all species) legally imported by China (kg),tion of eel migration, poachers use
2001-2017
hand nets, trap nets or small trawl70,000
ing nets to work the estuaries where
glass eels transit at night. According
60,000to European law enforcement sources,
50,000on average, a poacher can gather
between 200 g and one kg of glass eels
40,000per night, although much larger takes
are possible under the right condi30,000
tions.30 One kg of glass eels represents
20,000
about 3,000 individual fish,31 so eachpoacher can remove between 600 and
10,0003,000 eels for every night of work.
0
The number of poachers is unknown,
but they collectively add to glass eel
shipments measured in the tens andhundreds of kilograms.
Source: UN Comtrade

Price per kg for illegal eels paid to poachers,
traders and importers in 2018 (euros)€ 180 - 300

Poacher€ 400 - 900
Trader€ 800 -1500

WORLD WILDLIFE CRIME REPORT 2020

98

00
16

00
14

00
12

00
10

0

Source: UNODC- -- They are shipped in refrigerated

containers via air freight undercover of, or mis-declared as,other seafood products.
- -- They are smuggled using commercial air couriers in speciallyprepared luggage.

The two trafficking techniques roughly
correspond to the two forms of illegal sourcing (diversion and poaching),
although it is entirely possible thateels sourced from poaching could be
shipped using cover loads, or thatdiverted eels could be smuggled by
Based on World WISE data and inter- couriers.
views with law enforcement officials,
glass eels are smuggled using two To be transported internationally andmain techniques:arrive alive, glass eels must be kept
in controlled conditions and released

Trafficking

80

0
60

0
40

20

0

Importer0

After the glass eels are collected fromthe poachers or licensed collectors,
they are transported to consolidation facilities, often located nearinternational airports. These facilities
generally include a series of aerated
tanks in which the glass eels are stored;
typically, about 20 kg of glass eels are
put into oxygenated water tanks with
about 1,000 litres of water. To ensure
the highest survival rates, the eels are
kept in these conditions no longer
than 15 days, so the exports should
be closely tied to the harvest season.
At these facilities, the local buyers arepaid between 400 and 900 euros per
kg by those who traffic the glass eelsinternationally.33

as quickly as possible. Containers
suitable for transporting other live
seafood can be used in airfreight, so
mislabelling (as shrimp, mussels, or
octopi, for example) or concealing
the eels in these containers containing
other forms of live seafood is common
practice.
Air couriers make use of luggage containing bags of glass eels in addition
to some form of refrigeration, typically frozen bottles of water. Thisluggage may be shielded with inexpensive insulation material, such as
car windshield sun protectors. Raidson consolidation sites have revealed
hundreds of identical suitcases used
for this purpose. The longer the flight,
the fewer glass eels will survive theEnforcement activities associated with
Europol’s Operation Lake (20172019) uncovered a new variation intrafficking method, in which glass eels
are hidden in Styrofoam ice chests
that are packed in checked luggage.
European eel was also detected inEuropean consumer markets mislabelled as American eel. In connection
with Operation Lake, some 3.8 tonsof European glass eels were seized in
the 2017-2018 season and 5.8 tons in
2018-2019.34 Speaking of the 20172018 season, Europol estimated thataround 100 tons were smuggled fromthe European Union to China.35
Seizures of European glass eels haveincreased from an annual average ofless than 1.5 metric tons in the first
four years of the European Union ban

Fig. 12 Number of people
arrested for European
glass eel trafficking
in Spain by citizenship, 2016-2018
Morocco3

to an average of just under 5.5 tons
in the last four years. Considerable
resources were applied to interdiction,and this trend is surely affected bythese dedicated efforts. Some 80 per
cent of these seizures were made by
the governments of Spain, France andPortugal, the origins of almost all theeels seized. To put this figure in context, these seizures are equivalent toabout 10 per cent of the total supplyof glass eels introduced into aquaculture in major producer states.36
Of those seizures whose destination
was known between 2011-2018, morethan half were destined for China and19 per cent for Thailand. Thailand
does export hundreds of tons of eels
every year, but this is about 1 per centof what China exports, so some shareof these is likely trans-shipped. Thosearrested in connection with theseseizures represent a mix of Europeanand Asian citizenships (Figure 12).
Of intercepted shipments, the mostcommon destination was Hong Kong,
China, which is located near the largest eel farms, located in the provincesof Guangdong and Fujian. Genetic
testing has proven that European eel
are smuggled from Europe to Hong
Kong, China.37

China
29

Source: SEPRONA response to UNODC
questionnaire

On arrival in Asia, it appears theillicitly exported European glass eels
are fed into the commercial eel farming industry. According to the Foodand Agriculture Organization of theUnited Nations (FAO), in 2017 some
259,000 tons of eel (all species) were
produced, of which about 221,000
tons were produced by China,accounting for 85 per cent of global
production.38 According to the China
Eel Industrial Association, more thanhalf of this is exported, with the restfor domestic consumption. Much of
the exports are destined for the Japanese market, but also to the UnitedStates and other destinations aroundthe world.
From the 1970s to the 1990s, live
eels imported by Japan mainly camefrom Taiwan, Province of China,39but eel production gradually moved
to the southern provinces of mainland
China, predominantly Guangdong
and Fujian, which have been responsible for about 86 per cent of Chinese
production in recent years. Before
the European glass eel export ban in
2010, Fujian production was focusedon European eel.40 Once imported,

Fig. 13 Share of total seizure volume by reported shipment
destination, 2011-2018*
Spain
1.4%
Viet Nam
2.3%
Thailand
7.7%

Hungary
0.8%

Russian Federation
0.8%

Excluding seizures with unknown
final destination

Other
1.9%
Hungary
2.0%
Spain
3.6%
Viet Nam
5.6%

Spain
4
Malaysia
4

Destination markets

CASE STUDY: European glass eels

trip, so direct flights are likely to befavoured, unless a secondary staging area is used. In the latter case,
European, North African and other
Asian countries are used for transit toAsia. Upon arrival, the traffickers arepaid between 800 and 1,500 euros
per kg for the contraband. In effect,each buyer in the initial stages of the
supply chain doubles or triples theirmoney.

7

China
25.6%

Unknown
59.5%

RussianFederation
2.0%

Thailand
19.0%

Other
4.6%

China
63.2%

Source: UNODC World WISE Database* The year 2018 is based on partial data.

99

EUROPEAN GLASS EELS

despite starting out larger than other unwittingly contract with an overseas
species, it takes between 18 and glass eel supplier who illegally sources
36 months to grow European glass European glass eel.
eels to marketable size (400 to 500
grams for export, or 600 grams for the Aside from the seizure record, one way
domestic market), making them one of estimating the amount of illegal eelof the slowest growing species of eels, introduced into legal supply chainsaccording to the Chinese Industrial is to compare the amounts of glass
Eel Association.41
eels of all species imported and theamounts of adult eels produced. In
The Chinese Bureau of Fisheries the case of China, this analysis is comreported that there were 797 eel plicated by the fact that the country
aquaculture operators in 2017.42 In is within the range of Japanese eel
2013, the United Nations Indus- and could, in theory, supply most oftrial Development Organization the aquaculture demand for glass eels
(UNIDO) produced a study focused from this source. In practice, howon an eel processing company (Firm ever, this has not been the case. Rather,Y) from the Guangdong province. The glass eels from a variety of species arecompany employed 200 workers and used in Chinese aquaculture, while
procured live eels from 16 different China exports about half the Japanesesuppliers to produce 10,000 tons of glass eel it catches. Between 2008 andoutput per year.43 The sheer volume 2016, China exported roughly halfof production, the number of firms the Japanese glass eel it caught.44 As
involved, and the complexity of the a result, only one-third of aquaculsupply chain makes this industry vul- ture demand for glass eels between
nerable to the introduction of illicit between 2008-09 and 2015-16 camesources of supply. For example, any of from domestic sources, leaving thethe 797 aquaculture operators could industry two-thirds dependent on
imports.

Fig. 14 Share of legal exports of prepared orpreserved eels (allspecies), whole or inpieces (excluding
minced), from China
by destination country
or territory, 20142018 (metric tons)

but stark changes between glass eel
imports and production (taking into
account utilization of domesticallycaught Anguilla japonica) suggest an
undocumented source of glass eel
supply. This supply need not be ofEuropean eel, but the fact that theseascribed imports of glass eels are notrecorded raises suspicions about their
origins.
Between 1995 and 2000, China’sreported production amounts toan average of about 1.5 tons of eel
for every kg of glass eel imported.
Between 2001 and 2008, this figurerose to about 4.5 tons of eel for every
kg of glass eel imported. From 2009
(the year of the CITES listing) to2015, the figure rose to an average ofalmost 15 tons of eel for every kg ofglass eel imported. Even considering
the likelihood that eel growing technology has improved, mortality rates
in transit and production will havedecreased and that domestic sourcing of glass eels may have increased,
this tenfold rise is difficult to explain,
whatever the yield of the species introduced.

With this in mind, it is difficult toreconcile reported imports of glass While there are often discrepancies ineels with total eel production and trade statistics, there are stark differexports over time. Of course, glass ences between the data presented byeels of any species can be utilised, CITES, UN Comtrade and Eurostat.45

Fig. 15 Kilograms of adult eel produced in China for every
kilogram of glass eel imported, 1995-2015
20,000

Others
21,883

Russia15,814
USA
24,194

Japan
94,66516,00014,00012,00010,000
8,000
6,000
4,000
2,000

Source: ITC Trade Map.

100

Source: China Customs for imports, FAO for production

2015

2013

2011

2009

2007

2005

2003

2001

1999

1997

0
1995

WORLD WILDLIFE CRIME REPORT 2020

TaiwanPO China
10,893kilograms of eel production per
kilogram of glass eel input

18,000Hong Kong
SAR China
6,246

Analysis
Thousands of kg of European glass
eels have been seized since 2012,
representing millions of individual
eels. It is unclear what share of thetotal illegal flow is interdicted, but
law enforcement surveillance andintelligence suggest the share is relatively low. For example, one operation
seized less than 500 kg of eels froma group that evidence later suggested
had exported more than ten times
that amount.46

production, but this would only bepossible if all European eel meat were
exported and none retained for thedomestic market. Additional, thoughincomplete, data reported to the
CITES Animals Committee suggestthat only 4.5 tons of European glass
eels may have been introduced into
Chinese cultivation ponds between
2011 and 2017.47 Teamed with theseizure data, which indicate themajority of intercepted shipments
were destined for China, these trade
data provide evidence of a sizable
illegal flow.

out. Interviews with aquaculture specialists indicate that one kilogram ofEuropean glass eels yields 750 kg of
filet. If so, it should be possible to reconcile glass eel imports with eel meat
exports. Even taking into account the
gap between introduction and harvest,
it is unclear how such large exports ofEuropean eel meat would be possible
given the low quantities of reported
European glass eel imports (Figure17). This suggests that glass eelswere imported without CITES certification. In 2017, eel meat exports
were commensurable with expected

CASE STUDY: European glass eels

Comparison is complicated by thevery wide range of codes used todescribe eels and eel products in trade:
72 different, partly overlapping, codes
were identified in this study. In theabsence of evidence of illegal trade,
it would be difficult to ascribe significance to the discrepancies, but whentaken in context, they appear to beevidence that the industry is affectedby some unrecorded supply.

7

Fig. 16 Transformation of European glass eels to eel filet
One kilogram
glass eels

900g

750 kgof fillet

about 3000

survive to

1,215 kg of

Metric tons

glass eels
destination
adult eels
The volume and value of this trade isthus difficult to estimate. The 6,000
kg of glass eels seized in 2018 alone
Importer costs:
Wholesale value:
would have been worth up to nine
€ 1,500€ 9,000
million euros to importers. According to law enforcement sources Source: UNODC
interviewed by UNODC, records
seized from a criminal group as evidence suggest that similar volumes
are shipped by individual groups Fig. 17 Comparison of European glass eel imports, expected
production, and legal European eel meat exports reported
annually. Of course, the glass eels are
only the front end of the production
by China (tons), 2009-2017 aggregatedprocess. Each kg of glass eels, cost50,000
ing 1,500 euros on the black market,
46,011can be converted into some 9,000
euros worth of filet on a wholesale
40,000level, thus enriching businesses who
use trafficked eels in their production
28,15430,000process. Wholesalers do not pocket
all this money, of course, since the
20,000costs of farming must be taken into
account, but given the volumes, theprofits appear considerable.
10,000At this point in time, every European
38
0glass eel imported for the purposes ofReported imports
farming requires a CITES certificate
of glass eels
to export, as should every adult European eel exported after being grown Source: CITES Trade Database

Expected
production

Exportsof meat101

EUROPEAN GLASS EELS

Box 1. Sea cucumbers
Sea cucumbers have important functions
within marine ecosystems; they are considered the ‘ocean’s vacuum cleaners’aand important for the overall health ofthe ocean.b They are harvested primarily
as a food,c and are considered a delicacy in their processed form, known as
bêche-de-mer, trepang or hai-som.d Sea
cucumbers’ emergence as a luxury food
item in the 1980s has since expanded
into a highly lucrative market, e withdemand for hundreds of thousands oftons annually.

1.6 million MT, with China accounting
for 99 per cent of this production.k
While there are approximately 1,500
species of sea cucumbers, only 42l wereidentified in the first half of the 2000s
as being under population stress due todemand for international trade.m While
price varies considerably by species, nthey can reach US$1,800 per kg.o The
value and demand for sea cucumbers
appear to be increasing in recent years.p

In 2002, the Parties to CITES started toconsider whether a listing on any of the
CITES Appendices would be appropriate
To meet this demand, capture fisheriesf for some of the most harvested wild speq
have grown, and aquaculture has also cies. In 2003, Ecuador decided to list
expanded exponentially, surpassing one species, the Brown sea cucumberrcapture production in 2003. Global cap- ( Isostichopus fuscus) on Appendix III,
ture fisheries increased from 4,300 tons and at the 18th meeting of the Conferin 1950 to 53,000 MT in 2017; aqua- ence of the Parties to CITES in 2019,culture production rose from virtually three species of sea cucumbers (Holothuzero in 2002 to 222,000 MT in 2017 ria fuscogilva, Holothuria nobilis and(Figure 18), with an estimated value of Holothuria whitmaei ) were listed inAppendix II.s
US$1.4 billion.g
illegalSea cucumber capture fisheries are Similar to other capture fisheries,tfishingforsea
cucumbers
is
a
known
important for the livelihoods of coastal
communities across a wide range of threat, either perpetrated by sourceu
countries, and, in some regions, is the country nationals or by foreign vessels.
most economically important fishery. i Local fishermen are offered high prices
Ten countries accounted for 87 per cent and pressured to poach by internationalof global capture production in 2018: buyers, which often leaves fishermen in
Canada, Iceland, Indonesia, Japan, a ‘loan-to-debt’ cycle, where buyers will
Mexico, Nicaragua, Republic of Korea, provide cash advances for harvesting but
the Russian Federation, Sri Lanka and then buy fishermen’s catch at low prices,
the United States of America. j In con- requiring them to pay back part of the
trast, aquaculture is dominated by one advance orv overfish to compensate forcountry: global aquaculture production low prices.
from 2008 to 2017 was estimated to be

Fig. 18 Global production of sea cucumbers, live weight (tons),
1950 to 2017
225,000
Live weight in tons

175,000
150,000
125,000

Capture production (live weight)
Orginal
Excel?

Aquaculture production (live weight)

75,00050,00025,000Fig. 19 Reported countryof origin of sea
cucumber seizures(by estimatedmass in kg),
2008 - 2017

���Nicaragua
6%

Ecuador
2%

Canada21%0

Source: Data obtained from FAO FishStatJ. Data presented in live weight;
no conversions applied.h102

Although transnational organized crime
involvement in illegal fishing is hard toquantify, strong anecdotal evidence suggests that sophisticated trafficking networks target totoaba fish, abalone, andsea cucumbers, among other marine
species.x In a notable case in the UnitedStates, in March 2018, an Arizona firm
and two of its executives pleaded guilty
to illegal trafficking in US$17 million
worth of sea cucumber from Mexico from2010-2012. They were further charged
with conspiracy to illegally export sea
cucumber to Asia by means of documents containing false information,
importation contrary to the law andfalse labelling. They were sentenced to
pay over US$1.2 million in fines, forfeiture and restitution.y

Others1%

Unknown
15%

100,000

1950
1953
1956
1959
1962
1965
1968
1971
1974
1977
1980
1983
1986
1989
1992
1995
1998
2001
2004
2007
2010
2013
2016

WORLD WILDLIFE CRIME REPORT 2020

200,000

Data on illicit trade is quite limited.
World WISE has data for CITES-listed
species (Isostichopus fuscus), and a few
seizures for non-CITES listed species. For
the period between 2008 and 2017,
World WISE contains seizures accounting for approximately 139 tons (wetweight, 365,000 live equivalents) ofBrown sea cucumbers (Isostichopus fuscus).w The majority of sea cucumber seizures in World WISE appear to becoming from Mexico with almost a third(29 per cent) headed for the UnitedStates, where the seizures were made.

Mexico56%

Source: UNODC World WISE Database

a

b

c

d

e
f

g

h

Purcell et al. (2016) Ecological Rolesof Exploited Sea Cucumbers. Retrieved
from https://www.researchgate.net/publication/311234596_Ecological_Roles_of_
Exploited_Sea_Cucumbers
National Geographic, 30 August 2018.
https://www.nationalgeographic.com.au/
animals/watch-sea-cucumbers-are-theoceans-vacuum-cleaners.aspx
To a lesser extent, they are also used for
traditional medicines, as well as cosmetic, pharmaceutical, aquaria, and biomedical research purposes. See CITES.
(2002b). Trade in sea cucumbers in thefamilies Holothuriidae and Stichopodidae. Twelfth meeting of the Conferenceof the Parties Santiago (Chile), 3-15
November 2002. CoP12. Doc. 45
Annex; CITES. (2007a). Biological andtrade status of sea cucumbers in thefamilies Holothuriidae and Stichopodidae. Report by Verónica Toral-Granda,
Charles Darwin Foundation. Fourteenthmeeting of the Conference of the Parties.
The Hague (Netherlands), 3-15 June
2007. CoP14 Doc. 62 Annex 1; CITES.
(2019a). Consideration of proposals
for amendment of appendices I and II.
Eighteenth meeting of the Conference of
the Parties Geneva (Switzerland), 17-28
August 2019. CoP18 Prop. 45 (Rev. 1);
Conand, C. (2006). Harvest and trade:
Utilization of sea cucumbers; sea cucumbers fisheries trade; current international
trade, illegal, unreported and unregulatedtrade; bycatch, socio-economic characteristics of the trade in sea cucumbers.
In: Bruckner A (editor) The Proceedingsof the CoP18 Prop. 45 (Rev. 1) – p. 20
Technical workshop on the conservation of sea cucumbers in the families
Holothuridae and Stichopodidae. NOAA
Technical Memorandum NMFS-OPR
44, Silver Spring, 239 pp; Toral-Granda,
V., Lovatelli, A., Vasconcellos, M. (eds).
(2008). Sea cucumbers. A global review
of fisheries and trade. FAO Fisheries andAquaculture Technical Paper. No. 516.
Rome, FAO. 317p.
Conand, 2006; CITES, 2002b; 2019a;
Toral-Granda et al., 2008; Purcell, S.W.
(2010). Managing sea cucumber fisheries
with an ecosystem approach. Edited/compiled by Lovatelli, A.; M. Vasconcellos and Y. Yimin. (2010). FAO Fisheries
and Aquaculture Technical Paper. No.
520. Rome, FAO. 157p.
CITES, 2002b; 2019a.
Capture fisheries refer to harvesting of
naturally occurring living resources (wildfish catches), which can be in marine or
freshwater environments. Aquaculture is
the farming of aquatic organisms.
Based on live weight for sea cucumber
and Japanese sea cucumbers. FAO.
(2019a). Fishery and Aquaculture Statistics. Global aquaculture production
1950-2017 (FishstatJ). In: FAO Fisheries
and Aquaculture Department [online].
Rome. Updated 2019. www.fao.org/fishery/statistics/software/fishstatj/en.
FAO presented sea cucumber and Japanese sea cucumbers data in live weight.
FAO, 2019a; 2019b; Data obtained fromFAO FishStatJ, collected since 1950,

were presented in live weight, while inprevious years FAO data was presented
in dried weight. This made it difficult
to compare with prior studies on sea
cucumbers which used also used FAO
data, but where the unit of measurement
was different.
i Conand, 2006; Toral-Granda et al.,
2008.
j FAO, 2019b.
k FAO, 2019a.
l Belonging to the families Stichopodidae,
Holothuriidae and some in Cucumariidae(Purcell, 2010; CITES, 2007a).
m CITES, 2007a.
n Conand, 2006.
o M. Fabinyi, K. Barclay & H. Eriksson(2017). Chinese trader perceptions on
sourcing and consumption of endangered seafood. Frontiers in Marine
Science, 181: 1-12; Purcell, S.W., Williamson, D.H., and Ngaluafe, P. (2018).
Chinese market prices of beche-de-merImplications for fisheries and aquaculture. Marine Policy. 91: 58-65.
p Purcell et al., 2018.
q At CoP12, the US submitted a background document on sea cucumbers,
specifically on the families Holothuridae
and Stichopodidae to highlight exploitation and trade concerns and consider
a CITES listing. While a proposal was
not put forward, decisions were taken at
CoP12 to evaluate these unlisted species,
since they were subject to significant
international trade, and determine
whether they would qualify and benefit
from a CITES listing (CITES Decisions
12.60 and 12.61 refers to a technicalworkshop and preparation of a discussion document on the biological andtrade status of the species). At CoP13,
CITES Decision 13.48 and 13.49 wereadopted (to review the proceedings of
the workshop, extend the deadline forthe preparation of the discussion document, and to assist in raising funds
for the development of the discussion
paper). CITES, 2002b; CITES, 2007a;
CITES. (2002a). CITES Decisions.
Decisions of the Conference of the Parties to CITES in effect after the 12th
meeting. Retrieved from: https://cites.
org/sites/default/files/eng/dec/valid13/
E12-Dec.pdf; CITES. (2007b). Interpretation and implementation of theConvention. Species trade and conservation issues Sea cucumbers. Fourteenthmeeting of the Conference of the Parties.
The Hague (Netherlands), 3-15 June
2007. CoP14 Doc. 62. CITES. (2004).
CITES Decisions. Decisions of the Conference of the Parties to CITES in effectafter the 13th meeting. Retrieved from:https://cites.org/sites/default/files/eng/
dec/valid13/E13-Dec.pdf.
r UNEP. (2019). The Species+ Website.
Nairobi, Kenya. Compiled by UNEPWCMC, Cambridge, UK. Available
at: www.speciesplus.net. [Accessed
21/08/2019].
s This listing took effect on 28 Aug 2020.
CITES, 2019b. Summary record of thetwelfth session for Committee I. CoP18

t

u
v
w

x

y

CASE STUDY: European glass eels

7
Com I. Rec. 12. Eighteenth meeting of
the Conference of the Parties Geneva(Switzerland), 17-28 August 2019.
As defined by CITES, “illegal Holothurian fisheries are characterized by:1) poaching and exports by nationals
in remote areas, marine protected areas,
the use of illicit devices, the existence ofdifferent regulations between regions ofa country and 2) poaching and exportingby foreigners in the majority of casesby temporary bandits ‘poach and go’,
Chinese entrepreneurs, in remote areas,
countries with low regulations, poor
countries.” (CITES CoP18 Prop45, p.
12). This is however not necessary fittingwith the FAO definition so I would suggest to be more general.
CITES, 2007a; CITES, 2019a.
Ibid.
Based on live sea cucumbers and bodies.
WorldWISE recorded 99,839 kg(converted to wet weight) or a total of272,543 live equivalents of Isostichopus
fuscus from 2008 to 2017. An additional
100,226 sea cucumbers with no description were also reported, so it is impossible to determine if they were fresh/frozen
or dried, but they would be equivalent toapproximately 38,703kg (wet weight).
Bergenas, J. (2016). Fish crime: What dothe numbers say? Retrieved from: https://www.stimson.org/2016/fish-crime-whatdo-numbers-say/.
https://www.justice.gov/usao-sdca/pr/
illegal-sea-cucumber-trade-nets-more-12million-dollars-fines-forfeiture-and103

EUROPEAN GLASS EELSWORLD WILDLIFE CRIME REPORT 2020

Endnotes
1 A juvenile eel is approximately six to eight
centimeters in length and with a transparent appearance. See https://www.scmp.
com/news/world/europe/article/3035646/
chinese-man-and-woman-caught-francesmuggling-60kg-live-baby-eels
2 Based on World WISE data. There are
frequent small seizures of non-compliant
caviar in Europe, as well as seizures of“caviar” face creams without CITES documentation. Some larger-scale internationaltrafficking does continue, however, but
not from the Caspian. For example, in
2017, the United States made two large
seizures (71 and 30 kg) of kaluga caviar
shipped from China. In addition, there
have been some very large seizures of sturgeon meat, including 14 metric tons seizedin Genoa harbour on its way to Georgia in
2016.
3 General facts on eel biology and reproduction can be found in Tesch, F.-W., The Eel(Fifth Edition), Oxford: Wiley, 2003.
4 Ibid.
5 According to Food and Agriculture Organization of the United Nations (FAO), Fisheries Global Information System (FIGIS),
global river eel aquaculture was worth
US$2,042,180,000 in 2017. The retailtrade is necessarily worth significantly
more (FIGIS is available at:
http://www.fao.org/fishery/figis/en).
6 FAO FIGIS (ibid.). That is, about
260,000 metric tons out of about 270,000 metric tons globally.
7 This is based on data of the species introduced into aquaculture in the largest eel
producer countries, as shared in the TenthMeeting of the Informal Consultation
on International Cooperation for Conservation and Management of Japanese
Eel Stock and Other Relevant Eel Species(CITES AC29 Inf. 13). FAO does gather
species-specific eel production data but
it does not appear to be accurate in lightof the data presented at this meeting, as
it suggests the vast bulk of eel production
since 1970 was based on Japanese eel. It
does suggest, however, that a wider rangeof eels have been used in production,
including the use of speckled longfin eel(Anguilla reinhardtii) in Oceania. This
species, however, accounted for less than
two-tenths of one per cent of Oceania eel
production between 1952 and 2017.
8 According to the International Union forConservation of Nature (IUCN), Japanese
eel is only found in China (including
Taiwan Province of China), Japan, thePhilippines and the Republic of Korea.
See Jacoby, D. & Gollock, M., Anguillajaponica, The IUCN Red List of Threatened Species 2014: e.T166184A1117791,
2014 (available at: http://dx.doi.
org/10.2305/IUCN.UK.2014-1.RLTS.
T166184A1117791.en).
9 According to the IUCN, American eel isfound throughout Central America andthe Caribbean, as well as in the Bolivarian
Republic of Venezuela, Canada, Colombia, Greenland and the United States.
See Jacoby, D., Casselman, J., DeLucia,
M. and Gollock, M., Anguilla rostrata(amended version of 2014 assessment).
The IUCN Red List of Threatened
Species 2017: e.T191108A121739077,

1042017 (available at: http://dx.doi.
org/10.2305/IUCN.UK.2017-3.RLTS.
T191108A121739077.en).
10 According to the IUCN, shortfin eel isfound in Australia, Bangladesh, Federated
States of Micronesia, India, Indonesia(Sulawesi, Lesser Sunda Island, Java),
Kenya, Madagascar, Maldives, Mozambique, Myanmar, Northern Mariana
Islands, Oman, Papua New Guinea,
Philippines, Somalia, South Africa, Sri
Lanka, United Republic of Tanzania, Viet
Nam and Yemen (Socotra). See Jacoby, D.,
Harrison, I.J. and Gollock, M., Anguillabicolor. The IUCN Red List of Threatened
Species 2014: e.T166894A67015710,
2014 (available at: http://dx.doi.
org/10.2305/IUCN.UK.2014-1.RLTS.
T166894A67015710.en).
11 Possibly due to its very wide range – see
the reference above.
12 See references above.
13 European eel is also produced in North
Africa, but at a lower rate than in Europe.
For example, in 2017, just over 1000 MT
of European eel was produced in Africa,
compare to over 8000 MT in Europe.
14 Dekker, W., ‘The history of commercial
fisheries for European eel commenced
only a century ago.’ Fisheries Managementand Ecology, Vol. 26, pp. 6-19, 2019;
International Council for the Explorationof the Sea (ICES), Report of the Joint
EIFACC/ ICES /GFCM Working Groupon Eel, 3 - 10 October 2017, ICES CM
2017/ACOM:15.
15 International Council for the Explorationof the Sea (ICES), Report of the Joint
EIFACC/ ICES /GFCM Working Groupon Eel, 3 - 10 October 2017, ICES CM
2017/ACOM:15, pp. 32-33.
16 Contributing factors may include changing oceanic conditions, migration barriers,
predation, pollution, disease and parasites. See Miller, M. J., Feunteun, E. andTsukamoto, K., ‘Did a “perfect storm” ofoceanic changes and continental anthropogenic impacts cause northern hemisphere anguillid recruitment reductions?’,
ICES Journal of Marine Science: Journal duConseil, Vol. 73, No. 1, pp. 43-56, 2016.
17 Based on responses to a UNODC questionnaire administered to law enforcement
officials in 2018.
18 This total is more than twice that needed
for restocking and eel aquaculture on
a European level (estimated at 30 metrictons).
19 Based on responses to a UNODC questionnaire administered to law enforcement
officials in 2018.
20 FAO FIGIS, op.cit. That is, about
260,000 metric tons out of about 270,000(?) metric tons globally.
21 According to the IUCN, “Threats tothis species include overfishing, loss ofhabitat and changes to oceanic conditions
among other threats” Jacoby, D. and Gollock, M., Anguilla japonica. The IUCNRed List of Threatened Species 2014:
e.T166184A1117791, 2014 (available
at: http://dx.doi.org/10.2305/IUCN.
UK.2014-1.RLTS.T166184A1117791.en).
22 Ibid.

23 Briand, C., Bonhommeau, S., Beaulaton,
L. and Castelnaud, G., An appraisal of
historical glass eel fisheries and markets:landings, trade routes and future prospectfor management, The Institute of Fisheries
Management Annual Conference 2007,
conference paper, 2008, p. 21.
24 The CITES Appendix II listing took effecton 13 March 2009 and the European
Union import and export ban went into
effect in December 2010.
25 7.4 million kilograms of 7.7 million kilograms in trade based on importer reporting, all exported from China.
26 In the United States, only Maine andSouth Carolina have legal glass eel fisheries,
and South Carolina’s data are confidential.
27 According to import data, in the eight
years between 2001 and 2008, China
reported importing 310 metric tons oflive eel fry, and in the eight years between
2009 and 2016, it reported importing
only 141 metric tons.
28 During 2018, law enforcement officials
were contacted in a variety of forums,
including CITES meetings and closed
operational sessions. Questionnaires werealso completed by key national enforcement agencies, including those of France
and Spain. The information that follows isbased on their investigations from aroundfrom 2012 to date, which involved seizureof multiple tons of glass eel annually andover 100 arrests. See Methodological
Annex for details.
29 Ibid.
30 Ibid.
31 The China Eel Industrial Association
reports that there were between 2,200 and
3,800 European glass eels per kilogram,
making them the largest glass eel species
imported. In contrast, there are between
5,500 and 6,000 Japanese eels per kilogram, and around 5,000 American eels
per kilogram.
32 Based on responses to a UNODC questionnaire administered to law enforcement
officials in the affected European countries
in 2018. These observations are based onpolice operations.
33 Ibid.
34 EU Trade Enforcement Meeting, Brussels,
16 October 2019.
35 https://www.europol.europa.eu/newsroom/
news/glass-eel-traffickers-earned-more-eur37-million-illegal-exports-to-asia
36 CITES Twenty-ninth meeting of the Animals Committee, Joint press release on theoccasion of the tenth meeting of the informal
consultation on international cooperation forconservation and management of Japaneseeel stock and other relevant eel species, AC29
Inf. 13, 2017.
37 Stein, F.M., Wong, J.C.Y., Sheng, V. Law,
C., Schröder, B. and Baker, D., ‘First
genetic evidence of illegal trade in endangered European eel (Anguilla anguilla)from Europe to Asia. Conservation Genetics
Resources Vol 8, pp. 533–537 (2016).
38 The FAO statistics have been questioned
by some analysts, but they corresponddirectly to figures cited in the official
China Fishery Statistical Yearbooks.

39 United Nations Industrial Development
Organization (UNIDO), ’Case Study:
Chinese Eel Exports’, Meeting Standards,
Winning Markets: Regional Trade Standards
Compliance Report, East Asia 2013, Ch. 4,
pp. 49-61, November 2013.
40 Ibid.
41 In contrast, the China Eel Industrial Association reports Japanese eels only require
12 to 24 months to grow to marketablesize, and American eels between 15 and 30
months42 CITES Twenty-ninth meeting of the Animals Committee, Joint press release on theoccasion of the tenth meeting of the informal
consultation on international cooperation forconservation and management of Japaneseeel stock and other relevant eel species, AC29
Inf. 13, 2017. In e-mail communication,
the China Eel Industrial Association estimates that there were between 900 and
1,000 eel farms in China in mid-2018.
The Japanese Ministry of Health, Labourand Welfare lists 93 Chinese eel farms registered for the export of live eels to Japanand 278 farms authorized to supply 49
food processing companies. See List of 278
Chinese eel farms. Available at:https://www.mhlw.go.jp/file/06-Seisakujouhou-11130500-Shokuhinanzenbu/0000080001.pdf and List of theregistration farm of live eel exportation.
Available at: https://www.mhlw.go.jp/
file/06-Seisakujouhou-11130500-Shokuhinanzenbu/0000079999.pdf
43 United Nations Industrial Development
Organization (UNIDO), ’Case Study:
Chinese Eel Exports’, Meeting Standards,
Winning Markets: Regional Trade Standards
Compliance Report, East Asia 2013, Ch. 4,
pp. 49-61, November 2013.

CASE STUDY: European glass eels

7
44 According to the data attached to CITES
AC29 Inf. 13 (CITES Twenty-ninth meeting of the Animals Committee, Joint press
release on the occasion of the tenth meetingof the informal consultation on international
cooperation for conservation and management of Japanese eel stock and other relevant
eel species, 2017), between 2008-09 and2015-16, China caught 253 metric tonsof Japanese glass eel and introduced only
123.5 metric tons of Japanese glass eel.
Between 2008 and 2016, China exported
108.5 metric tons of Japanese glass eel.
45 CITES AC30 Doc 18.1, Annex 1, Implementation of the CITES Appendix II
listing of European Eel Anguilla (available
at: https://cites.org/sites/default/files/
eng/com/ac/30/E-AC30-18-01-A1.pdf ).
CITES has recently revised the guidance
regarding reporting of eel trade and illegal
trade. See Guidelines for the preparationand submission of CITES annual reports(December 2019), Ch. 6a) ‘Description of
specimens and units of quantity’, pp. 7-11
(available at: https://cites.org/sites/default/
files/notif/E-Notif-2019-072-A1.pdf ) and
Guidelines for the preparation and submission of the CITES annual illegal trade report(https://cites.org/sites/default/files/notif/ENotif-2019-072-A2.pdf ).
46 Based on responses to a UNODC questionnaire administered to law enforcement
officials in 2018.
47 CITES Twenty-ninth meeting of the Animals Committee, Joint press release on theoccasion of the tenth meeting of the informal
consultation on international cooperation forconservation and management of Japaneseeel stock and other relevant eel species, AC29
Inf. 13, 2017.

105

Supply and value chains andillicit financial flows from thetrade in ivory and rhinoceros horn
The market for illicit wildlife productsis – like all other markets – driven
by profit. In recent years, wildlife
crime has grown into a significant
and specialized area of transnationalorganized crime, driven by highdemand.1 Illicit wildlife trade is ahighly lucrative business, with wildlife products commanding high prices
on international, illicit markets.
Wildlife criminal cases very often
start and end with the seizure, withlimited investigation into the wider
criminal network beyond the poacher
or courier. Financial investigation andanti-money-laundering techniques
are rarely used in the fight against
wildlife crime.2 As a result, there aremajor gaps in the understanding of
the financial flows behind wildlife
crime, which means that inadequate
measures are being undertaken to mitigate the risks of wildlife crime andassociated money-laundering.

A detailed understanding of thevalue chain of illegal wildlife products, from producers (for example
poachers) through intermediaries to
end consumers, allows for identifying
vulnerabilities that may enable disruption of illegal markets and the value
chain. This encompasses understanding the trading patterns, assessing thevalue added at each step of the value
chain, the overall illicit income generated and the income made by eachgroup of actors, as well as analysing
illicit financial flows from the tradein illegal wildlife products.

This chapter presents such an analysis using the examples of illegal tradein ivory and rhino horn, which wereselected out of relevance and data
availability. Both come from large,
valuable and endangered animals
and have received considerable attention from national law enforcement
authorities and international bodies,such as the United Nations5 and otherLittle is known about the profits made governmental and non-governmental
by organized crime groups from illicit organizations concerned with wildlife
wildlife trafficking and the significant conservation. Because of this attengaps in understanding supply and tion, these two species are better
demand for certain wildlife products documented than most others, andmake such estimates challenging. the information available allows for
Existing estimates that monetize the an estimation of the volumes traded,size of wildlife trafficking and crime as well as the economic value of theare highly aggregated and utilize markets and associated illicit financial
broad frameworks that include envi- flows.
ronmental costs and loss of public
revenues. These aggregates are useful The analysis demonstrates the imporfor advocacy purposes but have lim- tance of profits as an engine forited usefulness for understanding how wildlife crime. It also provides counwildlife traffickers operate and for tries with a tool to monitor trends tomonitoring and evaluating progress understand if progress is being mademade in containing the illicit profits in disrupting the illicit financial flows
and financial flows generated by the related to wildlife trafficking.
illegal wildlife trade.3 Estimates ofthe monetary value of global wildlife crime also suffer the challenge ofinternationally defining the crime.4

8

The illegal trade in ivory
and rhino horn
Over the past decade, complex anddiverse illegal supply chains for rhino
horn and ivory have developed, andtrafficking routes from Africa to Asia
span multiple countries. Exploiting
weaknesses and adapting dynamically to changed situations, traffickers
move ivory and rhino horn by land,sea and air, often concealed in legitimate cargo.6
Citizens of destination countries in
Asia are often heavily engaged within
Africa in rhino horn and ivory trafficking. They play major roles in theacquisition and transport of rhino
horn out of Africa to Asian destinations.7 Motivated by the potential
high revenues, these trafficking networks form a crucial part of the illegal
supply chains.
A comprehensive understanding of
the entire trade chain from poacher
to end-consumer is necessary because
it allows for a careful formulation ofpolicy responses in the countries
affected by the illegal trade in rhino
horn and ivory.

A model supply chain ofillegal trade in ivory andrhino horn
The illegal supply chain for ivory andrhino horn describes the processes
and actors involved in sourcing,
manufacturing, trafficking and selling
products to end consumers.
The illicit supply chains start withpoaching: Most of the ivory andrhino horn on illicit markets come107

SUPPLY AND VALUE CHAINS AND ILLICIT FINANCIAL FLOWS

Box 1: The value of wildlife crime: concepts and estimatesThe ‘value’ of an illegal activity can be
defined in different ways, depending the
purpose of the estimates and the conceptual framework behind the estimates.

WORLD WILDLIFE CRIME REPORT 2020

In economic terms, the value of anactivity can be measured by the overall
income they generate, be it licit or illicit
income. Estimating markets in economic
terms often involves estimating theamounts produced and sold, and thevalue thereof. Such measurements are(most often) direct estimates, whichmeans that they are estimated in direct
relation to the underlying economic
activity, and reflect – in simple terms– the amount of money made by allparticipating in a certain economic
activity. This approach is in line with the
System of National Accounts, a standard
used by all countries to construct thegross domestic product (GDP) and it has
been applied to illegal activities, too.a
Other approaches to quantify wildlife
trafficking have used broader concepts
such as economic loss and have adopted
a full cost analysis. These concepts do
not measure the value of wildlife trafficking as described above in the context
of generated income, but they consider
factors such as loss of taxes or other licit
income and assets through the illicit
nature of the activity. In the context ofwildlife, this includes environmental
costs and damageb for example throughthe loss of capacity for carbon sequestration in illegal forestation,c (potential)
loss of tourismd through loss of species
diversity, or loss of natural resources
through for example illegal fisheries.
Estimates produced through this approachYearly average estimatedillicit income throughout 
the entire supply chain

Yearly average estimatedeconomic loss from taxation,
environmental costs,
natural resouces andpotential tourism losses

Eurostat (2018), Handbook on the compilation of statistics on illegal economic
activities in national accounts and balanceof payments, Luxembourg.
b For detailed discussion on environmental crime see Christian Nellemann,
Rune Henriksen, Patricia Raxter, NevilleAsh, and Elizabeth Mrema (eds), The
Environmental Crime Crisis – Threatsto Sustainable Development from Illegal
Exploitation and Trade in Wildlife andForest Resources. A UNEP Rapid Response
Assessment. United Nations Environment
Programme and GRID-Arendal, Nairobi
and Arendal, 2014, p. 23.
World Bank. 2019. Illegal Logging,
Fishing, and Wildlife Trade: The Costs
and How to Combat it. World Bank,
Washington, DC. © World Bank.
https://openknowledge.worldbank.org/
handle/10986/32806 License: CC BY
3.0 IGO.”

a

108

c

are by their very nature much larger
than those constructed on the basis of
economic value and are not comparable
to illicit income estimates.
The estimates provided in this chapter
focus on illicit income and are in linewith the System of National Accounts
and Eurostat’s recommendations e on
how to incorporate illicit income in GDP
estimates. The estimates are based on adisaggregated, direct measurement
approach using estimates on supply ofrhino horn and ivory and respective
price data. The approach allows for frequent updates based on updated priceand supply data and thus facilitates a
close monitoring of the market.

d Robin Naidoo, Brendan Fisher, Andrea
Manica & Andrew Balmford, Estimating
economic losses to tourism in Africa fromthe illegal killing of elephants. Naturecommunications 7.1 (2016): 1-9.
e Eurostat, op cit.

As shown in chapter 3, 86 per cent of
the recorded rhino poaching incidents
between 2006 and 2017 took placein South Africa, which was home
to 75 per cent of the African rhino
population in 2017.8 Other countries of origin of illegally sourced
rhino horn were for example Zimbabwe, Namibia and Kenya. Elephantpopulations are much larger and lessconcentrated than rhino populations,and research showed that illegal killings of elephants took place in a large
number of range states, in Southern,
Eastern and Central Africa.9
Once poached, the horn and tusks arecollected and further trafficked. These
products are passed on or sold to local
traders and then to intermediaries
who compile and organize larger shipments at the national or subregional
level. Typically, these shipments arethen trafficked by internationallyconnected individuals or groups todestination markets in Asia, where
wholesale and retail traders sell final
products to end-consumers. Smallquantities are also trafficked towards
destinations outside Asia.

Supply and value chains and illicit financial flows

from (newly) illegally killed animals
and some – comparatively small –amounts from other sources such as
stockpile thefts or theft from natural
mortalities.

8
Box 2: Illicit supply chains
Supply chain analysis helps to understand the functioning of illicit markets
and how organized crime groups interact to organize the – often global –illicit trade in goods and services.
Supply chains exist in licit and illicit
markets alike. Broadly speaking, a
supply chain is a set of actors involvedin the (licit or illicit) flows of products,
services, information and finances fromthe source to the end customer. A
supply chain consists of all parties
involved, directly or indirectly, in fulfilling a customer demand (the term‘market’ encompasses all actors whoare producing, trading and purchasing
a good or service).

Criminal organizations plan activities,
source and procure raw materials,
manufacture, refine, transport, store
inventory, sell and distribute products
to customers. Often more than one
group is involved in the supply chain,fulfilling different roles.
The primary differences between licit
and illicit supply chains lie in risk
levels and mitigation strategies.
Organized crime groups face the risk ofdetection and arrest by law enforcement and the risk of losing products
when they are confiscated by authorities. Actors in illicit supply chains facelogistical challenges and extra costs toconceal their operations.

Illicit supply chains share many of thesame functional attributes as licit ones.

trades, the general set-up of the illegal
supply chain appears to be comparable.11 The levels may vary case by casein composition and nature, and someproducts may not be handled by alllevels when arriving at their end-consumer; they provide, however, a usefulmodel for analysing illegal markets.

Poachers can be roughly grouped bytheir degree of professionalization.12,13
Subsistence or artisanal poachers are
According to UNODC World WISE usually from poor communities andseizure data from 2015-2019, most are driven by the need to sustain theirivory tusk shipments were destined livelihoods. These poachers are notfor Viet Nam (42 per cent), China highly organized, often hunt oppor(34 per cent) and Cambodia (12 tunistically and do not use long range
per cent). For rhino horn, based on weapons or tranquillizers.14 They area longer time period from 2002 to often driven by their socio-economic
2019, the main destinations were situation,15 taking the risk of poachsimilar, with Viet Nam (41 per cent), ing for comparatively little reward.
China (39 per cent), Malaysia (5 percent) and Thailand (3 per cent).10
On the other side, there are highlyorganized poachers and poaching
A common model to describe the groups who work with a degree of proillegal supply chain uses six differ- fessionalisation, and are well equipped
ent trade levels: poachers, runners with, for example, long-range weapor brokers, intermediaries, exporters, ons. This has been reported for rhino
importers/wholesalers and retail trad- horn poachers,16 and was substaners. While there are some differences tiated by reports on the increased
between the rhino horn and ivory involvement of military personnel,

police officers or game scouts, all ofwhom would have had specialized
training to develop tracking or shooting skills.17 These poachers achieve
higher prices for their products, areoften paid up front and are well connected with trafficking organizations
who organize the further traffickingof the illicit products.
Poachers may work independently or
may be hired by trafficking groups(‘dependent poacher’). A poachinggroup typically comprises a skilledshooter, an experienced tusk or horncutter, and porters to carry food,water and the product back to safety.
A rhino poaching group will usually
be smaller than one for elephants;
two to four members for rhinos andfrom four to more than a dozen forelephants.18 Independent poachers
self-finance the hunt and sell thehorn or tusk to the highest bidder;dependent poachers are hired andsubsidized by others higher up in the
supply chain.
Besides poaching, rhino horn andivory can enter the illegal market
from stockpile theft (for example,

109

SUPPLY AND VALUE CHAINS AND ILLICIT FINANCIAL FLOWS

from government-held repositories poacher(s). These players are often
of seized products), and from being termed ‘runners’ in Southern Africa,
harvested from natural mortalities or ‘brokers’ in East Africa or ‘commanlegal killings (such as problem animal ditaires’ in Francophone Africa (ifcontrol).
they have ordered and financed thehunt). In most cases, the persons
Runners or brokers are the next link in involved in the onward trafficking of
the supply chain. These low-level traf- illegal wildlife parts are not the same
fickers usually live in the vicinity of persons carrying out the poaching.19
the poaching areas and are familiar There are indications that higher-levelwith community leaders and persons traffickers systematically attempt
who purchase the products from the to distance themselves from theFig. 1

Actors along the value chain of rhino horn andivory (violet actors are thought to be in Africa,
green ones in destination countries, yellow may
be located in either region)
Poachers

1

Runners/
brokers

2

Intermediaries
or dealers

3

Value
chain

WORLD WILDLIFE CRIME REPORT 2020

6

4

Exporters /importers

5

Wholesaletraders

Retailers

Source: Adapted from INTERPOL and UN Environment, Strategic Report: Environment, Peace and Security – A Convergence of Threats, p. 40, 2016; Maggs, K.,‘South Africa’s National Strategy for the safety and security of rhino populations
and other relevant government and private sector initiatives’ in Dean, C. (ed.),Proceedings of the tenth meeting of the IUCN African Rhino Specialist Group,
5-10 March 2011, pp. 130–146, 2011 and Milliken, T. and Shaw, J., The South
Africa – Viet Nam Rhino Horn Trade Nexus, TRAFFIC, 2012.

110

poaching offence.20 Runners or brokers separate higher-level traffickers
from poachers.
Intermediaries or dealers operate at thenational level and are often based ina large urban area. They aggregate
products and either sell them toexporters or export them themselves(in this case this role conflates with
the next). Intermediaries are tasked
with the logistical organization of thetransaction and the transport of the
products to exporters or international
wholesalers. Intermediaries are often
of Asian (destination country) descent
but are resident in or close to source
countries.21
Exporters/importers are usually part oforganized crime groups. They facilitate international trafficking (forexample, by using front companies
and corrupting authorities), and carryout packing, preparation of paperwork and export of the products.
Packing may involve specialists whomake use of fake stones, hollowed
out logs or other methods to conceal the products. These players are
based in cities with an international
airport or seaport. The products canbe shipped in containers by sea or air
freight, carried by air by couriers inpersonal luggage, or sent in packages
by courier service or the post.
Wholesale traders receive the products inthe destination country. Once in the
country, the products are processed22
and sold to end consumers at markets,
jewellery stores and other retail outlets
or online.
Retailers in destination markets sell
refined products to end-consumers,
where the supply chain ends.
Besides these actors, who can be
categorized as “primary actors” andhandle ivory or rhino horn products
directly, many others make profits byproviding supporting services, such astransportation or money-laundering.
Others facilitate the trade by taking
bribes; at lower levels, it is generallySupply and value chains and illicit financial flows

8
Box 3: Limitations and strengths of seizure data
Organized crime groups invest a lot ofeffort in concealing their activities. For
this reason, statistics on trade patterns
and routes, volumes traded and profits
made are hard to come by.
Seizure data provide some insight into
the illegal trade. A seized parcel is anindication of illegal activity and accompanying information on alleged origin
and destination or the citizenship of theoffenders can shed light on operations
otherwise conducted in the dark.
Seizure data require careful interpretation because they are a mixed indicator,
demonstrating both the presence of aproblem and the initiative of the relevant authorities in addressing it. On

When used in aggregated form andinterpreted together with other indicators, seizure data can yield insights on
major trafficking routes, concealment
methods and techniques used by traffickers. Data from ivory seizures forexample provide valuable information
on transit and destination countries, andmake it possible to assess the share ofivory taken out of the trade by law
enforcement. This report uses seizure
data included in UNODC World WISE
Database for the analysis.

Comparison between ETIS and World WISE ivory seizure data, 2008 - 2017
80,0001,500

60,000

Seized ivory (kg)

2,000

1,000
500

40,00020,000ETISWorld WISE

2017

2016

2015

2014

2013

2012

2011

2010

2017

2016

2015

2014

2013

2012

2011

2010

2009

2008

World WISE

2009

0

0

2008

Fig. 2
Number of seizure cases

There is a parallel data collection
system, the CITES Elephant Trade Information System (ETIS), which appears to
be more complete than UNODC’s data. A
comparison between aggregated datareported by ETISa and World WISE showsthat the ETIS system recorded more seizure cases and more seized weight overtime. Data reported by ETIS was only
available in aggregated form andinclude imputation of missing weights,
but no open source information wasavailable to assess it and understandhow much it accounts for the difference
between the two database systems.

their own, they cannot be used todemonstrate the magnitude of trafficking or effectiveness and capacity of law
enforcement.

ETIS

Source: Source: ETIS a and UNODC World WISE databaseaT. Milliken, F. Underwood, R. Burn and L. Sangalakula, The Elephant Trade Information System (ETIS) and the Illicit Trade in Ivory:
A report to the 18th meeting of the Conference of the Parties to CITES. CoP18 Doc. 69.3 (Rev. 1) Annex 1, December 2018.

products before smuggling them toconsumers in Asia. Police investigations in South Africa have uncovered
small home workshops where rhino
horn is cut into rough “discs”, beads
and bracelets are manufactured, andoffcuts and rhino horn powder are
packaged for export. Other cases suggest that intermediaries, exporters andNo generalization fits all cases. There wholesalers conflate. In such cases,
have been reports24 that some traffick- the supply chains are cut short anding networks of East Asian origin involve a smaller number of actors.
operate in South Africa, and process
and craft rhino horn locally into final

local police officers and park rangers
who take their cut, while at the international level, it is custom officers at
the borders and high-level officials.23
These groups are facilitators and beneficiaries of the illegal trade in wildlife
goods, and part of the illicit supply
chain, too.

The size of the illicit
market
The illicit markets for ivory and rhino
horn comprise all buyers and sellers,
and thus all actors in the supply chain,including end consumers. The market
sizes in monetary terms is defined as
the total illicit income generated fromthe trade in ivory and rhino horn.
Overall illicit income is calculated
as amounts purchased multiplied by

111

SUPPLY AND VALUE CHAINS AND ILLICIT FINANCIAL FLOWS

prices. There are, however, no direct
estimates of the annual amounts ofrhino horn and ivory purchased bycustomers in destination countries, ordata on the numbers of buyers andsellers. Studies have investigated thenumber of ivory and rhino horn items
displayed,25 estimated the weight of
the items,26 or studied the behaviour
and motivation of customers.27 Noneof these studies allowed for the inference of the total amounts of ivory
or rhino horn purchased in a year,
however.

purchased by end consumers indestination countries under certain(critical) assumptions (see Boxes 3
and 4). Multiplying these volumes
with respective prices yields the illicit
gross income generated from the tradein ivory and rhino horn and thus amarket size estimate in monetary
terms. Disaggregated price data allow
for a further breakdown of the illicit
income by group of actors, providing
an indication of the distribution ofincome along the supply chain.

One quantity that can be assessedis supply: elephant and rhino populations are well-documented, and(relatively) good poaching data are
available. These data together withestimates on average amounts ofrhino horn and ivory per animal yieldan annual average supply of raw ivory
and rhino horn from poaching. Dataon rhino horn and ivory entering
the market from sources other thanpoaching are less robust but can beused to complete the assessment.

Annual supply ofrhino horn

As described in chapter 3, between
2016 and 2018,28 an annual averageof 1,060 rhinos have been illegallykilled in Eastern and Southern Africa.29 Each animal carried two horns,
weighing on average together 5.56 kg
or 2.78 kg each.30 This yielded some
2,100 horns31 or 5.8 tons of rhino
horn harvested from poached animals
per year. Of these, 91 per cent or 5.3
tons were estimated to have enteredWith supply estimates available, the the illegal market (sold onwards), thetotal quantities purchased by end con- remainder supposedly recovered insumers can be assessed considering the field before being sold. 32that along the supply chain productis seized by law enforcement, stock- Poached animals are not the only
piled or otherwise lost. In terms of source of rhino horn entering thewhere the final products are pur- illegal market. It was estimated thatchased UNODC World WISE data an annual average of 113 horns or
is used to estimate the destination of 314 kg of horn were obtained fromthe products.
sources other than poaching, suchas stockpile theft, theft from natuCombining all these data allows ral mortalities or trophy hunting.33
for an assessment of the volumes In these ways, an estimated total ofWORLD WILDLIFE CRIME REPORT 2020

Fig. 3

Tons of rhino horn entering the illegal market,
annual average 2016-2018
Horn from poached animals 		5.8 tons
Recoveries in the field- 0.5 tons

Horn from other sources+ 0.3 tons

Horn entering the illegal market= 5.6 tons

Note: Numbers are rounded, calculations were done with full precision.

112

some 5.6 tons of rhino horn entered
the illegal market in Africa each year
between 2016 and 2018.
These numbers may be underestimations and are surrounded by someuncertainty. The numbers of illegallykilled rhinos are to be understood as
minimum numbers, since it is possible that carcasses were not detected.
The weight of horn per animal is anaverage that may mask significant variation in the data. Older animals havelarger horns than younger ones, males
larger than females, and the probability of being poached might varydepending on horn size. Estimatedrecoveries from the field and sharesof horns entering from other sources
may also vary over time.

Annual supply of ivory
Illegally traded ivory can come from avariety of sources. Most important forconservation of the elephant species
is ivory harvested from illegally killed
elephants, but ivory can also originate
from private stockpiles or from leakages from national ivory repositories.
Such repositories hold ivory seized
during law enforcement operationsor harvested from legal killings (forexample, killings in the context ofproblem animal control) or natural
mortalities.

Ivory from illegally killed
elephants
As detailed in Chapter 3, there are two
ways to estimate the number of elephants poached, and thus the size ofillicit ivory supply. This chapter used
results from a modelling approachthat determined the numbers ofillegally killed elephants by using
data on detected elephants’ carcasses(illegally killed or died from naturalcauses) recorded by the CITES program “Monitoring the Illegal Killingof Elephants” (MIKE). 34
As with rhino horn, a three-year
average of the latest available data of

Estimated numbers of illegally killed elephants,
total and by subregion, 3-year-average, 2016-2018

Supply and value chains and illicit financial flows

Fig. 414,000Estimated number of illegallykilled elephants

illegally killed elephants was used asa basis for estimating the illegal ivory
supply. Between 2016 and 2018, an
estimated average of 10,000 (range
8,300 – 13,000)35 elephants wereillegally killed per year in Central,
Southern and Eastern Africa.

8

12,00010,0008,000

These estimates are highly uncer6,000
tain. The model used to estimate thenumber of illegally killed elephants
4,000
incorporated variation in demo2,000
graphic rates and from the carcass
1,900
5,600
2,500
10,000sampling process (reflected in the0ranges), but not from population
Central Africa
Southern
Eastern Africa
Sum
Africasurvey data. The model was run on
carcass data from MIKE sites in Cen- Source: UNODC estimates based on modelling by George Wittemyer
tral, Southern and Eastern Africa, but Note: Uncertainty ranges represent a 95 per cent confidence interval. The model incorporated variation in demographic
did not incorporate information from rates and from the carcass sampling process, but no uncertainties from the underlying population survey data.
West Africa due to their comparatively
lower reporting rates.36
Table 1 Annual estimated ivory harvested from illegally killed
The IUCN African Elephant Status
Report 2016 put the estimated elephant population in a bracket ofroughly ±5 per cent and acknowledged that there “may be an additional
117,127 to 135,384 elephants in areas
not systematically surveyed.”37 These
additional population numbers are
obtained from statistically less reliable
methods and referred to as ’guesses’.
Guesses potentially add another 28
to 33 per cent to the total elephantpopulation, and are of significant size
in Central Africa, where in addition
to the estimated 24,119 ± 2,865 elephants, another 87,190 to 103,355(up to 4 times as many) may exist.
Elephants may have been poachedfrom these populations, but theestimated poaching rates cannot bedirectly applied to guessed elephantpopulations. In absence of any means
to estimate poaching rates for elephant populations in this category,
the total estimates are considered to
be on the lower, conservative side.
The estimated numbers of illegallykilled elephants combined withestimates of the average weight ofelephant tusks yield an estimate of
the ivory entering the illegal market
per year.

elephants, 3-year average 2016-2018

SUB-REGION
Central Africa
Eastern Africa
Southern Africa
West Africa*
Total

TONS OF IVORY HARVESTED PER YEAR
19.2 (12.7-32.2) tons
25.8 (18.1 - 40.4) tons
57.1 (42.7-81.2) tons
2.9 tons
105 (88 – 136) tons

Source: UNODC estimates based on modelling by George Wittemyer* Note: The illegal killing rate applied to West Africa is a weighted average of the other subregions (UNODC calculations).
The ranges reflect the 95% confidence intervals of the estimates on illegally killed elephants.

Elephant tusks are continuously growing front teeth that come usually, but
not always, in pairs. The yield figure
used historically has been 1.9 tusks
per elephant and about 5.5 kg pertusk, resulting in an average of some
10 kg38 per elephant.39 Applying suchan average to estimated numbers ofillegally killed elephants provides
an order of magnitude but can bemisleading. Poachers would seek out
older, male animals with the largest
tusks to increase the ivory yield perhunt, so the above average might be at
the lower end for mature, undisturbed
populations. In populations that
already suffered substantial losses in
the oldest age groups, average expected
ivory yield per poached animal may
have drastically decreased40 and theabove number may overestimate thecurrent ivory yield. 41
Combining estimates of illegallykilled elephants with estimates of
the average ivory yielded per elephantresults in an annual average of 105(88-136) tons of ivory available forthe illegal market between 2016 and2018.

Ivory from other sources
Poaching is not the only source forivory entering the illegal market.
There are national stocks of tusks insource, transit and destination countries, and ivory has gone missing in
the past.42 These stockpiles accrue
due to several factors, including legal

113

SUPPLY AND VALUE CHAINS AND ILLICIT FINANCIAL FLOWS

killings, natural elephant mortality
and seizures of contraband.

Fig. 5Flows of illicit ivory and rhino horn products,
by destination

In the absence of systematic monitoring and public reporting on ivory
stocks held by countries affected byivory trafficking,43 producing a wellfounded estimate of ivory stocks andLossesleakages does not appear to be feasible.
There are, however, some indicationsof the magnitude of leakages in comparison to the annual supply of newly Source: UNODC
sourced ivory.

Stockpiles

SeizuresEnd-consumer

law enforcement, stockpiled for later A detailed description of trafficking
sale or otherwise lost in the process. modalities, routes, origin and desHow much of the supply reaches end tination countries can be found in
consumers is therefore determined by Chapter 3. Here, the focus is on thethe amounts seized, stockpiled or lost. overall volumes traded from Africa
to destination countries in Asia andStockpiles or inventories may be on the approximation of the illicit
kept by all actors (poachers, traffick- income generated by the illicit tradeers, wholesalers and retailers) along at a regional level.
the supply chain. Some actors may
keep stocks as an investment to
speculate on higher prices,46 others
may hold on to products to wait for Between 2016 and 2018, an annual
less risky trafficking opportunities or average of 426 kg48 of rhino horn
to collect more products to collate and rhino horn parts were seized ina larger shipment. Losses include Africa and 500 kg in Asia, according
products rendered unusable during to data from the UNODC World
Estimates presented by Nkoke et al.45 transportation, products lost during WISE Database. In total, some 976
point towards amounts that are small manufacture of items47 and products kg were seized per year (50 kg outsidecompared to ivory collected from disposed to avoid arrest. With the of Asia and Africa).
poaching: The authors estimated a uncertainty around stockpiles andminimum amounts of stockpile leak- in absence of data to estimate losses The data, together with the assessment
ages in Central Africa of a total of other than seizures, the calculations that there is hardly a retail market for56.5 tons over the course of 26 years in this report assume that all products rhino horn in Southern and Eastern(1990 to 2015).
that enter the market over a certain Africa,49 indicate that the main flow of
period are either seized or sold to end rhino horn originates in Southern andLeakages from repositories may thus consumers in the same period (this Eastern Africa and goes to East andbe small in comparison to the ivory goes with the implicit assumption South-East Asia for final consumpharvested from poached animals and that inventories are constant, that tion. A minor flow of rhino hornleakages are not considered in the fol- is, products entering inventories are could be destined for the European
lowing analysis. It needs to be stressed offset by products entering the market market (accounting for 4 per cent ofthat the available data is very weak, from inventories).
all World WISE seizures). However,
and more data is needed to come toout of all products seized in Europe
a reliable estimate of leakages from The annual estimates are based on between 2016 and 2018 for which athree-year averages of supply and destination country was reported, 43
legal stockpiles.
seizures, which is thought to account per cent were destined for East Asia
for some delays in the supply chain and 15 per cent for South-East Asia.
between source and destination of the The remainder, less than 2 per cent all
product and to smooth the volatility horn seized, was believed to have its
final destination in Europe.
All rhino horn and ivory entering the in seizure data.
illegal market in a year is either purchased by end consumers, seized by
Cerling et. al.44 used C-14 dating
methods to determine the time
between elephant death and tusk seizure. The examination of 231 African
ivory samples from 14 seizures madebetween 2002 and 2014 showed thatthe lag time between elephant deathand seizure had median values generally ranging between 6 months and3 years. The authors concluded thatthey did not find evidence that longterm government or other stockpiles
contributed significant amounts ofivory to the illegal trade and emphasized that poached ivory was being
rapidly moved into the illegal trade.

WORLD WILDLIFE CRIME REPORT 2020

Annual supply

Volumes reaching theend-consumer

114

Rhino horn

Fig. 6Flows of rhino horn, annual estimates based on
2016-2018 data
Supply of
African rhino horn
(5.6 tons)

Trafficked
outside Africa(5.2 tons)

Seized in Africa(0.4 tons)

Ivory

Stockpiles(unknown)

To East andA similar calculation can be made for
Other markets
South-East Asia
(<
100
kg)
ivory. The destination of the prod(5.1 tons)
ucts is estimated by using the countryof destination of the shipments, as
End-consumers
reported by Member States.51 If allin Asia
ivory harvested within a certain(4.6 tons)
period is consumed in the same period,52 and if the information provided
Source: UNODC estimations
on the destination represents actual Note: Numbers are rounded, calculations were conducted in full precision.
trade patterns, the following flows of Seizure data for 2018 was approximated with an average of 2016 and 2017.
ivory can be deduced.

An annual average of 105 (88 – 136)
tons of ivory was supplied fromAfrican range states between 2016
and 2018. Based on World WISE
seizures,53 out of these, 5 tons wereseized by law enforcement in theregion, and 9 tons were destined forthe region,54 leaving 92 tons available
for export to destination markets.
Some 88 tons reach Asian countries
via various routes (including routes
passing through European countries).
In Asia, 24 tons were seized by law
enforcement and 63 tons remained
available for consumption. Some
3.6 tons were destined for Europe,of which 2 were seized and 1.6 were
thought to be consumed.

The value of theillicit market

Supply and value chains and illicit financial flows

Combining supply estimates withseized amounts and destinations offlows, makes it possible to estimatethat out of the 5.6 tons of rhino horns
entering the illegal market each year,
5.2 tons leave Africa and out of these,
4.6 tons reach end-consumers in Asia.
Less than 100 kg might be destinedfor other regions in the world.50

8Fig. 7

Stockpiles(unknown)

Seized in Asia
(0.5 tons)

Flows of ivory, annual estimates based on
2016-2018 data
Supply of African ivory(105 tons)

Seized in Africa(5 tons)

Ivory exported(92 tons)

Final destination in
Africa (9 tons)

Europe(3.6 tons)

To East andSouth-East Asia
(88 tons)Other(<1 tons)

Seizure(2 tons)

Seizures(24 tons)

End-consumer(1.6 tons)

End-consumer(63 tons)

The annual, overall gross illicit income
generated by ivory was estimated to Source: UNODC estimations
be US$400 (310 – 570) million and Note: Numbers are rounded, calculations were conducted in full precision. Seizure data for 2018
was approximated with an average of 2016 and 2017.
the income generated by rhino horn
US$230 (170 – 280) million between
2016 and 2018. The gross income isthe overall income made by retailers.
These estimates pertain to the quantities reaching South-East and East Asia.

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SUPPLY AND VALUE CHAINS AND ILLICIT FINANCIAL FLOWS

Box 4: Uncertainty surrounding the estimates:
impact of assumptions
All estimates presented on market sizes
and illicit income are subject to uncertainty. Each estimate is based on incomplete information. Access to better
information may affect the quality ofthe estimates.
Illegal killings of elephants. The
methodology yields results on thelower, cautious side. Better information on elephant populations and thegeographical distribution of poaching
may lead to an increase in the supplyof ivory (as would incorporating estimates on Asian ivory). The extrapolation made using the proportion ofillegally killed elephants is based on anumber of assumptions (see Box 1 inchapter 3).
Leakages of ivory and rhino hornfrom private and government repositories. The few data points availablea
indicate leaked quantities that aresmall in comparison to supply fromnewly killed elephants and rhinos.
Better data might yield an increased
supply of ivory and rhino horn.
Seizures. Seizures are suspected to beunderreported,b and a comparison of
officially reported seizures with media
reports corroborated the hypothesisthat seizures officially reported may
not be complete. More complete seizure data would decrease the amountsof ivory and rhino horn reaching end
consumers and thus decrease themarket value.

WORLD WILDLIFE CRIME REPORT 2020

Table 2

Ivory yield per elephant. The impact
of better data on this element isunclear. The data used for the calculations are based on natural measurements. Selective poaching may lead tolarger tusks, on average, when old,male animals are sought out. In populations that already suffered substantial losses in the oldest age groups, theaverage expected ivory yield perpoached animal may be much smaller
than the assumed size in the calculations.
Losses in production. Milliken et al
estimate that up to 30 per cent of theivory is lost in the carving process cwhen final products are made fromivory and rhino horn. If these losses areincorporated into the estimates, theestimated weight of ivory and rhino
reaching end consumers - thus thevalue of the retail market - would
decrease accordingly.
aNkoke, S. C. et. al., Ivory markets inCentral Africa, TRAFFIC, September
2017.
b T. Milliken, F. Underwood, R. Burnand L. Sangalakula, The Elephant Trade
Information System (ETIS) and the
Illicit Trade in Ivory: A report to the18th meeting of the Conference of theParties to CITES. CoP18 Doc. 69.3
(Rev. 1) Annex 1, December 2018.
c In CITES document CoP14 Doc. 53.2,
the losses through various carving andmechanized manufacturing processes
were taken as 30 per cent. Losses could
thus be of significant size and reduce
the estimated illicit financial flows
accordingly.

There are indications that rhino hornand ivory are sold in other regions,too, for example, in Europe. These
markets are not considered here giventhat their size is very small, and thatprice data are not available.
In the absence of a systematic monitoring of prices by Member States,
UNODC undertook field and desk
research to collect prices of ivory andrhino horn at all levels of the supply
chain.55 The prices used were average
prices covering multiple years. A multi-year average was used to smoothen
year-on-year variations, to increasesample sizes and to make the value
estimates consistent with the supply
estimates.
With these prices, the illicit income
generated can be further broken down
by group using the supply chain
model presented above. Intermediaries, exporters and wholesale traders
are grouped together under “international trafficking”.
For both products, the largest
increases in prices - and thus income- are found between wholesale andretail selling in Asian countries. As
in many other licit and illicit markets,the largest value added is generated inretail. At this stage, rhino horn andivory are manufactured into artistic
products with qualities varying frommachine made items to carefully
crafted pieces of art.

Annual illicit income generated by the illicit trade in ivory andrhino horn (US$ millions), annual average, 2016-2018

Overall market size Asia
(end-consumer), gross income
RetailInternational trafficking
Runners and brokers
Poachers

IVORY

RHINO HORN

US$ 400 (310 – 570) million

US$ 230 (170 – 280) million

US$ 260 – 490 million
US$ 38 – 60 million
US$ 7 – 11 million
US$ 8 – 13 million

US$ 120 – 160 million
US$ 28 – 79 million
US$ 7 – 15 million
US$ 6 – 43 million

Note: International trafficking summarizes intermediaries, exporters and wholesale traders. The income presented as breakdown of the overall market size is the gross income minus theincome of the actors earlier in the supply chain. The estimates are to be understood as orders of magnitude, not robust statistics. The numbers are based on the model of a consecutive
supply chain: poacher – trafficker Africa – international trade – trafficker Asia – retail Asia. This model is thought to be applicable to a majority of cases, but not all. One such exception
would be manufacturing in Africa and direct shipments to end consumers in Asia. The ranges reflect different degrees of uncertainty (see methodology section).

116

Gross and net income
As every productive process, illicit
income can be represented by threemain aggregates: illicit gross income(or output), intermediate expenditure or intermediate costs, and value
added, presented in this chapter as
illicit net income (see Box 7).
The estimated annual illicit income
broken down by actor does not reflect
the net income, which accounts for all
the costs the actors face in conducting the illicit activity (intermediate
expenditure). Net income is key tounderstanding the proceeds of crimealong the supply chains and it is themore accurate metric for comparing
the profitability of crime across theactors of the supply chain. Net income
is the income available to actors for
consuming other goods and services
and for investing in licit or other illicit
activities or terrorist groups.

Variation of price data for rhino horn, by trade level,
multi-year average, 2014-2018

Supply and value chains and illicit financial flows

Comparing the rates of increase(mark-ups) of prices between rhino
horn and ivory shows that they are
consistently higher for ivory than forrhino horn. Mark-ups cover profits(net income) and costs. They are thus
not only reflecting the actor’s desireor ability to make profits, but also thecosts an actor incurs. Besides overallmarket dynamics and the dynamics
between actors, their power in pricenegotiations, the costs and the related
business models can drive differencesin prices between trade levels.

Fig. 8160,000
140,000

US$/kg120,000
100,000
80,00060,00049,30040,00020,000

4,300

5,900

9,600

Poacher

RunnerDealer

16,00024,3000
Exporter Wholesale

Retail(workedhorn)

Source: UNODC estimations based on data collected in 52 field interviews and available
literature (poacher to exporter) and on data provided by the Wildlife Justice Commission
and the Environmental Investigation Agency, UK (wholesale to retail). Mid-points area simple average of all observations (weighted by weight where available). To increasesample sizes and coverage, data from 2016 to 2018 was supplemented with earlier years.
Note: Ranges reflect varying degrees of uncertainty.

Fig. 9Variation of ivory price data, by trade level,
multi-year average, 2014-2018.

16,00014,00012,00010,000
US$/kg

The price data at retail needs thus
to be interpreted with caution. The
prices cover a very broad range, withprices per kg differing between minimum and maximum by a factor of
13 in ivory items and a factor of 36
for rhino horn products, reflecting
the wide range of possible qualities(see Box 6). Using an average pricemasks these large differences, and theresulting values therefore represent anorder of magnitude rather than a precise statistical estimate.

8

8,000

6,346

6,000
4,000
1,009

2,000
0

93

125

236

387

PoacherBrokerDealer

Exporter

Ivory
tusks
Asia

Workedivory Asia

Source: UNODC estimations based on data collected in 52 field interviews and available
literature (poacher to exporter) and on data provided by the Wildlife Justice Commission
and the Environmental Investigation Agency, UK (wholesale to retail). Mid-points area simple average of all observations (weighted by weight where available). To increasesample sizes and coverage, data from 2016 to 2018 was supplemented with earlier years.
Note: Ranges reflect varying degrees of uncertainty.

117

SUPPLY AND VALUE CHAINS AND ILLICIT FINANCIAL FLOWS

Fig. 10 Percentage increase of per kg-prices between different
actors in the supply chain, rhino horn and ivory,
average 2014-2018
529%

Wholesale Asia - retail

103%
161%

Exporter - wholesale Asia

52%
64%

Dealer - exporter

67%
88%

Broker - dealer

62%
35%

Poacher - broker

37%
0%

100%

200%
Ivory

300%

400%

500%

Rhino horn

Source: UNODC estimations
Only the percentage changes from one level to the next are shown. Ranges are omitted for clarity.

Box 5: Rhino horn is less valuable thancommonly believed
The prices of rhino horn found during
the research for this study were significantly lower than the widely quoted
US$65,000 per kilogram at the wholesale level in Asian countries.a The average price found was US$24,300; lessthan half of the prices frequently
reported by media sources.

WORLD WILDLIFE CRIME REPORT 2020

The price data used in this report fordestination countries is based on two
main sources: Stoner et alb who collected prices between 2015 and 2016
in a village in Viet Nam that held at
this point more than one ton of rhino
horn products (see Case study 3), andprices provided by the Wildlife JusticeCommission c and the Environmental
Investigation Agency.d The majority ofprices was collected by Stoner et al.
In the absence of more detailed pricedata, it is not possible to assess whether
the high prices cited in the media (whichappear to date to 2012) have been
overestimated and/or were higher than
the now observed prices due to differences in the market structure. There areindications for an actual reduction in
prices (see Chapter 3 and Stoner et al.
2018, note b), but it remains unclear if

118

Box 6: Price building
at the retail level

the reduction can explain the magnitudeof the differences in prices.
At US$24,300 per kg of raw rhino
horn, rhino horn might not be morevaluable than gold. It is, however, as
the efforts made to poach rhinos show,
still a highly sought-after product thatyields sound revenues to those involvedin the trade.
aTracking down this number was challenging. In their oft-quoted article,
Biggs et al. (Biggs, D., Courchamp,F., Martin, R. and Possingham, H. P.,‘Legal trade of Africa’s rhino horns’,
Science, 339(6123), 1038-1039, 2013)
list US$65,000 per kg as price, naminga National Geographic blog entry as
a source (Record 618 South African
Rhinos Poached for Horns in 2012,
so far, 11 December 2012, available
at: https://blog.nationalgeographic.
org/2012/12/11/record-618-southafrican-rhinos-poached-for-horns-in2012-so-far/). This source appears to
be a dead end, however, as it does notprovide the origin of this number.
b Stoner, S., Verheij, P. and Jun Wu, M.,‘Illegal rhino horn trade in Nhi Khe,
Viet Nam,’ UNODC Forum on Crime
and Society, Vol. 9, Nos. 1 and 2,
2018.
c In litt.
d In litt.

600%

The large differences in retail pricesof ivory and rhino horn are due tothe large variation in quality andartistic value of the products. A
product carefully crafted by handcommands higher prices than aproduct that is produced (partially)by machines.
The material used can make a difference too. Stoner et al.a noted forrhino horn that “the structure andcolouring of a rhino horn differs frombase to tip. If a segment of rhino
horn is cut from the middle and held
up to the light, it has a translucent,amber glow. In contrast, horn tips
are compressed, almost black, andthe material is much firmer than thebase of the horn. Colour and density
can affect the price. In general, theblacker the horn, the more expensive it will be.
The most precious part is the core,sometimes referred to as the“meat”, where it is darkest, gradually fading into brown, red, yellow
and even white in successive concentric rings towards the surface. The
tip is the most expensive part of thehorn because that is believed to bewhere the energy of the rhino is concentrated.”

Ivory as a material is more homogenous, although the products arevery diverse. Ivory products range
from machine-produced chopsticks
or bangles to highly artistically
crafted whole tusks with respective
great variations in prices.baStoner, S., Verheij, P. and Jun Wu,
M., ‘Illegal rhino horn trade in
Nhi Khe, Viet Nam,’ UNODC
Forum on Crime and Society, Vol. 9,
Nos. 1 and 2, 2018.
b See Gao, Y., and Clark, S. G.,‘Elephant ivory trade in China:
Trends and drivers’, BiologicalConservation, 180, 23-30, 2014
for a detailed discussion on ivory
products.

Supply and value chains and illicit financial flows

8
Box 7: Market size, illicit income and expenditure
The market for a product involves all
buyers and sellers of the product in acertain geographic region. Its size canbe determined by the number of buyers
and sellers, the amounts traded and therespective prices.
Illicit gross income ( market value orsales) is the value of illicit goods andservices produced in a given period (forexample, a year). The value is determined as quantity multiplied by price,where prices need to correspond to thegeographic extension of the market
under consideration. In a global market,
gross income is represented by retailprices and corresponding quantities soldat retail; in a country, the appropriate
prices may be domestic retail prices
multiplied by domestic consumption andexport prices multiplied by the amountsof goods exported.
Gross income =Quantity purchased * Price.

The available data did not allow for acomprehensive estimation of costs andnet income, although understanding
the cost structure affecting different
actors would provide insights into thetrade business models.

The costs of theillicit trade

Intermediate expenditure is the valueof inputs acquired to produce the illicit
goods and services over a given period.
The value of inputs is determined as
quantity multiplied by price. Intermediate expenditures for poachers may
include lodging, transportation, guns orbribes to persons facilitating the trade.
Intermediate expenditure for traffickers
includes the costs for purchasing raw
material (for example, the payments
traffickers make to poachers), but also
others, such as expenditure for transportation or bribes.
Illicit net income of an actor or a groupof actors is the illicit gross income minus
intermediate expenditure. Illicit net
income is the income available to an
actor after accounting for costs.
Net income =Gross income - Costs.
Net income is the income that remains
with the actors after accounting for their

These costs can be substantial. Casestudy 1 (p. 121) shows that the costsof purchasing and transporting ivory
for international traffickers can makeup from two-thirds to 90 per cent of
their gross income, with bribes alone
making up 4 to 10 per cent of thesales value. A different study56 on
smuggling in South-East Asia foundthat border officials were paid an‘unofficial fee’ from US$10-20 per
shipment.

Organizing crime can be costly. The
illegal trade in ivory and rhino horn
comprises all activities also found in The possible cost components can be
the legal sphere, such as the procure- grouped into four broad categories.57
ment, production, transportation,
sales and distribution of commodities; - -- Operational costs, which arecosts encountered in activiand all these activities are associatedties required to facilitate thewith expenditures for the organizers.
smuggling. Examples are transOperations of an illegal nature require
portation, labour, material andadditional precautions to evade detecother inputs.
tion, arrest and prosecution by law
enforcement, to mitigate the risk ofinterception, and to conceal or erase - -- Concealment costs, stemmingfrom the actor’s activities totraces that may lead to the organizers
conceal and disguise their operthemselves.
ations. These costs comprise, forexpenditures.a Net income is considered
to be the more suitable metric for comparing the amounts of money made byactors.
Illicit income generation refers to alltransactions that are carried out in acertain illicit productive process (supply
chain) where profits are made. Here, it
refers to all transactions directly related
to the trade in ivory or rhino horn.
Income generation can be represented
by three main aggregates: gross income,intermediate expenditure (or intermediate cost), and net income or value
added.
Once the illicit income is generated, it isused by the actors. Income management refers to all transactions of illicit(net) income outside of income generating activities, such as purchasing property or movement of funds to offshorebank accounts.
aThis corresponds to the value added innational economics.

example, the costs for concealment in transportation (such as
hiding products in legal shipments), financing safe houses
used for hiding products, or purchasing custom-made vehicles (ormodifying existing vehicles) totransport illegal commodities.
- -- Evasion costs, associated withevading arrest and prosecution
by law enforcement. Organizersof large-scale operations employ
intermediaries to distancethemselves from the poaching
offence and from the goods andservices trafficked. They use
complex structures to launder
the proceeds of crime into legal
businesses, use non-traceable
ways for monetary transactions(including nominee accounts andshell companies) and pay othercriminal organizations to protect
their contraband (security payments).

119

SUPPLY AND VALUE CHAINS AND ILLICIT FINANCIAL FLOWS- -- Corruption costs, that can bepart of any of the above or aseparate category. Corruption
costs are payments (bribes) togovernment officials and othercorruptive acts or that facilitate
the illegal trade at all levels.

Each link in the supply chain faces
different costs, and the costs can varysignificantly between cases, dependingon the business model, the size of theoperation and the modus operandiof the organized crime group. Analysing the possible cost components
by group of actors yields insights into
their finances and helps to shed lighton the motivations for choosing one
business model over the other.

Poachers and first-leveltraffickers
The costs of poaching operations canvary substantially and depend on thebusiness model under which poachers operate. Independent poachers
finance their own guns, ammunition, food and transport. To makeup for their expenses, these poachers may achieve higher prices thandependent ones, who are hired andsubsidized by individuals higher up in
the supply chain. Dependent poachers are thought to have less influenceon the price building process thanindependent ones.58

WORLD WILDLIFE CRIME REPORT 2020

The differences in prices between ivory
and rhino horn are substantial. At thepoacher’s level, a kg of rhino horn is
55 times more valuable than a kg ofivory and a poached elephant yields
on average some US$1,000 for its
ivory,59 but a rhino some US$24,000
for its horns.60
These differences may not directlytranslate into a difference in net
income of the same magnitude. There
are indications that rhino poachers may face – on average - higher
costs than elephant poachers. The
data available on the costs of poaching is scattered for both species.
Fenio61 obtained data from in-depth

120

interviews in communities whererhino poaching takes place. The interviewed persons reported that poachers
spend between three to four days on ahunt, and community members canmake up to US$1,000 per night forproviding shelter to poaching gangs(some nights however may be spentin the bush). That shows how muchincome poaching can bring to local
communities.

as traditional and highly prized meat,with a considerable cash value, evenin poor areas. The estimated income
made from the ivory of a poachedelephant may thus underestimate
the overall income made from anelephant.

Elephant poaching thus appears not
to be in the hands of few, highlyorganized groups, but more an activity conducted as one of many different
Other cost components depend on strategies to build one’s livelihood.
the methods used. Cost components In contrast to rhinos, which mostly
identified in the literature include live in heavily monitored nationalcosts for guns and rifles,62 transporta- parks, elephants can in some placestion,63 the use of helicopters,64 bribes be hunted with little risk of detecto law enforcement, and other equip- tion, and indeed, all the interviewees
ment such as tranquilisers to sedate of Leggett and Salgueiro69 in thethe animals before harvesting the researched parks perceived the riskhorn.65 All these require well-organ- from law enforcement as marginal.
ized logistics and substantive up-front
investments.
All these findings rather speak for
low-cost operations with little risk of
Such sophisticated methods do not detection, which can be an indication
seem to be applied for killing ele- of why elephant poaching is profitaphants. Elephants are more easily ble70 even when much lower prices areaccessible due to the larger popula- obtained than for rhino horn. Thistion size and the fact that populations however does not exclude that highly
are more wide-spread. Leggett and organized elephant poaching operaSalgueiro66 researched the motiva- tions are being conducted.
tions of elephant poachers in selectedareas of the Central African Republic. Acknowledging the limitationsof transferability of the findings to Little is known about runners andareas other than the studied one, brokers who link poachers withthey found that hunting remained international traffickers. The services
an important part of the livelihoods provided by this group71 encompassesof many people, including elephant everything from collecting and storhunting.
ing the ivory to concealing it fortransport to paying off law enforceThese findings can be indications that ment officers. It is used by those whoelephant poachers are operating – on have the funds available to distanceaverage – more opportunistically, are themselves from handling the contraless specialized in hunting elephants band to evade arrest.
and might therefore employ simpler
and less costly methods of hunting
than rhino poachers. Moreto andLemieux67 reported the use of snares, Intercontinental trafficking of large
wire traps, poison or nails to catch shipments from Africa to Asia requires
elephants, and spears as weapons to well-organized logistics, and illegal
kill the trapped animals.
operations have unique requirements
in terms of routing and transportation
Another difference may lie in profits: that make them distinct from legal
in addition to the income made from trade. Trafficking logistics are specifivory, elephant meat was mentioned68 ically designed to evade detection by

Runners and brokers

International traffickers

Supply and value chains and illicit financial flows

8
Case study 1: “The Shuidong connection” - the gains and costs of trafficking
In 2017 an organized crime group(OCG) trafficked three tons of ivory fromAfrica to Shuidong in China. The case
led to convictions of several individuals
in 2019 by the Anti-Smuggling Bureauof China Customs.a
The case provided evidence for a numberof distinct practices:b• The OCG consisted of individuals operating from China.c
The OCG employed locals in Africa tocollect and store the tusks in order tominimize physical contact with the ivory.

•

The group chose complex trade routes
with multiple transit ports such as
Mombasa (Kenya), Singapore, Busan(Republic of Korea), and Hai Phong(Viet Nam) for shipping products fromAfrica to China.

•

The OCG used a variety of legitimate
products to conceal several tons of ivory
in containers. The goods used to conceal
ivory included plastic pellets, sea shells,
peanuts and tea leaves.

•

All payments in Africa were made in
US dollars, with the group using blackmarket moneychangers based in Dar es
Salaam (United Republic of Tanzania)
and Pemba (Mozambique). Money waspaid in Chinese renminbi into designated accounts in China, after which
local moneychangers in Africa were
informed, who then provided the cash
for collection in dollars.

The traffickers who were arrested
financed the operation and madeUS$720 per kg of ivory, yielding a grossincome of US$2.16 million. After
deducting costs of the operation, net
earnings of US$80 to 240 per kg or
US$234,000 to 720,000 per operation
remained for the group of at least three
persons.
The information presented on this operation highlights the following:
A single shipment can result in a noteworthy gross income; the remaining net
income may be much smaller (here,
between 10 and 30 per cent of the grossincome).
A single shipment of large size requiresa large number of persons involved andthe organizers behind the trade use

Fig. 11complex structures to distance themselves from the predicate offence ofpoaching.
The high volumes of funds involved
show potential to use financial investigations to identify and prosecute theorganisers of the tradea

Details on the case can be found here:
Environmental Investigation Agency(EIA), The Shuidong Connection:
Exposing the global hub of the illegal
ivory trade, 2017.
b Ibid.
c World Customs Organisation, ‘China
Customs disrupts major wildlife traf­
ficking syndicate, WCO News 88 –Panorama. Details on the case can befound here: Environmental Investigation Agency (EIA), The Shuidong
Connection: Exposing the global hub of
the illegal ivory trade, 2017.”

Gross and net income (US$ per kg) of ivory
traffickers in the “Shuidong Connection”, 2016.
Poacher, US$ 90•

Customs, US$ 50

Net income
US$ 158

Collectors
US$ 250

Costs

Freight agent
US$ 150
Coordinators
US$ 22

Source: See footnote aTable 3
ACTOR
Poachers
Collectors of ivory (low to midlevel traffickers), packers in Africa
Customs (bribes)
Freight agent onwards trafficking
Coordinators of the shipments
Net income traffickers

Costs for traffickers and net income of a single
shipment of ivory from Africa to Asia.
PRICE PER KILOGRAM (US$)

OVERALL EXPENDITURE (US$)

80-100240,000-300,000

200-300

600,000-900,000

30-70
150
22
80 – 240

90,000-210,000
450,000
66,000234,000 – 720,000

Source: See footnote a

121

SUPPLY AND VALUE CHAINS AND ILLICIT FINANCIAL FLOWS

law enforcement and to reduce therisk of interception.

The main means of transport for rhino
horn appears to be air. Between 2014
and 2019, 62 per cent of all rhino
All this can be costly. In an excep- horn was seized in air traffic. The
tional case study, EIA documented a second largest quantity was seizedshipment of three tons of ivory from on the road (31 per cent), together
Africa to Asia, including all the logis- accounting for 93 per cent of alltics and costs that the traffickers faced seized weight. Ivory on the other(see Case study 1).
hand was seized in largest quantities
in maritime traffic (62 per cent), followed by road (14 per cent) and air(10 per cent).

How traffickers may
decide their modus
operandi

The means of transport, routes, concealment methods and the logistics
involved are strongly interlinked as
one determines the other. How traffickers or trafficking groups makedecisions may differ from operation
to operation and may be led by different circumstances and need including
a drive to minimize the costs of theoperation while maximizing theincome.

WORLD WILDLIFE CRIME REPORT 2020

When choosing their modus operandi,organized crime groups may compare
expected costs and income. Expected
costs involve all costs related to thetransportation logistics, including
bribes, and the perceived risk of losing
a shipment to law enforcement or
being arrested. The expected income
is the income that can be achieved
when successfully selling all illegal
products multiplied by the probability that the sale will be completed.
A basic distinction can be madebetween choosing to ship small orlarge amounts. Whole rhino horns
seized between 2014 and 2019 had a
median weight of 4.4 kg per seizure;
2 per cent of seizure cases were larger
than 100 kg (accounting for 28 percent of seized weight) and none werelarger than 500 kg.72 Ivory seizures
had median weight of 12.8 kg per
seizure, and 18 per cent of seizures
were larger than 100 kg, and 7 percent larger than 500 kg (accounting
for 79 per cent of seized weight).73

122

these are potential weaknesses thatcan be exploited by law enforcement
and thus increase the risks of detection. However, due to economies ofscale, costs per unit may decrease
and the returns on investment could
increase.

Lastly, more complex operations use
the services of persons specialized in
facilitating the movement of large
amounts of money across borders.
While the intra-African trade of
Larger shipments promise higher ivory and rhino horn is reportedly
income per operation but require mostly financed by cash transactions,74
larger upfront investments and transferring larger amounts of moneystronger logistics. A large shipment from destination to source countries
requires logistics on the ground in requires formal or informal money
source and destination countries. service providers. These services, in
Products need to be purchased and particular when operating in the illecollected, stored, then packed, moved gal sphere, incur costs that need to
to a seaport and transported to the be priced in.
destination country. The logistics,
personnel and cash requirements can Smaller scale shipments, on the otherbe substantive and require up front hand, involve – in all likelihood – lessinvestments to purchase all the ivory complex structures. Trafficking aneeded (see Case Study 2). Logistics small number of rhino horns requires
in destination countries involve the less upfront investment, storage orneed for buyers and storage for the personnel handling the products in
product if it cannot be sold imme- source countries. Finding buyers indiately.
destination countries may be easier,and in demand shipments (forThere are differences in the personnel example, by mail order or throughrequirements, too. Large shipments internet-based trade) link the trafrequire more personnel, more trans- ficker directly to the end consumer,
actions and more communication cutting costs for intermediaries.
between the persons involved. All

Fig. 12 Means of transport for ivory and rhino horn,as percentage of total weight seized, 2014-2019
Rhino horn

62%

Ivory tusks

2%

10%

0%

31%

75%

20%
Air

4%

14% 1%

40%

60%

Maritime

Road

80%
Other

Source: UNODC World WISE Database
Note: Based on seizures where information on means of transport was available (236 ivory seizure cases and 144 rhino
horn seizure cases). “Other” includes mail, rail and seizures that took place e.g., in a house or other stationary place.

100%scenarios (more complex operations
may allow the organizers to distancethemselves from the products more
effectively) and may affect pricing.

The risk, or perceived risk, of being
intercepted may vary in the different

Case study 2: The ivory queen
UNODC’s SHERLOC database contains
a significant case (“The ivory queen”)
involving the conviction of a major
ivory trafficking ring.a The following are
extracts from the case documentation.
The case received wide attention fromthe media. The main perpetrator wassoon after referred to as the “Ivory
Queen”. Intensifying public interest in
the case was the long period of timethe illegal business was maintained(14 years); the amount of money
generated; the iconic specimen trafficked (elephant ivory); and the factthat a female foreigner, who held apublic position, was heading the illegal
operations.
Adding to the severity of the case was
the fact that the main perpetrator was
involved in several public and private
engagements during the time of herarrest. She was the vice-president of
the China-Africa Business Council andoperating a Chinese restaurant as wellas an investment company in the
United Republic of Tanzania. Moreover,
she was fluent in Swahili, having lived
in Tanzania for several years.
In 2015, three perpetrators were foundguilty of running one of Africa’s biggest ivory smuggling rings in Dar Es
Salaam, United Republic of Tanzania.
The three individuals smuggled 860
elephant tusks, worth more than 5.4
billion Tanzanian shilling (around
US$2.5 million) between 2000 and
2014.
In total, 11 witnesses testified against
the trio. They were able to report thatthe head of the operations received
ivory tusks from the other two perpe-

trators and shipped them through theport of Dar Es Salaam to Asia.
The witnesses were individuals that
had been contracted by the perpetrators in functions such as security guard,
taxi driver, waiter or banker. The perpetrators denied all accusations; however, the considerable evidence led thejudge to sentence each of the three
individuals to 15 years’ imprisonment.
The court ordered the confiscation of
the buildings used for the illegal operations and a fine double the value ofivory trafficked.
Some details from the court records:• One of the witnesses worked at abank where two of the offenders heldbank accounts. The bank statementsthat showed the transactions proved
the business relationship of the two
individuals to the court.
The convicted Tanzanian citizens
were tasked with collecting ivory fromvarious places, and the operations ofthese two were financed by the Chinese
citizen.

•

The trio used property in the country
to store and hide tusks for later shipment.

•

The offenders kept books of theiroperations, which helped the court toestablish that 860 tusks had been trafficked over the time period.

•a

UNODC, Sharing Electronic
Resources and Laws on Crime (SHERLOC), Case Law Database, available
at: sherloc.unodc.org. Case number
TZAx002.

RetailSupply and value chains and illicit financial flows

In small shipments, the per-operation gross income is smaller; however,
low-level logistics can reduce costs
drastically and the remaining net
income can be considerable.

8

Retailers sell the illegal products
directly to end consumers. Retailers may operate openly in shops or
hidden, with remote communication
with customers if the selling is, forexample web-based.

Box 8: Economic
damage caused by
seizuresIntercepting wildlife contraband
reduces the amount of productavailable on the market and acts asa deterrent to criminals, as seized
contraband is an economic loss for
those trafficking it.
The damage caused by a seizure isaffected by the mark-ups in the
supply chain. a With an increasing
value and increasing mark-ups, thevalue of the products seized closer
to the destination is much higher
than the value of products at lower
levels. With that, the costs of
replacing seized products in source
countries are much lower for organized crime groups than the cost of
replacing the same amounts seized
at the retail level.
By weight, most of the products
seized come from large seizures at
the international trafficking level(such as intermediaries, importers/
exporters or wholesalers in Asia).
The monetary loss of trafficking
chains is thus not reflected by theretail prices that would have been
accrued, but in the prices at thelevel where the seizure is made.
a

For a discussion of drug markets
see: Caulkins, J. P., and Reuter, P.,’What price data tell us about drug
markets’, Journal of drug issues,
28.3: 593-612, 1998.

123

SUPPLY AND VALUE CHAINS AND ILLICIT FINANCIAL FLOWS

Depending on the risk level for selling of ivory and rhino horn, retailsellers may openly operate as any
legal business or may have to resort
to clandestine operations (see Casestudy 3 for a detailed description).
An important element of the retailmarket is the quality of the product.
Higher quality products require morelabour inputs than lower quality ones,
but can achieve higher profits.

Illicit financial flows
Volumes of IFF from ivory
and rhino horn(for example, originating in criminal activities or tax evasion), illicitlytransferred (for example, violating
currency controls), or illicitly used(for example, for financing terrorism).
IFFs concern the exchange of value,
which includes currency but also theexchange of goods and services andfinancial and non-financial assets.77
As such, IFFs are a flow measure as
opposed to illicit income which measures a stock. ‘Cross-border’ meansthat an exchange is made between aresident and a non-resident of a country, regardless of their geographicallocation.78

IFFs can emerge at various stages ofillicit activities, relating to different
The 2030 Agenda for Sustainable actions and exchanges. A basic disDevelopment75 identified the reduc- tinction of transactions can be madetion of illicit financial flows (IFFs) as based on their purpose: transactions
a priority area to build peaceful soci- can be performed for either genereties around the world. Countering ating or managing income. Income
IFFs is considered a crucial compo- generation describes transactions
nent of global efforts to promote that directly generate illicit income
peace, justice and strong institutions or that are performed in the context
as reflected in the SDG target 16.4.76 of the production of illicit goods andservices (for example, for purchasing
IFFs are cross-border flows of necessary inputs). Income manageresources that are illicitly generated ment describes transactions related tothe use of the illicit income for investment in financial and non-financial
assets or for consuming goods andservices.79 An income managementtransaction would be acquiring realestate with illicit income in a different
country.
The overall volumes of IFF in theillegal trade in ivory and rhino horndepend on the number and size ofcross-border transactions of the illicit
income. The larger the volumes thatare transferred across borders and themore frequently such transactions
occur along the supply chain, thelarger the related IFFs are.
In terms of income generation, theoverall number of transactions
constituting IFF depends on the (geographical) complexity of the supply
chains. If supply chains are shortand final products are sold directlyfrom the source to the destination
country, only a few cross-bordertransactions are involved. If complex
constructs involve actors from many
countries, more complex cross-bordertransactions are made, which in turnincreases the overall volumes of IFF.

WORLD WILDLIFE CRIME REPORT 2020

Box 9: Major rhino horn seizures in air cargo
Viet Nam

Hong Kong, China

TurkeyOn 25 July 2019, at the warehouse of
the Noi Bai Cargo Terminal Service JSC(NCTS), Viet Nam, national authorities
and the Viet Nam Institute of Ecology
and Biological Resources inspected 14
suspicious packages. The packages weretransported from the United Arab Emirates via airplane to Noi Bai International Airport.

On 5 April 2019, Hong Kong Customs
seized 82.5 kg of suspected rhino hornwith an estimated market value of about
US$16.5 million from a trans-shipment
cargo at the Hong Kong International
Airport. This was a record seizure of suspected rhino horn in the past five years.

In February 2019, a Turkish customs
enforcement team confiscated 21 rhino
horns, and seven packs of wild animal
claws at Istanbul Atatürk Airport.
Authorities through X-ray imaging
detected horn-shaped objects in thesuitcases belonging to two suspectedpassengers reportedly flying fromSouthern Africa to East Asia.

The forces identified 55 rhino horn
pieces with a total weight of 125.15 kg.
The horns were hidden inside gypsum
blocks to evade detection.
Source: Customs news under the general
department of Vietnam customs, “Holding
in custody 125.15kg of rhino horn transported
to Noi Bai International Airport”, press
release, https://customsnews.vn/holding-incustody-12515kg-of-rhino-horn-transported-to-noi-bai-international-airport-11467.
html

124

Customs officers screened cargo that
arrived from South Africa with Malaysia
as its destination. The cargo was
declared as “auto parts” but suspicious
X-ray images alerted the authorities.
The seizure was made subsequent to the
opening of the consignment.
Source: The Government of the Hong
Kong Special Administrative Region, Hong
Kong Customs makes a five-year record seizureof suspected rhino horn under smuggling,press release, 6 April 2019.

Turkish police detained the two passengers for carrying rhino horns.
Source: Hurriyet Daily News, Rhino horns
seized at Istanbul Ataturk Airport, February
2019 (available at: https://www.hurriyetdailynews.com/photo-rhino-horns-seized-at-istanbul-ataturk-airport-141102#photo-1).

Supply and value chains and illicit financial flows

8
Case study 3: Retail sale in South-East Asia
Stoner et. al.a and the Wildlife JusticeCommission documented the illegal
trade in rhino horn products in a village
in Viet Nam in 2015 and 2016. The
research was based on six field investigations in the village over the course of
July 2015 to October 2016, and on
monitoring of 36 Facebook and 27
WeChat accounts to detect illegal advertisement and sales of wildlife products.
The following summarizes the findings.
The rhino horn trade in the village
catered to tourists mainly interested
in ornamental objects, rather than medicine. The larger shops in the market
arranged the smuggling of products into
China. The traders used Chinese terms in
relation to the illicit trade and prices
were primarily quoted in Chinese renminbi. The traders were found to use
Chinese bank accounts for the receipt of
payments for wildlife products. In addition, an emerging trend of Chinese
buyers using WeChat Wallet to pay Vietnamese suppliers was identified. This isa payment application within the instantmessaging service WeChat.
During the one-year research, large
amounts of rhino horn, ivory, tiger andother illegal wildlife parts and products
were found for sale. The quantity of raw
and processed rhino horn aloneamounted to an estimated 1,061 kg,
corresponding to between 401 and 579
rhinos killed.b Since about 1,000 rhinos
have been poached annually in theyears prior to the research, and far lower
volumes before 2013, this represents a
substantial portion of the global market.

Stoner et. al. estimated the retail valueof the rhino horn items observed
between 2015 and 2016 at US$42.7
million. While profit margins were notestimated, this represents a significant
sum, given the limited number of traders identified and the size of the village(in 2016, an estimated 600 families
lived in the village).
The retail outlets had a number of policies in place similar to those of legitimate businesses, including:• Volume discounts;
A deposit policy (usually quoted
at between 20-30 per cent);•

Refunds for shipments interceptedby enforcement agencies;••

Use of international bank accounts.

The traders offered delivery services forrhino horn products to China. The strong
preference for certain delivery points
suggested that their ability to offer thisservice was dependent on connections to
specific locations where, according to
the trades of the village, border control
officials could be corrupted. Investigators observed that the delivery services
were important to Chinese customers.
The fee requested varied by destination,
an average of US$357 per kg wascharged for delivery to Pingxiang, on theborder, and an average of $893 fordelivery to Fujian Province, which lies
further away. In addition to corruptionof border control officials, interviewed
traders suggested that local police corruption was essential to their businessmodel.

Many of the traders used social media
platforms for advertising their products,
with WeChat and Facebook being theplatforms of choice. While fewer traders(some 10 per cent of all observed) usedboth platforms to advertise their products, others displayed a clear preference
for one or the other, possibly indicating
the target audience, given that Facebook is not available in China while
WeChat is a Chinese platform.
aStoner, S., Verheij, P. and Jun Wu, M.,‘Illegal rhino horn trade in Nhi Khe,
Viet Nam,’ UNODC Forum on Crime
and Society, Vol. 9, Nos. 1 and 2, 2018.
b Stoner et. al. used the following calculations. Raw horn: in 2015, only front
horns were observed, therefore, one
rhino horn or rhino horn tip was taken
to represent one rhino. During 2016,
several back horns were observed inaddition to front horns; one rhino hornor rhino horn tip was considered to represent a minimum of half a rhino, anda maximum of one rhino. For processedrhino horn products, the total weightrecorded was divided by 2 kilograms,
which was the average weight of rhino
horns observed.

125

SUPPLY AND VALUE CHAINS AND ILLICIT FINANCIAL FLOWS

Fig. 13 Illicit income and illicit financial flows

IVORY
Illicit financial flows
in income generation

Illicit income
from the illegal trade

Illicit financial flows
from the income management

US$10 – 570 million

US$400 (310 – 570) million

No estimate available

Illicit gross income?

Illicit net income=
Illicit gross income–
Intermediate expenditure
IFFs cross borders

IFFs cross borders

RH IN O H ORN
Illicit financial flows

Illicit financial flows

in income generation

Illicit income
from the illegal tradefrom the income management

US$24 – 390 million

US$230 (170 – 280) million

No estimate available

Illicit gross income?

Illicit net income=
Illicit gross income–
Intermediate expenditure
IFFs cross borders

IFFs cross borders

Note: Illicit financial flows are cross-border flows of illicitly generated, transferred or used income.
IFFs emerge from the trade in ivory and rhino horn (income generation) and from the use of thegenerated net income for consumption or investment outside of the supply chain (income management).

WORLD WILDLIFE CRIME REPORT 2020

Illicit income is the money made from the illegal trade by all actors in the supply chain. It is the valueof all goods traded and can be broken down in illicit net income and intermediate expenditure.

126

8

Overall illicit
income generated

Net income is used for:investments/savings
or consumption of
goods and services

Supply and value chains and illicit financial flows

Fig. 14 Streams of illicit income management (IFF and non-IFF)
Capitalize/savings andconsumption canbe domestic (no IFF)
or international (IFF)

Investment

Illicit grossincomeDomestic

Consumption of goods
and services
Illicit net income:
Income available
after accounting
for expenditure inincome generation

Investment (IFF)International(IFF)
Consumption of goods
and services (IFF):

The overall volume of the transactions
depends on the value that is transferred between the trade levels.
The volumes of illicit income moved
across borders for income management depend on a variety of factors,
all of which are more challenging toestimate and monitor than volumes
illegally traded and their value. A few
possible determinants can be listed
without claiming to be comprehensive (for more details see Box 10):
- -- Only income that is available tothe actors can be moved abroad.
The available income is part of
the net illicit income, but not
all net income is available forcross-border movements. At
least some of the illicit income
generated will likely remain in
the country where the illegal
activity takes place80 to be used
for daily, ‘normal’ expenditures
such as housing, transportation,
food and other daily needs.

- -- The structure of the illicit market

can play an important role. In a
competitive market that involves
a large number of small-scale
players, the net income available

may be smaller and more evenly
distributed. In such a scenario,
there are no players making
excessive profits that may benefit
from being moved abroad. If, on
the other hand, the international
trade is in the hands of a few,
highly successful organized crimegroups,81 these groups may makesubstantive amounts of moneythat they might move abroad.
- -- The proportion of net income

moved abroad depends on theactors’ propensity to invest andconsume internationally rather
than investing and consuming
domestically. This in turn may
be determined by their personal characteristics/attitudes/
preferences as well as structuralcharacteristics of the country
in which the illicit income isgenerated.

Numerical examples anda simulation study

or ivory (income generation flows).
However, by using different scenariosand numerical simulations,82 an orderof magnitude of the IFFs involved canbe mapped out. The scenarios considered were based on possible numbersof transactions along the supply chain(length of the supply chains) and on
different proportions of volumes
transferred that constitute IFFs (forexample, only a certain proportionof wholesale-retail transactions crossa border and thus constitutes an IFF).
The possible range of IFFs for the scenarios considered was for rhino horn
between US$24 and 390 million ayear and the average of all scenarios was $163 million. For ivory, theminimum was $10 million and the
maximum $570 million with anaverage value of $240 million. 83 The
IFF do not include bribes or income
management flows; if these were
included, the resulting IFFs would
be correspondingly larger. The results
show that the volume of IFF could
be almost twice as large as the overallillicit income generated.

The available data were not comprehensive enough to produce a The more complex the supply chainsstatistical estimate of the overall IFFs (the more actors are involved), thefrom the illegal trade in rhino horn more complex and diverse the127

SUPPLY AND VALUE CHAINS AND ILLICIT FINANCIAL FLOWS

Box 10: Illicit financial flows from income management:
possible drivers and motivations
Illicit financial flows from income management are challenging to measure.
There is no standardized way to assess
the proportion of illicit net income
moved abroad, nor to measure howmuch illicit income enters a country
from outside. Direct measurement methods (for example, based on identifying
illicit transactions) are difficult to
employ as the money-laundering process is clandestine in nature. The following presents an initial list of factors thatmay drive individuals to send illicit
income to another country (push factors)
and factors that may influence the decision of the destination of the funds (pullfactors).
Push factors: motivating people tosend their illicit income abroad
Most push factors that apply when legal
income is invested abroad apply to illicit
income, too. Reasons to invest or spend
the illicit income abroad may include,for example, buying products and services that do not exist domestically or
not at the desired prices or quality,
sending money to family/friends abroadin the form of remittances, diversifying
investment or increasing the security ofinvestments (for example, against political instability or currency crises).

WORLD WILDLIFE CRIME REPORT 2020

There are, however, factors that are specific to (large amountsa of) illicit income.
Concealing illicit income and moving it
abroad requires some effort and may
incur costs. It may therefore be – allother things being equal – the preferable choice to keep illicit income in the
country where it was earned. There are,however, certain reasons that push individuals to spend/invest illicit income
abroad.
Avoiding scrutiny from law enforcement. Sending illicit income abroad can
reduce (perceived) scrutiny from law
enforcement. The degree to whichdomestic law enforcement is effective in
detecting and confiscating the proceedsof crime may push illegal income toother countries.
Avoiding scrutiny from family andfriends. Illicit income may involve a
degree of stigma and maintaining alifestyle that is hard to explain by legal
earnings may cause unwanted atten-

128

tion. Individuals may therefore choose
to diversify their spending to othercountries, for example by purchasing
real estate abroad.
The political environment. Politicalinstability and a lack of trust in the government can motivate criminals to movetheir money abroad. In highly corrupt
environments, criminals may not trust
the authorities to maintain impunity
and may choose to move their illicit
income abroad to secure it in case of achange in the political environment.
Limited domestic possibilities tolaunder money. Large volumes of illegal income may call for sophisticatedmoney-laundering schemes, such asshell companies or assistance from professional money-laundering service providers.b If such services do not exist in
the criminals’ home country or if theavailable services are too costly or otherwise unfavourable, criminals may opt
to launder their proceeds via other countries.
Factors that attract illicit income
from abroad
Some research has argued that factorsthat influence consumption and savings
patterns of licit income influence consumptions and savings of illicit income,too: c if countries are likely to attract
legal income from other countries, they
may also attract illicit income. The effect
was assumed to become proportionallylarger with the level of illicit proceeds
generated in the sending countries.
Factors that have been shown to attract
income from abroad include common
borders, common languages, common
colonial legacies d, common legal systemse and common currenciesf, to mention some. For financial investments,
the size, reliability, sophistication andfinancial openness to foreign investments of the financial sector are also
likely to be factors in attracting income
from abroad.
Other factors pertain specifically to illicit
income, for example, the lack of effective measures against money-laundering. Effective measures include but are
not limited to: g Providing proper andeffective money-laundering legislation;

providing regulators, law enforcement
and supervisors proper tools, incentives
and authority to combat IFF from othercountries; making it easy and effective
for national authorities engaging ininternational cooperation regarding
money-laundering.
The availability of high-risk money-laundering products and services,hsuch as shell companies, may be anotherfactor. Such products can be used tohide the beneficial owner and provide alayer of anonymity, which make themattractive for hiding illicit proceeds. Sectors that operate unregulated are likewise commonly seen as high-risk, suchas lawyers, hawala brokers or the realestate sector, as all these operate
unregulated in several jurisdictions.i
a
b
c

d

e

f

g

h

i

Often well above the average grossdomestic product (GDP) per capita ineach country.
For more info see: Financial Action
Task Force (FATF), Professional Money
Laundering, FATF Report, July 2018.
Walker, J. and Unger, B., ‘Measuring
Global Money Laundering: “The Walker
Gravity Model”’, Review of Law andEconomics, 5 (2), January 2009.
Ekanayake, E. M., Mukherjee, A. and
Veeramacheneni, B., ‘Trade Blocks andthe Gravity Model: A Study of Economic Integration among Asian Developing Countries’, Journal of Economic
Integration, 25(4), 627-643, December
2010.
Anderson, J. E. and van Wincoop,
E., ’Trade Costs’, Journal of Economic
Literature, 42, pp. 691-751, September
2004.
Miron, D., Miclaus, P., and Vamvu,D., ‘Estimating the Effect of Common
Currencies on Trade: Blooming orWithering Roses?’, Procedia Economics
and Finance, 6, pp. 595-603, 2013.
To see more about contextual factors,
see Financial Action Task Force (FATF),
Methodology for Assessing Compliancewith the FATF Recommendations andthe Effectiveness of AML/CFT Systems,
updated October 2019.
See Asia-Pacific Group on Money
Laundering, World Bank and Financial
Action Task Force, FATF Guidance:
Anti-Money Laundering and Terrorist
Financing Measures and Financial
Inclusion, June 2011.
See Asia-Pacific Group on Money
Laundering, World Bank and Financial
Action Task Force, FATF Guidance:
Anti-Money Laundering and Terrorist
Financing Measures and Financial
Inclusion, June 2011.

To illustrate the effect of complexity
on IFF with an example, case study
4 is used. The case study includes
few details but may represent a short
supply chain. Namibia is a source
country for rhino horns. Assumingthat the suspect obtained rhino hornfrom residents in Namibia and sold it
directly to wholesalers or retailers ina destination country (China or VietNam), a single illicit financial flow
would have occurred from the destination country (outflow) to Namibia(inflow).

Fig. 15 Annual IFF resulting
from the traffickingof ivory and rhino
horn (US$ millions)2016-2018600

US$ (million)

500
400
300
200
100
0
Rhino horn

Ivory

Note: based on ~14,000 possible scenarios. The depicted
box shows the range of 50% of all values for eachcommodity; the whiskers show (here) the maximum andminimum values possible. The simulated lengths of the
supply chain followed a truncated normal distribution withmean 3.5 for rhino horn and 4.5 for ivory (to accountfor the possibly more complex supply chains of the ivory
trade), and a standard deviation of 2. The values werebased on discussed prices multiplied by the estimatedoverall amounts trafficked (point estimates) between
actors. At each trade level, a randomly chosen percentage
between 20% and 80% of volumes transferred constituted
an IFF with equal probability. Each IFF was only counted
once, either as in- or outflow, and not twice. The minima
reflect a situation when all rhino horn/ivory is purchased byforeign residents at poachers’ prices, the maxima the situation when all transactions can cross borders and are 80 per
cent IFFs. No additional flows from income management orintermediate expenditure such as bribes were considered.
Including such flows would increase the IFFs accordingly.

The case study could be part of a more
complex scenario, too. Residents
in Namibia could have purchased
the rhino horns from residents of anearby country (for example, South
Africa or Mozambique) and thensold the horns onwards to the suspect in Namibia. Further trafficking
could involve the suspect selling the
products to wholesalers in SouthEast Asia who then sold it onwards
to Chinese or other end consumers(see, for example, Mid-level traders in
Namibia.). In addition, bribes would
be paid to customs officers in transit
countries who are resident in otherjurisdictions.

for example, Case study 3), the overall amounts of IFF are much larger,
since the mark-ups between these twolevels are much higher than for theother levels. The overall IFFs are lessaffected if poachers and intermediaries are not in different jurisdictions
since the volume of transactions
between these actors is smaller.

Supply and value chains and illicit financial flows

resulting IFF can be. The illegal tradein ivory – larger in volumes and with(presumably) longer supply chains generate a broader possible range of
IFF than the illegal trade in rhino
horn. However, compared to overall
volumes trafficked, rhino horn has alarge potential for IFF.

8

The very broad range of possible
IFF volumes could be narrowed
down with better information on
the distribution networks (numberof cross-border transactions). Moreprecise estimates would be achievedby incorporating country level pricedata, and country level demand andIn addition to the complexity of the supply data. Such data could help
supply chain, the locations of the to formulate more precise model
specific actors can strongly affect the assumptions, which lead to a smaller
overall IFFs. If wholesalers and retail- range of possible outcomes.
ers are in different jurisdictions (see,Case study 4: Mid-level traders in Namibia
A Chinese citizen was arrested in a
town in north-western Namibia for
dealing in illegal rhino horns in 2014.
The man was arrested in a sting operation after police received a tip off
from members of the public that a Chinese trader had sent out people to lookfor elephant tusks and rhino horns for
him to buy. At the time of arrest, he
was in possession of two rhino horns.
Locals were given an estimation ofwhat they would be paid and contact
details of the local link up. The goingrate was said to be between US$640
and $1,300 per horn. The intermediarysold the horn for $3,200 to $5,100.
The locals were paid in cash and theChinese national did not use the bank-ing system in Namibia. It was suspected that money was to be launderedthrough legitimate businesses andfront companies in the construction,mining and tourism industries.
The case study also indicated that itwas commonly accepted locally that
the Chinese community does not makemuch use of the financial system. Theirbusinesses are cash intensive.
Source: Republic of Namibia Financial
Intelligence Centre, Trends and typology
report No 1 of 2017: Rhino and elephantpoaching, illegal trade in related wildlife
products and associated money launderingin Namibia, 2017.

129

SUPPLY AND VALUE CHAINS AND ILLICIT FINANCIAL FLOWSWORLD WILDLIFE CRIME REPORT 2020

Endnotes
1 UNODC and the Asia/Pacific Group on
Money Laundering (APG), Enhancing the
Detection, Investigation and Disruption of
Illicit Financial Flows from Wildlife Crime,
2017.
2 Ibid.
3 See Box 1
4 Every country protects its own animals,
fish, timber and other plant life in different ways. There is no international
agreement in defining wildlife crime. The
UNODC World Wildlife Crime Reportfocuses on CITES-listed species, whichalone include roughly 35,000 species, butthere are species illegally traded that are
not regulated by CITES.
5 See, for example, Convention on International Trade in Endangered Species ofWild Fauna and Flora (CITES) Resolution
Conf. 9.14. (Rev. CoP17), Conservation ofand trade in African and Asian rhinoceroses,
2016.
6 UNODC, World Wildlife Crime Report:
Trafficking in protected species, 2016.
7 Emslie, R. H. et al, African and Asian Rhinoceroses – Status, Conservation and Trade,a report from the IUCN Species Survival
Commission (IUCN SSC) African andAsian Rhino Specialist Groups and TRAFFIC to the CITES Secretariat pursuant
to Resolution Conf. 9.14 (Rev. CoP17),2019.
8 Ibid.
9 For a detailed analysis of the latest trends
in ivory and rhino horn trafficking see
Chapter 3.
10 Percentages based on seizures where thedestination of shipments was reported (seeChapter 3).
11 Supply chain actors and descriptions:
Maggs, K. (2011) and Milliken andShaw (2012) (both ibid.) and based oninterviews with experts conducted during
UNDOC background research. Within
Africa, the scheme thought to have apyramid structure, with many poachers,
fewer brokers and only a small number ofexporters.
12 Eastern and Southern Africa Anti-Money
Laundering Group (ESAAMLG), A
Special Typology Report on Poaching andillegal trade in wildlife and wildlife products
and associated money laundering in the
ESAAMLG region, 2016; Milliken, T. andShaw, J., The South Africa – Viet Nam
Rhino Horn Trade Nexus, TRAFFIC, 2012.
13 Another distinction could be madebetween targeted poaching and killings inhuman/elephant conflict. The latter were
found to be rare (see Hauenstein, S., Kshatriya, M., Blanc, J. et al. African elephantpoaching rates correlate with local poverty,
national corruption and global ivory price.
Nat Commun 10, 2242 (2019). https://doi.org/10.1038/s41467-019-09993-2)
14 Eastern and Southern Africa Anti-Money
Laundering Group (ESAAMLG) op cit.
15 For elephant poaching, annual poachingrates were found to strongly correlatewith proxies of ivory demand in China,
between-country and between-site variation was strongly associated with indicators of corruption and poverty. Hauenstein,S., Kshatriya, M., Blanc, J. et al. op cit.

130

16 Milliken and Shaw (2012), op cit.
17 Ibid.
18 Milliken and Shaw, 2012, op cit; Stiles,
D., Elephant Meat Trade in Central Africa:
Summary Report, International Union forConservation of Nature (IUCN), 2011.
19 Eastern and Southern Africa Anti-Money
Laundering Group (ESAAMLG), op cit.
20 Republic of Namibia Financial IntelligenceCentre, Trends and typology report No 1 of
2017: Rhino and elephant poaching, illegal
trade in related wildlife products and associated money laundering in Namibia, 2017.
21 Emslie, R. H. et al, African and Asian
Rhinoceroses – Status, Conservation andTrade, a report from the IUCN Species
Survival Commission (IUCN SSC)
African and Asian Rhino Specialist Groups
and TRAFFIC to the CITES Secretariat
pursuant to Resolution Conf. 9.14
(Rev. CoP17), 2019.
22 Processors could be another level in the
supply chain. Processors obtain ivory
and rhino horn from importers, process
it into ornaments or medicine and sell it
onwards to retailers. This level is omitted
in absence of respective price data.
23 Eastern and Southern Africa Anti-Money
Laundering Group (ESAAMLG), A
Special Typology Report on Poaching andillegal trade in wildlife and wildlife products
and associated money laundering in the
ESAAMLG region, 2016.
24 Moneron, S., Okes, N. and Rademeyer,J., Pendants, powder and pathways: A rapid
assessment of smuggling routes and techniques
used in the illicit trade in African rhino
horn, TRAFFIC, 2017.
25 See for example, Vigne, L., and Martin, E.,‘Consumption of elephant and mammoth
ivory increases in southern China’, Pachyderm, 49, 79-89, 2011; Gao, Y., and Clark,
S. G., ‘Elephant ivory trade in China:
Trends and drivers’, Biological Conservation,
180, 23-30, 2014.;
26 Stoner, S., Verheij, P. and Jun Wu, M.,‘Illegal rhino horn trade in Nhi Khe, Viet
Nam,’ UNODC Forum on Crime and Society, Vol. 9, Nos. 1 and 2, 2018.
27 Xiao, Y., ‘China’s ivory market after theivory trade ban in 2018’, TRAFFIC briefing paper, September 2018.
28 The following calculations apply a threeyear average to smoothen year-on-year
variations and to make data comparable toprice data.
29 Knight, M., ‘African Rhino Specialist
Group report’, Pachyderm, 59: 14-26,
2018.and Emslie, R. H. et al, African andAsian Rhinoceroses – Status, Conservation
and Trade, a report from the IUCN Species Survival Commission (IUCN SSC)
African and Asian Rhino Specialist Groups
and TRAFFIC to the CITES Secretariat
pursuant to Resolution Conf. 9.14 (Rev.
CoP17), 2019.
30 Pienaar, D. J., Hall-Martin, A. J. andHitchins, P. M., ‘Horn growth rates offree-ranging white and black rhinoceros’,
Koedoe 34.2: 97-105, 1991; Martin, E.B.,‘Rhino horn weights’, IUCN Traffic Bulletin, 5(2): 23, 1983.; Martin, E. B. andRyan, T. C. I., ‘How Much Rhino Hornhas come onto International Markets since
1970?’, Pachyderm, Vol 13, 1990.

31 Following Emslie et al. (2019, op.cit.), theaverage number of horns per rhino wasassumed to be 1.98. Numbers are rounded,calculations were done with full precision.
32 Emslie et al. (2019, op. cit.) assumed
recoveries in 9 per cent of rhino poachingcases.
33 Emslie et al. (2019 op cit.) provided estimates for the the reference period fromJanuary 2016 to December 2017; here theaverage was applied for 2018, too.
34 Analysis performed by George Wittemyer
who updated and extended the estimatespresented in Wittemyer et al. 2014 for theyears 2010 to 2018 (paper made available
to UNODC). A three-year average of2016 to 2018 was the basis for the calculations. While outputs from Wittemyer
et. al. 2014 relied on published birth anddeath rates for African savanna elephants,
the present model was updated such that
estimates for forest elephants were basedon more recently published data on forest
elephant demography (natural mortality
and natality).
35 95 per cent confidence interval (rounded).
36 UNODC approximated illegal killingrates in West Africa by a weighted averageof the subregions Central, Eastern andSouthern Africa.
37 Thouless, C. R. et. al., ‘African ElephantStatus Report 2016: an update from theAfrican Elephant Database’, Occasional
Paper Series of the IUCN Species Survival
Commission, No. 60 IUCN / SSC Africa
Elephant Specialist Group, IUCN, 2016,
p. 3.
38 More precisely, it is 10.25 kilograms (1.88
tusks per elephant with 5.45 kilogrameach); see Parker, I.S.C. and Martin, E.B.
1982. “How many elephants are killed forthe ivory trade?” Oryx XVI, 235-239. An
alternate tusk weight sometimes used is
6.9 kg per elephant, which would reducevolumes by one-third, but this figure isderived from an analysis of the average
weight of a raw ivory piece in illicit trade,
not a whole tusk weight; See Hunter,
Nigel, Esmond Martin, and Tom Milliken.
“Determining the number of elephantsrequired to supply current unregulated
ivory markets in Africa and Asia.” Pachyderm 36. January–June (2004): 116-128.
39 Martin, R.B. et. al., Decision-Making
Mechanisms and Necessary Conditions fora Future Trade in African Elephant ivory:
Final Report, CITES document SC62 Doc.
46.4., 2012, p. 16. “The mean tusk weight
for the male ivory in all age classes is
8.36kg and that for the females is 2.55kg.
This results in mean tusk weight for bothgenders of 5.45kg, assuming an evengender spread.”
40 See e.g. Chiyo, P. I., Obanda, V. and Korir,
D. K., ‘Illegal tusk harvest and the declineof tusk size in the African elephant’, Ecology and Evolution, 5: 5216-5229, 2015.
The authors found that severe ivory harvesting in the 1970s and 1980s may have
had a lasting impact on tusk sizes, since
it eliminated large tuskers among survivors and elephants born thereafter had
smaller tusks. Poaching can also favour
the prevalence of the genetic condition oftusklessness, see Jachmann, H., Berry, P.
S. and Imae, H., ‘Tusklessness in Africanelephants: a future trend’, African Journalof Ecology, 33: 230-235, 1995.
41 To approximate the effects of selective
poaching, simulation models can beapplied that model the expected population structure based on various assumptions. The models investigated for thisstudy indicated a decline of average ivory
per illegally killed elephant from over 20
kg per animal prior 2007 to only some
4 to 6 kg per animals in 2016 (Martin,R., Illegal killing of elephants and ivory
production, paper prepared for the United
Nations Office on Drugs and Crime,2019). There is, however, only limited
empirical evidence that can validate thesimulated outputs. In the subsequent
analysis, the ‘traditional’ conversion ratioof roughly 10 kg per elephant is therefore
used, while acknowledging the uncertainty
and the potential bias behind this number.
The underlying idea is that poachers facea trade-off between hunting time and tusk
size: the less frequent elephants with large
tusks become, the more likely it is thatpoachers seek out smaller elephants, whichthen reduces the average ivory outtake perpoached elephant.
42 See e.g., CITES SC65 Doc. 42.2 andSC65 Doc. 42.7, Sixty-fifth meeting of
the Standing Committee Geneva (Switzerland), 7-11 July 2014; and CITES SC69
Doc 51, Sixty-ninth meeting of the Standing Committee. Geneva (Switzerland), 27
November - 1 December 2017.
43 Paragraph 6. e) of Resolution Conf. 10.10(Rev.CoP17) urges CITES parties tomaintain inventories of government-heldand where possible significant privately
held stockpiles of ivory and inform the
CITES secretariat of the level of thisstock. CITES document SC70 Doc. 49.1
comments that the CITES secretariat isaware of a number of ivory thefts fromgovernment-held stockpiles, but “in order
to avoid elevating potential security risks,
it has not included details of the information that it has received from the Parties in[report SC70 Doc. 49.1]”.
44 Cerling, T. E., et al., ‘Radiocarbon datingof seized ivory confirms rapid decline in
African elephant populations and provides
insight into illegal trade,’ Proceedings of
the National Academy of Sciences, 113.47:
13330-13335, 2016.
45 Nkoke, S. C. et. al., Ivory markets in Central Africa, TRAFFIC, September 2017.
46 The UNODC World Wildlife Crime Report(2016) chapter on ivory explored thepossibility that ivory became an object ofspeculation and was being kept in stockpiles.
47 Wastage of ivory in the carving process
has been estimated to make up an averageof 30 per cent (see Milliken, T., ‘The
Japanese trade in ivory: tradition, CITES
and the elusive search for sustainable utilisation’, in Cobb, S. (Ed.), The Ivory Tradeand Future of the African Elephant, Ivory
Trade Review Group, 1989).
48 Conversion ratios for numbers seized to
seized weight were applied where needed.
49 Eastern and Southern Africa Anti-Money
Laundering Group (ESAAMLG), A
Special Typology Report on Poaching andillegal trade in wildlife and wildlife products

and associated money laundering in the
ESAAMLG region, 2016.
50 This stems from the assumption that theshares of rhino horn seized outside of
Africa and Asia reflect the shares tradedoutside of these regions. This is a strong
assumption, as described in Box 3.
51 While seizure data is a valuable source of
information, there are limitations as theinformation on the origins and destinations of shipments may not be reported ina systematic way, which potentially introduces bias.
52 Implying that stockpiles remain of thesame size.
53 2018 was approximated with an 20162017 average.
54 These could be for local processing andmarkets, or these destinations could be
merely way stops towards destinations outside the region. If the latter is the case fora significant portion of seized weight, theamounts reaching end-consumers would
increase accordingly.
55 Fieldwork involved interviews with law
enforcement agencies, experts on theillegal wildlife trade from academia andNGOs, and key informant interviews.
During fieldwork, 52 interviews were conducted in Central, Eastern and Southern
Africa, and numerous reference publications were studied. Additional price data
was provided by the Wildlife Justice Commission (WJC) and the Environmental
Investigation Agency (United Kingdom),
who collated price data from investigations
in destination countries.
56 Wildlife Conservation Society, In Plain
Sight: An Analysis of Transnational Wildlife Crimes in Quang Ninh Province,
Viet Nam. Hanoi: Wildlife Conservation
Society Viet Nam Program, 2012.
57 Extended from Basu, Gautam. “Concealment, corruption, and evasion: A transaction
cost and case analysis of illicit supply chain
activity.” Journal of Transportation Security
7.3 (2014): 209-226.
58 Eastern and Southern Africa Anti-Money
Laundering Group (ESAAMLG), A
Special Typology Report on Poaching andillegal trade in wildlife and wildlife products
and associated money laundering in the
ESAAMLG region, 2016.
59 Excluding potential income from sellingthe meat of the elephant.
60 Based on price data and average weights
collected per animal.
61 Fenio, K. G., Poaching rhino horn in South
Africa and Mozambique: Community andexpert views from the trenches, U.S. Department of State, November 2014.
62 An interviewee in Fenio 2014 (ibid.)reported that in their village, 7-10 people
all use (rent) one rifle and purchaseammunition for hunting rhinos. The
respondent named police officers as possible source for the rifle.
63 Fenio 2014 (ibid.) reported the widespreaduse of “high-tech 4x4” vehicles by poachers.
64 Milliken, T. and Shaw, J., The South Africa– Viet Nam Rhino Horn Trade Nexus: A
Deadly Combination of Institutional Lapses,
Corrupt Wildlife Industry Professionals andAsian Crime Syndicates, TRAFFIC, 2012.

Supply and value chains and illicit financial flows

865 Eastern and Southern Africa Anti-Money
Laundering Group (ESAAMLG), A
Special Typology Report on Poaching andillegal trade in wildlife and wildlife products and associated money laundering in
the ESAAMLG region, 2016. The rhino
subsequently dies either from an overdoseof tranquillizers or bleeds to death, usually after the poachers are gone. It is said
to take less than seven minutes to bring
down the animal.
66 Leggett, T. and Salgueiro, J., ‘The motivations of elephant poachers in the Central
African Republic,’ UNODC Forum on
Crime and Society, Vol. 9, Nos. 1 and 2,
pp. 1-16, 2018.
67 Moreto, William & Lemieux, A.
(2015). Poaching in Uganda: Perspectives of Law Enforcement Rangers. Deviant Behavior. 36. 1-21.
10.1080/01639625.2014.977184.
68 Ibid.
69 Leggett, T. and Salgueiro, J., ‘The motivations of elephant poachers in the Central
African Republic,’ UNODC Forum on
Crime and Society, Vol. 9, Nos. 1 and 2,
pp. 1-16, 2018.
70 In subsistence poaching, if nothing else isavailable, even a very low expected return
may motivate some to engage in poaching.
71 Case Study 1 referred to services provided
by this group of actors as “Dragon” service.
72 UNODC World WISE Database, basedon 350 analysed cases.
73 UNODC World WISE Database, basedon 600 analysed cases.
74 Republic of Namibia Financial IntelligenceCentre, Trends and typology report No 1 of
2017: Rhino and elephant poaching, illegal trade in related wildlife products andassociated money laundering in Namibia,
2017; Eastern and Southern Africa AntiMoney Laundering Group (ESAAMLG),
A Special Typology Report on Poaching andillegal trade in wildlife and wildlife products
and associated money laundering in the
ESAAMLG region, 2016.
75 Further information on the 2030 Agenda– including all goals, targets and indicators– is available at the United Nations Sustainable Development Goals knowledge
platform: https://sustainabledevelopment.
un.org/76 This target calls on countries to: “[b]y2030, significantly reduce illicit financial
flows and arms flows, strengthen the recovery
and return of stolen assets and combat all
forms of organised crime”. Progress towards
SDG target 16.4 (IFF) is measured byindicator 16.4.1, “Total value of inward
and outward IFFs in current United States
dollars”. The United Nations Conference
on Trade and Development (UNCTAD)
and the United Nations Office on Drugs
and Crime (UNODC) are the custodian
agencies of the indicator and have worked
jointly on a statistical definition and ameasurement framework for the indicator,
which was published in the SDG indicator
metadata repository on the SDG websiteof the United Nations Statistics Division:
https://unstats.un.org/sdgs/metadata/files/
Metadata-16-04-01.pdf.

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77 Cross-border bartering - the exchange of(here illicit) goods and services for othergoods and services that is a common practice in illicit markets - is also considered as
IFF.
78 A resident of a country has their centre of
economic interest within the country. Thisdefinition is different from a legal one andfollows the international Balance of Payments statistics, see International Monetary
Fund (IMF), Balance of Payments Manual,
Fifth Edition, 2005, para. 58. If a residentof country A pays a resident of country B
in cash, it is an IFF even if both parties areat the same location.
79 Economists distinguish between spending for acquiring utility (consumptionof goods and services) and spending for
acquiring future income, which is investment. Savings (e.g., in bank accounts for
gaining interest) are part of investments.
80 There may be cases where all the net
income from trafficking is available tothe trafficker, for example, if all daily
consumption needs are covered by other,
legitimate businesses. However, on average,some of the net income will stay in the
country where it has been generated.
81 See, for example, Case Study 2.
82 A Monte Carlo simulation calculates thepotential outcomes of a large number ofhypothetical scenarios. Its results reflectpossible IFFs depending on different
model inputs.
83 In the supply chain model used, both markets have a theoretical maximum value of
IFF transactions when all 6 different tradelevels are in 6 different jurisdictions and if
all transactions between the actors are IFF.
The resulting maximum IFF are an annual
US$540 million for rhino horn and $720
million for ivory. The maxima presented
in the paragraph are the maximum model
outputs.

132

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