A North American Perspective

Commission for Environmental

Cooperation of North America

North American Wildlife

Enforcement Group
The Commission for Environmental Cooperation (CEC) was established

under the North American Agreement on Environmental Cooperation

(NAAEC) to address environmental issues in North America from a continental perspective, with a particular focus on those arising in the 

context of liberalized trade. 

This publication was prepared by the Secretariat of the CEC. The views

contained herein do not necessarily reflect the views of the CEC, or the

governments of Canada, Mexico or the United States of America.

Reproduction of this document in whole or in part and in any form for

educational or nonprofit purposes may be made without special permission from the CEC Secretariat, provided acknowledgement of the source

is made. The CEC would appreciate receiving a copy of any publication

or material that uses this document as a source.

Commission for Environmental Cooperation

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h t t p : / / w w w . c e c . o r g

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© Commission for Environmental Cooperation, 2005

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Acronyms

Preface

1. Introduction

2. The International Wildlife Trade

3. The Illegal Global Trade in Wildlife 

4. A Global Response

5. Enforcement Cooperation Efforts in North America

6. NAWEG and the Need for North American Cooperation

2

3

4

6

8

13

17

21
CEC Commission for Environmental Cooperation

CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora

EWC Enforcement Working Group

Interpol International Criminal Police Organization

IUCN World Conservation Union

NAAEC North American Agreement on Environmental Cooperation

NAFTA North American Free Trade Agreement

NAWEG North American Wildlife Enforcement Group

NWFP nonwood forest product

UNEP United Nations Environment Programme

USFWS US Fish and Wildlife Service

WWF World Wildlife Fund

2 I L L E G A L T R A D E I N W I L D L I F E
3 A NORTH AMERICA PERSPECTIVE

I

n North America, we share a rich environmental heritage that includes air, oceans and rivers,

mountains and forests. Together, these elements form the basis of a complex network of ecosystems that sustains our livelihoods and well-being. If these ecosystems are to continue to be a source

of life and prosperity, they must be protected. Doing so is a responsibility shared by Canada,

Mexico and the United States.

The Commission for Environmental Cooperation of North America (CEC) is an international

organization created by Canada, Mexico and the United States under the North American

Agreement on Environmental Cooperation (NAAEC) to address regional environmental concerns,

help prevent potential trade and environmental conflicts, and promote the effective enforcement

of environmental law. The Agreement complements the environmental provisions of the North

American Free Trade Agreement (NAFTA).

The work of the North American Wildlife Enforcement Group (NAWEG) has been an important

component of the CEC’s work. The smuggling of rare and endangered plants and animals is a 

significant problem in North America. It is imperative that the countries of North America enhance

cooperative efforts to monitor and control legal wildlife trade and to stem illegal trade. This booklet

outlines some of the reasons why this cooperation is necessary and why groups such as the NAWEG

are important vehicles in combating the illegal trade in wildlife.

This booklet was prepared by the Secretariat of the CEC under the Law and Policy Program.

The Secretariat wishes to thank TRAFFIC North America which contributed significantly to the

development of this booklet. TRAFFIC is a nongovernmental organization whose mission is to ensure

that trade in wild plants and animals is not a threat to the conservation of nature. The Secretariat

also wishes to thank the many employees of Environment Canada, the United States Fish and

Wildlife Service, and Mexico’s Ministry of the Environment and Natural Resources whose reviews

and comments helped move this booklet to completion.
The illegal trade in wildlife is a big problem

worldwide. Domestic and international

black markets in a broad range of wildlife c o mmodities cover the globe. From animal parts

s u c h as tiger bone and bear gallbladders for the

m e d i c i n a l trade, to live reptiles and birds for the

pet trade, caviar for the gourmet food market,

rare furs and wools for the apparel industry,

elep h a n t ivory for the ornamental trade, and

orchids and cacti for the garden trade,

s m u gglers illegally traffic a staggering variety

of wild species and associated products,

often with devastating consequences for the

species involved. 

North America is a central player in the

international wildlife market as both a consumer

and supplier of wildlife products. Canada, Mexico

and the United States not only engage in direct

cross-border commerce in various endemic

North American species, but also serve as trade

conduits for wildlife products from other regions

and continents. In particular, Mexico, with its

rich diversity, represents a highly potential

exporter of wildlife and genetic resources. The

increase in trade among the three countries since

the passage in 1994 of the North American Free

Trade Agreement (NAFTA) requires closer c o o pe r a t i o n between the countries to both manage the

legal wildlife trade and combat the illegal trade.

The wildlife trade in Canada, Mexico and

the United States is regulated by national laws

and through the Convention on International

Trade in Endangered Species of Wild Fauna

and Flora (CITES), a treaty signed by all three

countries. With the passage of NAFTA, the

three countries recognized the need for crossborder coordination of common environmental

issues in North America. This recognition led in

the 1990s to the creation of the trilateral C o mm i ssion for Environmental Cooperation (CEC).

As part of this effort for closer cross-border

coordination, wildlife enforcement officials

in Canada, Mexico and the United States also

formed the North American Wildlife Enforcement Group (NAWEG) to address the specific

issues revolving around wildlife trade and

enforcement.

The chapters that follow describe a North

American perspective on the illegal international

wildlife trade and the role of CITES, the CEC

and NAWEG in combating this trade. The

overview in Chapters 2 and 3 of the global

trade—legal and illegal—in wild fauna and flora

is followed by a closer look in Chapter 4 at the

global response to the illegal trade, especially

the subset of species and wildlife products

whose international trade is governed by CITES.

Chapter 5 then summarizes the steps each of

the three countries has taken to meet its CITES

obligations and the cooperative steps the coun -

tries have taken together through the CEC and

NAWEG. Chapter 6 concludes by describing

the gaps, obstacles and challenges to improving

the implementation of CITES in North America,

and especially the role of NAWEG in that effort. 

4 I L L E G A L T R A D E I N W I L D L I F E
N AW E G

The North American Wildlife

Enforcement Group, created

i n1995, is a network of senior

wildlife enforcement officials

from Canada, Mexico and the

United States. It seeks to improve North America’s

capacity to enforce laws regulating the sustainable

use and conservation of its wildlife, particularly with

respect to the Convention on International Trade in

Endangered Species of Wild Fauna and Flora (CITES).

In doing so, it works with other cooperative enforcement and compliance programs in collaboration with

the Commission for Environmental Cooperation.

C I T E S

The Convention on International Trade in Endangered

Species of Wild Fauna and Flora grew out of a resolution adopted in 1963 at a meeting of members

of the World Conservation Union. The text of the

convention was finally agreed at a meeting of

r e presentatives of 80 countries in Washington,

DC, on 3 March 1973, and on 1 July 1975, CITES

entered in force.

CITES is an international agreement to which

states (countries) adhere voluntarily. Those that

have agreed to be bound by the convention (that

is, they "joined" CITES) are known as parties.

Although CITES is legally binding on the parties—

in other words, they have to implement the convention—it does not take the place of national

laws. Rather, it provides a framework to be

respected by each party, which has to adopt its

own domestic legislation to ensure that CITES is

implemented at the national level.

Not one species protected by CITES has

become extinct as a result of trade since the convention entered into force, and, for many years,

CITES has been among the largest conservation

agreements in existence, with now 167 parties.

C E C

The Commission for Environmental Cooperation is an

international organization

created by Canada, Mexico

and the United States under

the North American Agreement

on Environmental Cooperation

(NAAEC). The CEC was established to address

regional environmental concerns, to help prevent

potential trade and environmental conflicts, and

to promote the effective enforcement of environmental law. The agreement complements the

environmental provisions of the North American

Free Trade Agreement (NAFTA).

In 1995, the CEC established an Enforcement

Cooperation Program to provide a forum for

regional cooperation and to exchange expertise,

build enforcement capacity and explore altern ative approaches to effective enforcement.

The Council of the CEC then constituted a North

American Working Group on Environmental

Enforcement and Compliance Cooperation (called

the Enforcement Working Group or EWG) to

serve as this forum for regional cooperation. The

North American Wildlife Enforcement Group

(NAWEG) is a member of the EWG.
The international wildlife trade is a massive,

multibillion-dollar-a-year business.1 T h e

two major categories of traded items are live

specimens of wildlife species and products

derived from wildlife species. 

The international trade in live specimens

of wildlife species is dominated by reptiles,

birds and ornamental fish, but it also includes

mammals and invertebrate species such as

scorpions and spiders. Trade in exotic animals

for pets or hobbyist collections has expanded

dramatically in recent decades, perhaps in part

because farther-reaching air transportation now

allows traders to move wild species around the

globe. Many common garden and indoor

plants have also found their way into interna -

tional trade, including species such as snowdrops, crocuses, cyclamens, orchids, tree ferns,

bromeliads, cycads, palms and cacti. Even though

much of the trade now consists of artificially

propagated plants, millions of wild plants are

still traded internationally every year,

including a specialist trade in rare species. 

Medicines derived from wild plants

or compounds extracted from them also

figure prominently in the international

wildlife trade. The global trade in medicinal

and aromatic plants exceeded 440,000

metric tons in 1996 and was valued at

US$1.3 billion. Traditional medicine, 

particularly in Asia, also uses derivatives

from animals such as bear gallbladders

and tiger bone.

And there is a substantial international trade in a variety of food products such

as fruits, mushrooms, nuts, leaves and

starches, as well as meat and fish. A l t h o u g h

not usually thought of as wildlife, marine

fish are the largest group of wild animals

exploited for food. 

Beyond these consumptive uses, a wide

variety of wildlife products are found in the

ornamental and apparel trades, and are used in

manufacturing and construction. Items often

associated with the ornamental trade are ivory,

coral, turtle and mollusk shells, reptile and

other skins, and feathers, as well as mounted

insects such as butterflies and beetles. Tourist

items are often fashioned from local wildlife

such as jewelry and ornaments crafted from

corals and shells, curios that consist of insects

or other small animals encased in plastic, and

stuffed animals. Skins, furs and fibers from many

mammal, reptile, bird and even fish species are

traded internationally to make products ranging

from clothing and accessories (e.g., footwear,

bags, shawls and wallets) to ornaments and furnishings such as charms, rugs and trophies.

Forest products, including timber,

rattan and bamboo for

6 I L L E G A L T R A D E I N W I L D L I F E
house construction and furniture making, plant

oils and gums, dyes, resins and latex, are all

traded internationally in large volumes. 

Attempts to quantify the scope and scale

of the international wildlife trade have produced

very different estimates, depending on what

c a tegories of trade and w h i c h types of species are

included. For example, t i m b e r and fishery products dominate the international wildlife trade in

both volume and value, even though the public

may not think of many of the species involved

as “wildlife.” In the late 1980s and 1990s, various

attempts were made to d o c u m e n t the quantities

and value of the international wildlife trade, but

these studies reached different conclusions and

figures, depending on the statistics used and

the wildlife products included. All also

came with the caveat that information

and documentation remain lacking

in many areas. For example, in

1989 the United Nations Environment

Programme (UNEP) estimated the value of the

international wildlife trade, not including timber

and fisheries, at US$4–5 billion a year (Broad et

al. 2001). Fitzgerald (1989) estimated a wholesale value of wildlife products in trade of “at

least” US$5 billion. In the early 1990s, TRAFFIC

estimated an import value approaching US$15

billion for all wildlife products, excluding wildsourcedtimber and fish products (Broad et al.

2001). Finally, Iqbal (1995; cited in Broad et al.

2001) estimated the value of trade in nonw o o d

forest products (NWFPs) at US$11 billion.2

Another major complication in efforts to

estimate accurately the scope and scale of the

trade is the fact that wildlife products are both

consumed directly and sold into the cash econ -

omy, sometimes by the same people at the

same locations. Local use of wild plants and

animals may account for the majority of global

wildlife trade in terms of trade volume and

p e rhaps even value, but the nature of the trade

is such that it is often carried out through infor -

mal networks and seldom closely monitored.

Such subsistence-level trade or bartering often

does not show up in government trade s t a t i stics, even though it may account for a significant

proportion of the world’s wildlife trade (Broad

et al. 2001).

1. This chapter is based largely on Broad et al. (2001), Roe

et al. (2002) and TRAFFIC (2003).

2. Categories of commercially significant NWFPs measured

by Iqbal were food products, herbs and spices, industrial

plant oils and waxes, plant gums, natural pigments, oleo -

resins, fibers and flosses, vegetable tanning materials,

latex, insect products, incense woods, essential oils,

plant insecticides, medicinal plants, wild plants, animals

and animal products, and other miscellaneous items.

Tourist items are often fashioned from local wildlife such as jewelry

and ornaments crafted from corals and shells, curios that consist of

insects or other small animals encased in plastic, and stuffed animals.
Most wildlife trade is legal, but some is

not. It is for all practical purposes impossible to define the precise extent of the illegal

wildlife trade worldwide. The International

Criminal Police Organization (Interpol), however,

estimates that wildlife smuggling is worth up to

US$10 billion a year, ranking it third in illegal

trade behind drug trafficking and arms dealing. 

All categories of wildlife products are traded illegally; the black market commerce continues even when trade is restricted or banned.

For some products, the illegal trade parallels

the legal trade. For example, alongside a legal,

regulated international trade in caviar from the

Caspian Sea region of the former Soviet Union

to primary markets in the United States, Europe

and Japan is a significant black market caviar

trade that spans several continents (De

Meulenaer and Raymakers 1996; Williamson

2003). Similarly in North America, alongside

the legal trade in live reptiles from South

America for the exotic pet market, is an illegal

one. The same is true for Chihuahuan Desert

cacti in the United States and Mexico, which

are used primarily for landscaping and for orna -

mentation (Hoover 1998; Robbins 2003).

Sometimes, the illegal trade is in species

and products that are banned from legal trade,

often with very serious implications for the

species involved. For example, the illegal trade

in tiger bone for the Asian medicinal market

has had a devastating impact on wild tiger pop -

ulations—their numbers have dropped by

some 95 percent since the turn of the 20th

c e ntury. Poaching for the black market trade

continues to threaten the survival of remaining

populations, which are now believed to num -

ber only 5,000–7,000 animals (Jackson and

Kemf 1999).

Factors Driving the Illegal Wildlife Trade

The international trade in wildlife, both legal

and illegal, is largely driven by market demand.

Meeting the world’s market demand for illegal

wildlife can be a lucrative business, and the

poachers who collect wildlife and the smugglers

who transport it to market are largely in the

business for the profits (Moyle 1998). 

Wildlife generally flows from developing

nations to developed nations (Broad et al.

2001). The demand for wildlife and wildlife

products in developed country markets is so

enormous that it often surpasses what the legal

market can provide. Between 1990 and 2000, for

example, the European Union, United S t a t e s a n d

Japan reported annual caviar imports a v e r a g i n g

288 metric tons a year, even as concern about the

Caspian Sea fisheries led to the imposition of

quotas on the catch and trade of sturgeon from

the states of the former Soviet Union (Williamson

2003). The gap between demand and legally

available supply has helped to open the door

for significant illegal trade activity. In one 2002

law enforcement case alone, the president of

a Miami caviar company was prosecuted and

convicted for running a smuggling ring that

unlawfully took more caviar out of Russia in one

year than was allowed under the country’s

entire export quota (USFWS 2003). 

In North America, Mexico is a potential

exporter of wildlife specimens, products and

by-products aimed at the US and European

markets. The most highly trafficked species are

orchids, cacti, cicadas, tarantulas and songbirds

and ornate birds, such as passerinos and

psittacids. Mexican wildlife is exported illegally

to member and nonmember countries of the

European Union, including Austria, Belgium, the

Czech Republic, Germany and the Netherlands,

and as well as to Asian countries such as Japan

8 I L L E G A L T R A D E I N W I L D L I F E

Caviar 

Caviar from sturgeon forms the basis for large

industries, contributing greatly to national

economies and the economic survival of

whole communities. In recent decades, 

however, burgeoning human populations,

unsustainable harvesting and increasing 

illegal harvesting have put tremendous 

pressure on these resources. For example, in

four former Soviet republics on the Caspian

Sea, the legal catch of sturgeon at the end of

the 1990s plummeted to less than one-tenth

of the catch in the 1970s. It is also estimated

that the illegal catch is now at least 10 times

higher than the legal catch. 

More information: http://www.traffic.org.
9 A NORTH AMERICA PERSPECTIVE

and to the United States. A high percentage of

the exports to Europe and Asia pass through

US territory. The most notable example is the

cactus. Some 7–8 million specimens are traded

worldwide, at a market value ranging from

US$2 to $2,000 per specimen.3

Beyond economic incentive, strong cultural

elements are also driving some wildlife trade. A

well-known example of this phenomenon is the

trade in traditional Asian medicine, which has

used ingredients derived from wild plant and

animal species for thousands of years. But

international trade in rhino horn, a substance

once widely used in traditional Chinese medi -

cine, has been banned since 1977. And trade

in tiger bone, also once widely used in tradi -

tional Chinese medicine, has been banned

since 1987. Yet TRAFFIC investigations4 since

then have found such medicines claiming to

contain rhino horn and tiger bone in Australia,

Canada, China, EU countries, New Zealand and

the United States, despite domestic and inter -

national trade bans. Although the factors driving

this continuing trade are complex and include

market demand and profit, the TRAFFIC findings

seem to confirm research indicating that some

people may not obey laws that contradict

c u ltural traditions or what they believe is the

greater human good. This observation is

s u pported by statements from some specialists

in traditional Chinese medicine, who believe

that the bans have hampered their efforts to

alleviate human suffering (Lee et al. 1998).

The wildlife trade, both legal and illegal, is also

driven by diverse socioeconomic and cultural

factors. After all, people need to secure a food

supply and health care (from herbal remedies

to ingredients of industrial pharmaceuticals),

practice their religion (sometimes requiring live

animals and a wide range of wild plants and

animal parts), and obtain industrial and building

materials. They also enjoy collecting things,

including live plants and animals and a range of

wildlife specimens and curios; buying clothing

and fashions such as leather, furs and feathers;

and engaging in sport, including trophy hunting

and falconry (Broad et al. 2001). 

How Illegal Wildlife Products Enter the

Stream of Commerce

The illegal wildlife trade is by its very nature highl y secretive. It is dominated by well-organized

networks of poachers, wholesalers, middlemen,

smugglers and retailers. Illegal wildlife products

often enter the stream of commerce along this

chain, with price markups at each step. The

bear gallbladder trade from the Canadian

province of British Columbia is one example of

how the illegal wildlife trade chain often works.

Although the province prohibits the sale or

trade of black bear gallbladders, provincial

wildlife officials believe both continue, with the

product passing from hunters, through middlemen

such as Asian traffickers and apothecary shops,

to destinations in the United States, Republic of

Korea, Hong Kong (China) and Taiwan. Provincial

officials estimate that along this chain hunters

receive C$75 for a gallbladder, middlemen

receive $200, and retailers receive $850–$1,200

(Williamson 2002).

In some areas, traditional organized crime

groups may even be players in this trade. For

example, in the former Soviet Union there is

evidence that the “red mafia” may be heavily

involved in the illegal caviar trade. The US Fish

and Wildlife Service (USFWS) has reported dis -

coveries of illegal wildlife shipments mixed in

with shipments of illegal narcotics, suggesting

the participation of drug cartels in illegal

wildlife trade in nations such as Colombia.

Tiger Bone 

Many traditional medicines use wildlife as

ingredients. Traditional East Asian medicine,

for example, uses more than 1,000 plant and

animal species. Throughout Asia, nearly

every part of a tiger is believed to have a 

prescribed benefit, with cures claimed for 

ailments ranging from epilepsy to laziness.

Tiger bone is the most used. The marked fall

in the consumption of tiger-bone medicines

in recent years is an indication that close

cooperation and work with traditional medicine practitioners and users are essential.

These communities can play an important

role in eliminating any remaining illicit trade,

promoting the use of substitutes and raising

conservation awareness among consumers. 

More information: http://www.traffic.org.

The international trade in wildlife, both legal and illegal, is largely

driven by market demand.
Although hard evidence on the extent to which

traditional organized crime is involved in illegal

wildlife trafficking is limited, the adeptness of

such groups at evading detection points to the

difficulty of determining the full extent of the

trade (Cook et al. 2002). 

Beyond such organized efforts, illegal

wildlife products sometimes enter the stream 

of commerce in yet another way—the “pocket”

trade. In this aspect of the trade, tourists or

other travelers often wittingly or unwittingly

purchase wildlife items that are banned from

international commerce and then transport them

across borders to either keep or sell. In recent

years, officials have seized products ranging from

ivory, to illegal coral or other curios, to caviar and

even live reptiles. Such trade is difficult to stop,

because it is principally detected at airports 

or other ports of entry where the likelihood

of inspection is extremely low. 

Finally, the advent of the Internet may

have opened the door to a new stream of com -

merce—illegal trade through online auction

sites or direct Internet sales. For example, a

2002 report on the US ivory market found that

ivory dealers in China, Hong Kong (China) and

Europe were willing to ship ivory items to the

United States without proper documentation of

its legality (HSUS 2002). Like the pocket trade,

such trade is very difficult to detect and combat,

because sellers find it easy to ship small items

across borders and because of the immense

scope of the Internet itself. 

Environmental Effects of Illegal Trade

The illegal trade in wildlife, for subsistence or

commercial purposes, is leading to the depletion

of populations of great whales, marine turtles,

rhinoceroses, elephants and tigers, among

other species, through overexploitation (Broad

10 I L L E G A L T R A D E I N W I L D L I F E

The advent of the Internet may have opened

the door to a new stream of commerce. . . .

Bear Gallbladders 

Bear gallbladder and bile are used in 

traditional Chinese medicine to treat many

ailments, including convulsions, fever and

hemorrhoids. But this traditional way of 

treating these complaints is starting to take 

its toll on its source—the bears. The Asiatic

black bear, sloth bear, sun bear and certain

Asian brown bears are all endangered

because of, in part, the demand for 

gallbladders. Although the black bears in

North America are in pretty good shape,

they, too, are sometimes killed illegally for

their gallbladders. 

More information: 

h t t p : / / w w w . w o r l d w i l d l i f e . o r g / b u y e r b e w a r e / b e a r . c f m .

Ivory 

The demand for ivory fueled a dramatic

decline in African elephant populations in 

the 1970s and 1980s, and eventually led to a

CITES ban on international commercial trade

in 1989. Monitoring systems are being 

developed to provide countries with a deeper

understanding of the illegal trade and the 

illegal killing of elephants. For example, in

2001 the Elephant Trade Information System

held the details of nearly 4,500 ivory seizures

in 54 countries totaling 125 metric tons.

More information: http://www.traffic.org.

African black rhinoceros

Diceros bicornis

CITES Appendix I 
et al. 2001). For example, populations of the

African black rhinoceros have plummeted

d r amatically in recent decades because of

poaching for their horns, which are in demand

as a component of traditional Asian medicines

and for the manufacture of traditional dagger

handles in Yemen. Shot, snared and speared

for their horns alone, black rhinoceroses saw

their numbers decline from an estimated

65,000 in 1970, to 14,785 by 1980, to perhaps

2,000 by 1997. African white rhinoceroses, even

though better protected in South Africa, also

disappeared by the thousands in their northern

range in Central Africa (Martin et al. 1997). 

According to the World Wildlife Fund

(WWF), parrots, or psittacines, constitute a sig -

nificant part of the global black market trade in

wildlife. “Parrots’ beauty, ability to mimic, and

tendency to bond with humans make them

among the most valued species in illegal trade.

And despite national and international laws

protecting them, the United States has one of

the world’s largest black markets,” said Ginette

Hemley, when she was director of international

wildlife policy at WWF in the mid-1990s. The

smuggling of endangered parrot species a l o n g

the Texas-Mexico border remains a serious conservation concern. John Flicker, president of

the National Audubon Society, has noted that

“smuggling operations typically involve young

birds that frequently die before reaching mar -

kets. . . . Unfortunately, smugglers have found

that chicks are easier to smuggle. They can be

laundered as captive-bred hatchlings and bring

more money than adults.” Bird smugglers also

often destroy habitat by cutting down trees to

catch birds (http://usembassy-australia.

state.gov/hyper/WF980601/epf110.htm).

In 2003 a TRAFFIC study reported that a

large part of the Chichuahuan Desert in West

Texas is the “dominant producer of showy cacti

(such as barrel cacti and hedgehog cacti) and

other succulents . . . for urban markets in

Arizona, Nevada, and southern California.

Between 1998 and June 2001, nearly 100,000
12 I L L E G A L T R A D E I N W I L D L I F E

succulents, with an estimated value of US$3

million, were harvested from mostly wild populations in Texas or were illegally imported into

Texas from Mexico and destined for consumers

in cities such as Phoenix and Tucson, Arizona.”

The TRAFFIC study found that even though none

of the species identified faces imminent extinc -

tion, with one possible exception, the robust

trade does raise questions about the “long-term

transparency, legality, sustainability, and impact

of large-scale harvest. Faced with the added

pressures of habitat loss and the vagaries of

an unforgiving and possibly changing climate,

many of the taxa exploited for trade may

become threatened and even disappear locally

if conservation measures are not implemented”

(http://www. traffic.org/news/press-releases/

prickly–trade–part1.pdf).

Illegal wildlife trade is a means of dispersing

infectious-contagious diseases. The deliberate

cross-border entry or movement of wildlife could

be a form of dispersion of infectious-contagious

disease, with fast zoonotic or anthropozoonotic

dissemination among domestic and wild animal

populations. As an example, in Mexico the

taxonomic and ecological affinity of nationally

distributed taxa to taxa of other New and Old

World regions may lead to the establishment

of pathogens in Mexican taxa not having ade -

quate immunological capabilities. A review by

the National Technical Advisory Board on

Animal Health (Consejo Técnico Consultivo de

Nacional de Sanidad Animal—Conasa) in 2000

identified 203 infectious diseases in amphibians,

reptiles, birds and mammals in Mexico. Of these,

25 are regarded as exotic species in the country,

including 7 high-risk and 33 low-risk enzootic

diseases, according to the International Office

for Epizootic Diseases. These data indicate the

extent of the potential risk to biodiversity in a

country such as Mexico.

Finally, illegal wildlife trade may also repres e n t a threat to ecosystems and economies as

well as to species survival. Countries around

the world have long recognized the need to

k e e p their borders closed to invasive species —

species that supplant native wildlife, change

ecological relationships, and take an economic

toll. The United States, Canada and Mexico

have legislation banning the importation of

c e rt a i n injurious species.

Laws alone, however, cannot stem the

tide of “bioinvaders,” particularly given the

globalization of the world’s economy and the

resulting ease of species movement, not only

from country to country but from continent to

continent. Scientists report that the pace of

“bio-immigration” is accelerating worldwide.

In San Francisco Bay, for example, a new exotic

animal, plant, or microbe now “moves in” every

14 weeks on average (compared to one every

55 weeks in the period from 1851 through

1960). While many invasive species arrive “by

accident” (sucked into the ballast of cargo ships,

for example), others are deliberately imported

to be eaten, kept as pets, displayed in home

aquariums, or used for fish farm predator control.

Preventing the importation of species banned

as invasive is another challenge for agencies

tasked with regulating global wildlife trade.

3 . Information provided by the natural resources branch

of Mexico’s Federal Attorney General for Environmental

Protection (Procuraduría Federal de Protección al

Ambiente)

4. TRAFFIC, a wildlife monitoring network, is a joint program

of the World Wildlife Fund (WWF) and the World

Conservation Union (IUCN).
13 A N O R T H A M E R I C A P E R S P E C T I V E

I

n the 1960s the international community

began to recognize that the exploitation and

trade levels for some species, combined with

other factors such as habitat loss, could deplete

populations to the brink of extinction. An inter -

national framework was needed, some nations

concluded, to ensure the sustainability of the

trade in endangered and threatened species.

CITES

In response, an international agreement, the

Convention on International Trade in Endangered

Species of Wild Fauna and Flora (CITES), was

developed to safeguard species vulnerable to

trade from overexploitation. CITES entered into

force in 1975, and as of May 2005, 167 nations

were parties to the convention.5

CITES established a worldwide system of

controls on international trade in threatened

and endangered wildlife and wildlife products.

At present, some 5,000 species of animals

(mammals, birds, reptiles, amphibians, fish and

invertebrates) and 28,000 species of plants are

covered by the convention (see table). CITES’s

appendices describe the status of the species

and specify which species may enter international

commercial trade. The most endangered

species, listed in Appendix I, are all those species

threatened with extinction that are or may be

affected by trade. Commercial trade of these

species is not permitted, and other trade for

purposes such as scientific research is strictly

controlled through import and export permits.

Listed in Appendix II are those species that are

not rare or endangered at present, but could

become so if trade is not regulated. International

trade in such species requires the issuance of a

CITES export permit by the exporting country.

Appendix III species are not endangered, but

they are subject to regulation within the listing

nation for the purposes of preventing or restricti n g exploitation and, as requested, promoting

the cooperation of other parties in the control

of trade. (The complete appendices appear on

the CITES web site <http://www.cites.org>.)

Within this system, legal trade continues in

species listed under CITES Appendices II and

III (see box).

5. This chapter is largely based on information provided on

the CITES web site, http://www.cites.org.

Parties to CITES 

When the government of a state decides

that it would like to be bound to the provi -

sions of CITES, it can "join" the convention

by making a formal declaration to this effect

in writing to the "Depositary Government,"

which is the government of Switzerland.

Once a document containing this declaration

has been received by the Depositary

through diplomatic channels, the convention

enters into force for the state concerned 

90 days later (see Article XXI of CITES).

Currently, 167 countries are parties to

CITES. A party to CITES may withdraw from

the convention at any time by a process of

denunciation (see Article XXIV).

More information: http://www.cites.org.
14 I L L E G A L T R A D E I N W I L D L I F E

Appendix I

Appendix II

Appendix III

Total Number of Plant and Animal Species Listed in the CITES Appendices as of October 2003

Walrus 

(Odobenus rosmarus) 

Appendix III 

Bald eagle 

(Haliaeetus leucocephalus)

Appendix I 

Boa constrictor 

Appendix II

Green poison arrow frog 

(Dendrobates auratus) 

Appendix II 

Mammals

228 species 

28 subspecies 

13 populations

369 species 

34 subspecies 

14 populations

57 species 

11 subspecies

Birds

146 species 

19 subspecies 

2 populations

1,401 species 

8 subspecies 

1 population

149 species

Reptiles

67 species 

19 subspecies 

4 populations

508 species 

3 subspecies 

4 populations

25 species

Amphibians

16 species

90 species

—
15 A N O R T H A M E R I C A P E R S P E C T I V E

Source: http://www.cites.org

Beluga sturgeon 

(Huso huso) 

Appendix I 

Mexican red-kneed tarantula 

(Brachypelma smithi) 

Appendix II 

O c otillo 

( Fouquieria splendens) 

Fish

9 species

68 species

—

Invertebrates

63 species 

5 subspecies

2,030 species 

1 subspecies

16 species

Plants

298 species 

4 subspecies

28,074 species 

3 subspecies 

6 populations

45 species 

1 subspecies 

2 populations

Total

827 species 

52 subspecies 

19 populations

32,540 species 

49 subspecies 

25 populations

291 species 

12 subspecies 

2 populations
16 I L L E G A L T R A D E I N W I L D L I F E

Reported International Trade in Selected CITES-listed Flora and Fauna

The following lists reveal the scale of the reported international trade in selected CITES-listed

species between 1995 and 1999. As the statistics indicate, the trade is significant, even though no

precise monetary estimate is provided. 

Fauna (annual mean, 1995–1999)

■ Over 1.5 million live birds (250,000 Appendix II; 1.25 million Appendix III)

■ 640,000 live reptiles

■ 300,000 crocodilian skins (world trade is over 1.2 million, but mostly farmed)

■ 1.6 million lizard skins

■ 1.1 million snake skins

■ 150,000 furs

■ Almost 300 metric tons of caviar

■ Over 1 million pieces of coral

■ 21,000 hunting trophies.

Flora (1999)

■ 19 million bulbs exported from Turkey

■ Over 53,000 live wild-collected orchids exported from Central America and Vietnam

■ Over 200 metric tons of dried orchid roots exported from Vietnam to the Republic of Korea

■ 360,000 cacti “rainsticks” exported from Chile and Peru

■ 70 metric tons of Aloe ellenbeckii resin exported from Kenya to China

■ Over 300 metric tons of Aloe ferox exported from South Africa

■ 120 metric tons of Agarwood Aquilaria malaccensis chips exported from Indonesia and Malaysia

■ 30 metric tons of American ginseng Panax quinquefolius roots exported from the United States.

Source: Broad et al. (2001).

CITES obligates each party to designate one or more “management authorities” to administer the

permitting system that controls the trade in CITES-listed species, and also one or more “scientific

authorities” to determine what effects trade may have on the status of the species in question

(these authorities are listed in the table in the next chapter). Enforcement of the convention, including efforts to combat illegal trade, falls largely under the purview of law enforcement agencies at the

national and subnational levels. 
17 A N O R T H A M E R I C A P E R S P E C T I V E

Canada, Mexico and the United States have all enacted legislation to govern the domestic and

international trade of wildlife generally, and to implement CITES specifically. The three nations

have also designated management and scientific authorities, as called for by the convention, and the

agencies responsible for enforcement of wildlife trade statutes. Wildlife enforcement officials work

closely with customs authorities and other specialized agencies to stem the illegal trade in wildlife. The

table in this chapter summarizes the key laws, management and scientific authorities, and law enforcement authorities responsible for CITES implementation in Canada, Mexico and the United States. 

● Endangered Species Act of 1973

(ESA)

● Lacey Act

● Marine Mammal Protection Act of

1972 (MMPA)

● US Criminal Code

● Animal Welfare Act

● US Fish and Wildlife Service,

Division of Management Authority

(USFWS/DMA),

● Division of Scientific

Authority(USFWS/DSA)

● Animal and Plant Health Inspection

Service (USDA)

● US Fish and Wildlife Service,

Office of Law Enforcement

(USFWS/OLE)

● US Customs and Border Protection

(CBP)

● State wildlife agencies

● US Department of Agriculture

● General Law of Ecological Balance

and Environmental Protection

(LGEEPA)

● General Wildlife Law (LGVS)

● Federal Criminal Code

● Mexican Official Standards:

NOM059-Semarnat and NOM126-

Semarnat

● Semarnat’s Manual for the Import

and Export of Wildlife

● National Commission for the

Knowledge and Use of Biodiversity

(CONABIO)

● Secretariat of Environment and

Natural Resources (Semarnat)

● Federal Attorney General for

Environmental Protection (Profepa)

● Federal Attorney General of the

Republic

● Customs Agency

● Wild Animal and Plant Protection

and Regulation of International and

Provincial Trade Act (WAPPRIITA)

● Wild Animal and Plant Trade

Regulations (WAPTR)

● Customs Act

● Criminal Code

● Canadian Wildlife Service

● Fisheries and Oceans Canada

(DFO)

● Canadian Forest Service

● Provincial and territorial wildlife

agencies

● Environment Canada

● Royal Canadian Mounted Police

(RCMP)

● Canadian Customs and Revenue

Agency (CCRA)

● Provincial and territorial wildlife

agencies

Laws and regulations Management and scientific authorities Enforcement agencies

Sources: Hoover and Tarr (1997); Cooper and Chalifour (in press); Pérez Gil and Arroyo (in press).

Key Laws and Regulations, Management and Scientific Authorities, and Enforcement Agencies Pertaining 

to CITES: Canada, Mexico and United States

Canada

Mexico

United

States
18 I L L E G A L T R A D E I N W I L D L I F E

G r e at Hornbill 

(Buceros bicornis)

CITES Appendix I 

O c otillo 

( Fouquieria splendens) 

Smugglers in North America operate as part of

global networks. In the development and

implementation of enforcement actions, domestic

law enforcement agencies work directly with

other law enforcement agencies or through

international police organizations such as Interpol.

Although there are no reliable estimates of the

percentage of illegally traded wildlife captured

or seized by enforcement personnel, the fol -

lowing cases illustrate the types of smuggling

faced by North American wildlife personnel. 

In1999, cooperation between

Environment Canada, the Canadian Wildlife

Services, the US Fish and Wildlife Service

(USFWS) and other agencies led to the convic -

tion of the owners of Flikkema Aviaries, a major

supplier of exotic birds that illegally imported

into Canada and then illegally exported into the

United States endangered tropical birds (finches) protected under CITES. The illegal opera -

tions of this organization between December

1997 and October 1999 involved over 4,000

tropical finches, 30 parakeets and 20 mynas,

with an estimated value of over C$100,000.

Most species of birds were from Africa. After

an investigation of about six months, enough

evidence was obtained to press 162 charges

against three people in Canada for possessing

illegally imported birds, importing and exporting birds without a permit, and possessing

birds for the purpose of illegal export. 

In another example of cooperation

between the United States and Canada, a large

network of trade in black bear gallbladders was

dismantled in November 2002 when the US

F i s h and Wildlife Service alerted Canadian officials that bear gallbladders were being sold via

Internet from Ontario and Quebec. Bear gall -

bladders, which are used in traditional Asian

medicine, have a foreign black market value that

ranges from C$2,000 to $10,000 per gallbladder

or up to $55 per gram. 

A common smuggling route in North

America is from Mexico into the United States

and Canada. From cactus to protected parrots,

Mexico’s natural diversity makes its wildlife

susceptible to the demands of the North

American black market. Cacti are particularly

valuable items on the global black market.

Mexico, the world’s richest cactus breeding

ground, has 850 species of cacti, many of them

extremely valuable. But, of these, 270 species

are considered threatened or endangered, and

it is illegal to remove them without a permit.

Collectors in the United States, Europe and

Asia will pay thousands of dollars for a single

rare cactus from Mexico in an increasingly

sophisticated smuggling network. Diana Ponce

Nava, a lawyer with the enforcement division of

Mexico’s Secretariat of Environment and

Natural Resources (Secretaría del Medio

Ambiente y Recursos Naturales—Semarnat),

20 I L L E G A L T R A D E I N W I L D L I F E

told the Washington Post in 2003, “It used to

be just people with shovels and suitcases, but

the trafficking is getting much more sophisticat -

ed” (Jordan and Sullivan 2003). Ponce’s agency

recently raided the famous Xochimilco flower

market just south of Mexico City and a private

greenhouse in Monterrey, where it recovered

thousands of rare cacti.

According to a report by TRAFFIC,

Mexican authorities seized nearly 800 cactus

specimens from travelers entering or passing

through the United States from Mexico in 1998.

Many consumers and tourists are unaware they

may be breaking the law when they collect,

purchase or export cacti from countries that

restrict their trade. US border agents are finding

them, too. In one celebrated cactus bust, US

Customs agents, working with US Fish and

Wildlife Service investigators, arrested two

Americans in 1999 for smuggling 21,000 Mexican

ocotillo cactus plants into Texas (Jordan and

Sullivan 2003).

Parrots are another common form of wildlife

smuggled into the United States and Canada.

In 1998 US Customs Service and the US Fish

and Wildlife Service broke up an international

smuggling ring dealing in protected birds and

other wildlife. The smuggling ring, which was

located along the US-Mexico border, extended

into nine states, the Commonwealth of Puerto

Rico, and 10 other countries. The birds seized

during Operation Jungle Trade included 356

yellow-headed Amazon parrots, 110 yellownaped Amazon parrots (a Guatemalan species),

57 Mexican red-headed parrots, 31 red-lored

Amazon parrots and small quantities of several

other psittacine species.

Another case that highlights the global

reach of these smuggling rings involved Anson

Wong, a well-known wildlife dealer and s m u ggler of endangered animals. The USFWS tracked

Wong for more than five years on the suspicion

of smuggling wildlife into the United States,

including species such as Komodo dragons and

plowshare tortoises, already on the brink of

extinction, that are found only in very limited,

geographically isolated habitats. Mexican

authorities arrested Wong, and he was extradited

to the United States, where he was convicted

of several offenses, including conspiracy and

money laundering. He was sentenced to six

years in a federal prison—one of the longest

sentences ever handed down for violating US

wildlife laws—and fined US$60,000.
21 A N O R T H A M E R I C A P E R S P E C T I V E

I

nternational capacity building and information

sharing are vital components of international

law enforcement efforts. Although domestic

law enforcement agencies work directly with

other law enforcement agencies or through

police organizations such as Interpol on specific

enforcement actions, establishment of contacts,

training and identification of problems and trends

require international collaborative efforts—

efforts that often occur through the support of

international organizations. In North America, this

cooperation largely stems from the work of the

North American Wildlife Enforcement Group.

When Canada, Mexico and the United

States strengthened economic ties through the

North American Free Trade Agreement (NAFTA),

they also pledged to undertake a new environ -

mental partnership. In 1993 the three nations

signed the North American Agreement on

Environmental Cooperation (NAAEC) and c r eated the CEC. The NAAEC commits the NAFTA

parties to building regional cooperation aimed

at conserving, protecting and enhancing the

environment, and to enforcing their respective

environmental laws, including those protecting

wild flora and fauna. 

Responding to these commitments, the

CEC established in 1995 an Enforcement

Cooperation Program to provide a forum for

regional cooperation and to exchange expertise,

build enforcement capacity and explore alternative approaches to effective enforcement. The

Council of the CEC then constituted a North

American Working Group on Environmental

Enforcement and Compliance Cooperation

(called the Enforcement Working Group, or EWG)

to serve as this forum for regional cooperation. 

Created in 1995, the North American

Wildlife Enforcement Group is a member of the

EWG. NAWEG is a network of senior wildlife

enforcement officials from Canada, Mexico and

the United States devoted to improving North

America’s capacity to enforce the laws that regulate the sustainable use and conservation of its

wildlife, particularly CITES. NAWEG, which

works with other cooperative enforcement and

compliance programs in collaboration with the

CEC, provides guidance in identifying priorities

for regional cooperation in protecting wildlife

across the continent and it develops strategies

and proposals for cooperative enforcement

activities. It also tries to serve as an effective

voice for North America in the global enforcement community and to strengthen participation

within international alliances such as Interpol,

CITES and the World Customs Organization. 

NAWEG’s efforts to address wildlife trade

and enforcement issues have received invaluable

support and participation from numerous p r i v a t e

conservation groups, the business sector and the

academic community across North America.

Groups as diverse as the Association of Zoos,

Breeders and Aquariums of the Mexican

Republic (Asociación de Zoológicos, Criaderos y

Acuarios de la República Mexicana) f r o m

Puebla, the Institute of Ecology of Xalapa

(Instituto de Ecología de Xalapa, A.C.), the

North American Fur Auction House, the

Northwest Association of Forensic Scientists,

and TRAFFIC North America have taken part in

NAWEG workshops and other activities. Federal

and state and provincial agencies in all three

countries also have supported NAWEG’s mission by offering scientific and technical support. 

NAWEG Workshops

NAWEG-sponsored workshops have allowed

wildlife officials to take a closer look at the illegal

practices surrounding big game hunting and

game farming, orchids and cacti and coral reefs.

For example, in 2000 NAWEG sponsored a

meeting in Monterrey, Mexico, on big game
22 I L L E G A L T R A D E I N W I L D L I F E

hunting and game farming. Big game hunting in

the wild is an accepted practice in nearly every

corner of the world. However, the poaching of

big game remains a serious problem in all three

countries because of the big profits that can be

reaped by poachers. A large mule deer rack

with a 1-meter spread can fetch US$40,000.

Animal antlers can be sold as trophies or sent

to Asia where they are ground up and used in

traditional medicines. The gallbladder of one

bear can bring as much as US$18,000 in Asia. 

Game farming is an increasingly common

practice in which wild animals are enclosed so

that they can be harvested for sale of the meat.

Private game management facilities can and do

trade, move and sell game, crossing state and

sometimes international borders. These movements of animals between states and countries

take animals far beyond the range they would

move on foot. Moving game animals can a c c e lerate the spread of disease if the moved animals

are infected.

At the Monterrey workshop, enforcement

officers from the three countries examined

ways to close enforcement loopholes, improve

understanding of regulations among the countries and exchange information on enforcement

and compliance strategies. The officers also

reviewed the status of animal populations and

the ranges of the main trophy species, the legal

framework for hunting in North America, as

well as case studies that highlight ways to deal

with import/export fraud and smuggling.

In February 2003 NAWEG organized an

enforcement workshop on the trade and illegal

harvest of protected plant species. In view of the

black market that has emerged for protected

species of plants, NAWEG recognized that enforcem e n t officers must be better able to identify

these species and understand how organized

crime is driving this activity. 

In great demand as ornamental plants or

for use in the production of medicines, foods,

commercial beverages, cosmetics and furniture,

CITES-protected species of cacti, cycads,

orchids and tropical wood are being smuggled

into and from North America. Out of the world’s

298 cycad species, more than half are endan -

gered, vulnerable or extinct. Their rarity has

made them highly prized targets for wealthy

collectors, who are willing to pay several thousand

dollars just to own a specimen. And, as noted

earlier, cacti, in high demand as a landscaping

plant, have also become targets for poachers

willing to supply a multimillion-dollar market.

Attended by over 50 enforcement officers

from the three countries, the NAWEG workshop

gave participants information on ways in which

to apply laws so that they could tighten the

i l l egal traffic in plants. Officers also received

technical information, such as the characteristics

of the major taxonomic groups of commercial

plant species, and learned more about the trends

in international trade and the role of networks

in monitoring illegal trade.

In yet another example of a NAWEG

capacity-building effort, the group held a seminar

on the Use and Sharing of Intelligence in Wildlife

Enforcement in Ottawa in February 2004. This

seminar brought together intelligence officers,

analysts, seasoned investigators with limited

intelligence awareness, and high-level managers

with enforcement supervisory duties from the

three countries. The seminar demonstrated the

purpose, value and accomplishments of an

integrated intelligence unit within a wildlife

enforcement service. Enforcement agencies in

the three countries recognize that it is important

to enhance the capabilities of wildlife enforce -

ment officers to gather and analyze information

so that they can better understand the methods

of operation used by violators, identify trends

in the illegal wildlife trade and anticipate likely

violations.

The seminar succeeded in establishing a

common understanding of the intent and pur -

pose of intelligence and the specific language

used by intelligence practitioners. Participants

took part in workshops and case studies to

f u rther demonstrate the understanding of intel-
23 A N O R T H A M E R I C A P E R S P E C T I V E

ligence, the intelligence process and the tools

required to operate an intelligence unit. The

seminar also provided participants with an

understanding of the national and international

constraints in setting up an intelligence network

and the obstacles both internally and externally

with the three countries. 

The Remaining Challenges

Although it is difficult to predict future trends

in the illegal wildlife trade with any precision,

the black market will no doubt continue to

flourish, and may well expand. As noted earlier,

levels of wildlife trade in general have risen in

recent decades, indicating that the markets for

wildlife and wildlife products are continuing to

grow, both globally and in North America. 

Enforcement of CITES trade control measures

and national wildlife laws is likely to become ever

more complex and difficult as more species are

added to the convention’s appendices. Furthermore,

assuming that all nations continue to negotiate

and implement bilateral and multilateral free

trade agreements, the challenges already facing

wildlife inspectors and customs agents in moni -

toring trade between Canada, Mexico and the

United States may well be exacerbated by an

increased flow of goods from other nations. 

In this environment, enhanced cooperative

efforts to monitor and control legal wildlife trade,

to stem illegal trade, to enable preventive actions

and to establish stricter mechanisms to control

and track transboundary movements are likely

to become an imperative. Groups such as

NAWEG serve the vital function of improving

the integration of wildlife enforcement activities

in North America, strengthening communication

and the exchange of intelligence between

Canada, Mexico and the United States, and

enhancing domestic operations in each country

through training and capacity building. Canada,

Mexico and the United States need to take

steps now to ensure that their individual and

cooperative wildlife trade control programs will

be effective in the future. 

N o rth American mule deer 

(Odocoileus hemionus) 
24 I L L E G A L T R A D E I N W I L D L I F E

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