COMBATING 

WILDLIFE 

TRAFFICKING

Opportunities Exist to 

Improve the Use of 

Financial Rewards

Report to the Ranking Member, 

Committee on Finance, U.S. Senate

April 2018

GAO-18-279

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-279, a report to the 

Ranking Member, Committee on Finance, 

U.S. Senate

April 2018

COMBATING WILDLIFE TRAFFICKING

Opportunities Exist to Improve the Use of Financial 

Rewards

What GAO Found

Multiple laws—such as the Endangered Species Act and Lacey Act—authorize 

the Departments of the Interior’s U.S. Fish and Wildlife Service (FWS) and

Commerce’s National Oceanic and Atmospheric Administration (NOAA) to pay 

rewards for information on wildlife trafficking. FWS and NOAA reported paying 

few rewards from fiscal years 2007 through 2017. Specifically, the agencies 

collectively reported paying 27 rewards, totaling $205,500. Agency officials said 

that the information was complete to the best of their knowledge but could not 

sufficiently assure that this information represented all of their reward payments. 

Turtle Taped for Transport (Left) and Other Illegally Trafficked Turtles (Right) Recovered 

Based on Information from a Source Who Then Received a Reward from the U.S. Fish and 

Wildlife Service

FWS and NOAA have reward policies that outline the general process for 

preparing reward proposals, but FWS’s policy does not specify factors for its 

agents to consider when developing proposed reward amounts. Some FWS

agents GAO interviewed said that in developing proposals, they did not know 

whether their proposed reward amounts were enough, too little, or too much. By 

augmenting its policy to specify factors for agents to consider, FWS can better 

ensure that its agents have the necessary quality information to prepare 

proposed reward amounts, consistent with federal internal control standards.

FWS and NOAA communicate little information to the public on rewards. For 

example, most agency websites did not indicate that providing information on 

wildlife trafficking could qualify for a reward. This is inconsistent with federal 

standards that call for management to communicate quality information so that 

external parties can help achieve agency objectives. FWS and NOAA officials 

said they have not communicated general reward information because of 

workload concerns, but they said it may be reasonable to provide more 

information in some instances. By developing plans to communicate more 

reward information to the public, the agencies can improve their chances of 

obtaining information on wildlife trafficking that they otherwise might not receive.

FWS and NOAA have not reviewed the effectiveness of their use of rewards. 

The agencies have not done so because using rewards has generally not been a 

priority. FWS and NOAA officials agreed that such a review would be worthwhile

but provided no plans for doing so. By reviewing the effectiveness of their use of 

rewards, FWS and NOAA can identify opportunities to improve the usefulness of 

rewards as a tool for combating wildlife trafficking.

View GAO-18-279. For more information, 

contact Anne-Marie Fennell at (202) 512-3841 

or fennella@gao.gov.

Why GAO Did This Study

Wildlife trafficking—the poaching and 

illegal trade of plants, fish, and 

wildlife—is a multibillion-dollar, global

criminal activity that imperils thousands 

of species. FWS and NOAA enforce 

laws prohibiting wildlife trafficking that 

authorize the agencies to pay financial 

rewards for information about such 

illegal activities.

GAO was asked to review FWS’s and 

NOAA’s use of financial rewards to 

combat wildlife trafficking. This report 

examines (1) laws that authorize FWS 

and NOAA to pay rewards for 

information on wildlife trafficking and

the extent to which the agencies paid 

such rewards from fiscal years 2007 

through 2017, (2) the agencies’ reward 

policies, (3) information available to the 

public on rewards, and (4) the extent to 

which the agencies reviewed the 

effectiveness of their use of rewards.

GAO reviewed laws, examined FWS 

and NOAA policies and public 

communications on rewards, analyzed

agency reward data for fiscal years 

2007 through 2017 and assessed their 

reliability, interviewed FWS and NOAA 

officials, and compared agency policies 

and public communications on rewards 

to federal internal control standards. 

What GAO Recommends

GAO is making seven 

recommendations, including that FWS 

and NOAA track reward information, 

FWS augment its reward policy to 

specify factors for agents to consider 

when developing proposed reward 

amounts, FWS and NOAA develop

plans to communicate more reward 

information to the public, and FWS and 

NOAA review the effectiveness of their 

reward use. Both agencies concurred 

with these recommendations.
Page i GAO-18-279 Combating Wildlife Trafficking

Letter 1

Background 6

Multiple Laws Authorize FWS and NOAA to Pay Rewards for 

Wildlife Trafficking Information, but the Agencies Reported 

Paying Few Rewards from Fiscal Years 2007 through 2017 12

FWS and NOAA Have Policies for Administering Reward 

Payments, but FWS’s Policy Does Not Specify Factors to 

Consider When Developing Reward Amounts 19

FWS and NOAA Communicate Little Information to the Public on 

Financial Rewards 21

FWS and NOAA Have Not Reviewed the Effectiveness of Their 

Use of Financial Rewards 26

Conclusions 27

Recommendations for Executive Action 28

Agency Comments 29

Appendix I Objectives, Scope, and Methodology 31

Appendix II Laws Implemented or Enforced by FWS 

and NOAA That Prohibit Wildlife Trafficking 

and Authorize Financial Rewards 36

Appendix III FWS and NOAA Cases in Which the 

Agencies Reported Paying Rewards, 

Fiscal Years 2007 through 2017 43

Appendix IV Comments from the Department of Commerce 45

Appendix V Comments from the Department of the Interior 48

Appendix VI GAO Contact and Staff Acknowledgments 49

Contents
Page ii GAO-18-279 Combating Wildlife Trafficking

Tables

Table 1: Laws the U.S. Fish and Wildlife Service (FWS) and the 

National Oceanic and Atmospheric Administration (NOAA) 

Reported Using to Pay Financial Rewards for Information 

on Wildlife Trafficking, Fiscal Years 2007-2017 13

Table 2: Number and Dollar Amount of Financial Rewards That 

the U.S. Fish and Wildlife Service (FWS) and the National 

Oceanic and Atmospheric Administration (NOAA) 

Reported Paying for Information on Wildlife Trafficking, 

Fiscal Years 2007-2017 16

Table 3: Laws That the U.S. Fish and Wildlife Service (FWS) 

Implements and Identified as Prohibiting Wildlife 

Trafficking and Authorizing the Payment of Financial 

Rewards 37

Table 4: Laws That the National Oceanic and Atmospheric 

Administration (NOAA) Enforces and Identified as 

Prohibiting Wildlife Trafficking and Authorizing the 

Payment of Financial Rewards 39

Table 5: Laws That the National Oceanic and Atmospheric 

Administration (NOAA) Enforces or National Marine 

Fisheries Service (NMFS) Administers and Identified as 

Prohibiting Wildlife Trafficking That Are Covered by the 

Reward Provisions in Other Laws 42

Table 6: U.S. Fish and Wildlife Service (FWS) and National 

Oceanic and Atmospheric Administration (NOAA) Cases 

in Which the Agencies Reported Paying Rewards for 

Information on Wildlife Trafficking, Fiscal Years 2007-

2017 43

Figures

Figure 1: Publicly-Available Information on Reporting Illegal 

Activities and Receiving Financial Rewards on U.S. Fish 

and Wildlife Service and National Oceanic and 

Atmospheric Administration Websites, as of December 

2017 and January 2018 22

Figure 2: National Oceanic and Atmospheric Administration 

(NOAA) Poster Advertising a $1,000 Financial Reward in 

2017 for Information on Sea Turtle Poachers in Guam 23
Page iii GAO-18-279 Combating Wildlife Trafficking

Abbreviations

FWS U.S. Fish and Wildlife Service

IRS Internal Revenue Service

NMFS National Marine Fisheries Service

NOAA National Oceanic and Atmospheric Administration

OLE Office of Law Enforcement

SEC U.S. Securities and Exchange Commission

UNEP United Nations Environment Programme

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Page 1 GAO-18-279 Combating Wildlife Trafficking

441 G St. N.W.

Washington, DC 20548

April 23, 2018

The Honorable Ron Wyden

Ranking Member

Committee on Finance

United States Senate

Dear Senator Wyden:

According to the Department of State, wildlife trafficking1

—the poaching 

and illegal trade of plants, fish, and wildlife—is a growing, multibilliondollar, transnational criminal activity that imperils the continued viability of 

thousands of plant and animal species worldwide, threatens global 

security, and harms legitimate businesses. Estimates place wildlife 

trafficking among the top-ranked illicit types of trade alongside trafficking 

in drugs, weapons, and humans; in 2016, a United Nations report 

estimated the illegal trade in wildlife to be worth from $7 billion to $23 

billion annually.2 The United States is one of the world’s largest trafficking 

markets and is increasingly becoming a source for illegal wildlife and 

wildlife products, according to a Department of the Interior document. It 

also serves as a transit point for wildlife that are illegally trafficked from 

their source countries to other countries for sale.

Wildlife trafficking undermines conservation efforts and continues to push 

some protected and endangered species to the brink of extinction, 

according to Department of State documents. As we have previously 

found, the capture and slaughter of animals are devastating wild 

populations of elephants, rhinoceroses, tigers, pangolins, turtles, exotic 

 1

In this report, we use the term wildlife trafficking to include the trafficking of plants, fish, 

and wildlife. We also use the definition of wildlife trafficking from the Eliminate, Neutralize, 

and Disrupt Wildlife Trafficking Act of 2016, which defines wildlife trafficking as the 

poaching or other illegal taking of protected or managed species and the illegal trade in 

wildlife and their related parts and products. 

2

C. Nellemann et al., eds., The Rise of Environmental Crime—A Growing Threat to 

Natural Resources, Peace, Development, and Security (Nairobi: United Nations 

Environment Programme, 2016).

Letter
Page 2 GAO-18-279 Combating Wildlife Trafficking

birds, and many other species.3 Moreover, wildlife trafficking threatens 

global security by fueling corruption and violence and destabilizing 

communities that depend on wildlife for biodiversity and ecotourism 

revenues. Wildlife trafficking can also have adverse economic impacts. 

For example, the trafficking of illegally harvested timber can harm 

legitimate businesses by causing products made with legally harvested 

timber to be less competitive with similar products made using illegally 

harvested timber.

In recent years, the federal government has emphasized strengthening 

law enforcement efforts to combat the escalating scope and scale of 

wildlife trafficking. For example, in 2014, the White House released a 

national strategy for combating wildlife trafficking that identified 

strengthening enforcement—including federal interdiction and 

investigative efforts—as one of three strategic priorities for the United 

States.4 In addition, in 2017, an executive order made it executive branch 

policy to strengthen enforcement of federal law to thwart the illegal 

smuggling and trafficking of wildlife, among other things.5

Paying rewards to people who provide critical information about illegal 

trafficking activities that leads to results, such as fines or criminal 

convictions, is one of many tools that law enforcement agents can use to 

help them investigate and enforce wildlife trafficking laws.6 Certain laws 

 3

GAO, Combating Wildlife Trafficking: Agencies Are Taking Action to Reduce Demand but 

Could Improve Collaboration in Southeast Asia, GAO-18-7 (Washington, D.C.: Oct. 12, 

2017), and Combating Wildlife Trafficking: Agencies Are Taking a Range of Actions, but 

the Task Force Lacks Performance Targets for Assessing Progress, GAO-16-717 

(Washington, D.C.: Sept. 22, 2016). 

4

Presidential Task Force on Wildlife Trafficking, National Strategy for Combating Wildlife 

Trafficking (Washington, D.C.: February 2014). The Presidential Task Force on Wildlife 

Trafficking is an interagency task force co-chaired by the Departments of the Interior, 

Justice, and State. The task force developed a national strategy to combat wildlife 

trafficking. In addition to strengthening enforcement, the strategy identified reducing 

demand for illegally traded wildlife and expanding international cooperation and 

commitment as strategic priorities for the United States.

5

Exec. Order No. 13773, 82 Fed. Reg. 10,691 (Feb. 14, 2017). 

6

In this report, we use the term reward to refer to a financial payment an agency makes to 

a person after the completion of an investigation, prosecution, or civil or administrative 

proceeding. A reward differs from purchasing information, which is an investigative tool to 

assist in completing an investigation and developing a civil, administrative, or criminal 

case. It is possible that an agency could purchase information from a person during a 

case and then pay that person a reward at the case’s conclusion if information the person 

provided met applicable requirements for a reward.
Page 3 GAO-18-279 Combating Wildlife Trafficking

that prohibit wildlife trafficking authorize federal agencies to pay financial 

rewards to people who provide information on such illegal activities. For 

example, the Endangered Species Act7 and the Lacey Act8 authorize the 

Secretaries of Commerce and the Interior to pay financial rewards to 

people who provide information that leads to arrests, criminal convictions, 

civil penalties, or property forfeitures for violations of those laws.9 The law 

enforcement offices for the Department of the Interior’s U.S. Fish and 

Wildlife Service (FWS) and the Department of Commerce’s National 

Oceanic and Atmospheric Administration (NOAA) are responsible for 

enforcing certain federal laws prohibiting wildlife trafficking.10 Specifically, 

FWS generally enforces federal laws that prohibit trafficking of terrestrial 

wildlife, freshwater fish and other species, and birds, and NOAA generally 

enforces federal laws that prohibit trafficking of marine wildlife and 

anadromous fish.

You asked us to review FWS’s and NOAA’s use of financial rewards to 

combat wildlife trafficking. This report examines (1) laws that authorize 

FWS and NOAA to pay financial rewards for information on wildlife 

trafficking and the extent to which these agencies paid such rewards from 

fiscal years 2007 through 2017, (2) the agencies’ policies on financial 

rewards, (3) information available to the public on financial rewards, and 

(4) the extent to which the agencies reviewed the effectiveness of their 

use of financial rewards in combating wildlife trafficking.

To identify laws that authorize FWS and NOAA to pay financial rewards 

for information on wildlife trafficking, we asked FWS and NOAA attorneys 

to compile a list of laws each of their agencies implements or enforces 

 7

16 U.S.C. § 1540(d)(1). The Endangered Species Act was enacted in 1973 to conserve 

threatened and endangered species and the ecosystems upon which they depend.

8

16 U.S.C. § 3375(d)(1). Among other things, the Lacey Act prohibits transporting and 

selling plants, fish, or wildlife taken in violation of U.S., state, tribal, or foreign law. 

9

The Endangered Species Act and Lacey Act also authorize the Secretaries of Agriculture 

and the Treasury to pay financial rewards. We excluded the Departments of Agriculture 

and the Treasury from this report, however, because of their limited roles in investigating 

wildlife trafficking cases. Agency officials from both departments confirmed that they had 

not paid financial rewards related to wildlife trafficking from fiscal years 2007 through 

2017.

10The NOAA Office of Law Enforcement is part of NOAA’s National Marine Fisheries 

Service (NMFS), which is responsible for the stewardship of the nation’s ocean resources 

and their habitat. The NOAA Office of Law Enforcement provides law enforcement 

services for all of NOAA, so we use the term NOAA in this report, but we focus on the 

office’s work enforcing laws that NMFS implements. 
Page 4 GAO-18-279 Combating Wildlife Trafficking

that prohibit wildlife trafficking and authorize the agency to pay rewards 

for providing information about wildlife trafficking. We then compared the 

list provided to the results of our search of the United States Code for 

such laws. To identify the extent to which FWS and NOAA have paid 

financial rewards for information on wildlife trafficking, we analyzed FWS 

and NOAA data on financial rewards the agencies reported paying from 

fiscal years 2007 through 2017. We took steps to assess the reliability of 

these data, such as interviewing agency officials knowledgeable about 

the data and comparing the data to case records. Specifically, FWS and 

NOAA officials said they track all expenditures, including reward 

payments, in their financial databases, but they are not able to readily 

identify reward payments because their financial systems do not include a 

unique identifier for such payments and their reward information is 

located in multiple databases and formats. As a result, FWS and NOAA 

officials said they identified the rewards they reported to us by manually 

reviewing their financial and law enforcement records, and officials said 

the information was complete to the best of their knowledge. Based on 

these steps, we found the data the agencies provided to be sufficiently 

reliable for reporting information on the rewards the agencies reported 

paying. However, as we discuss in the report, FWS and NOAA officials 

could not provide sufficient assurance that the data included all the 

financial rewards they had paid from fiscal years 2007 through 2017. To 

obtain additional detail about cases where financial rewards were paid, 

we reviewed a nongeneralizable sample of 10 wildlife trafficking cases. 

We selected these cases based on several factors, including amount of 

the reward payment. While the findings from our review cannot be 

generalized to cases we did not select and review, they illustrate how 

FWS and NOAA have used financial rewards in wildlife trafficking cases.

To evaluate FWS and NOAA policies on financial rewards, information 

available to the public, and the extent to which FWS and NOAA reviewed 

the effectiveness of their use of financial rewards in combating wildlife 

trafficking, we reviewed relevant agency policies, publications, websites, 

and examples of public communications on rewards for specific cases. 

We also interviewed agency officials and requested any reviews the 

agencies conducted regarding their use of financial rewards. We 

compared available FWS and NOAA policies, public communications, 
Page 5 GAO-18-279 Combating Wildlife Trafficking

and reviews on their use of financial rewards with federal internal control 

standards.11

Additionally, for all four objectives, we interviewed a nongeneralizable 

sample of 20 stakeholders whom we selected using factors such as the 

individuals’ experience investigating wildlife trafficking cases or their 

expertise in the use of financial rewards as a law enforcement tool. Our 

sample included

• FWS and NOAA law enforcement agents,

• federal prosecutors,

• federal officials responsible for programs that use financial rewards to 

combat illegal activities in contexts outside of wildlife trafficking,

• academics with expertise in the use of financial rewards as a law 

enforcement tool,

• members of the federal Advisory Council on Wildlife Trafficking,12 and

• representatives of nongovernmental organizations that investigate 

wildlife trafficking.

Views from these stakeholders cannot be generalized to those whom we 

did not select and interview. Appendix I presents a more detailed 

description of our objectives, scope, and methodology.

We conducted this performance audit from February 2017 to April 2018 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

 11GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014).

12The Advisory Council on Wildlife Trafficking advises and makes recommendations to the 

Presidential Task Force on Wildlife Trafficking on issues related to combating wildlife 

trafficking. The eight-member Advisory Council includes representatives from the private 

sector, former government officials, non-governmental organizations, and other experts on 

wildlife trade.
Page 6 GAO-18-279 Combating Wildlife Trafficking

As reported by the United Nations, the International Criminal Police 

Organization, and other organizations, wildlife trafficking networks span 

the globe. These organizations have attempted to measure the value of 

illegally traded wildlife, but available estimates are subject to uncertainty. 

In 2016, for example, the United Nations Environment Programme 

(UNEP) reported that various sources estimated the global scale of illegal 

wildlife trade to be from $7 billion to $23 billion annually.13 UNEP also 

estimated that the scale of wildlife crime has increased in recent years in 

part based on a rise in environmental crime.14

U.S. trade in wildlife and related products includes a variety of species, 

such as live reptiles, birds, and mammals, as well as elephant ivory, 

according to law enforcement reports and government and 

nongovernmental officials. FWS and NOAA data on wildlife products 

seized at U.S. ports provide examples of the diversity of illegally traded 

plants, fish, and wildlife imported into or exported from the United States. 

For example, from 2007 to 2016, the top 10 plant, fish, and wildlife 

shipments seized nationally by FWS were coral, crocodiles, conchs, deer, 

pythons, sea turtles, mollusks, ginseng, clams, and seahorses. During 

that time, FWS reported that more than one-third of the wildlife shipments 

it seized were confiscated while being imported from or exported to 

Mexico (14 percent), China (13 percent), or Canada (9 percent).

FWS and NOAA law enforcement offices are responsible for enforcing 

certain laws and treaties prohibiting wildlife trafficking.

• FWS Office of Law Enforcement. This office enforces certain U.S. 

laws and regulations as well as treaties prohibiting the trafficking of 

terrestrial wildlife, freshwater species, and birds.15 Among other 

things, the office aims to prevent the unlawful import, export, and 

interstate commerce of foreign fish and wildlife, as well as to protect 

U.S. plants, fish, and wildlife from unlawful exploitation. As of fiscal 

 13Nellemann et al., The Rise of Environmental Crime.

14Nellemann et al., The Rise of Environmental Crime. This UNEP report considered 

environmental crime to include the illegal trade in wildlife; forestry and fishery crimes; 

illegal dumping of waste, including chemicals; smuggling of ozone-depleting substances; 

and illegal mining. 

15The FWS Office of Law Enforcement is led by an Assistant Director who reports to the 

Deputy Director of Operations for FWS.

Background
Page 7 GAO-18-279 Combating Wildlife Trafficking

year 2016, the office had a budget of $74.7 million and employed 205 

special agents to investigate wildlife crime, including international and 

domestic wildlife trafficking rings.16 Most of these special agents 

report to one of eight regional offices, which receive national 

oversight, support, training, and policy guidance from the FWS Office 

of Law Enforcement headquarters. The office’s headquarters houses 

a special investigative unit focused on conducting complex, largescale criminal investigations of wildlife traffickers. In addition, the FWS 

Office of Law Enforcement has deployed special agents to serve as 

international attachés at seven U.S. embassies.17 These attachés 

provide countertrafficking expertise to embassy staff, work with host 

government officials to build law enforcement capacity, and contribute 

directly to casework or criminal investigations of wildlife traffickers.

According to FWS data, the FWS Office of Law Enforcement opened 

more than 7,000 investigations on wildlife trafficking and other illegal 

activities in fiscal year 2016, including nearly 5,000 cases involving 

Endangered Species Act violations and nearly 1,500 cases involving 

Lacey Act violations. FWS Office of Law Enforcement investigations 

have disrupted wildlife trafficking operations. For example, Operation 

Crash—an ongoing rhino horn and elephant ivory-trafficking 

investigation launched in 2011—has led to over 30 convictions and 

more than $2 million in fines.

• NOAA Office of Law Enforcement. This office enforces certain U.S. 

laws and regulations as well as treaties prohibiting the trafficking of 

marine wildlife, including fish, as well as anadromous fish.18 Among 

other things, the office aims to prevent the illegal, unregulated, and 

unreported harvesting and trade of fish as well as the trafficking of 

protected marine wildlife. As of fiscal year 2016, the office had a 

budget of $68.6 million and employed 77 special agents to investigate 

 16FWS Office of Law Enforcement special agents are trained criminal investigators who 

are charged with enforcing federal wildlife laws throughout the United States. The FWS 

Office of Law Enforcement also employs wildlife inspectors who may investigate wildlife 

crime in their role as import-export control officers responsible for ensuring that wildlife 

shipments comply with U.S. and international wildlife protection laws. 

17As of February 2018, FWS had attachés in Botswana, China, Gabon, Mexico, Peru, 

Tanzania, and Thailand. According to FWS’s fiscal year 2018 budget request, the agency 

plans to deploy additional attachés to Indonesia and the Netherlands by the end of 2018.

18The NOAA Office of Law Enforcement is led by a Director who reports to NOAA 

Fisheries’ Deputy Assistant Administrator for Operations. In addition, the NOAA Office of 

the General Counsel’s Enforcement Section handles civil cases. Together, the two offices 

make up NOAA’s enforcement program.
Page 8 GAO-18-279 Combating Wildlife Trafficking

wildlife crimes within its jurisdiction.19 These agents report to one of 

five regional offices, and those offices receive national oversight, 

support, and policy guidance from the NOAA Office of Law 

Enforcement headquarters.

According to NOAA data, the NOAA Office of Law Enforcement 

initiated more than 5,000 investigations in fiscal year 2016. About half 

of those investigations involved violations of the Magnuson-Stevens 

Fishery Conservation and Management Act, as amended,20 and some 

of the 5,000 investigations involved violations of the Endangered 

Species Act or the Lacey Act. NOAA Office of Law Enforcement 

investigations have disrupted wildlife trafficking operations. For 

example, in fiscal year 2016, a NOAA Office of Law Enforcement 

investigation led to the conviction of a company and five individuals 

for illegally trafficking whale bone carvings, walrus ivory carvings, 

black coral carvings, and other products derived from protected 

species into the United States.

The FWS and NOAA law enforcement offices collaborate with other 

government agencies and organizations to combat wildlife trafficking. 

Both agencies work with other federal, state, and tribal law enforcement 

officers as well as their international counterparts as needed during 

wildlife trafficking investigations. For example, FWS and NOAA work with 

U.S. Customs and Border Protection, U.S. Immigration and Customs 

Enforcement, and the U.S. Department of Agriculture to maintain import 

and export controls and interdict smuggled wildlife and related products at 

U.S. ports of entry. In addition, FWS and NOAA collaborate with 

Department of Justice prosecutors on criminal cases that result from 

agency investigations.

Both agencies also collaborate with nongovernmental organizations to 

combat wildlife trafficking. For example, FWS and NOAA officials said 

that nongovernmental organizations have, in some cases, offered 

financial rewards (in addition to rewards offered by FWS and NOAA) for 

information on a wildlife crime. In addition, some nongovernmental 

organizations proactively provide information to FWS and NOAA on 

wildlife trafficking activities in the United States or foreign countries that 

 19NOAA Office of Law Enforcement special agents conduct undercover operations and 

longer-term, complex investigations of wildlife crimes within NOAA’s jurisdiction. 

20Pub. L. No. 94-265, 90 Stat. 331 (Apr. 13, 1976) (generally codified as amended at 16 

U.S.C. §§ 1801-1891d). The Magnuson-Stevens Fishery Conservation and Management 

Act, as amended, governs marine fisheries management in federal waters.
Page 9 GAO-18-279 Combating Wildlife Trafficking

violate U.S. laws.21 For example, in 2017, a nongovernmental 

organization created a website to collect tips on wildlife crime and to 

connect the sources of those tips with relevant U.S. authorities for 

potential financial rewards.22

FWS may pay financial rewards from moneys in two accounts.

• Law Enforcement Reward Account. FWS may pay rewards under 

the Endangered Species Act, the Lacey Act, and the Rhinoceros and 

Tiger Conservation Act23 from moneys in the agency’s Law 

Enforcement Reward Account. The moneys in this account come from 

fines, penalties, and proceeds from forfeited property for violations of 

these three laws. According to FWS officials, these moneys are 

available until expended. These moneys can be used to (1) pay 

financial rewards to those who provide information that leads to an 

arrest, criminal conviction, civil penalty assessment, or forfeiture of 

property for any violation of the Endangered Species Act, the Lacey 

Act, or the Rhinoceros and Tiger Conservation Act or (2) provide 

temporary care for plants, fish, or wildlife that are the subject of a civil 

or criminal proceeding under the Endangered Species Act, Lacey Act, 

or the Rhinoceros and Tiger Conservation Act.24 As of the beginning 

 21Under the Lacey Act, it is illegal to import wildlife into the United States that was taken in 

violation of foreign law, so a nongovernmental organization could provide information to 

FWS or NOAA on wildlife that are being illegally taken in foreign countries and then being 

imported into the United States. 

22The National Whistleblower Center—a nongovernmental organization that advocates for 

whistleblowers—launched its Global Wildlife Whistleblower Program in 2017 with the aim 

of protecting and incentivizing individuals to report evidence of wildlife trafficking 

confidentially and anonymously via a secure online platform. The program incorporates a 

transnational reporting system designed to protect the identities of individuals who report 

information, as well as an educational program informing those individuals of potential 

financial rewards from federal agencies for reporting wildlife trafficking crimes. 

2316 U.S.C. § 5305a(f). Among other things, the Rhinoceros and Tiger Conservation Act 

prohibits the sale, import, and export of products containing any substance derived from 

any species of rhinoceros or tiger.

24The Endangered Species Act provision that authorizes the payment of financial rewards 

also requires deposits to be made into the Cooperative Endangered Species Conservation 

Fund whenever the amount of fines, penalties, and proceeds from forfeited property 

collected under the Endangered Species Act or the Lacey Act exceeds $500,000. In a 

separate report, we provided information on the extent to which NOAA tracked its 

Endangered Species Act and Lacey Act collections and requested that the Department of 

the Treasury make any statutorily required deposits. See GAO, Cooperative Endangered 

Species Conservation Fund: NOAA Should Track Its Endangered Species Act and Lacey 

Act Collections and Request Any Required Deposits, GAO-18-346R (Washington, D.C.: 

Apr. 9, 2018).
Page 10 GAO-18-279 Combating Wildlife Trafficking

of fiscal year 2017, the balance of the Law Enforcement Reward 

Account was about $7 million.

• Law Enforcement Special Funds Account. FWS may also pay 

rewards from moneys in its law enforcement office’s Special Funds 

Account. The moneys in this account come from an annual line item 

appropriation and are available until expended. Since fiscal year 

1988, this appropriation has provided FWS up to $400,000 each year 

to pay for information, rewards, or evidence concerning violations of 

laws FWS administers, as well as miscellaneous and emergency 

expenses of enforcement activity that the Secretary of the Interior 

authorized or approved.25

NOAA generally pays rewards from moneys available in the Fisheries 

Enforcement Asset Forfeiture Fund.26 The moneys in this account come 

from fines, penalties, and proceeds from forfeited property for violations of 

marine resource laws that NOAA enforces, including the MagnusonStevens Fishery Conservation and Management Act, the Endangered 

Species Act, and the Lacey Act. According to NOAA officials, moneys are 

available until expended and can be used to pay certain enforcementrelated expenses, including travel expenses, equipment purchases, and 

the payment of financial rewards. As of the beginning of fiscal year 2017, 

the Fisheries Enforcement Asset Forfeiture Fund had a balance of about 

$18 million.

Academic literature on the use of financial rewards to combat illegal 

activities and stakeholders we interviewed identified several advantages 

and disadvantages of using financial rewards to obtain information on 

wildlife trafficking. Potential advantages of using financial rewards include 

the following:

• Providing incentives. The potential for a financial reward can 

motivate people with information to come forward when they 

otherwise might not do so.

 25FWS received this line item appropriation prior to fiscal year 1988, but the amount 

appropriated increased to up to $400,000 that year. In fiscal year 2012, this line item 

appropriation became a permanent annual appropriation. Pub. L. No. 112-74, div. E, tit. I, 

125 Stat. 786, 988 (Dec. 23, 2011). 

26According to NOAA officials, the agency may also pay rewards from NOAA’s 

Operations, Research, and Facilities appropriation without express statutory authority if a 

reward is necessary or essential to the enforcement of a law. These officials said they 

were aware of NOAA paying one reward from this appropriation, but generally expect to 

pay future rewards from the Fisheries Enforcement Asset Forfeiture Fund.
Page 11 GAO-18-279 Combating Wildlife Trafficking

• Increasing public awareness. Financial rewards may bring greater 

public attention to the problem of wildlife trafficking, including federal 

efforts to combat wildlife trafficking.

• Saving resources. Using financial rewards may save agency 

resources by enabling agents to get information sooner and at a lower 

cost than they could have through their own efforts.

Potential disadvantages of using financial rewards include the following:

• Eliciting false or unproductive leads. Financial rewards may 

generate false or unproductive leads.

• Affecting witness credibility. Financial rewards may lead to a 

source’s credibility being challenged at trial by defense attorneys 

since sources receive compensation for the information they provide.

• Consuming resources. The potential for a financial reward may 

create a flood of tips that take agency time and resources to follow up 

on or corroborate.

Outside of wildlife trafficking, multiple federal agencies and federal courts 

are authorized to pay financial rewards for information on illegal activities 

under certain circumstances. For example, U.S. Customs and Border 

Protection—which controls, regulates, and facilitates the import and 

export of goods through U.S. ports of entry—is authorized, under certain 

circumstances, to pay rewards for original information about violations of 

any laws that it enforces.27 The Department of State may also pay 

rewards under certain circumstances, including for information leading to 

the disruption of financial mechanisms of a transnational criminal group.28

Similarly, the U.S. Securities and Exchange Commission (SEC) and 

Internal Revenue Service (IRS) may pay rewards for information about 

violations of federal securities laws and the underpayment of taxes, 

respectively, if certain conditions are met.29 Federal judges may award 

 2719 U.S.C. § 1619; 19 C.F.R. § 161.12. 

2822 U.S.C. § 2708(b)(7). Through its Transnational Organized Crime Rewards program, 

the Department of State has offered up to $1 million for information leading to the 

dismantling of the Xaysavang Network. The Xaysavang Network is an international wildlife 

trafficking syndicate that facilitates the killing of endangered elephants, rhinos, pangolins, 

and other protected species for products such as ivory and rhino horn. Department of 

State officials told us that as of January 2018 the department had not paid a reward as a 

result of this offer.

29The Office of the Whistleblower within the SEC administers the agency’s reward 

program, which is authorized by 15 U.S.C. § 78u-6. IRS’s Whistleblower Office 

administers the agency’s reward program, which is authorized by 26 U.S.C. § 7623.
Page 12 GAO-18-279 Combating Wildlife Trafficking

money to persons who give information leading to convictions for violating 

treaties, laws, and regulations that prohibit certain pollution from ships, 

including oil and garbage discharges.30

FWS and NOAA officials identified multiple laws, such as the Endangered 

Species Act and the Lacey Act, that authorize the payment of financial 

rewards to people who provide information on wildlife trafficking. FWS 

and NOAA reported paying few financial rewards under these laws from 

fiscal years 2007 through 2017. However, agency officials could not 

provide sufficient assurance that the reward information they provided to 

us represented all of their reward payments for this period.

 30Act to Prevent Pollution from Ships, 33 U.S.C. § 1908(a). According to Department of 

Justice officials, federal prosecutors regularly request that courts pay these rewards to 

sources, who are typically crew members working on ships violating the law. In addition, 

Department of Justice officials said that most of the cases they prosecute related to 

pollution from ships originate from tips provided by sources seeking rewards.

Multiple Laws 

Authorize FWS and 

NOAA to Pay 

Rewards for Wildlife 

Trafficking 

Information, but the 

Agencies Reported 

Paying Few Rewards 

from Fiscal Years 

2007 through 2017
Page 13 GAO-18-279 Combating Wildlife Trafficking

FWS and NOAA officials identified over 10 laws prohibiting wildlife 

trafficking—including the Endangered Species Act, Lacey Act, and Bald 

and Golden Eagle Protection Act31—that specifically authorize the 

payment of financial rewards in certain circumstances to people who 

provide information on violations of the law (see app. II for a complete list 

of the laws). These laws provide discretion to the agencies to choose 

whether to pay rewards but have varying requirements for who is eligible 

to receive a reward and the payment amounts.32 For example, the Bald 

and Golden Eagle Protection Act caps rewards at $2,500 for information 

that leads to a conviction. In contrast, the Endangered Species Act does 

not cap reward amounts and authorizes rewards for information that leads 

to a conviction as well as to an arrest, civil penalty, or forfeiture of 

property. Table 1 identifies the laws that FWS and NOAA officials 

indicated they have used to pay financial rewards for information on 

wildlife trafficking from fiscal years 2007 through 2017, along with 

information on these laws’ requirements for payment of rewards.

Table 1: Laws the U.S. Fish and Wildlife Service (FWS) and the National Oceanic and Atmospheric Administration (NOAA) 

Reported Using to Pay Financial Rewards for Information on Wildlife Trafficking, Fiscal Years 2007-2017

Laws

Secretaries authorized 

to pay rewards

Source of moneys 

to pay rewards

Who is eligible to 

receive rewardsa Possible reward amounts

African Elephant 

Conservation Act

16 U.S.C. § 4225

Secretary of the 

Treasury, upon 

recommendation 

of the Secretary of 

the Interior

Penalties collected 

under the act, 

subject to 

appropriations

Any person who furnishes 

information that leads to a civil 

penalty or criminal conviction 

under the act, except for an 

officer or employee of the 

United States or any state or 

local government who furnishes 

information in performing his 

or her official duties

Equal to not more 

than half of any 

criminal or civil 

penalty or fine with 

respect to which the 

reward is paid, or 

$25,000, whichever 

is less

Bald and Golden 

Eagle Protection Act, 

as amended

16 U.S.C. § 668(a)

Not specified Fines imposed for 

violating the act

Any person who gives 

information that leads 

to a conviction

Half of any fine 

imposed, not to 

exceed $2,500

 3116 U.S.C. § 668(a). The Bald and Golden Eagle Protection Act prohibits, among other 

things, the taking, sale, purchase, transport, export, or import of any bald or golden eagle, 

alive or dead, including any part, nest, or egg, unless allowed by permit.

32FWS and NOAA officials said that the FWS and NOAA Offices of Law Enforcement 

have the authority to pay such rewards. 

The Endangered Species 

Act, Lacey Act, and Other 

Laws Authorize the 

Payment of Financial 

Rewards
Page 14 GAO-18-279 Combating Wildlife Trafficking

Laws

Secretaries authorized 

to pay rewards

Source of moneys 

to pay rewards

Who is eligible to 

receive rewardsa Possible reward amounts

Endangered 

Species Act, as 

amended

16 U.S.C. § 1540(d)

Secretaries of 

Agriculture, 

Commerce, the 

Interior, and the 

Treasury

Penalties, fines, 

and forfeitures of 

property under 

the act

Any person who furnishes 

information that leads to an arrest, 

criminal conviction, civil penalty 

assessment, or forfeiture of 

property for any violation of the 

act or its implementing 

regulations, except for any 

officer or employee of the 

United States or any state or 

local government who furnishes 

information in performing his 

or her official duties

The amount of 

the reward is 

designated by the 

Secretary of 

Agriculture, 

Commerce, the 

Interior, or the 

Treasury, as 

appropriate

Fish and Wildlife 

Improvement Act, 

as amended

16 U.S.C. § 742l(k)(2)b

Secretaries of 

Commerce and 

the Interior

Appropriations Not specified Not specified

Lacey Act, as 

amended

16 U.S.C. § 3375(d)

Secretaries of 

Agriculture, 

Commerce, the 

Interior, and the 

Treasury

Penalties, fines 

and forfeitures of 

property under

the act

Any person who furnishes 

information that leads to an 

arrest, criminal conviction, civil 

penalty assessment or forfeiture 

of property for any violation of

the act or its implementing 

regulations, except for any officer 

or employee of the United States 

or any state or local government 

who furnishes information in 

performing his or her 

official duties

The amount of 

the reward is 

designated by 

the Secretary 

of Agriculture, 

Commerce, the 

Interior, or the 

Treasury, as 

appropriate

Magnuson-Stevens 

Fishery Conservation 

and Management Act, 

as amended

16 U.S.C. § 

1861(e)(1)(B)c

Secretaries of 

Commerce and 

the Treasury

Penalties, fines, and 

forfeitures of property 

for violations of the 

act or any other 

fishery resource 

law that the Secretary 

of Commerce 

enforces

Any person who furnishes 

information that leads to an 

arrest, conviction, civil penalty 

assessment, or forfeiture of 

property for any violation of the 

act or other marine resource law 

that the Secretary of Commerce 

enforces

Not less than 20 

percent of the 

penalty collected, 

or $20,000, 

whichever is the 

lesser amount

Source: GAO summary of laws authorizing financial reward payments. | GAO-18-279

a

These laws do not prohibit paying rewards to foreigners, but FWS and NOAA reward policies do not 

allow rewards to be paid to foreign government employees.

b

FWS has used the Fish and Wildlife Improvement Act, as amended, to pay financial rewards for 

information about violations of the Migratory Bird Treaty Act of 1918 (16 U.S.C. §§ 703–712), which 

prohibits, among other things, the taking, killing, and selling of migratory birds unless authorized by 

regulations.

c

NOAA has used the Magnuson-Stevens Fishery Conservation and Management Act, as amended, 

to pay financial rewards for information about violations of the Endangered Species Act and the 

Lacey Act.
Page 15 GAO-18-279 Combating Wildlife Trafficking

FWS and NOAA reported paying few financial rewards for information on 

wildlife trafficking from fiscal years 2007 through 2017, but agency 

officials could not provide sufficient assurance that this information was 

complete. Officials from both agencies said that their agencies have not 

prioritized the use of rewards, and they believed that the reward 

information they identified—such as the number, dollar amount, and year 

that rewards were paid—appropriately captured the few reward payments 

they made during this time frame. Based on the agencies’ reviews of their 

records, FWS reported paying 25 rewards for a total of $184,500 from 

fiscal years 2007 through 2017, and NOAA reported paying 2 rewards for 

a total of $21,000 during that same period (see table 2). See appendix III 

for additional details on the cases where financial rewards were paid.

FWS and NOAA Reported 

Paying Few Rewards for 

Information on Wildlife 

Trafficking but Could Not 

Assure the Completeness 

of the Information
Page 16 GAO-18-279 Combating Wildlife Trafficking

Table 2: Number and Dollar Amount of Financial Rewards That the U.S. Fish and Wildlife Service (FWS) and the National 

Oceanic and Atmospheric Administration (NOAA) Reported Paying for Information on Wildlife Trafficking, Fiscal Years 2007-

2017

Agency

Fiscal 

year

Number of 

rewards agency 

reported paying

Lowest 

reward amount 

(dollars)

Highest 

reward amount 

(dollars)

Total 

reward amount 

(dollars) 

FWS 2007 2 2,500 10,000 12,500

2008 2 7,500 12,000 19,500

2009 3 2,500 40,000 47,500

2010 4 4,000 30,000 43,500

2011 3 2,000 3,000 7,500

2012 3 3,500 8,500 15,500

2013 7 1,000 20,000 33,500

2014 1 5,000 5,000 5,000

2015 0 0 0 0

2016 0 0 0 0

2017 0 0 0 0

Total 25 — — 184,500

NOAA 2007 0 0 0 0

2008 0 0 0 0

2009 0 0 0 0

2010 0 0 0 0

2011 0 0 0 0

2012 1 1,000 1,000 1,000

2013 0 0 0 0

2014 0 0 0 0

2015 1 20,000 20,000 20,000

2016 0 0 0 0

2017 0 0 0 0

Total 2 — — 21,000

Source: GAO analysis of FWS and NOAA data. | GAO-18-279

Notes: FWS and NOAA officials could not provide sufficient assurance that the reward information 

reported to us and presented here represents all of their reward payments from fiscal years 2007 

through 2017, but they said the information was complete to the best of their knowledge. We use the 

term wildlife trafficking to include the trafficking of plants, fish, and wildlife. We use the definition of 

wildlife trafficking from the Eliminate, Neutralize, and Disrupt Wildlife Trafficking Act of 2016, which 

defines wildlife trafficking as the poaching or other illegal taking of protected or managed species and 

the illegal trade in wildlife and their related parts and products.
Page 17 GAO-18-279 Combating Wildlife Trafficking

FWS reported paying rewards in trafficking cases involving a variety of 

wildlife species, such as eagles, bears, reptiles, and mollusks, across the 

11-year period. FWS officials said they generally paid rewards to thank 

sources who proactively provided information. For example, based on our 

review of a reward case, FWS paid a reward in 2010 because the source 

provided information that was crucial in uncovering an attempt to illegally 

traffic leopards into the United States from South Africa. FWS would not 

have known about this illegal activity if the source had not come forward 

with the information. In several cases we reviewed, FWS officials said 

that the sources did not know about the possibility of receiving a reward 

when they contacted the agency with information.

The two rewards NOAA reported paying from fiscal years 2007 through 

2017 involved the illegal trafficking of sea scallops and a green sea turtle. 

NOAA officials said that in both cases they paid a reward to thank the 

source who proactively provided information to law enforcement agents. 

For example, the agent who investigated the sea scallop case reported 

requesting the reward because the information the source proactively 

provided was timely, credible, and led to the criminal conviction of several 

individuals.

FWS and NOAA officials could not provide sufficient assurance that the 

reward information they reported to us represented all of the rewards their 

agencies had paid from fiscal years 2007 through 2017, but they said the 

information was complete to the best of their knowledge. Specifically, 

FWS and NOAA officials said they track all their expenditures, including 

reward payments, in their financial databases. However, they are not able 

to readily identify reward payments because their financial systems do not 

include a unique identifier for such payments and their reward information 

is located in multiple databases and formats. As a result, FWS and NOAA 

officials said they identified the rewards they reported to us by manually 

reviewing their financial and law enforcement records. In particular, FWS 

officials said they reviewed their paper records to identify instances when 

the agency paid rewards and then retrieved additional information from 

their financial and law enforcement databases, such as final payment 

amounts. NOAA officials said they identified instances when the agency 

paid rewards by using a combination of paper and electronic records 

located at NOAA’s headquarters office. NOAA officials also contacted 

their regions to obtain additional information located at the regional offices 

to confirm information about the rewards NOAA had paid.

Seventeen stakeholders we interviewed who had experience investigating 

wildlife trafficking or expertise in using financial rewards as a law 

Trafficked Asian leaf turtle with legs taped 

during transport

The U.S. Fish and Wildlife Service (FWS) paid 

a $5,000 reward in fiscal year 2014 to a mail 

courier who provided law enforcement agents 

information on a reptile trafficking ring that 

was illegally importing and exporting reptiles 

to and from the United States and Hong 

Kong. The case resulted in the indictment of 

six defendants and the forfeiture of 

approximately $24,000 worth of shipments 

containing live turtles, Gila monsters, and 

snakes. A FWS official said the courier 

provided the information because the 

individual was concerned about the animals’ 

welfare, and was not initially aware of the 

potential for receiving a financial reward.

Source: FWS. | GAO-18-279
Page 18 GAO-18-279 Combating Wildlife Trafficking

enforcement tool said that it would be useful for FWS and NOAA to 

maintain comprehensive information on the rewards they paid. For 

example, two stakeholders said that maintaining comprehensive 

information and making that information available to law enforcement 

agents could motivate agents to make greater use of rewards as a law 

enforcement tool. Two other stakeholders said that maintaining 

information on and monitoring reward use would allow the agencies to 

make ongoing adjustments, such as adjusting payment amounts, to make 

the most effective use of rewards in combating wildlife trafficking.

Federal internal control standards say that management should clearly 

document internal control and all transactions and other significant events 

in a manner that allows the documentation to be readily available for 

examination.33 Control activities can be implemented in either an 

automated or a manual manner, but automated control activities tend to 

be more reliable because they are less susceptible to human error and 

are typically more efficient.34

FWS and NOAA officials agreed that maintaining reward information so 

that complete information is easily retrievable may be beneficial. FWS 

officials said having clearly documented and readily available reward 

information could improve how they manage rewards and enable them to 

monitor and examine their use of rewards more holistically. The officials 

said they may analyze options for creating a single repository for reward 

information but did not commit to doing so. They said that creating a 

single repository for reward information may involve some drawbacks, 

such as duplicating some data entry in separate databases. Similarly, 

NOAA officials said having clearly documented and readily available 

reward information would provide agency management with easier and 

more consistent access to that information. As a result, they said that they 

are exploring modifications to their financial and law enforcement 

databases to better identify and track rewards. For example, NOAA 

officials said they may be able to create a unique identifier to flag 

payments that are for rewards in their financial system to enable them to 

identify payment amounts more easily. NOAA officials did not provide a 

time frame for completing modifications to their financial system. By 

tracking reward information so that it is clearly documented and readily 

available for examination, FWS and NOAA can better ensure that they 

 33GAO-14-704G. 

34GAO-14-704G.

Cotton muslin bags filled with illegally 

trafficked sea scallop meat

The National Oceanic and Atmospheric 

Administration (NOAA) paid a $20,000 reward 

in fiscal year 2015 to a source who initiated 

contact with NOAA regarding fishermen who 

were illegally trafficking sea scallops. The 

investigation revealed that the fishermen 

illegally harvested a total of 34,277 pounds of 

scallop meat, valued at $641,900. Seven 

individuals and one company were convicted. 

A NOAA official said the source provided 

information thinking it was the right thing to do

and was not initially aware of the potential for 

receiving a financial reward.

Source: NOAA. | GAO-18-279
Page 19 GAO-18-279 Combating Wildlife Trafficking

have complete information on the rewards they have paid to help manage 

their use of rewards as a law enforcement tool.

FWS and NOAA have policies to guide their law enforcement agents on 

the process for preparing and submitting a request to pay a financial 

reward. Specifically, both agencies’ policies call for agents to include a 

description of the case, the nature of the information that the source 

provided, a justification for providing a reward, and an explanation of how 

a proposed reward amount was developed. These policies also outline 

the general review and approval process, how payments are to be made 

upon approval of a request, and eligibility criteria to receive a reward. For 

example, FWS and NOAA policies prohibit paying rewards to foreign 

government officials as well as paying rewards to any person whose 

receipt of a reward would create a conflict of interest or the appearance of 

impropriety.35

NOAA’s policy explicitly states that the NOAA Office of Law Enforcement 

is to use statutorily authorized rewards as a tool to obtain information 

from the public on resource violations and that rewards can help promote 

compliance with marine resource laws. NOAA’s policy suggests that 

agents consider advertising reward offers to assist investigations, 

encourages press releases, and describes the process agents should 

follow to do so. Moreover, NOAA’s policy specifies factors that agents 

might include in their reward requests to support the proposed reward, 

such as (1) the benefit to the marine resources that was furthered by the 

information provided; (2) the risk, if any, the individual took in collecting 

and providing the information; (3) the probability that the investigation 

would have been successfully concluded without the information 

provided; and (4) the relationship between any fines or other collections 

and the information provided.

FWS’s policy specifies that rewards may be provided in situations in 

which an individual furnishes essential information leading to an arrest, 

conviction, civil penalty, or forfeiture of property. However, it does not 

discuss the usefulness of financial rewards as a law enforcement tool or 

the types of circumstances when rewards should be used or advertised to 

the public. Further, FWS’s policy does not communicate necessary

 35FWS and NOAA policies do not prohibit paying rewards to foreigners who are not 

government officials. 

FWS and NOAA 

Have Policies for 

Administering Reward 

Payments, but FWS’s 

Policy Does Not 

Specify Factors to 

Consider When 

Developing Reward 

Amounts
Page 20 GAO-18-279 Combating Wildlife Trafficking

quality information internally that agents may need when deciding to 

request the payment of rewards. In particular, it does not specify factors 

for agents to consider when developing proposed reward amounts. 

Instead, the policy leaves it to the discretion of field and regional agents 

to develop proposed reward amounts within any limitations specified in 

law. Some FWS agents we interviewed said that they developed 

proposed reward amounts on a case-by-case basis and did not know 

whether their proposed amounts were enough, too little, or too much. In 

addition, some agents said that because FWS’s policy does not specify 

factors for agents to consider, the reward approval process is subjective 

and unclear and this has made it challenging for the agents to develop 

proposed reward amounts. For example, one agent we interviewed said 

he submitted a request to his supervisor to pay a $10,000 reward to a 

source who provided information on a major wildlife trafficker. But, for 

reasons unknown to the agent, his supervisor reduced the amount to 

$1,000. FWS headquarters officials said field agents submit reward 

requests to headquarters for approval, and these officials were not aware 

of instances of proposed reward amounts being changed or denied during 

the review process.

Seven of the 20 stakeholders we interviewed suggested that FWS 

augment its reward policy to specify factors for agents to consider when 

developing proposed reward amounts. For example, helpful factors to 

consider when developing a proposed reward amount may include (1) the 

number of hours the source dedicated to the case, (2) the risk the source 

took in providing the information, (3) the significance of the information 

provided by the source, and (4) the amount of fines or other penalties 

collected as a result of the information. Two stakeholders expressed 

concern that some of FWS’s reward payments were insufficient, 

especially when comparing the amount of time and effort or the risk a 

source faced in providing the information. A couple of stakeholders also 

said that without a policy that specifies factors for agents to consider, 

reward amounts may be subjective and could vary depending on which 

agent develops the reward proposal. Another stakeholder said that it was 

important to specify factors for agents to consider when developing 

proposed reward amounts so that the agency has a reasonable and 

defensible basis for the reward amounts it pays across cases.

According to federal standards for internal control, management should 

internally communicate the necessary quality information to achieve an 
Page 21 GAO-18-279 Combating Wildlife Trafficking

agency’s objectives.36 For example, management communicates quality 

information down and across reporting lines to enable personnel to make 

key decisions. FWS officials said they believe that their reward policy is 

sound, indicating they believe that law enforcement agents have the 

information they need to develop proposals for reward amounts in cases 

where rewards are warranted. However, they also agreed that it may be 

helpful to review their policy but did not commit to doing so. By 

augmenting its policy to specify factors for agents to consider when 

developing proposed reward amounts, FWS can better ensure that its 

agents have the necessary quality information to prepare defensible 

reward proposals.

Based on our review of the agencies’ websites and other 

communications, we found that FWS and NOAA communicate little 

information to the public on financial rewards for reporting information on 

wildlife trafficking, such as the potential availability of rewards and 

eligibility criteria. Specifically, some FWS and NOAA law enforcement 

websites provided information to the public on ways to report violations of 

the laws that the agencies are responsible for enforcing, such as via tip 

lines. Some of the websites also provided examples of the types of 

information the public can report, such as photos or other documentation 

of illegal activities. However, most of the agencies’ websites did not 

indicate that providing information on illegal activities could result in a 

reward. In contrast, the FWS Alaska regional office’s website provided 

information on the potential availability of rewards and ways the public 

may submit information for a potential reward. For example, this website 

provided phone numbers and an e-mail address for the public to use 

when submitting information. Figure 1 shows the information available on 

FWS’s and NOAA’s national and regional websites relevant to reporting 

violations of the laws the agencies enforce in general and on receiving 

rewards in particular.

 36GAO-14-704G.

FWS and NOAA 

Communicate Little 

Information to the 

Public on Financial 

Rewards
Page 22 GAO-18-279 Combating Wildlife Trafficking

Figure 1: Publicly-Available Information on Reporting Illegal Activities and Receiving Financial Rewards on U.S. Fish and 

Wildlife Service and National Oceanic and Atmospheric Administration Websites, as of December 2017 and January 2018

In addition, FWS and NOAA headquarters officials said their field agents 

have used other means to communicate the potential availability of 

rewards in specific cases when the agents had no other information that 

could help solve those cases. For example, a FWS field official said that 

the agency advertised a reward offer for information on a case of bald 

eagle killings by distributing reward posters and posting news releases in 

the vicinity where the killings occurred. Similarly, NOAA officials said they 

have advertised reward offers through various means, including 

circulating reward posters in specific geographic areas after an illegal 

activity has occurred. Figure 2 shows a reward poster that NOAA 

distributed in Guam in 2017 advertising a $1,000 reward for information 

leading to the arrest and conviction of sea turtle poachers.
Page 23 GAO-18-279 Combating Wildlife Trafficking

Figure 2: National Oceanic and Atmospheric Administration (NOAA) Poster 

Advertising a $1,000 Financial Reward in 2017 for Information on Sea Turtle 

Poachers in Guam

Instead of having a plan for communicating general information to the 

public on rewards, FWS and NOAA grant discretion to their regional 

offices and law enforcement agents to determine the type and level of 

communication to provide, according to FWS and NOAA policies. FWS 

officials explained that because they typically use financial rewards to 

thank individuals who come forward on their own accord—rather than 

using rewards to incentivize individuals with information to come 

forward—they have not seen the need to communicate more information 
Page 24 GAO-18-279 Combating Wildlife Trafficking

to the public on the potential availability of rewards. NOAA officials said 

they have targeted their communications on rewards by publicizing 

reward offers for specific cases where they do not have leads. They 

added that they want to receive quality information and already receive a 

substantial amount of information from sources who reach out to them 

proactively, so NOAA has not seen the need to communicate more 

information to the public on the potential availability of rewards.

Sixteen of the 20 stakeholders we interviewed said that it would be useful 

for FWS and NOAA to advertise the potential availability of financial 

rewards. Several stakeholders said that if the public does not know about 

the possibility for rewards, then some people with information may not be 

incentivized to come forward. Two stakeholders added that agencies 

should carefully consider how and which reward information to 

communicate to the public so that people who are most likely to have 

information on illegal wildlife trafficking learn about the potential for 

rewards. For example, one stakeholder suggested advertising rewards at 

ports where international shipments are offloaded or placing 

advertisements at wildlife trafficking nodes, such as entrances to African 

wildlife refuges. This stakeholder suggested advertising rewards along 

with wildlife trafficking awareness-raising posters that nongovernment 

organizations place in some airports.37

In addition, 14 stakeholders suggested that it would be useful for FWS 

and NOAA to provide information to the public on the process for 

submitting information to potentially receive rewards. Several other 

stakeholders said that it is important for the public to understand whether 

they may be eligible for a reward, how to submit information, and whether 

or to what extent their confidentiality will be protected. Another 

stakeholder provided examples of how other agencies provide information 

about their reward programs on their websites. SEC and IRS, for 

instance, use their websites to communicate information to the public on 

the process for reporting illegal activity for financial rewards. This 

information includes the types of information to report, confidentiality 

rules, eligibility criteria, and the process for submitting information to 

obtain a reward. In addition, the Department of State posts instructions on 

 37FWS partners with private companies and WildAid—a nongovernmental organization 

whose mission is to reduce global consumption of wildlife-related products, among other 

things—to place wildlife trafficking awareness-raising posters in some airports and create 

and display in-flight videos, among other efforts. 
Page 25 GAO-18-279 Combating Wildlife Trafficking

its websites on how to submit information on an illegal activity and 

potentially receive a reward.

Federal internal control standards say that management should externally 

communicate the necessary quality information to achieve an agency’s 

objectives.38 For example, using appropriate methods to communicate, 

management communicates quality information so that external parties, 

such as the public, can help the agency achieve its objectives. This could 

include communicating information to the public on the types of 

information and eligibility requirements for potentially receiving rewards 

for reporting information on wildlife trafficking.

FWS officials said that making more reward information available could 

lead to a significant increase in the amount of information the agency 

receives, which, in turn, could strain FWS’s resources in following up on 

that information. However, FWS officials also agreed that it was 

reasonable to consider making more reward information available to 

relevant members of the public, particularly in targeted circumstances, but 

did not commit to doing so. Similarly, NOAA officials said they had some 

concerns about the additional resources it might take to investigate 

potentially unreliable or false tips that may result if they make reward 

information broadly available to the public, but they agreed that it would 

be reasonable for the agency to consider doing so. NOAA officials also 

said they may consider making more reward information publicly available 

at the conclusion of our audit but provided no plans for doing so. By 

determining the types of additional information to communicate to the 

public on rewards—such as providing information on the agency’s 

website on the potential availability of rewards—and then developing and 

implementing plans to do so, FWS and NOAA can improve their chances 

of obtaining information on wildlife trafficking activities that they otherwise 

might not receive.

 38GAO-14-704G.
Page 26 GAO-18-279 Combating Wildlife Trafficking

FWS and NOAA have not reviewed the effectiveness of their use of 

financial rewards or considered whether any changes might improve the 

usefulness of rewards as a tool for combating wildlife trafficking. FWS 

officials said their agency has not reviewed or considered changes to its 

use of rewards because the agency has not prioritized the use of 

rewards. NOAA officials said their agency has not focused on using 

rewards or identified the need to review its use of this tool, particularly in 

light of other, higher mission priorities.

Nine of the 20 stakeholders we interviewed said that FWS and NOAA 

should review the effectiveness of their use of rewards and consider 

potential improvements. Several stakeholders said that it would be useful 

for FWS and NOAA to compare their respective approaches to those of 

federal agencies that use rewards in contexts outside of wildlife trafficking 

to identify best practices or lessons learned that might be applicable in 

the context of combating wildlife trafficking. For example, one stakeholder 

said that SEC has an effective whistleblower program and may have 

lessons learned that are relevant for FWS and NOAA to consider. 

Another stakeholder we interviewed separately indicated that in 2010,

before SEC had a whistleblower program that publicized rewards and 

provided detailed instructions on how members of the public could report 

information on illegal activities, SEC received few tips.39 Once SEC 

implemented a whistleblower program that publicized rewards and 

provided detailed instructions on its public website, the agency’s use of 

the program grew substantially, according to the stakeholder.40 Other 

stakeholders said it would be useful for the agencies to consider potential 

improvements to their use of rewards, such as making a standing reward 

offer for information on wildlife trafficking targeted at high-priority 

endangered species or particular criminal networks. Two of these 

stakeholders said such an offer might improve FWS’s and NOAA’s use of 

rewards by generating more tips than reward offers focused on individual 

cases. At the same time, they said such an offer would likely filter out 

 39In 2010, the SEC Office of Inspector General found that the SEC program was not 

designed to be successful. See Securities and Exchange Commission, Office of Inspector 

General, Assessment of the SEC’s Bounty Program, Report No. 474 (Washington, D.C.: 

Mar. 29, 2010).

40SEC’s whistleblower program generated tips that led to more than $975 million in 

monetary sanctions for violations of federal securities laws from fiscal year 2011—when 

SEC established policies and procedures for the program—through fiscal year 2017, 

according to its 2017 annual report.

FWS and NOAA 

Have Not Reviewed 

the Effectiveness of 

Their Use of Financial 

Rewards
Page 27 GAO-18-279 Combating Wildlife Trafficking

some of the false or unproductive tips that the agencies might receive if 

they made an untargeted standing reward offer.

Federal internal control standards state that management should design 

control activities to achieve objectives and respond to risks by, for 

example, conducting reviews at the functional or activity level by 

comparing actual performance to planned or expected results and 

analyzing significant differences. Further, under the standards, 

management should periodically review policies, procedures, and related 

control activities for continued relevance and effectiveness in achieving 

an agency’s objectives or addressing related risks.41 FWS and NOAA 

officials agreed that reviewing the effectiveness of their use of rewards 

would be worthwhile. Specifically, FWS officials said that it would be 

useful to compare their approach to those of other federal agencies that 

use rewards in investigating crimes that involve interstate and foreign 

smuggling of goods. Similarly, NOAA officials said that reviewing the 

agency’s use of financial rewards would be worthwhile but cautioned that 

such a review would need to be balanced against the agency’s 

constrained resources and many mission requirements. FWS and NOAA 

officials said they may consider conducting such a review at the 

conclusion of our audit but provided no plans for doing so. By reviewing 

the effectiveness of their use of rewards, FWS and NOAA can identify 

opportunities to improve the usefulness of rewards as a tool for 

combating wildlife trafficking.

Wildlife trafficking is a large and growing transnational criminal activity, 

with global environmental, security, and economic consequences. The 

federal government has emphasized strengthening law enforcement 

efforts to combat wildlife trafficking, and using financial rewards to obtain 

information on illegal activities is one tool that some federal agencies 

have used. However, to date, FWS and NOAA have not prioritized the 

use of rewards and were unable to provide sufficient assurance that the 

27 rewards they paid during fiscal years 2007 through 2017 represented 

all of the rewards they provided during that period. By tracking reward 

information so that it is clearly documented and readily available for 

examination, FWS and NOAA can better ensure that they have complete 

information on the rewards they have paid to help manage their use of 

rewards as a law enforcement tool.

 41GAO-14-704G. 

Conclusions
Page 28 GAO-18-279 Combating Wildlife Trafficking

Additionally, FWS and NOAA have policies outlining the processes their 

law enforcement agents are to use in making reward payments, and 

NOAA’s policy specifies factors for its agents to consider in developing 

proposed reward amounts, such as the risk the individual took in 

collecting the information. FWS’s policy does not specify such factors that 

could inform agents in achieving the agency’s objectives, which is not 

consistent with federal internal control standards. By augmenting its 

policy to specify factors for its agents to consider when developing 

proposed reward amounts, FWS can better ensure that its agents have 

the necessary quality information to prepare defensible reward proposals.

Both agencies have also advertised the potential for rewards in specific 

cases when agents had no other information, but FWS and NOAA have 

otherwise communicated little information to the public on the potential 

availability of rewards. If the public does not know about the possibility of 

rewards, then some people with information may not be incentivized to 

come forward. By determining the types of additional information to 

communicate to the public on rewards—such as providing information on 

the agency’s website about the potential availability of rewards—and then 

developing and implementing plans to do so, FWS and NOAA can 

improve their chances of obtaining information on wildlife trafficking 

activities that they otherwise might not receive.

Finally, FWS and NOAA have not reviewed the effectiveness of their use 

of financial rewards or considered whether any changes might improve 

the usefulness of rewards as a law enforcement tool. By undertaking such 

reviews, the agencies can identify opportunities to improve the usefulness 

of rewards as a tool for combating wildlife trafficking.

We are making a total of seven recommendations, including four to FWS 

and three to NOAA. Specifically:

• The Assistant Director of the FWS Office of Law Enforcement should 

track financial reward information so that it is clearly documented and 

readily available for examination. (Recommendation 1)

• The Director of the NOAA Office of Law Enforcement should track 

financial reward information so that it is clearly documented and 

readily available for examination. (Recommendation 2)

• The Assistant Director of the FWS Office of Law Enforcement should 

augment FWS’s financial reward policy to specify factors law 

Recommendations for 

Executive Action
Page 29 GAO-18-279 Combating Wildlife Trafficking

enforcement agents are to consider when developing proposed 

reward amounts. (Recommendation 3)

• The Assistant Director of the FWS Office of Law Enforcement should 

determine the types of additional information to communicate to the 

public on financial rewards and then develop and implement a plan for 

communicating that information. (Recommendation 4)

• The Director of the NOAA Office of Law Enforcement should 

determine the types of additional information to communicate to the 

public on financial rewards and then develop and implement a plan for 

communicating that information. (Recommendation 5)

• The Assistant Director of the FWS Office of Law Enforcement should 

review the effectiveness of the agency’s use of financial rewards and 

implement any changes that the agency determines would improve 

the usefulness of financial rewards as a law enforcement tool. 

(Recommendation 6)

• The Director of the NOAA Office of Law Enforcement should review 

the effectiveness of the agency’s use of financial rewards and 

implement any changes that the agency determines would improve 

the usefulness of financial rewards as a law enforcement tool. 

(Recommendation 7)

We provided a draft of this report for review and comment to the 

Departments of Commerce and the Interior. The departments transmitted 

written comments, which are reproduced in appendixes IV and V of this 

report. The Department of Commerce concurred with the three 

recommendations directed to NOAA and stated that NOAA is developing 

procedures to ensure that its rewards are closely tracked, clearly 

documented, and better communicated. In written comments from NOAA, 

NOAA stated the report fairly and thoroughly reviews NOAA’s use of 

financial rewards. NOAA outlined the steps it plans to take in response to 

our recommendations, including developing a procedure to track financial 

reward information, reviewing information currently disseminated to the 

public and evaluating whether additional information may be useful, and 

reviewing the agency’s reward policy to determine whether changes are 

needed to enhance reward effectiveness. 

In its written comments, the Department of the Interior concurred with the 

four recommendations directed to FWS. Interior stated that it appreciated 

our review of the challenges faced by FWS’s Office of Law Enforcement 

in combating wildlife trafficking and identifying areas where FWS and 

NOAA can improve the use of financial rewards as a tool for combating 

Agency Comments 
Page 30 GAO-18-279 Combating Wildlife Trafficking

wildlife trafficking. Interior also provided technical comments, which we 

incorporated as appropriate. 

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the appropriate 

congressional committees, the Secretaries of Commerce and the Interior, 

and other interested parties. In addition, the report will be available at no 

charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-3841 or fennella@gao.gov. Contact points for our Offices 

of Congressional Relations and of Public Affairs may be found on the last 

page of this report. GAO staff who made major contributions to this report 

are listed in appendix VI.

Sincerely yours,

Anne-Marie Fennell

Director, Natural Resources and Environment
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-18-279 Combating Wildlife Trafficking

The objectives of our review were to (1) identify laws that authorize the 

U.S. Fish and Wildlife Service (FWS) and the National Oceanic and 

Atmospheric Administration (NOAA) to pay financial rewards1 for 

information on wildlife trafficking2 and the extent to which these agencies 

paid such rewards from fiscal years 2007 through 2017, (2) evaluate 

FWS’s and NOAA’s policies on financial rewards, (3) evaluate the 

information available to the public on financial rewards, and (4) determine 

the extent to which FWS and NOAA reviewed the effectiveness of their 

use of financial rewards in combating wildlife trafficking.

To address these objectives, we reviewed academic literature on the use 

of financial rewards to combat illegal activities and United Nations 

Environment Programme reports on the scope and scale of wildlife 

trafficking. We also interviewed officials from federal agencies that play a 

role in combating wildlife trafficking or manage programs that pay 

financial rewards for information on illegal activities. Specifically, we 

interviewed officials from the Departments of Agriculture, Commerce, 

Homeland Security, the Interior, Justice, and State, as well as officials 

from the Internal Revenue Service, the U.S. Securities and Exchange 

Commission, and the U.S. Agency for International Development. In 

addition, we reviewed documentation that the Department of the Treasury 

provided on its role in paying financial rewards. We did not compare 

FWS’s and NOAA’s use of financial rewards in combating wildlife 

trafficking to federal agencies’ use of financial rewards in other contexts 

because the different contexts are not directly comparable. However, we 

reviewed information on other federal agencies’ use of financial rewards 

as examples of how financial rewards are used in contexts outside of 

wildlife trafficking. In addition, we interviewed representatives of six 

nongovernmental organizations that we selected based on those 

organizations’ knowledge or experience in combating wildlife trafficking. 

 1

In this report, we use the term reward to refer to a financial payment an agency makes to 

a person after the completion of an investigation, prosecution, or civil or administrative 

proceeding. A reward differs from purchasing information, which is an investigative tool to 

assist in completing an investigation and developing a civil, administrative, or criminal 

case. It is possible that an agency could purchase information from a person during a 

case and then pay that person a reward at the case’s conclusion if information the person 

provided met applicable requirements for a reward.

2

In this report, we use the term wildlife trafficking to include the trafficking of plants, fish, 

and wildlife. We also use the definition of wildlife trafficking from the Eliminate, Neutralize, 

and Disrupt Wildlife Trafficking Act of 2016, which defines wildlife trafficking as the 

poaching or other illegal taking of protected or managed species and the illegal trade in 

wildlife and their related parts and products.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-18-279 Combating Wildlife Trafficking

Specifically, we interviewed representatives from the Elephant Action 

League, the Environmental Investigation Agency, the National 

Association of Conservation Law Enforcement Chiefs, the National 

Whistleblower Center, TRAFFIC, and the World Wildlife Fund.

To identify laws that authorize FWS and NOAA to pay financial rewards 

for information on wildlife trafficking, we asked FWS and NOAA attorneys 

to compile a list of laws that each of their agencies implements or 

enforces that prohibit wildlife trafficking and authorize the agency to pay 

rewards for providing information about trafficking. We then compared 

that list to the results of our search of the United States Code for such 

laws. We also reviewed FWS and NOAA documentation for accounts 

where the fines, penalties, and proceeds from forfeited property that are 

used to pay rewards are deposited as well as the accounts where 

appropriations available to pay rewards were deposited.3 To identify the 

extent to which FWS and NOAA have paid financial rewards for 

information on wildlife trafficking, we analyzed FWS and NOAA data on 

financial rewards the agencies reported paying from fiscal years 2007 

through 2017.4 The data included information on, among other things,

• reward amounts,

• the fiscal years in which rewards were paid,

• laws under which rewards were paid,

• types of wildlife involved in those cases,

• the amounts of civil penalties or criminal fines imposed in those 

cases,

• the numbers of arrests and convictions as a result of those cases, and

• whether reward recipients were individuals or groups and U.S. or 

foreign citizens.

To assess the reliability of the data FWS and NOAA provided on financial 

rewards, we interviewed agency officials knowledgeable about the data 

and compared the data to case records the agencies provided. 

 3

We did not assess whether these accounts contained all the money that was supposed 

to be deposited in them because that was outside the scope of our review. 

4

We excluded 25 rewards with a combined value of $50,500 that FWS reported paying 

from fiscal years 2007 through 2017 and 3 rewards with a combined total of $2,500 that 

NOAA reported paying during that same period because the agencies paid those rewards 

for information on illegal activities other than wildlife trafficking. 
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-18-279 Combating Wildlife Trafficking

Specifically, FWS and NOAA officials said they track all expenditures, 

including reward payments, in their financial databases, but they are not 

able to readily identify reward payments because their financial systems 

do not include a unique identifier for such payments and their reward 

information is located in multiple databases and formats. As a result, 

FWS and NOAA officials said they identified the rewards that they 

reported to us by manually reviewing their financial and law enforcement 

records, and officials said the information was complete to the best of 

their knowledge. Based on these steps, we found the data that the 

agencies provided to us to be sufficiently reliable for reporting information 

on the rewards the agencies reported paying. However, as we discuss in 

the report, FWS and NOAA officials could not provide sufficient 

assurance that the data included all the financial rewards that they had 

paid from fiscal years 2007 through 2017.

To obtain additional detail about cases where financial rewards were 

paid, we reviewed a nongeneralizable sample of 10 wildlife trafficking 

cases. We selected these cases based on

• the agency that investigated the case (to include both FWS and 

NOAA cases),

• the amount of the reward paid in the case (to reflect both low and high 

amounts),

• the year in which the reward was paid (to include rewards paid more 

recently), and

• the type of wildlife trafficked in the case (to include both fish and 

wildlife cases—there were no plant trafficking cases to select).

While the findings from our review cannot be generalized to cases we did 

not select and review, they illustrate how FWS and NOAA have used 

financial rewards in wildlife trafficking cases.

To evaluate FWS and NOAA policies on financial rewards, we reviewed 

relevant FWS and NOAA policies and compared them to each other; 

interviewed FWS and NOAA officials about those policies; and compared 

the information in the policies with federal internal control standards on 

information and communication.5 To evaluate information available to the 

public on rewards, we reviewed relevant FWS and NOAA publications 

 5

GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014).
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-18-279 Combating Wildlife Trafficking

and examples of communications to the public on the availability of 

rewards in specific cases and interviewed FWS and NOAA officials. We 

also reviewed information available on FWS’s and NOAA’s national and 

regional websites as of December 2017 and January 2018, respectively, 

relevant to reporting violations of the laws that the agencies enforce in 

general and on receiving rewards in particular. We compared the 

agencies’ public communications on rewards with federal internal control 

standards on information and communication.6 To evaluate the extent to 

which FWS and NOAA reviewed the effectiveness of their use of financial 

rewards in combating wildlife trafficking, we interviewed FWS and NOAA 

officials and requested any reviews the agencies had conducted 

regarding their use of financial rewards to compare with federal internal 

control standards on control activities.7 FWS and NOAA did not have any 

such reviews to provide.

In addition, for all four objectives, we interviewed a nongeneralizable 

sample of 20 stakeholders who had experience investigating wildlife 

trafficking or expertise in the use of financial rewards as a law 

enforcement tool. To select stakeholders to interview, we first identified a 

list of stakeholders by reviewing (1) FWS and NOAA data on law 

enforcement agents with at least 5 years of experience who had 

investigated wildlife trafficking cases and used financial rewards, (2) 

Department of Justice data on federal prosecutors who had prosecuted 

wildlife trafficking cases since fiscal year 2014, (3) literature search 

results identifying academics with expertise in the use of financial rewards 

as a law enforcement tool and federal programs that use financial 

rewards to combat illegal activities in contexts outside of wildlife 

trafficking, (4) the biographies of members of the federal Advisory Council 

on Wildlife Trafficking, and (5) recommendations from stakeholders we 

interviewed. From this list, we then used a multistep process to select the 

20 stakeholders to interview. To ensure coverage and a range of 

perspectives, we selected stakeholders from the following groups:

• FWS and NOAA law enforcement agents, including field and 

supervisory agents;

• federal prosecutors responsible for prosecuting wildlife trafficking 

cases;

 6

GAO-14-704G.

7

GAO-14-704G. 
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-18-279 Combating Wildlife Trafficking

• federal officials responsible for programs that use financial rewards to 

combat illegal activities in contexts outside of wildlife trafficking;

• academics with expertise in the use of financial rewards as a law 

enforcement tool;

• members of the federal Advisory Council on Wildlife Trafficking;8 and

• representatives of nongovernmental organizations that investigate 

wildlife trafficking.

We conducted semistructured interviews with the 20 selected 

stakeholders using a standard set of questions. We asked questions 

about stakeholder views on the usefulness of financial rewards in 

combating wildlife trafficking; the strength and weaknesses of the 

statutory provisions that authorize federal agencies to pay financial 

rewards for information on wildlife trafficking; FWS’s and NOAA’s use of 

financial rewards to combat wildlife trafficking; and how, if at all, the two 

agencies could improve their use of financial rewards to combat wildlife 

trafficking. We analyzed the stakeholders’ responses to our questions, 

grouping the responses into overall themes. We summarized the results 

of our analysis and then shared the summary with relevant FWS and 

NOAA officials to obtain their views. Views from these stakeholders 

cannot be generalized to those whom we did not select and interview.

We conducted this performance audit from February 2017 to April 2018 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

 8

The Advisory Council on Wildlife Trafficking advises and makes recommendations to the 

Presidential Task Force on Wildlife Trafficking on issues related to combating wildlife 

trafficking. The eight-member advisory council includes representatives from the private 

sector, former government officials, representatives from nongovernmental organizations, 

and other experts on wildlife trade.
Appendix II: Laws Implemented or Enforced by 

FWS and NOAA That Prohibit Wildlife 

Trafficking and Authorize Financial Rewards

Page 36 GAO-18-279 Combating Wildlife Trafficking

The Department of the Interior’s U.S. Fish and Wildlife Service (FWS) and 

the Department of Commerce’s National Oceanic and Atmospheric 

Administration1 (NOAA) implement or enforce multiple laws that 

specifically authorize the payment, under specified circumstances, of 

financial rewards to persons for information about violations of laws that 

prohibit wildlife trafficking.2 The laws that FWS officials identified are 

listed and summarized in table 3, and the laws that NOAA officials 

identified are listed and summarized in table 4.3

 1

The NOAA Office of Law Enforcement is part of NOAA’s National Marine Fisheries 

Service, which is responsible for the stewardship of the nation’s ocean resources and their 

habitat. The NOAA Office of Law Enforcement provides law enforcement services for all of 

NOAA, so we use the term NOAA in this report, but we focus on the office’s work 

enforcing laws that the National Marine Fisheries Service implements. 

2

We use the term reward to refer to a financial payment an agency makes to a person 

after the completion of an investigation, prosecution, or civil or administrative proceeding. 

A reward differs from purchasing information, which is an investigative tool to assist in 

completing an investigation and developing a civil or criminal case. It is possible that an 

agency could purchase information from a person during a case and then pay that person 

a reward at the case’s conclusion if information the person provided met applicable 

requirements for a reward. 

3

FWS and NOAA reward policies provide a list of laws they identified as authorizing the 

payment of financial rewards to persons for information about violations of laws that 

prohibit wildlife trafficking. However, FWS’s policy does not identify the Antarctic 

Conservation Act as a law authorizing payment of rewards. FWS officials did not provide a 

reason why they excluded this law from the policy document. NOAA’s policy provides 

examples of laws that the NOAA Office of Law Enforcement enforces that authorize 

payment of rewards but does not list the Antarctic Conservation Act, the Antarctic Marine 

Living Resources Convention Act of 1984, or the National Marine Sanctuaries Act. NOAA 

officials said they excluded these laws because the Magnuson-Stevens Fishery 

Conservation and Management Act’s reward provision authorizes a reward for information 

provided about violations of these laws.

Appendix II: Laws Implemented or Enforced 

by FWS and NOAA That Prohibit Wildlife 

Trafficking and Authorize Financial Rewards
Appendix II: Laws Implemented or Enforced by 

FWS and NOAA That Prohibit Wildlife 

Trafficking and Authorize Financial Rewards

Page 37 GAO-18-279 Combating Wildlife Trafficking

Table 3: Laws That the U.S. Fish and Wildlife Service (FWS) Implements and Identified as Prohibiting Wildlife Trafficking and 

Authorizing the Payment of Financial Rewards

Law authorizing reward Summary of law

African Elephant Conservation Act

16 U.S.C. § 4225

• Who is authorized to pay rewards: The Secretary of the Treasury, 

upon recommendation of the Secretary of the Interior.

• Source of moneys to pay rewards: The penalties collected under 

the act, subject to appropriations.

• Who is eligible to receive rewards: Any person who furnishes 

information that leads to a civil penalty or criminal conviction under 

the act, except for an officer or employee of the United States or 

any state or local government who furnishes information in 

performing his or her official duties.

• Possible reward amount: Equal to not more than half of any 

criminal or civil penalty or fine with respect to which the reward is 

paid, or $25,000, whichever is less.

Antarctic Conservation Act, as amended

16 U.S.C. § 2409(b)(4)

• Who is authorized to pay rewards: Any officer authorized by the 

Director of the National Science Foundation or the Secretaries of 

Commerce, Homeland Security, the Interior, or the Treasury.

• Source of moneys to pay rewards: Not specified.

• Who is eligible to receive rewards: Persons who provide 

information that may lead to the apprehension of violators of the act 

or any regulation or permit issued under the act.

• Possible reward amount: Not specified.

Bald and Golden Eagle Protection Act, as amended

16 U.S.C. § 668(a)

• Who is authorized to pay rewards: Not specified.

• Source of moneys to pay rewards: Fines imposed for violating the 

act.

• Who is eligible to receive rewards: Persons who give information 

that leads to a conviction.

• Possible reward amount: Half of any fine imposed, not to exceed 

$2,500.

Endangered Species Act, as amended

16 U.S.C. § 1540(d)

• Who is authorized to pay rewards: The Secretaries of Agriculture, 

Commerce, the Interior, and the Treasury.

• Source of moneys to pay rewards: Penalties, fines, and 

forfeitures of property under the act.

• Who is eligible to receive rewards: Any person who furnishes 

information that leads to an arrest, criminal conviction, civil penalty 

assessment, or forfeiture of property for any violation of the act or its 

implementing regulations, except for any officer or employee of the 

United States or any state or local government who furnishes 

information in performing his or her official duties.

• Possible reward amount: The amount of the reward is designated 

by the Secretary of Agriculture, Commerce, the Interior, or the 

Treasury, as appropriate.
Appendix II: Laws Implemented or Enforced by 

FWS and NOAA That Prohibit Wildlife 

Trafficking and Authorize Financial Rewards

Page 38 GAO-18-279 Combating Wildlife Trafficking

Law authorizing reward Summary of law

Fish and Wildlife Improvement Act, as amended

16 U.S.C. § 742l(k)(2)a

• Who is authorized to pay rewards: The Secretaries of Commerce 

and the Interior.

• Source of moneys to pay rewards: Appropriations.

• Who is eligible to receive rewards: Not specified.

• Possible reward amount: Not specified.

Lacey Act, as amended

16 U.S.C. § 3375(d)

• Who is authorized to pay rewards: The Secretaries of Agriculture, 

Commerce, the Interior, and the Treasury.

• Source of moneys to pay rewards: Penalties, fines, and 

forfeitures of property under the act.

• Who is eligible to receive rewards: Any person who furnishes 

information that leads to an arrest, criminal conviction, civil penalty 

assessment, or forfeiture of property for violating the act or 

implementing regulations, except for any officer or employee of the 

United States or any state or local government who furnishes 

information in performing his or her official duties.

• Possible reward amount: The amount of the reward is designated 

by the Secretary of Agriculture, Commerce, the Interior, or the 

Treasury, as appropriate.

Marine Mammal Protection Act, as amended

16 U.S.C. § 1376(c)

• Who is authorized to pay rewards: The Secretary of the Treasury, 

upon the recommendation of the Secretary of Commerce or the 

Secretary of the Interior.

• Source of moneys to pay rewards: Not specified.

• Who is eligible to receive rewards: Any person who furnishes 

information that leads to a conviction for violating the act, except for 

officers or employees of the United States or any state or local 

government who furnishes information in performing his or her 

official duties.

• Possible reward amount: An amount equal to half of the fine 

incurred but not to exceed $2,500.

Rhinoceros and Tiger Conservation Act of 1998

16 U.S.C. § 5305a(f)

Authorizes rewards in accordance with the Lacey Act, 16 U.S.C. § 

3375(d). 

Wild Bird Conservation Act

16 U.S.C. §§ 4912(c), 4913(b)(2)(A)

Authorizes rewards in accordance with the Lacey Act, 16 U.S.C. § 

3375(d).

Source: GAO analysis of laws identified by FWS officials as prohibiting wildlife trafficking that FWS implements and that authorize the payment of financial rewards. | GAO-18-279

a

The Fish and Wildlife Improvement Act of 1978 as amended authorizes the Secretary of the Interior 

to use, in undercover or other enforcement operations, appropriations to pay for information, rewards, 

or evidence concerning violations of laws that FWS administers relating to plants, fish, or wildlife. In 

addition to the laws listed in the table, Department of the Interior officials identified the Migratory Bird 

Treaty Act of 1918 as a law that it administers relating to plants, fish, or wildlife that prohibits 

trafficking. These officials said that if an individual violates this law, which prohibits, among other 

things, the killing and selling of migratory birds not authorized by regulation, officials could pay a 

reward for information on the violation using the Fish and Wildlife Improvement Act’s reward 

provision.
Appendix II: Laws Implemented or Enforced by 

FWS and NOAA That Prohibit Wildlife 

Trafficking and Authorize Financial Rewards

Page 39 GAO-18-279 Combating Wildlife Trafficking

Table 4: Laws That the National Oceanic and Atmospheric Administration (NOAA) Implements and Identified as Prohibiting 

Wildlife Trafficking and Authorizing the Payment of Financial Rewards

Law authorizing reward Summary of law

Antarctic Conservation Act, 

as amended

16 U.S.C. § 2409(b)(4)

• Who is authorized to pay rewards: Any officer authorized by the Director of the 

National Science Foundation or the Secretary of Commerce, Homeland Security, 

the Interior, or the Treasury.

• Source of moneys to pay rewards: Not specified.

• Who is eligible to receive rewards: Persons who provide information that may 

lead to the apprehension of violators of the act or any regulation or permit issued 

under the act.

• Possible reward amount: Not specified.

Antarctic Marine Living Resources 

Convention Act of 1984

16 U.S.C. § 2439(b)(5)

• Who is authorized to pay rewards: Any officer or employee authorized by the 

Secretary of Commerce or the Secretary of Homeland Security.

• Source of moneys to pay rewards: Not specified.

• Who is eligible to receive rewards: Persons who provide information that may 

lead to the apprehension of people violating the act.

• Possible reward amount: Not specified.

Endangered Species Act, 

as amended

16 U.S.C. § 1540(d)

• Who is authorized to pay rewards: The Secretaries of Agriculture, Commerce, the 

Interior, and the Treasury.

• Source of moneys to pay rewards: Penalties, fines, and forfeitures of property 

under the act.

• Who is eligible to receive rewards: Any person who furnishes information that 

leads to an arrest, criminal conviction, civil penalty assessment, or forfeiture of 

property for any violation of the act or its implementing regulations, except for any 

officer or employee of the United States or any state or local government who 

furnishes information in performing his or her official duties.

• Possible reward amount: The amount of the reward is designated by the 

Secretary of Agriculture, Commerce, the Interior, or the Treasury, as appropriate.

Fish and Wildlife Improvement Act, 

as amended

16 U.S.C. § 742l(k)(2)a

• Who is authorized to pay rewards: The Secretary of Commerce and the Secretary 

of the Interior.

• Source of moneys to pay rewards: Appropriations.

• Who is eligible to receive rewards: Not specified.

• Possible reward amount: Not specified.

Lacey Act, as amended

16 U.S.C. § 3375(d)

• Who is authorized to pay rewards: The Secretaries of Agriculture, Commerce, the 

Interior, and the Treasury.

• Source of moneys to pay rewards: Penalties, fines, and forfeitures of property 

under the act.

• Who is eligible to receive rewards: Any person who furnishes information that 

leads to an arrest, criminal conviction, civil penalty assessment, or forfeiture of 

property for violating the act or implementing regulations, except for any officer or 

employee of the United States or any state or local government who furnishes 

information in performing his or her official duties.

• Possible reward amount: The amount of the reward is designated by the 

Secretary of Agriculture, Commerce, the Interior, or the Treasury, as appropriate.
Appendix II: Laws Implemented or Enforced by 

FWS and NOAA That Prohibit Wildlife 

Trafficking and Authorize Financial Rewards

Page 40 GAO-18-279 Combating Wildlife Trafficking

Law authorizing reward Summary of law

Magnuson-Stevens Fishery 

Conservation and Management Act, 

as amended

16 U.S.C. § 1861(e)(1)(B)

• Who is authorized to pay rewards: The Secretaries of Commerce and the 

Treasury.

• Source of moneys to pay rewards: Fines, penalties, and forfeitures of property for 

violations of the act or any other fishery resource law enforced by the Secretary of 

Commerce.

• Who is eligible to receive rewards: Any person who furnishes information that 

leads to an arrest, conviction, civil penalty assessment, or forfeiture of property for 

any violation of the act or other marine resource law enforced by the Secretary of 

Commerce.

• Possible reward amount: Not less than 20 percent of the penalty collected or 

$20,000, whichever is the lesser amount.

Marine Mammal Protection Act, as 

amended

16 U.S.C. § 1376(c)

• Who is authorized to pay rewards: The Secretary of the Treasury, upon the 

recommendation of the Secretary Commerce or the Secretary of the Interior.

• Source of moneys to pay rewards: Not specified.

• Who is eligible to receive rewards: Any person who furnishes information that 

leads to a conviction for violating the act, except for officers or employees of the 

United States or any state or local government who furnishes information in 

performing his or her official duties.

• Possible reward amount: An amount equal to half of the fine incurred but not to 

exceed $2,500.

National Marine Sanctuaries Act, 

as amended

16 U.S.C. § 1437(f)(1)(C)(ii)

• Who is authorized to pay rewards: Not specified.

• Source of moneys to pay rewards: Civil penalties received under the act and 

forfeitures of property, if any amounts received from forfeitures remain after paying 

the reasonable and necessary costs of temporary storage, care, maintenance, and 

disposal of seized sanctuary resources or other property seized in connection with a 

violation of the act or implementing regulation or permit issued thereunder.

• Who is eligible to receive rewards: Any person who furnishes information leading 

to an assessment of a civil penalty or forfeiture of property for violating the act, its 

implementing regulations, or a permit issued thereunder.

• Possible reward amount: Not specified.

Source: GAO analysis of laws identified by NOAA officials as prohibiting wildlife trafficking that NOAA implements and that authorize the payment of financial rewards. | GAO-18-279

a

The Fish and Wildlife Improvement Act of 1978 as amended authorizes the Secretary of Commerce 

to use, in undercover or other enforcement operations, appropriations to pay for information, rewards, 

or evidence concerning violations of the laws that NOAA administers relating to plants, fish, or 

wildlife. NOAA officials said they could use the reward provision in the Fish and Wildlife Improvement 

Act to pay a reward for information regarding a violation of any of the laws listed in this table or in 

table 5.

In addition, as noted above, the reward provisions in the MagnusonStevens Fishery Conservation and Management Act as amended and the 

Fish and Wildlife Improvement Act as amended authorize the payment of 

rewards for information about violations of multiple laws. Specifically, the 

Magnuson-Stevens Fishery Conservation and Management Act as 

amended authorizes the payment of rewards for information about 

violations of the act as well as any other marine resource law that the 

Secretary of Commerce enforces. Further, the Fish and Wildlife 

Improvement Act as amended authorizes the payment of rewards for 
Appendix II: Laws Implemented or Enforced by 

FWS and NOAA That Prohibit Wildlife 

Trafficking and Authorize Financial Rewards

Page 41 GAO-18-279 Combating Wildlife Trafficking

information about violations of any law administered by NOAA’s National 

Marine Fisheries Service relating to plants, fish, or wildlife. NOAA officials 

identified 14 such laws that prohibit wildlife trafficking (see table 5). If a 

violation of the laws listed in table 5 occurs, NOAA officials said they 

could use the Magnuson-Stevens Fishery Conservation and Management 

Act or Fish and Wildlife Improvement Act reward provision to pay a 

reward for information on the violation. None of the laws listed in table 5 

specifically authorize the payment of financial rewards.
Appendix II: Laws Implemented or Enforced by 

FWS and NOAA That Prohibit Wildlife 

Trafficking and Authorize Financial Rewards

Page 42 GAO-18-279 Combating Wildlife Trafficking

Table 5: Laws That the National Oceanic and Atmospheric Administration (NOAA) 

Enforces or National Marine Fisheries Service (NMFS) Administers and Identified as 

Prohibiting Wildlife Trafficking That Are Covered by the Reward Provisions in Other 

Laws 

Atlantic Tunas Convention Act of 1975

16 U.S.C. §§ 971-971k

Billfish Conservation Act of 2012a

16 U.S.C. § 1827

Ensuring Access to Pacific Fisheries Act

16 U.S.C. §§ 7701-7710

Fur Seal Act of 1966, as amended

16 U.S.C. §§ 1151-1175

High Seas Fishing Compliance Act of 1995

16 U.S.C. §§ 5501-5509

North Pacific Anadromous Stocks Act of 1992, as amended

16 U.S.C. §§ 5001-5012

Northern Pacific Halibut Act of 1982, as amended

16 U.S.C. §§ 773-773k

Northwest Atlantic Fisheries Convention Act of 1995, as amended

16 U.S.C. §§ 5601-5610 

Pacific Salmon Treaty Act of 1985, as amended

16 U.S.C. §§ 3631-3645

South Pacific Tuna Act of 1988, as amended

16 U.S.C. §§ 973-973r

Sponge Actb

16 U.S.C. §§ 781-785

Tuna Conventions Act of 1950, as amended

16 U.S.C. §§ 951-962

Western and Central Pacific Fisheries Convention Implementation Act, as amended

16 U.S.C. §§ 6901-6910 

Whaling Convention Act of 1949

16 U.S.C. §§ 916-916l 

Source: GAO analysis of laws identified by NOAA officials as prohibiting wildlife trafficking that NOAA enforces or NMFS administers. |

GAO-18-279

Note: The laws listed in this table are covered by the reward provisions in the Fish and Wildlife 

Improvement Act of 1978 as amended and the Magnuson-Stevens Fishery Conservation and 

Management Act as amended.

a

NOAA does not consider this law to prohibit wildlife trafficking because it prohibits only sale of 

billfish, but does not specifically prohibit the import, export, or transport of billfish in interstate or 

foreign commerce.

b

NOAA does not consider this law to prohibit wildlife trafficking because it prohibits the taking, 

possession, or sale of certain sponges, but does not specifically prohibit the import, export, or 

transport of these sponges in interstate or foreign commerce.
Appendix III: FWS and NOAA Cases in Which 

the Agencies Reported Paying Rewards, Fiscal 

Years 2007 through 2017

Page 43 GAO-18-279 Combating Wildlife Trafficking

Table 6 provides information on U.S. Fish and Wildlife Service and 

National Oceanic and Atmospheric Administration cases where these 

agencies reported paying rewards for information on wildlife trafficking 

from fiscal years 2007 through 2017.

Table 6: U.S. Fish and Wildlife Service (FWS) and National Oceanic and Atmospheric Administration (NOAA) Cases in Which 

the Agencies Reported Paying Rewards for Information on Wildlife Trafficking, Fiscal Years 2007-2017

Fiscal 

year

Reward 

amount 

(dollars)

Law(s) under 

which reward 

was paid

Types of plants, 

fish, or wildlife 

involved in 

the case

Civil penalties or 

criminal fines 

imposeda (dollars) 

Number of 

convictions 

resulting from 

the case

FWS 2007 10,000 Endangered Species Act Angelfish 30,000 1

2007 2,500 Lacey Act Chameleon 2,000 1

2008 12,000 African Elephant 

Conservation Act

African elephant 100,000 1

2008 7,500 Lacey Act Golden eagle, grizzly 

bear

123 1

2009 5,000 Lacey Act Rhesus monkey 325 2

2009 40,000 Lacey Act Bald eagle, golden 

eagle

825 13

2009 2,500 Fish and Wildlife 

Improvement Act

(for violation of the Migratory 

Bird Treaty Act), Bald and 

Golden Eagle Protection Act

Bald eagle, hawk 0 2

2010 5,000 Lacey Act Grizzly bear 6,000 2

2010 4,500 Lacey Act White-tailed deer, wolf 10,000 1

2010 4,000 Lacey Act Leopard 65,000 8

2010 30,000 Lacey Act Black-backed wagtail, 

washboard mussels

123,000 8

2011 2,000 Lacey Act Bobcat 0 2

2011 3,000 Endangered Species Act Rhinoceros horn 0 2

2011 2,500 Lacey Act North American brown 

bear

50,000 1

2012 8,500 Endangered Species Act Jaguar, crocodile 600 2

2012 3,500 Lacey Act White-tailed deer 20,864 7

2012 3,500 Fish and Wildlife 

Improvement Act

(for violation of the Migratory 

Bird Treaty Act)

Bald eagle, hawk, 

golden eagle, Delhi 

sands fly, Cooper’s 

hawk

2,475 4

2013 20,000 Lacey Act and Endangered 

Species Act

Indian star tortoise, 

radiated tortoise, gavial

0 2

2013 3,000 Lacey Act Alligator 0 3

Appendix III: FWS and NOAA Cases in 

Which the Agencies Reported Paying 

Rewards, Fiscal Years 2007 through 2017
Appendix III: FWS and NOAA Cases in Which 

the Agencies Reported Paying Rewards, Fiscal 

Years 2007 through 2017

Page 44 GAO-18-279 Combating Wildlife Trafficking

Fiscal 

year

Reward 

amount 

(dollars)

Law(s) under 

which reward 

was paid

Types of plants, 

fish, or wildlife 

involved in 

the case

Civil penalties or 

criminal fines 

imposeda (dollars) 

Number of 

convictions 

resulting from 

the case

2013 4,500b Lacey Act Deer 1,000,000 1

2013 5,000 Endangered Species Act Leopard 2,000 1

2013 1,000 Fish and Wildlife 

Improvement Act

(for violation of the 

Migratory Bird Treaty Act)

Bald eagle 15,000 2

2014 5,000 Endangered Species Act Pig-nosed turtle, 

spotted turtle, keeled 

box turtle, boa 

constrictor, twinspotted rat snake, 

black-breasted hill 

turtle, Gila monster, 

Arakan forest turtle, 

beauty rat snake, bigheaded turtle, ball 

python, eastern box 

turtle

0 2

NOAA 2012 1,000 Magnuson-Stevens 

Fishery Conservation 

and Management Act, as 

amended (for violation of the 

Endangered Species Act)

Green sea turtle 0 1

2015 20,000 Magnuson-Stevens 

Fishery Conservation and 

Management Act, as amended 

(for violation of the Lacey Act)

Sea scallops 520,371 7 individuals 

and 1 company 

Source: GAO analysis of FWS and NOAA data. | GAO-18-279

Notes: FWS and NOAA officials could not provide sufficient assurance that the reward information 

reported to us and presented here represents all of their reward payments from fiscal years 2007 

through 2017, but they said the information was complete to the best of their knowledge. We use the 

term wildlife trafficking to include the trafficking of plants, fish, and wildlife. We use the definition of 

wildlife trafficking from the Eliminate, Neutralize, and Disrupt Wildlife Trafficking Act of 2016, which 

defines wildlife trafficking as the poaching or other illegal taking of protected or managed species and 

the illegal trade in wildlife and their related parts and products.

a

Multiple laws, such as the Endangered Species Act and Lacey Act, authorize civil penalties and 

criminal fines to be imposed for violations. 

b

FWS paid three rewards in this case—one for $2,500 and two for $1,000 each.
Appendix IV: Comments from the Department 

of Commerce

Page 45 GAO-18-279 Combating Wildlife Trafficking

Appendix IV: Comments from the 

Department of Commerce
Appendix IV: Comments from the Department 

of Commerce

Page 46 GAO-18-279 Combating Wildlife Trafficking
Appendix IV: Comments from the Department 

of Commerce

Page 47 GAO-18-279 Combating Wildlife Trafficking
Appendix V: Comments from the Department 

of the Interior

Page 48 GAO-18-279 Combating Wildlife Trafficking

Appendix V: Comments from the Department 

of the Interior
Appendix VI: GAO Contact and Staff 

Acknowledgments

Page 49 GAO-18-279 Combating Wildlife Trafficking

Anne-Marie Fennell, (202) 512-3841 or fennella@gao.gov

In addition to the contact named above, Alyssa M. Hundrup (Assistant 

Director), David Marroni (Analyst-in-Charge), Cindy Gilbert, Keesha 

Luebke, Jeanette Soares, Sheryl Stein, Sara Sullivan, and Judith Williams 

made key contributions to this report.

Appendix VI: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(101657)
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