The RegTech Pulse

Combating Wildlife Trafficking: Battling a Twenty-Billion Dollar Industry

• LexisNexis Risk Solutions

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Dive into the world of illegal wildlife trafficking with our special guests, Rob Campbell and Geraldine Fleming from United for Wildlife. This conversation reveals the true scale of this trade, which poses a serious threat to biodiversity, human health, economies and global security. We examine the ever-evolving tactics of traffickers, and the importance of public/private partnerships to fight back.

To download your copy of our new joint white paper, Combating Wildlife Trafficking with the Power of Collaboration, visit our website. To learn more about the work of United for Wildlife and the Royal Foundation, see unitedforwildlife.org and royalfoundation.com.

DISCLAIMER: The information provided in this podcast is for informational purposes only and is not intended to and shall not be used as legal advice.  The views and opinions expressed in this podcast are solely those of the speakers and do not necessarily reflect the views or positions of LexisNexis Risk Solutions. LexisNexis Risk Solutions does not warrant that the information provided in this podcast is accurate or error-free.

Jonny Bell - LexisNexis Risk Solutions:

Hi everyone, welcome to the RegTech Pulse. I'm Jonny Bell, director of Financial Crime Compliance Market Planning at Risk Solutions. On today's podcast we're going to delve a little bit deeper into a joint white paper that we've published alongside United for Wildlife that looks at combating illegal wildlife trafficking through the power of collaboration. So, without further ado, I would like to introduce you to our guests, Rob Campbell and Geraldine Fleming. Rob, could you go first?

Rob Campbell - United for Wildlife:

Hi, my name is Rob Campbell. I lead the United for Wildlife programme, which was set up by His Royal Highness Prince William and the Royal Foundation as a way to combat the increasing issues around wildlife trafficking.

Jonny Bell - LexisNexis Risk Solutions:

Great, and Geraldine?

Geraldine Fleming - United for Wildlife:

Hi all and thank you for having me. My name is Geraldine Fleming and I am the Financial Task Force Manager for United for Wildlife. I've been with United for Wildlife for about a year now and it's a real passion point for me.

Jonny Bell - LexisNexis Risk Solutions:

Fantastic. Thank you, and for those listeners not familiar with the illegal wildlife trade, that was really how we wanted to kick off this podcast was just understanding the size, scale and severity of the issue in hand. Rob, are you able to elaborate on this a little bit more?

Rob Campbell - United for Wildlife:

Yeah, I think so. You know the illegal wildlife trade isn't the most well known of illicit trades. I think people could be forgiven for not, you know, being fully aware of its implications and its damage that it causes. But to put it in perspective, we would assess the illegal wildlife trade to be valued between 20 and 23 billion dollars, which is quite a vague and large estimate. But that's not money that you find hidden under beds.

Rob Campbell - United for Wildlife:

That's a serious profession that's driving a poaching crisis, you know, in some parts of the world and feeding a demand in other parts of the world. When you look at the implications or impact, you know, outside of the monetary value of the illegal wildlife trade, you're also looking at countries having a biodiversity stripped, some of these animals that are iconic to some countries around the world, you know, put in on the endangered list and at times, you know, becoming extremely or at risk of becoming extinct. People suggest that the illegal wildlife trade would be the fourth largest illicit trade. So where people will be very familiar with the narcotics trade, you know, obviously highly profitable, truly global. Behind that you have human trafficking and arms trafficking, but wildlife trafficking doesn't sit too far behind, and especially when you include the illegal timber trade and the stripping of forests and things for illegal timber for demand around the world, then you're looking at increasing that value quite dramatically.

Geraldine Fleming - United for Wildlife:

Exactly, Rob, and I think I can add, the UN environmental programme and Interpol looked at those numbers a few years ago now. Unfortunately the data is a little bit out of date. But when you look at, as Rob said, the broader environmental crime, you're looking at an estimated $260 billion per annum and compared to the drug trade at the time of $344 billion per annum. You're looking at environmental crime being around 75% of the value of the drug trade but not getting quite the same attention. So it's very important for us to kind of look. We see a lot of convergence and I think these days we're starting to see more and more focus because of the convergence on illegal wildlife trade and I think also thanks to organisations like yourselves in the United for Wildlife who are pushing quite hard to raise awareness around the subjects.

Rob Campbell - United for Wildlife:

Yeah, the sad reality is you, unlike the narcotics trade, once the animals are gone, they're gone Because you know you're looking at, you know, when children grow up you look at rhinos and elephants and you think these, you know, majestic, magnificent species, that are quite peculiar looking, but for a reason. Well, these are being hunted to extinction and once they are gone, that's it, no more. It's not a, you know, reciprocating trade. There is a finite supply and that's a sobering reminder of where we sit.

Jonny Bell - LexisNexis Risk Solutions:

Yes, so we're aware that illegal wildlife trade is a global issue. I understand there's some regional nuances. Are we able to talk a little bit more about some of the most trafficked routes or most trafficked species, or some species that are potentially at risk of endangerment or extinction?

Rob Campbell - United for Wildlife:

Yeah, I think, and I think you can you can again associate this to sort of that that the shifts, that we're seeing an adaption from criminals in days gone by the typical routes would have been, you know obviously, Africa to Asia. You know poaching in Africa, demand in Asia.

Rob Campbell - United for Wildlife:

And. But I think we have seen that change as awareness has grown, as capability to detect this has increased and as red flags, crucially, have become more widespread. You're seeing the traffickers divert these routes. So if, for example, it's a South Africa to China case, it wouldn't go direct. It would go. It might go through the Middle East, it might go through Europe and then to China, and the reason for doing this is because airlines will have red flags, which you know a typical route will be a red flag and if there is a number of red flags, then they might look at the bags.

Rob Campbell - United for Wildlife:

But we one thing we've seen a lot recently is is the rise of the pet trade. So in the past, obviously, we've spoken a bit about the elephants and rhinos and things like that. Well actually elephant or ivory market is dramatically down and many of the domestic markets have been closed over the last 10 years, you know, through much campaigning and advocacy, and actually the Prince was in China in 2015, I think, helping with the awareness and the push to close their markets there. But as a result, we've seen the rise of other species. We're seeing donkey skin being one, there's actually a huge crime. You're seeing five million donkey skins moved throughout the year, which is shocking, and this trade is really being born out of the last few years and I think it's down to some of these syndicates are fairly influential and as demand for one trade like ivory loses, don't get me wrong, there is still a demand for ivory, but as it drops, other trades will emerge and there'll be new laws. There'll be new messaging about this solves cancer or this cures that, and so, yeah, we are seeing other trades crop up, but I think one of the bigger trends that we've seen grow in recent years is this growth of the pet trade. It's songbirds from Asia, it's tigers to the US, it's reptiles to Europe. This is no longer looking at just the Africa Asia route. You're now seeing the growth of Latin America come into this. As increased transport options crop up in Latin America, you're seeing more of the biodiversity be stripped out of those rainforests often with the the deforestation happening in some parts of the Amazon, you often have poaching syndicates or trafficking networks following right behind and picking up these animals that have recently sort of lost their homes, put in a sack and then within a couple of weeks they're probably on a plane to somewhere else. So, as things have changed, we've seen the growth of these other markets.

Rob Campbell - United for Wildlife:

But I think the worrying one for us at the moment is the pet trade, because there's this big blurred line between legal and illegal, and in some countries a species is illegal and others it's legal, and so when it comes to the sort of export, import of this, it becomes really difficult to have a position on it. And then, as a result of that, you've got the customs agencies at the border. They don't know every single species. So if they see on a document it says this is a gray parrot, it looks gray, it looks like a parrot. That's who you're sort of looking to deal with.

Rob Campbell - United for Wildlife:

And unless there is a real expert on the ground at the right time, your, I guess, impact is restricted. But so, yeah, for us the roots are shifting and now it's much more of a global framework, especially as traffickers don't seem to be flying direct to many places, they seem to divert. So it is quite a confusing one, but in a way you have to take that as almost a compliment that the world has become better at identifying and cramping down on criminals. So they are adapting. So it should be expected, but we have to adapt as the criminals adapt.

Jonny Bell - LexisNexis Risk Solutions:

Pet trade is potentially trending upwards. There is, unfortunately, some consistency in those trends, right? So when we look at some LexisNexis Risk Solutions data, it kind of correlated with what the market thought in that pangolin was the most trafficked animal worldwide and continues to be so in 2023. Are you able to just give some insight into why the pangolin is the most trafficked animal in the world and the typical trade routes for the pangolin being trafficked?

Rob Campbell - United for Wildlife:

Yeah, I think, the typical routes. So the destination for pangolin would typically be Vietnam, Cambodia, China. In Vietnam it's the meat as well as the scales. The scales for traditional Chinese medicine can be used by pharmaceutical companies in, I guess, medicine, but the other parts of Asia, as I say, the meat is also used.

Rob Campbell - United for Wildlife:

Personally, I don't know why the pangolin is so trafficked. I'm not an expert. This is United for Wildlife would lead on our network to provide the expertise.

Rob Campbell - United for Wildlife:

But off the top of my head, pangolins are pretty defenseless when found or cornered. They roll into a place where they want to. They roll into a ball and in traffickers or poachers would just pick them up, put them in a sack and then they're collected with thousands of other pangolins and either they're moved like that or they're killed. The scales are taken off and the scales are moved by the ton and when you look at some of the seizures of pangolin scales and you see the scale, the size of these seizures, it's horrifying to think how many animals would have been in that. Yeah, it's sad. I think that this is the reality. But as law enforcement get better and as we are sort of able to clamp down, I hope to have more of an effect on the poaching end of this, so that we're in a space where there are less animals poached, which is where we all want to be. The animals are less at risk, less endangered.

Jonny Bell - LexisNexis Risk Solutions:

And that's probably a good point to touch on, I guess, the inception of United for Wildlife and the relationship to the Royal Foundation. I'd assume that, just given the size and scale of the illegal wildlife trade and the fact that species are being driven to extinction, there were some of the priorities for Prince William when setting up United for Wildlife. Is that a fair statement to make?

Rob Campbell - United for Wildlife:

Yeah, I think so. I know the Prince is obviously very passionate about wildlife and this program in particular, but I guess it's a life of growing up and seeing these species as a child and through the years, which is a privileged place to be, but it's about now using his position and this program to bring people together to protect those species. So United for Wildlife has been running for roughly around 10 years. We where it started with certainly some visual campaigns that looked at raising awareness of the rhino horn trade, ivory trade and things like that. We've now expanded to sort of include certainly timber, but other species less iconic, because it's too easy to just focus on those magnificent species that I've mentioned. But there are countless, you know, hundreds or thousands of other species that are on an endangered list and we also cover it.

Rob Campbell - United for Wildlife:

So United for Wildlife uses its position to bring in information or intelligence partners to tell us what's happening, what's moving and where it's going. We bring in the transport sector to have a better focus on those choke points or bottlenecks that trade has to pass through, because this is a trade, that is, it moves through commercial means, it doesn't have its own infrastructure, so there's opportunities for the private sector to come in and have an impact at certain stages along the supply chain and then, as Geraldine leads the financial task force, looking at those suspicious transactions that happen along those supply lines. But we feel that within those groups so NGO partners with information, private sector, both transport, finance and also law enforcement we feel we have a really good network and platform to have an impact on those trafficking operations and cause disruption where possible.

Jonny Bell - LexisNexis Risk Solutions:

And it's fair to say I think a lot of the work that United for Wildlife do is bringing together industries from across the world right, be that financial task force, be that the transport task force or various other different industries. Is it fair to say that some of the work that United for Wildlife do is actually just getting regions, geographies, different jurisdictions to understand the severity of illegal wildlife trafficking? And my understanding is you've set up some specific regional chapters to look at bringing these geographies and jurisdictions to focus on illegal, combating illegal wildlife trade.

Rob Campbell - United for Wildlife:

Yes, yeah, as I say, we've been going for a few years now, so we've learned some lessons along the way. I think one of the real learnings or, I guess, strategic shifts that we've done recently is, while we were growing, we tried to have membership across the world. So that's we're talking about NGO, the conservation organizations that typically know what's happening with the transport companies and the banks, and law enforcement. We tried to have a global footprint covering the supply lines in the various stages of the trade. In more recent times, we found that actually having a global outlook was a slight hindrance, in that it's not the same problem in different parts of the world. It's very different.

Rob Campbell - United for Wildlife:

So, as a most basic example, in South Africa where Geraldine is, you're looking at poaching and then therefore export of species. I n parts of Asia, but also parts of Europe and the US,

Rob Campbell - United for Wildlife:

you're looking at import of species and sort of demand or distribution, and so what we've tried to do more in the last three years is set up regional chapters, but look at them as hubs, geographic hubs, and within those hubs we have law enforcement.

Rob Campbell - United for Wildlife:

It's the same stakeholders, so it's law enforcement, transport, finance and NGOs, but they're obviously much more focused on the issues or challenges within their region so they can have quite specific solutions to quite specific problems, and so we've targeted regions. So we have a North America chapter, a Latin America and Caribbean chapter, a Middle East North Africa chapter, an East Africa chapter, Southern Africa chapter, a Hong Kong chapter because of the prevalence of illegal wildlife trade going through Hong Kong that's why it's separate and a Southeast Asia and Australasia chapter, and there are plans to have a few more this year. But we feel this model it also gives those chapters identity because they might be a key species that are unique to those areas, but also improves the relationships and the network within them and then therefore better at responding to cases, because they all know each other, they know the process of responding. Yeah, so our role has been to try to create those things.

Geraldine Fleming - United for Wildlife:

Yes, Rob, you're exactly right and so important by bringing these different public and private sectors together that are looking at whether it's how the product moves or how the syndicate access the financial systems and working together with law enforcement.

Geraldine Fleming - United for Wildlife:

I think also the importance of the conservation organizations that Rob mentioned. You know we've got the bigger conservation organizations that do a lot of research but the smaller ones, particularly in local areas or regional areas, that often know what's happening on the ground and are able to bring that information into the kind of broader team. But I think, in terms of those teams working together, what we're starting to see, which is really exciting is how United for WIldlife can aid connecting those different regional chapters internationally. And recently we had a case in Singapore where there was a seizure of rhino horn, where United for Wildlife was able to facilitate introductions and connect law enforcement and financial intelligence units between South Africa and Singapore and we've seen amazing collaboration on that investigation since with really good results both sides. And I think the more that we're starting to see these international connections, the more important it is, so that will help us start to work as an international network and hopefully be more effective in disrupting the international trade.

Jonny Bell - LexisNexis Risk Solutions:

And Geraldine, are you able to elaborate on some of the success stories we've seen across the financial task force in recent years?

Geraldine Fleming - United for Wildlife:

Absolutely. I think I would start out by saying what is really exciting is that we are starting to see more focus on financial investigations that are related to the illegal wildlife trade and, consequently, convictions as well. So in South Africa we've seen two convictions for money laundering related to rhino horn and reptile trafficking and they had 16 people who were part of a trafficking syndicate who were arrested for money laundering charges, not for wildlife trafficking. Malawi has done outstanding work on the Lin Zeng family syndicate over the past few years and not just rested at one conviction but continued to track down members of the syndicate and get financial convictions against them. Singapore brought their first case of charges for money laundering against a rhino horn courier who was unfortunately acquitted, but we may still see success on the appeal or, alternatively, on subsequent cases because they now know to look at these cases and how to go about building the financial cases. So we're starting to see more and more learning. You know there's a massive job to be done in terms of prosecutors and them bringing financial cases to the courts and for the actual judiciary to also understand these kind of complex financial cases. So the US has had massive investigation into primate trafficking, with multiple agencies, led with the RAS, and in Europe there was a one and a half tons of glass eels, worth about two million euro, where you had 27 people arrested and charged with trafficking, smuggling and money laundering. So we're starting to see these more and more.

Geraldine Fleming - United for Wildlife:

Law enforcement has definitely changed their focus, which is really exciting to see. And I would also just add that financial investigations take time. You know they're not just a matter of a couple of months. You know they take a lot of resources, a lot of often intensive forensic investigation and you can be looking at two to three years. So for me, if we're seeing convictions now, when most law enforcement wasn't looking at this, imagine now that more and more awareness around these cases is happening and more and more activity around these investigations is happening. Imagine how many more we're going to see in the years to come, in the shorter term rather than longer term. So I think that's really, really exciting.

Geraldine Fleming - United for Wildlife:

I think, if I can add one particular case where United for Wildlife was very active was the case of the Singapore Rhino Horn Trafficking seizure. It was shortly after United for Wildlife had had a global summit and we had a large number of people together who were really excited and enthused about the subject. And then an individual was arrested in Singapore for smuggling rhino horns. And what was really exciting about that is United for Wildlife were able to gather a group of people very quickly from Interpol to law enforcement in Singapore and South Africa, to financial intelligence units, to conservation organizations to bring everyone together. Everyone was really excited and committed to see how they could facilitate that investigation straight away. So really, as you say in your report, Jonny, and as Rob has said as well, just the absolute power of bringing those people together to be able to work together and collaborate, bring their skills, their resources to the table, to actually work as a team and and bring some of these networks down.

Jonny Bell - LexisNexis Risk Solutions:

Great. Thank you, Geraldine. It's great to see how United for Wildlife are connecting the dots across industries that are resulting in in these convictions enforcement. So really positive to see that progress. Rob, it'd be great to hear your thoughts, too, on the impact organizations like you at UFW are having on combating IWT.

Rob Campbell - United for Wildlife:

I think an honest outlook on this is that the problem is shifting. So I think that's a positive in itself. But as of 12 years ago or so, criminals operated in this space with almost free reign. There was very little enforcement awareness of how they operated and what they did. There was certainly very little awareness in the private sector of what was going on and if you're not aware of what's going on you're not aware of how to stop it or detect it.

Rob Campbell - United for Wildlife:

I think one thing United for Wildlife has done is to raise awareness, so it is acknowledged in the ports for shipping and it's the airports are now aware of what to look for and there have been really significant arrests and seizures in those spaces. And I think, as Geraldine says, you in the financial space, where I would say there was probably one bank, globally, Standard Chartered, who were leading the way before we set up the financial task force. They have shared all the things and a lot of those best practices have been improved upon by other banks. But you've now got within the financial task force is at least 60 banks, maybe slightly more, who have a capability to respond to this. They know what they're looking for, they have a process set up for how to respond, how to report and how to you know, I guess carry out the financial investigation in this space. So these are all really promising developments and I think because of that we've seen criminals adapt, starting to adapt and realize that it isn't such a free reign anymore. There are risks now which they weren't before and there's actually two case studies I think useful to share here, one of them quite recently, probably a couple of weeks ago, it's in the BBC News.

Rob Campbell - United for Wildlife:

It was in sort of global news but in Australia there was a big seizure of a lizard smuggling syndicate, so moving native lizards. The syndicate were moving native lizards to Australia, out to Hong Kong, for pet trade and things like that. I think it was valued roughly just under a million US dollars, so I think 900,000 US dollars. The whole syndicate was detected through a postal auto detection system. So some AI software that has been developed over the last few years only in the last few years to monitor postal logistics and within that they had uploaded various wildlife precursors so that it could detect and it did detect a few lizards and from those few lizards they carried out a more significant operation or investigation and over time they managed to bag a whole syndicate. There were quite dramatic raids throughout Sydney, I think it was. But it was big news and for me this is interesting because lizard trafficking, pet trade it's not a big headline usually but now we're starting to see these things come on the news as if it's a big drugs bust and things like that and maybe it wasn't big enough news for most of the readership or the listenership for this, but from someone who's in this world, I think that was a significant development for us. And the second case, I'd say it actually just happened. We've just seen results of it today.

Rob Campbell - United for Wildlife:

So in Hong Kong we have our little chapter in Hong Kong, and a couple of years ago they worked hard with stakeholders in Hong Kong to push for wildlife trafficking to be added to a serious and organized crime bill. It's a piece of legislation which was successful and it enables law enforcement more resources and measures to investigate wildlife trafficking crimes. They already have this for terrorist financing or narcotics, but so adding wildlife to this, which is a, you know, a simple, simple addition, has enabled, as of this morning, I think we saw a case that was a money laundering case of the value of seven, just under seven and a half million dollars, and it started with a network that was smuggling 300 corals and I think they were moving them through frozen meat and fish. So there's this sort of convergence between this illegal trade and legal trade, but they were hiding them in these containers and that's how they were found. A subsequent financial investigation uncovered, I think, nearly 7,000 transactions over the course of two and a half years. There were 700 third party accounts and, as I say yeah, to the value of about seven half million dollars.

Rob Campbell - United for Wildlife:

So the important thing for us here is this is the first time that law enforcement have arrested and tried a group on wildlife trafficking on money laundering charges.

Rob Campbell - United for Wildlife:

So typically wildlife trafficking charges you don't tend to get a big penalty it's one of the sad realities of this but on money laundering charges you get a much bigger penalty, and so now we're seeing the capability of money laundering investigations come into wildlife trafficking. It's something that Geraldine and the financial task force have been pushing globally for some time. But we, as I said, this problem's shifting. I think law and law enforcement are certainly up to speed on how to do this. You're, we're gonna see traffickers adapt again, and I don't know where that means they're completely resort to cash. But there's probably lessons to be taken from the narcotics trade and other trades which have had this sort of exposure and the criminals you know sort of adapt again. But I think those two cases just really good examples of how there have been success and slowly but surely we're sort of restricting the criminals ability to manoeuvre in this space and and I think you alluded to it there right that that's come about through legislative change.

Jonny Bell - LexisNexis Risk Solutions:

That was an example in Hong Kong. Is that, then, a focus for United for wildlife and some of these task forces is engaging with, with governmental bodies and regulators around the world to, I guess, make the link between wildlife trafficking and money laundering? Because I think for many of our listeners, and myself included, prior to embarking on this partnership with United for Wildlife, I hadn't quite made the correlation between illegal wildlife trafficking and money laundering, whereas now, a year, two years down the line, I understand that they're they're they're inextricably linked between each other, right?

Rob Campbell - United for Wildlife:

Yeah, I think like any you know serious crime, you know where proceeds, you know in the billions there are perpetrators who are making millions, and so you know these people are protecting their assets and their, their structures and and their way of life, unfortunately, and so we need to, we need to move. You know what's the one thing that you know people want it. We're not. Wildlife trafficking is about money. It it's not really about the animals. That's the issue is is the animal is just a commodity, much like drugs or or or weapons or something it's. It's the people do it because of the money. So, if I think what United for Wildlife is doing is, as I say, it's a two-pronged approach, one where we're trying to create the operational capability to to carry out financial investigation and and recognize suspicious activity, but also we're trying to develop the legislation. And we're not the only one. There's countless partners WWF, traffic, WCS, all the wildlife organizations.

Rob Campbell - United for Wildlife:

But with those two things we're squeezing the ability for the traffickers to maneuver in the space and I think we are seeing results. But the key thing to recognize is that this is all about money. So if we go after the money rather than the commodity and the product, then you know we're going after what the trafficker is truly trying to achieve or the network is trying to achieve. There's also an element of protecting the species on the ground, which is a slightly separate issue, but it's also.

Geraldine Fleming - United for Wildlife:

It's also really good to see, or what we're seeing Jonny is - to build on what Rob is saying - is that we are seeing different regions approaching the challenges in different ways and what we are able to do is to facilitate the sharing of that best practice, exactly like Hong Kong have added, you know, put pressure on to adjust the legal framework.

Geraldine Fleming - United for Wildlife:

In South Africa, we've seen changes in legal approaches in terms of enabling information sharing acts regarding public private partnerships, and we're starting to see, for example, there's an agreement between the South African and US Treasuries to collaborate to look at case studies particular to the illegal wildlife trade and and unpack them on both sides of the different continents and, and from there even taking it further, United for Wildlife has been building on what they call a statement of principles, by actually encouraging different countries to sign up, to commit to prioritizing the illegal wildlife trade as a money laundering risk and to take action and steps to actually address that. So the more that we start seeing the sharing of best practice. You know, we're aware of other organizations, other big conservation organizations who have a focus specifically on legalities or on particular areas of specialism or expertise, and by bringing those people into our audiences and entire network and being able to share that best practice and information much more effectively is going to mean that we're going to have a much more impactful approach across the world.

Jonny Bell - LexisNexis Risk Solutions:

Yeah, absolutely. And I think the key thing for me that United for Wildlife is doing I mentioned this earlier is is bringing industries together to help combat illegal wildlife trade. When we look at the problem in hand, it's impossible, as with any other predicate crime that that FATF outlines, it's impossible for us as an industry to combat that crime in isolation. There needs to be public private partnerships that have been set up and needs to be collaboration between governments and jurisdictions around the world. So I think can completely hats off to you guys, at United for Wildlife, for the progress you're making and, Geraldine, you work with, with many of the world's leading financial institutions and the employees that work within those financial institutions. Just just given this, are there any red flags or risk indicators that these employees can look out for to help combat illegal wildlife trade?

Geraldine Fleming - United for Wildlife:

Absolutely. I think what we always need to remember is that it always starts with the usual money laundering indicators. You know: round amounts, financial statements not matching up with bank statements, businesses that have no tax payments or just very specific expenses that don't go through others. So I think what I would say is, as I've said before, go and read up on the reports that you can see, because they often provide absolute lists of transaction descriptions and things like that. But I would encourage them to look very carefully at high risk industries and occupations.

Geraldine Fleming - United for Wildlife:

For example, the role of casinos comes up again and again, particularly in third world countries, as an easy way to launder money. Attorneys, the role of attorneys and attorney trust accounts. Secondhand vehicle markets, particularly in places like Africa and South America. Guest house accommodation, where you'll have people going, staying in guest houses, for example in South Africa, and they get told where to find the reptiles or succulents and to go and look at and take photographs, except they just kind of take them out instead. So, and then, of course, mobile phone payments.

Geraldine Fleming - United for Wildlife:

The importance of mobile phones is critical, not just, obviously, in terms of information that can be gleaned or not, in terms of a particular suspect's phone number that might be recorded in their personal data, but what mobile numbers are they making payments to? And there's been quite a big learning curve that we've seen within the financial intelligence units in the banks in terms of how to request that information and how to provide that information, because obviously that then links to another person who potentially becomes another suspect in the in the kind of broad picture. So the key is to understand the indicators and then to overlay the red flag. So the fact that somebody withdrew or made a deposit in a particular high risk area is nothing in itself. But if in a high risk area with a high risk industry, with a high risk occupation, a deposit and a round amount that's different from their salary or excessive lifestyle spending could certainly be something that's worth a closer look.

Geraldine Fleming - United for Wildlife:

And we saw when I was working within a bank as we did more work around awareness and what those red flags might be. We started seeing our transaction monitoring staff looking much more closely at transaction descriptions and actually starting to question them. But all of that came from actually understanding what the issues were in the first place. So there are lots of other red flags that that we could look at: couriers, cash and transit companies. For example, in abalone, which is a big issue in Southern Africa, they see lots of boat purchases or sales to restaurants and things like that.

Geraldine Fleming - United for Wildlife:

That just don't make sense. So they're all these different things that they look at to see what they can pick up. And actually the Vanny Biotech case, which is, if you go and look at it, you'll see that the kind of first flag that was raised was a bank official, I think one of the frontline officials who who looked at particular deposits in an environment officials count and it it doesn't quite make sense and they questioned it and this whole massive primate smuggling cases come out of that. So sometimes just one person being a little bit aware and and taking that extra step in terms of if you see something, say something, has made a massive impact on on a global smuggling ring.

Jonny Bell - LexisNexis Risk Solutions:

Great, thank you. Many of our listeners will be from the world of financial institutions and financial services, will have listeners from transport and trade companies. Just just given this, this listener base, is there any recommendations to them that you'd like to conclude with?

Rob Campbell - United for Wildlife:

Hopefully it's come across in some of the examples we've shared. But but the the importance of collaboration in the space I mean we just touched on the public-private partnerships Absolutely critical. That's again something fairly new that's been established. But I think collaboration and this sort of power of partnerships this is a global issue with touch points, you know, all around the world. I think if your readership are interested and, you know, have some sort of desire to learn more and have more position on how to, you know, detect, how to report and who to report to then reach out to us.

Rob Campbell - United for Wildlife:

I think involvement in some of these regional chapters is a is a simple addition they can make which would hopefully dramatically enhance their, their understanding and their capability to respond to it. We don't ask for money. It is just a free resource that we we hand out. What we want is to develop these networks, for people to come in and be better at responding. So yeah, my sort of would be to reach out to United World like, get involved if you see yourself along this touch point and, again, an understanding of what's happening. You know, receive our free intelligence bulletins that go out on specific cases with red flags and learnings and things like that, and come into a network which Can provide resources, tools and things that already are available, you know, ready off the shelf solutions and training and see what you think.

Jonny Bell - LexisNexis Risk Solutions:

And and for those listeners interested, we we can find that at www. unitedforwildlife. org.

Geraldine Fleming - United for Wildlife:

What I would encourage people to do, particularly in the financial industry, is to just appreciate the power of the financial system to make a positive impact on reducing the illegal wildlife trade and, as Rob said, to educate yourselves.

Geraldine Fleming - United for Wildlife:

The biggest key is ensuring that you are informed and understand what wildlife, illegal wildlife transactions, might look like. There are numerous reports now that have come out specifically looking at Red flags and high risk indicators for money laundering: One from Canada, two from South Africa, one from the Middle East, one from Hong Kong, with more to come. So there certainly is a lot of information out there available specific to the financial sector and and I would encourage them to go and find those reports and just read and just be that little bit more aware and, as Rob said, sign up to the United for Wildlife Financial Task Force so that you can get the bulletins and alerts that keep you up to date much more, much more quickly. So by doing that it'll just make you more aware and once you're away, then you you get much more effective in what you do. So go out and learn.

Jonny Bell - LexisNexis Risk Solutions:

Brilliant, thank you, so we'll be posting all of the respective websites and links and how you can help out or get any more insight in the show notes. But with that I will conclude and say a big thank you to Rob and Geraldine.

Rob Campbell - United for Wildlife:

Thanks, Jonny, and thanks to your team, look forward to collaborating in the future.

Jonny Bell - LexisNexis Risk Solutions:

And to our listeners. Thank you for tuning into this episode of the RegTech Pulse. Our new report written in conjunction with United for Wildlife, Combating wildlife trafficking with the power of collaboration is now live. Check out the show notes to download your copy and to learn more about the work of United for Wildlife and the Royal Foundation.

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