Combating Wildlife Trafficking: Battling a Twenty-Billion Dollar Industry

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.

Episode Transcript

Jonny Bell - LexisNexis Risk (00:12):
Hi everyone, welcome to the
RegTech Pulse.
I'm Jonny Bell, director ofFinancial Crime Compliance
Market Planning at RiskSolutions.
On today's podcast we're goingto delve a little bit deeper
into a joint white paper thatwe've published alongside United
for Wildlife that looks atcombating illegal wildlife

(00:33):
trafficking through the power ofcollaboration.
So, without further ado, Iwould like to introduce you to
our guests, Rob Campbell andGeraldine Fleming.
Rob, could you go first?

Rob Campbell - United for Wi (00:46):
Hi , my name is Rob Campbell.
I lead the United for Wildlifeprogramme, which was set up by
His Royal Highness PrinceWilliam and the Royal Foundation
as a way to combat theincreasing issues around
wildlife trafficking.

Jonny Bell - LexisNexis (00:59):
Great, and Geraldine?

Geraldine Fleming - United f (01:02):
Hi all and thank you for having me
.
My name is Geraldine Flemingand I am the Financial Task
Force Manager for United forWildlife.
I've been with United forWildlife for about a year now
and it's a real passion pointfor me.

Jonny Bell - LexisNex (01:17):
Fantastic .
Thank you, and for thoselisteners not familiar with the
illegal wildlife trade, that wasreally how we wanted to kick
off this podcast was justunderstanding the size, scale
and severity of the issue inhand.
Rob, are you able to elaborateon this a little bit more?

Rob Campbell - United for (01:39):
Yeah , I think so.
You know the illegal wildlifetrade isn't the most well known
of illicit trades.
I think people could beforgiven for not, you know,
being fully aware of itsimplications and its damage that
it causes.
But to put it in perspective,we would assess the illegal
wildlife trade to be valuedbetween 20 and 23 billion

(02:01):
dollars, which is quite a vagueand large estimate.
But that's not money that youfind hidden under beds.
That's a serious professionthat's driving a poaching crisis
, you know, in some parts of theworld and feeding a demand in
other parts of the world.
When you look at theimplications or impact, you know
, outside of the monetary valueof the illegal wildlife trade,

(02:23):
you're also looking at countrieshaving a biodiversity stripped,
some of these animals that areiconic to some countries around
the world, you know, put in onthe endangered list and at times
, you know, becoming extremelyor at risk of becoming extinct.
People suggest that the illegalwildlife trade would be the
fourth largest illicit trade.
So where people will be veryfamiliar with the narcotics

(02:47):
trade, you know, obviouslyhighly profitable, truly global.
Behind that you have humantrafficking and arms trafficking
, but wildlife traffickingdoesn't sit too far behind, and
especially when you include theillegal timber trade and the
stripping of forests and thingsfor illegal timber for demand
around the world, then you'relooking at increasing that value
quite dramatically.

Geraldine Fleming - Uni (03:08):
Exactly , Rob, and I think I can add,
the UN environmental programmeand Interpol looked at those
numbers a few years ago now.
Unfortunately the data is alittle bit out of date.
But when you look at, as Robsaid, the broader environmental
crime, you're looking at anestimated $260 billion per annum

(03:32):
and compared to the drug tradeat the time of $344 billion per
annum.
You're looking at environmentalcrime being around 75% of the
value of the drug trade but notgetting quite the same attention
.
So it's very important for usto kind of look.

(03:52):
We see a lot of convergence andI think these days we're
starting to see more and morefocus because of the convergence
on illegal wildlife trade and Ithink also thanks to
organisations like yourselves inthe United for Wildlife who
are pushing quite hard to raiseawareness around the subjects.

Rob Campbell - United for (04:12):
Yeah , the sad reality is you, unlike
the narcotics trade, once theanimals are gone, they're gone
Because you know you're lookingat, you know, when children grow
up you look at rhinos andelephants and you think these,
you know, majestic, magnificentspecies, that are quite peculiar
looking, but for a reason.
Well, these are being hunted toextinction and once they are

(04:34):
gone, that's it, no more.
It's not a, you know,reciprocating trade.
There is a finite supply andthat's a sobering reminder of
where we sit.

Jonny Bell - LexisNexis Ris (04:46):
Yes , so we're aware that illegal
wildlife trade is a global issue.
I understand there's someregional nuances.
Are we able to talk a littlebit more about some of the most
trafficked routes or mosttrafficked species, or some
species that are potentially atrisk of endangerment or
extinction?

Rob Campbell - United for (05:07):
Yeah , I think, and I think you can
you can again associate this tosort of that that the shifts,
that we're seeing an adaptionfrom criminals in days gone by
the typical routes would havebeen, you know obviously, Africa
to Asia.
You know poaching in Africa,demand in Asia.

(05:29):
And.
But I think we have seen thatchange as awareness has grown,
as capability to detect this hasincreased and as red flags,
crucially, have become morewidespread.
You're seeing the traffickersdivert these routes.
So if, for example, it's aSouth Africa to China case, it

(05:53):
wouldn't go direct.
It would go.
It might go through the MiddleEast, it might go through Europe
and then to China, and thereason for doing this is because
airlines will have red flags,which you know a typical route
will be a red flag and if thereis a number of red flags, then
they might look at the bags.
But we one thing we've seen alot recently is is the rise of

(06:13):
the pet trade.
So in the past, obviously,we've spoken a bit about the
elephants and rhinos and thingslike that.
Well actually elephant or ivorymarket is dramatically down and
many of the domestic marketshave been closed over the last
10 years, you know, through muchcampaigning and advocacy, and
actually the Prince was in Chinain 2015, I think, helping with

(06:34):
the awareness and the push toclose their markets there.
But as a result, we've seen therise of other species.
We're seeing donkey skin beingone, there's actually a huge
crime.
You're seeing five milliondonkey skins moved throughout
the year, which is shocking, andthis trade is really being born

(06:59):
out of the last few years and Ithink it's down to some of
these syndicates are fairlyinfluential and as demand for
one trade like ivory loses,don't get me wrong, there is
still a demand for ivory, but asit drops, other trades will
emerge and there'll be new laws.
There'll be new messaging aboutthis solves cancer or this

(07:22):
cures that, and so, yeah, we areseeing other trades crop up,
but I think one of the biggertrends that we've seen grow in
recent years is this growth ofthe pet trade.
It's songbirds from Asia, it'stigers to the US, it's reptiles
to Europe.
This is no longer looking atjust the Africa Asia route.

(07:44):
You're now seeing the growth ofLatin America come into this.
As increased transport optionscrop up in Latin America, you're
seeing more of the biodiversitybe stripped out of those
rainforests often with the thedeforestation happening in some
parts of the Amazon, you oftenhave poaching syndicates or
trafficking networks followingright behind and picking up

(08:07):
these animals that have recentlysort of lost their homes, put
in a sack and then within acouple 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.
But I think the worrying one forus at the moment is the pet
trade, because there's this bigblurred line between legal and

(08:27):
illegal, and in some countries aspecies is illegal and others
it's legal, and so when it comesto the sort of export, import
of this, it becomes reallydifficult 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 singlespecies.

(08:48):
So if they see on a document itsays this is a gray parrot, it
looks gray, it looks like aparrot.
That's who you're sort oflooking to deal with.
And unless there is a realexpert on the ground at the
right time, your, I guess,impact is restricted.
But so, yeah, for us the rootsare shifting and now it's much

(09:11):
more of a global framework,especially as traffickers don't
seem to be flying direct to manyplaces, they seem to divert.
So it is quite a confusing one,but in a way you have to take
that as almost a compliment thatthe world has become better at
identifying and cramping down oncriminals.
So they are adapting.
So it should be expected, butwe have to adapt as the

(09:34):
criminals adapt.

Jonny Bell - LexisNexis Ris (09:42):
Pet trade is potentially trending
upwards.
There is, unfortunately, someconsistency in those trends,
right?
So when we look at someLexisNexis Risk Solutions data,
it kind of correlated with whatthe market thought in that
pangolin was the most traffickedanimal worldwide and continues

(10:02):
to be so in 2023.
Are you able to just give someinsight into why the pangolin is
the most trafficked animal inthe world and the typical trade
routes for the pangolin beingtrafficked?

Rob Campbell - United for (10:16):
Yeah , I think, the typical routes.
So the destination for pangolinwould typically be Vietnam,
Cambodia, China.
In Vietnam it's the meat aswell as the scales.
The scales for traditionalChinese medicine can be used by
pharmaceutical companies in, Iguess, medicine, but the other

(10:41):
parts of Asia, as I say, themeat is also used.
Personally, I don't know why thepangolin is so trafficked.
I'm not an expert.
This is United for Wildlifewould lead on our network to
provide the expertise.
But off the top of my head,pangolins are pretty defenseless
when found or cornered.
They roll into a place wherethey want to.
They roll into a ball and intraffickers or poachers would

(11:04):
just pick them up, put them in asack and then they're collected
with thousands of otherpangolins and either they're
moved like that or they'rekilled.
The scales are taken off andthe scales are moved by the ton
and when you look at some of theseizures of pangolin scales and
you see the scale, the size ofthese seizures, it's horrifying

(11:27):
to think how many animals wouldhave been in that.
Yeah, it's sad.
I think that this is thereality.
But as law enforcement getbetter and as we are sort of
able to clamp down, I hope tohave more of an effect on the
poaching end of this, so thatwe're in a space where there are
less animals poached, which iswhere we all want to be.

(11:48):
The animals are less at risk,less endangered.

Jonny Bell - LexisNexis Ris (11:53):
And that's probably a good point to
touch on, I guess, theinception of United for Wildlife
and the relationship to theRoyal Foundation.
I'd assume that, just given thesize and scale of the illegal
wildlife trade and the fact thatspecies are being driven to
extinction, there were some ofthe priorities for Prince

(12:13):
William when setting up Unitedfor Wildlife.
Is that a fair statement tomake?

Rob Campbell - United for (12:20):
Yeah , I think so.
I know the Prince is obviouslyvery passionate about wildlife
and this program in particular,but I guess it's a life of
growing up and seeing thesespecies as a child and through
the years, which is a privilegedplace to be, but it's about now
using his position and thisprogram to bring people together

(12:40):
to protect those species.
So United for Wildlife has beenrunning for roughly around 10
years.
We where it started withcertainly some visual campaigns
that looked at raising awarenessof the rhino horn trade, ivory
trade and things like that.
We've now expanded to sort ofinclude certainly timber, but

(13:02):
other species less iconic,because it's too easy to just
focus on those magnificentspecies that I've mentioned.
But there are countless, youknow, hundreds or thousands of
other species that are on anendangered list and we also
cover it.
So United for Wildlife uses itsposition to bring in information
or intelligence partners totell us what's happening, what's

(13:24):
moving and where it's going.
We bring in the transportsector to have a better focus on
those choke points orbottlenecks that trade has to
pass through, because this is atrade, that is, it moves through
commercial means, it doesn'thave its own infrastructure, so
there's opportunities for theprivate sector to come in and
have an impact at certain stagesalong the supply chain and then

(13:47):
, as Geraldine leads thefinancial task force, looking at
those suspicious transactionsthat happen along those supply
lines.
But we feel that within thosegroups so NGO partners with
information, private sector,both transport, finance and also
law enforcement we feel we havea really good network and
platform to have an impact onthose trafficking operations and

(14:11):
cause disruption where possible.

Jonny Bell - LexisNexis Ris (14:15):
And it's fair to say I think a lot
of the work that United forWildlife do is bringing together
industries from across theworld right, be that financial
task force, be that thetransport task force or various
other different industries.
Is it fair to say that some ofthe work that United for

(14:36):
Wildlife do is actually justgetting regions, geographies,
different jurisdictions tounderstand the severity of
illegal wildlife trafficking?
And my understanding is you'veset up some specific regional
chapters to look at bringingthese geographies and

(14:57):
jurisdictions to focus onillegal, combating illegal
wildlife trade.

Rob Campbell - United for W (15:05):
Yes , yeah, as I say, we've been
going for a few years now, sowe've learned some lessons along
the way.
I think one of the reallearnings or, I guess, strategic
shifts that we've done recentlyis, while we were growing, we
tried to have membership acrossthe world.
So that's we're talking aboutNGO, the conservation

(15:26):
organizations that typicallyknow what's happening with the
transport companies and thebanks, and law enforcement.
We tried to have a globalfootprint covering the supply
lines in the various stages ofthe trade.
In more recent times, we foundthat actually having a global
outlook was a slight hindrance,in that it's not the same

(15:48):
problem in different parts ofthe world.
It's very different.
So, as a most basic example, inSouth Africa where Geraldine is,
you're looking at poaching andthen therefore export of species
.
I n parts of Asia, but alsoparts of Europe and the US,
you're looking at import ofspecies and sort of demand or
distribution, and so what we'vetried to do more in the last

(16:11):
three years is set up regionalchapters, but look at them as
hubs, geographic hubs, andwithin those hubs we have law
enforcement.
It's the same stakeholders, soit's law enforcement, transport,
finance and NGOs, but they'reobviously much more focused on
the issues or challenges withintheir region so they can have
quite specific solutions toquite specific problems, and so

(16:34):
we've targeted regions.
So we have a North Americachapter, a Latin America and
Caribbean chapter, a Middle EastNorth Africa chapter, an East
Africa chapter, Southern Africachapter, a Hong Kong chapter
because of the prevalence ofillegal wildlife trade going
through Hong Kong that's whyit's separate and a Southeast
Asia and Australasia chapter,and there are plans to have a

(16:54):
few more this year.
But we feel this model it alsogives those chapters identity
because they might be a keyspecies that are unique to those
areas, but also improves therelationships and the network
within them and then thereforebetter at responding to cases,
because they all know each other, they know the process of
responding.
Yeah, so our role has been totry to create those things.

Geraldine Fleming - United (17:20):
Yes , Rob, you're exactly right and
so important by bringing thesedifferent public and private
sectors together that arelooking at whether it's how the
product moves or how thesyndicate access the financial
systems and working togetherwith law enforcement.
I think also the importance ofthe conservation organizations

(17:41):
that Rob mentioned.
You know we've got the biggerconservation organizations that
do a lot of research but thesmaller ones, particularly in
local areas or regional areas,that often know what's happening
on the ground and are able tobring that information into the
kind of broader team.

(18:01):
But I think, in terms of thoseteams working together, what
we're starting to see, which isreally exciting is how United
for WIldlife can aid connectingthose different regional
chapters internationally.
And recently we had a case inSingapore where there was a
seizure of rhino horn, whereUnited for Wildlife was able to

(18:24):
facilitate introductions andconnect law enforcement and
financial intelligence unitsbetween South Africa and
Singapore and we've seen amazingcollaboration on that
investigation since with reallygood results both sides.
And I think the more that we'restarting to see these

(18:47):
international connections, themore important it is, so that
will help us start to work as aninternational network and
hopefully be more effective indisrupting the international
trade.

Jonny Bell - LexisNexis Ris (19:03):
And Geraldine, are you able to
elaborate on some of the successstories we've seen across the
financial task force in recentyears?

Geraldine Fleming - (19:14):
Absolutely .
I think I would start out bysaying what is really exciting
is that we are starting to seemore focus on financial
investigations that are relatedto the illegal wildlife trade
and, consequently, convictionsas well.
So in South Africa we've seentwo convictions for money

(19:35):
laundering related to rhino hornand reptile trafficking and
they had 16 people who were partof a trafficking syndicate who
were arrested for moneylaundering charges, not for
wildlife trafficking.
Malawi has done outstandingwork on the Lin Zeng family

(19:55):
syndicate over the past fewyears and not just rested at one
conviction but continued totrack down members of the
syndicate and get financialconvictions against them.
Singapore brought their firstcase of charges for money
laundering against a rhino horncourier who was unfortunately

(20:17):
acquitted, but we may still seesuccess on the appeal or,
alternatively, on subsequentcases because they now know to
look at these cases and how togo about building the financial
cases.
So we're starting to see moreand more learning.
You know there's a massive jobto be done in terms of

(20:37):
prosecutors and them bringingfinancial cases to the courts
and for the actual judiciary toalso understand these kind of
complex financial cases.
So the US has had massiveinvestigation into primate
trafficking, with multipleagencies, led with the RAS, and

(21:01):
in Europe there was a one and ahalf tons of glass eels, worth
about two million euro, whereyou had 27 people arrested and
charged with trafficking,smuggling and money laundering.
So we're starting to see thesemore and more.
Law enforcement has definitelychanged their focus, which is

(21:23):
really exciting to see.
And I would also just add thatfinancial investigations take
time.
You know they're not just amatter of a couple of months.
You know they take a lot ofresources, a lot of often
intensive forensic investigationand you can be looking at two
to three years.
So for me, if we're seeingconvictions now, when most law

(21:48):
enforcement wasn't looking atthis, imagine now that more and
more awareness around thesecases is happening and more and
more activity around theseinvestigations is happening.
Imagine how many more we'regoing to see in the years to
come, in the shorter term ratherthan longer term.
So I think that's really,really exciting.

(22:11):
I think, if I can add oneparticular case where United for
Wildlife was very active wasthe case of the Singapore Rhino
Horn Trafficking seizure.
It was shortly after United forWildlife had had a global

(22:32):
summit and we had a large numberof people together who were
really excited and enthusedabout the subject.
And then an individual wasarrested in Singapore for
smuggling rhino horns.
And what was really excitingabout that is United for
Wildlife were able to gather agroup of people very quickly
from Interpol to law enforcementin Singapore and South Africa,

(22:57):
to financial intelligence units,to conservation organizations
to bring everyone together.
Everyone was really excited andcommitted to see how they could
facilitate that investigationstraight away.
So really, as you say in yourreport, Jonny, and as Rob has

(23:19):
said as well, just the absolutepower of bringing those people
together to be able to worktogether and collaborate, bring
their skills, their resources tothe table, to actually work as
a team and and bring some ofthese networks down.

Jonny Bell - LexisNexis R (23:34):
Great .
Thank you, Geraldine.
It's great to see how Unitedfor Wildlife are connecting the
dots across industries that areresulting in in these
convictions enforcement.
So really positive to see thatprogress.
Rob, it'd be great to hear yourthoughts, too, on the impact
organizations like you at UFWare having on combating IWT.

Rob Campbell - United for Wil (23:56):
I think an honest outlook on this
is that the problem is shifting.
So I think that's a positive initself.
But as of 12 years ago or so,criminals operated in this space
with almost free reign.
There was very littleenforcement awareness of how
they operated and what they did.
There was certainly very littleawareness in the private sector

(24:19):
of what was going on and ifyou're not aware of what's going
on you're not aware of how tostop it or detect it.
I think one thing United forWildlife has done is to raise
awareness, so it is acknowledgedin the ports for shipping and
it's the airports are now awareof what to look for and there
have been really significantarrests and seizures in those
spaces.
And I think, as Geraldine says,you in the financial space,

(24:43):
where I would say there wasprobably one bank, globally,
Standard Chartered, who wereleading the way before we set up
the financial task force.
They have shared all the thingsand a lot of those best
practices have been improvedupon by other banks.
But you've now got within thefinancial task force is at least
60 banks, maybe slightly more,who have a capability to respond
to this.
They know what they're lookingfor, they have a process set up

(25:06):
for how to respond, how toreport and how to you know, I
guess carry out the financialinvestigation in this space.
So these are all reallypromising developments and I
think because of that we've seencriminals adapt, starting to
adapt and realize that it isn'tsuch a free reign anymore.
There are risks now which theyweren't before and there's

(25:28):
actually two case studies Ithink useful to share here, one
of them quite recently, probablya couple of weeks ago, it's in
the BBC News.
It was in sort of global newsbut in Australia there was a big
seizure of a lizard smugglingsyndicate, so moving native
lizards.
The syndicate were movingnative lizards to Australia, out
to Hong Kong, for pet trade andthings like that.

(25:49):
I think it was valued roughlyjust under a million US dollars,
so I think 900,000 US dollars.
The whole syndicate wasdetected through a postal auto
detection system.
So some AI software that hasbeen developed over the last few
years only in the last fewyears to monitor postal

(26:12):
logistics and within that theyhad uploaded various wildlife
precursors so that it coulddetect and it did detect a few
lizards and from those fewlizards they carried out a more
significant operation orinvestigation and over time they
managed to bag a wholesyndicate.
There were quite dramatic raidsthroughout Sydney, I think it
was.
But it was big news and for methis is interesting because

(26:36):
lizard trafficking, pet tradeit's not a big headline usually
but now we're starting to seethese things come on the news as
if it's a big drugs bust andthings like that and maybe it
wasn't big enough news for mostof the readership or the
listenership for this, but fromsomeone who's in this world, I
think that was a significantdevelopment for us.
And the second case, I'd say itactually just happened.

(26:58):
We've just seen results of ittoday.
So in Hong Kong we have ourlittle chapter in Hong Kong, and
a couple of years ago theyworked hard with stakeholders in
Hong Kong to push for wildlifetrafficking to be added to a
serious and organized crime bill.
It's a piece of legislationwhich was successful and it

(27:19):
enables law enforcement moreresources and measures to
investigate wildlife traffickingcrimes.
They already have this forterrorist 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 moneylaundering case of the value of
seven, just under seven and ahalf million dollars, and it

(27:43):
started with a network that wassmuggling 300 corals and I think
they were moving them throughfrozen meat and fish.
So there's this sort ofconvergence between this illegal
trade and legal trade, but theywere hiding them in these
containers and that's how theywere found.
A subsequent financialinvestigation uncovered, I think

(28:03):
, nearly 7,000 transactions overthe course of two and a half
years.
There were 700 third partyaccounts and, as I say yeah, to
the value of about seven halfmillion dollars.
So the important thing for ushere is this is the first time
that law enforcement havearrested and tried a group on
wildlife trafficking on moneylaundering charges.

(28:26):
So typically wildlifetrafficking charges you don't
tend to get a big penalty it'sone of the sad realities of this
but on money laundering chargesyou get a much bigger penalty,
and so now we're seeing thecapability of money laundering
investigations come intowildlife trafficking.
It's something that Geraldineand the financial task force
have been pushing globally forsome time.
But we, as I said, thisproblem's shifting.

(28:48):
I think law and law enforcementare certainly up to speed on
how to do this.
You're, we're gonna seetraffickers adapt again, and I
don't know where that meansthey're completely resort to
cash.
But there's probably lessons tobe taken from the narcotics
trade and other trades whichhave had this sort of exposure
and the criminals you know sortof adapt again.

(29:08):
But I think those two casesjust really good examples of how
there have been success andslowly but surely we're sort of
restricting the criminalsability to manoeuvre in this
space and and I think youalluded to it there right that
that's come about throughlegislative change.

Jonny Bell - LexisNexis Ri (29:28):
That was an example in Hong Kong.
Is that, then, a focus forUnited for wildlife and some of
these task forces is engagingwith, with governmental bodies
and regulators around the worldto, I guess, make the link
between wildlife trafficking andmoney laundering?
Because I think for many of ourlisteners, and myself included,
prior to embarking on thispartnership with United for

(29:51):
Wildlife, I hadn't quite madethe correlation between illegal
wildlife trafficking and moneylaundering, whereas now, a year,
two years down the line, Iunderstand that they're they're
they're inextricably linkedbetween each other, right?

Rob Campbell - United for (30:06):
Yeah , I think like any you know
serious crime, you know whereproceeds, you know in the
billions there are perpetratorswho are making millions, and so
you know these people areprotecting their assets and
their, their structures and andtheir way of life, unfortunately
, and so we need to, we need tomove.

(30:27):
You know what's the one thingthat you know people want it.
We're not.
Wildlife trafficking is aboutmoney.
It it's not really about theanimals.
That's the issue is is theanimal is just a commodity, much
like drugs or or or weapons orsomething it's.
It's the people do it becauseof the money.
So, if I think what United forWildlife is doing is, as I say,

(30:49):
it's a two-pronged approach, onewhere we're trying to create
the operational capability to tocarry out financial
investigation and and recognizesuspicious activity, but also
we're trying to develop thelegislation.
And we're not the only one.
There's countless partners WWF,traffic, WCS, all the wildlife

(31:09):
organizations.
But with those two things we'resqueezing the ability for the
traffickers to maneuver in thespace and I think we are seeing
results.
But the key thing to recognizeis that this is all about money.
So if we go after the moneyrather than the commodity and
the product, then you know we'regoing after what the trafficker

(31:30):
is truly trying to achieve orthe network is trying to achieve
.
There's also an element ofprotecting the species on the
ground, which is a slightlyseparate issue, but it's also.

Geraldine Fleming - United (31:40):
It's also really good to see, or
what we're seeing Jonny is - tobuild on what Rob is saying - is
that we are seeing differentregions approaching the
challenges in different ways andwhat we are able to do is to
facilitate the sharing of thatbest practice, exactly like Hong

(32:03):
Kong have added, you know, putpressure on to adjust the legal
framework.
In South Africa, we've seenchanges in legal approaches in
terms of enabling informationsharing acts regarding public
private partnerships, and we'restarting to see, for example,

(32:25):
there's an agreement between theSouth African and US Treasuries
to collaborate to look at casestudies particular to the
illegal wildlife trade and andunpack them on both sides of the
different continents and, andfrom there even taking it
further, United for Wildlife hasbeen building on what they call

(32:47):
a statement of principles, byactually encouraging different
countries to sign up, to committo prioritizing the illegal
wildlife trade as a moneylaundering risk and to take
action and steps to actuallyaddress that.
So the more that we startseeing the sharing of best
practice.
You know, we're aware of otherorganizations, other big

(33:15):
conservation organizations whohave a focus specifically on
legalities or on particularareas of specialism or expertise
, and by bringing those peopleinto our audiences and entire
network and being able to sharethat best practice and
information much moreeffectively is going to mean

(33:35):
that we're going to have a muchmore impactful approach across
the world.

Jonny Bell - LexisNexis Ri (33:41):
Yeah , absolutely.
And I think the key thing forme that United for Wildlife is
doing I mentioned this earlieris is bringing industries
together to help combat illegalwildlife trade.
When we look at the problem inhand, it's impossible, as with
any other predicate crime thatthat FATF outlines, it's
impossible for us as an industryto combat that crime in

(34:05):
isolation.
There needs to be publicprivate partnerships that have
been set up and needs to becollaboration between
governments and jurisdictionsaround the world.
So I think can completely hatsoff to you guys, at United for
Wildlife, for the progressyou're making and, Geraldine,
you work with, with many of theworld's leading financial

(34:25):
institutions and the employeesthat work within those financial
institutions.
Just just given this, are thereany red flags or risk
indicators that these employeescan look out for to help combat
illegal wildlife trade?

Geraldine Fleming - (34:42):
Absolutely .
I think what we always need toremember is that it always
starts with the usual moneylaundering indicators.

You know (34:50):
round amounts, financial statements not
matching up with bank statements, businesses that have no tax
payments or just very specificexpenses 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 youcan see, because they often

(35:13):
provide absolute lists oftransaction descriptions and
things like that.
But I would encourage them tolook very carefully at high risk
industries and occupations.
For example, the role of casinoscomes up again and again,
particularly in third worldcountries, as an easy way to

(35:35):
launder money.
Attorneys, the role ofattorneys 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, forexample in South Africa, and
they get told where to find thereptiles or succulents and to go

(35:59):
and look at and takephotographs, except they just
kind of take them out instead.
So, and then, of course, mobilephone payments.
The importance of mobile phonesis critical, not just, obviously
, in terms of information thatcan be gleaned or not, in terms
of a particular suspect's phonenumber that might be recorded in

(36:24):
their personal data, but whatmobile numbers are they making
payments to?
And there's been quite a biglearning curve that we've seen
within the financialintelligence units in the banks
in terms of how to request thatinformation and how to provide
that information, becauseobviously that then links to
another person who potentiallybecomes another suspect in the

(36:47):
in the kind of broad picture.
So the key is to understand theindicators and then to overlay
the red flag.
So the fact that somebodywithdrew or made a deposit in a
particular high risk area isnothing in itself.
But if in a high risk area witha high risk industry, with a
high risk occupation, a depositand a round amount that's

(37:10):
different from their salary orexcessive lifestyle spending
could certainly be somethingthat's worth a closer look.
And we saw when I was workingwithin a bank as we did more
work around awareness and whatthose red flags might be.
We started seeing ourtransaction monitoring staff

(37:34):
looking much more closely attransaction descriptions and
actually starting to questionthem.
But all of that came fromactually understanding what the
issues were in the first place.
So there are lots of other redflags that that we could look

at (37:53):
couriers, cash and transit companies.
For example, in abalone, whichis a big issue in Southern
Africa, they see lots of boatpurchases or sales to
restaurants and things like that.
That just don't make sense.

(38:14):
So they're all these differentthings that they look at to see
what they can pick up.
And actually the Vanny Biotechcase, which is, if you go and
look at it, you'll see that thekind of first flag that was
raised was a bank official, Ithink one of the frontline

(38:37):
officials who who looked atparticular deposits in an
environment officials count andit it doesn't quite make sense
and they questioned it and thiswhole massive primate smuggling
cases come out of that.
So sometimes just one personbeing a little bit aware and and
taking that extra step in termsof if you see something, say

(39:01):
something, has made a massiveimpact on on a global smuggling
ring.

Jonny Bell - LexisNexis R (39:08):
Great , thank you.
Many of our listeners will befrom the world of financial
institutions and financialservices, will have listeners
from transport and tradecompanies.
Just just given this, thislistener base, is there any

(39:29):
recommendations to them thatyou'd like to conclude with?

Rob Campbell - United (39:34):
Hopefully it's come across in some of the
examples we've shared.
But but the the importance ofcollaboration in the space I
mean we just touched on thepublic-private partnerships
Absolutely critical.
That's again something fairlynew that's been established.
But I think collaboration andthis sort of power of
partnerships this is a globalissue with touch points, you

(39:55):
know, all around the world.
I think if your readership areinterested and, you know, have
some sort of desire to learnmore and have more position on
how to, you know, detect, how toreport and who to report to
then reach out to us.
I think involvement in some ofthese regional chapters is a is

(40:15):
a simple addition they can makewhich 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 resourcethat we we hand out.
What we want is to developthese networks, for people to
come in and be better atresponding.
So yeah, my sort of would be toreach out to United World like,

(40:38):
get involved if you seeyourself along this touch point
and, again, an understanding ofwhat's happening.
You know, receive our freeintelligence bulletins that go
out on specific cases with redflags and learnings and things
like that, and come into anetwork which Can provide
resources, tools and things thatalready are available, you know

(41:01):
, ready off the shelf solutionsand training and see what you
think.

Jonny Bell - LexisNexis Ris (41:09):
And and for those listeners
interested, we we can find thatat www.
unitedforwildlife.
org.

Geraldine Fleming - United (41:16):
What I would encourage people to do,
particularly in the financialindustry, is to just appreciate
the power of the financialsystem to make a positive impact
on reducing the illegalwildlife trade and, as Rob said,
to educate yourselves.
The biggest key is ensuring thatyou are informed and understand

(41:39):
what wildlife, illegal wildlifetransactions, might look like.
There are numerous reports nowthat have come out specifically
looking at Red flags and highrisk indicators for money

laundering (41:53):
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 ofinformation out there available
specific to the financial sectorand and I would encourage them

(42:13):
to go and find those reports andjust read and just be that
little bit more aware and, asRob said, sign up to the United
for Wildlife Financial TaskForce so that you can get the
bulletins and alerts that keepyou up to date much more, much
more quickly.
So by doing that it'll justmake you more aware and once

(42:34):
you're away, then you you getmuch more effective in what you
do.
So go out and learn.

Jonny Bell - LexisNex (42:41):
Brilliant , thank you, so we'll be posting
all of the respective websitesand links and how you can help
out or get any more insight inthe show notes.
But with that I will concludeand say a big thank you to Rob
and Geraldine.

Rob Campbell - United fo (42:59):
Thanks , Jonny, and thanks to your team
, look forward to collaboratingin the future.

Jonny Bell - LexisNexis Ris (43:05):
And to our listeners.
Thank you for tuning into thisepisode of the RegTech Pulse.
Our new report written inconjunction with United for
Wildlife, Combating wildlifetrafficking with the power of
collaboration is now live.
Check out the show notes todownload your copy and to learn
more about the work of Unitedfor Wildlife and the Royal
Foundation.