Disrupting Illegal Wildlife Trade: Have We Followed the Money?

As global leaders gathered for the first London Conference on Illegal Wildlife Trade (IWT) back in 2014, ambition was running high. The first high-level meeting of its kind saw a set of powerful commitments from delegates ‘to act together to bring . . . [IWT] to an end’. Associated money laundering featured – but only in passing. At the time, policy and practical action to apply ‘follow the money’ principles to these crimes were in their infancy, with the power of financial tools to target IWT yet to be fully recognised.

From around this time, the authors’ and other early research across East and Southern Africa highlighted the significant potential of parallel financial investigation to help law enforcement move beyond charging low-level poachers with possession to target higher-level criminal actors. These actors, a decade back, could rest easy in the knowledge that few attempts would be made to trace the money trail leading directly to them. The private sector, for its part, remained largely unaware of the risks and financial characteristics of this criminal activity. But all this was about to change.

Enter the Financial Action Task Force

In 2020, in a prominent development, the Financial Action Task Force (FATF), the global anti-money laundering standard-setter, placed IWT firmly on its agenda. It did so by releasing a landmark report on IWT, referencing the billions in criminal proceeds generated.

For the first time, it called on countries to act – by considering their exposure to IWT-linked illicit finance as part of the recently introduced national risk assessment process, ensuring the necessary legal powers to bring financial charges, and undertaking parallel financial investigations in IWT cases. The FATF subsequently widened its lens to broader environmental crime – particularly illegal activity linked to forestry, mining and waste – calling on countries to address risks of criminals misusing their domestic financial and non-financial sectors to hide the relevant proceeds.

These initiatives have been backed in other fora. Under the UK’s 2021 G7 presidency, Leaders and Interior Ministers committed to ‘tackle illicit threats to nature . . . as serious organised crimes, including intensifying efforts to combat money laundering of the criminal proceeds.’ The same year, G20 leaders called on countries ‘to fight money laundering from environmental crime’ in line with FATF guidance. In 2022, the latter welcomed FATF efforts to promote implementation of international standards on virtual assets and transparency of beneficial ownership, recognising their role in the fight against environmental crime.

In the case of IWT specifically, a plethora of initiatives have risen up alongside this. Much work has been done to develop IWT finance typologies and build capacity to follow financial leads across the supply chain. With the establishment of the IWT Financial Taskforce in 2018, major players across the banking sector also committed to implement measures to improve identification and reporting of suspicious activity linked to IWT. These efforts have been sustained over the intervening years in a concerted push to ensure this predicate offence is taken seriously and support progress on the FATF’s agenda.

Answering the Call to Arms

Five years since the FATF’s call to arms, there is no doubting that all involved in responding to the financial dimension of IWT have invested considerable time and resources. They have certainly succeeded in raising the profile of the agenda at a range of levels. What is less clear is what has been achieved on the ground and what benefits have accrued where. A dedicated review of the overarching results of over half a decade of stepped-up action is needed, to understand what is working and what is not.

There is much that is positive. As an initial step, many countries have answered the FATF’s call to include an assessment of IWT in their National Risk Assessments. This provides an important baseline from which to act.

Valuable capacity building work has been provided to law enforcement and financial intelligence units (FIUs), with inputs from experts across the counter-trafficking community. Alongside this, awareness within financial institutions has been significantly raised – a positive development compared to a decade back, when a bank would have been unlikely to be on the lookout for financial activity linked to IWT. The Financial Transactions and Reports Analysis Centre of Canada, for example, has reported an increased volume of suspicious activity reporting linked to IWT, leading to disclosures of actionable intelligence to law enforcement and FIUs internationally.

Yet weaknesses remain that have affected the impact of this activity. At times, a nuanced articulation of the threat by national authorities remains lacking, despite the ramped-up focus on the issue. Notably, gaps have characterised affected countries’ responses to FATF guidance, with mapping of the financial dimension of IWT – and wider environmental crime – in many National Risk Assessments still superficial at best.

This situation impedes affected countries’ ability to adopt the risk-based approach that is the centrepiece of the FATF’s approach to responding to financial crime. National Risk Assessments are designed to inform all aspects of a country’s efforts to combat financial crime, including legislation, supervisory priorities and resourcing. Where the contents are under-developed, efforts to mitigate risks are skewed, impeding effective prioritisation and leading, ultimately, to gaps in practical action.

In some countries, significant investment and effort has nonetheless gone into parallel financial investigations. This has translated into operational results in some cases. These experiences are all the more important when considering what is required to follow the money in complex, transnational IWT cases – bridging multiple jurisdictions, involving multiple agencies and faced with systemic corruption.

In Malawi, for example, the conviction of 11 members of the Lin-Zhang wildlife trafficking network saw substantial jail sentences for money laundering for key members. The use of financial investigation tools in this case has been hailed as a ‘milestone in Malawi’s fight against wildlife trafficking’; this remains the case despite the recent presidential pardon of convicted network members. Neighbouring Zambia, meanwhile, has seen strong momentum in targeting relevant assets, as shown in the forfeiture in September 2025 of more than $1 million in assets linked to illegal logging networks.

In South Africa, financial investigation tools were key to the results achieved under Project Blood Orange. This was an intensive multi-year operation led by the South African Police Service, involving a multi-disciplinary team of South African law enforcement agencies, KPMG South Africa and NGO Save the Rhino. In 2025, the investigation saw Congolese national Francis Kipampa sentenced to 18 years for money laundering offences linked to rhino poaching, among other offences.

Zooming out, however, the question is whether we are seeing such results with the frequency required – applied incisively against the more powerful actors across the range of at-risk geographies. A further question is how often and how broadly financial investigations have fed into enduring criminal justice outcomes with deterrent impact.

Indeed, it is not always clear how far levels of IWT activity have been impacted by stepped-up action in this space. While the South African Anti-Money Laundering Integrated Task Force has attributed to Project Blood Orange a drop in rhino poaching in Kruger National Park of 40% in 2022 and 49% in the first half of 2023, and deterrent impact has been shown in Malawi, few such analyses exist elsewhere. Similarly, little clarity exists on how far – if at all – efforts to follow the money have impacted existing patterns of money laundering activity linked to IWT.

The authors argue that more focused, clear-eyed reflection on these gaps is now due. At times, there has been a tendency to celebrate the very involvement of the FATF with IWT – with limited effort to engage with the outcomes of this activity in practice.

Other side-effects have occurred. Notably, the rapid elevation of the profile of the issue has at times appeared to have become disconnected from the ultimate goal of action in this area, with many – primarily from the private sector – spending more time publicly promoting their credentials in this space. At times, all this has risked drowning out the core mission – that of supporting grassroots financial investigations with deterrent impact.

To be sure, private-sector input and information is vital. Yet it is just one ingredient in this larger mission. And while capacity and awareness may have increased at this level, the enduring situation in many contexts is one of a lack of public sector capacity and domestic political will to develop financial intelligence on IWT and follow the financial footprints of offenders. While this situation persists, the potential of financial approaches to IWT remains unfulfilled.

What Comes Next?

There is no doubting the effort that has gone into responding to the financial challenge posed by IWT. This activity now needs to be recalibrated and targeted in a manner that engages more directly with on-the-ground realities, beyond high-level corporate statements. To do this, action needs to be taken in several areas.

Notably, the next generation of national risk assessments needs to dive deeper into the detail of IWT, to genuinely understand how associated illicit finance operates, moving beyond superficial observations. Affected countries should now be producing detailed analyses of the financial dimension of the IWT threats facing them, accompanied by targeted action plans – with external support provided as required. In addition, enforcement actors responsible for investigating IWT need to be held accountable for developing and sharing financial intelligence on high-value cases.

In parallel, the nature of FATF and other forms of international engagement should be reviewed. While the call to conduct parallel financial investigations provides valuable impetus, the response cannot be solely linked to FATF evaluations as these occur infrequently. Such activity needs to be a constant, with other international bodies considering how they might support this in a more systematic way as part of their engagement with countries on related issues.

Alongside this, the private sector needs to ensure that it is maximising the value it can add in the fight against the financial dimensions of IWT. In 2025, this should involve reflection on the role it has played to date. This is not to look to dim the commitment of the private sector – which is essential. Rather, it is to pose a set of questions to allow private-sector actors – via independent assessment – to check and demonstrate that they are contributing in practice to the disruption of finance related to IWT.

Such questions revolve around the metrics used to judge key initiatives, and the tools used by private-sector actors continuously evaluate and refine their operations in identifying suspicious activity related to IWT. Lessons and best practice should be shared openly across these areas, with attention focused here, over more promotional campaigns.

Finally, greater attention should be paid to parts of the process of using financial intelligence that may have received less focus. Key public-sector actors need greater support to use the financial investigation tools at their disposal – and to overcome spoilers to successful outcomes. Relevant partnership models exist that can be built on, with investment in research and evaluation needed to identify and share best practice. Meanwhile, donor countries should apply the same standards across domestic efforts to counter IWT-related illicit finance as they promote elsewhere.

The vision articulated in the years since 2014, echoed by the FATF, the G7 and many other bodies, remains as relevant today as ever. The commitment of those fighting IWT across the globe is undimmed. But over the years, the mission has risked losing direction – and losing sight of what it will take to truly make a difference in the financial fight against IWT. This must now change.

© RUSI, 2025.

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