Part 2: Illegality in the exotic pet trade

1. Trafficked live wild animals make up a large proportion of the international illegal wildlife trade.
2. Impacts of the illegal pet trade include biodiversity loss, habitat destruction, invasive species risks, increased pandemic disease risk and large-scale animal suffering.
3. Demand is greatest for rare animals and is often driven by "cuteness", the film industry, social media fads, addiction or prestige. Online platforms greatly facilitate the illegal pet trade.
4. Once procured, live wild animals are either laundered into a captive breeding or other live animal-based business, sold locally, smuggled out of the country or mislabelled as captive bred and “legally” exported.
5. Criminals working in legal animal-based businesses, as well as corrupt officials, play a key role in obtaining and clearing falsified or otherwise fraudulent paperwork for live animal traffickers, and in helping traffickers to avoid the consequences when detected.
6. As with some other commodities, the main proof of wildlife legality relies on a system of permits and paperwork. Fraudulent paperwork can transform wildlife contraband into seemingly legitimate merchandise, enabling it to be openly traded and evade interdiction.
7. Once traffickers move wildlife outside of the source jurisdiction it can be freely traded internationally, even when the collection and smuggling of these species is prohibited at the source.
8. Captive breeding and wild animal farming facilities, along with trade shows, create significant ambiguity about the legality of animal exports and create opportunities for "laundering" wildlife into legal markets.
9. Enforcing regulations pertaining to captive-bred versus wild-caught specimens remains a substantial challenge for enforcement officials.
10. Australia is a major hub for the illegal pet trade, in particular for reptiles destined for markets in the EU, China and Japan. The US is another high-volume consumer of the pet trade.

Large numbers of wild animals across the globe are captured, transported and sold to serve the international pet trade. Illegal activity takes place at multiple points along the supply chain, allowing illegally sourced animals to enter legal markets.

While it is unknown what percentage of animals in the pet trade are trafficked, the overall number of wild animals sold each year in domestic and international markets is staggering. For example:

• Within Brazil, 38 million birds are caught and sold illegally every year (Ortiz-von Halle, 2019)
• Togo, Benin and Ghana export 100,000 ball pythons each year (World Animal Protection, 2020)
• Every year, Central and East Java export more than one million tokay geckos (Nijman, 2012)
• As many as 400,000 Asiatic softshell turtles are trafficked from Sumatra (Nijman, 2012)
• Millions of salt-water aquarium fish, almost entirely wild caught, are imported into the EU each year with few checks on their legality (Earth Journalism Network, 2020).

Individual cases of live animal trafficking can involve large numbers of animals across several species. To take just one example, an Australian man was arrested in May 2019 and charged with 169 counts of animal abuse and trafficking. Among the animals he poached and trafficked to China by mail were crocodiles, lizards, snakes and turtles. He had already been implicated in a 2017 seizure of 147 reptiles of various species.

Habitats, species and individual animals suffer as a result of over-exploitation for the pet trade. The illegal pet trade is a serious driver of biodiversity loss, including as a result of the introduction of invasive species. Illegal harvest can deplete populations to the point of extinction, especially for endemic populations.

For each wild pet sold, as many as 50 other animals may die during capture, transport and sale. At least 60–70 percent of wild animals are estimated to die within their first six weeks in captivity as a pet.

Animals kept as wild pets commonly suffer “as a result of an unsuitable environment, malnutrition, inadequate or inappropriate social contact, and the stress of confinement… and many are neglected or abandoned” (ENDCAP, 2012).

Moreover, the risk of zoonotic spillover is high, as wild pets can carry pathogens infectious to humans as well as domestic pets, livestock and indigenous wildlife. Diseases that may be transferred from wild animals to humans via the illegal pet trade include avian influenza, salmonellosis, hepatitis A, tuberculosis, monkey pox, herpesvirus simiae-B, and various coronaviruses (Charity & Machado Ferreira, 2020).

Just because a certain trade in wildlife might be legal, this does not necessarily mean that across its supply chain the goods are:

• Effectively regulated 
• Sustainable
• Ethical
• Legally sourced/harvested
• Compliant with CITES Decisions and Resolutions
• Not associated with illegality

Demand for exotic pets has exploded globally, with demand the greatest for animals that are rare in the wild or within the pet market (Auliya, 2016).

In countries with strong bird ownership traditions, collectors may seek out birds for their songs, as good luck charms or for their plumage. Live animal collectors can also become addicted to purchasing wildlife and handling animals and animal parts (Sollund, 2016).

Animal videos shared on social media and online platforms featuring “cute” animals drive demand and normalise treating wild animals as pets. In many cases, collectors seek out wild animals simply in response to fads, without regard for their conservation status or the legality of the trade (Chng & Eaton, 2016).

Recent seizures and media reports also indicate the desire of high-level politicians and personalities in the Middle East, Asia and North America to own exotic pets. These cover a wide array of species, from big cats to apes and lizards.

Japan’s pet market, growing for the past three decades, is driving the illegal import of a wide variety of species from across Asia. This threatens species with extinction and increases the risks of zoonotic disease spread. A major driver of pet trafficking in Japan relates to kawaii (かわいい), or “cuteness”. Animals considered cute, such as slow loris, owls and otters, are often found in animal-themed cafes and pet stores, and also feature prominently in the illegal wildlife trade.

Another popular trend in Japan is the collection of reptiles, amphibians and insects. This relates more to the status associated with purchasing and owning rare and expensive wildlife.

Red flags include:

• Repeat offenders: Traffickers exploit gaps in the Japanese legal system (which generally lacks protections for most non-native species) to launder illegally trafficked species into legal pet markets. When caught, traffickers face light penalties, including little or no prison time. Re-offending is common.
• Non-native species sales: Pet stores, animal-themed cafés, online dealers, and individual sellers advertising CITES-listed species for sale or for animal experiences may be involved in laundering trafficked species.

For a detailed overview, see Kitade & Naruse (2020).

Much of the transnational pet trade is coordinated online, particularly at the retail end. This provides multiple opportunities to launder illegally procured or trafficked pets into the legal trade. Through trading platforms, online shops and social media sites, traffickers and consumers easily find one another and arrange transactions.

Online sales platforms often have not established or do not enforce wildlife trade policies and rarely provide clear information on relevant legislation and/or policies regarding trade in wildlife and/or live animals, including for CITES-listed species (UNODC, 2020). The lack of controls, regulations or oversight allow traders formerly convicted of illegally selling wildlife to openly sell wildlife online (Crook & Van der Henst, 2020).

For more information on this aspect of the illegal pet trade, see the Coalition to End Wildlife Trafficking Online. The multi-stakeholder collaboration brings together tech companies across the world with WWF, TRAFFIC and the International Fund for Animal Welfare (IFAW) with the aim of preventing online trafficking of wildlife.

Pet trafficking involves criminal activity across the supply chain, including during the harvest, breeding, transport, marketing and retail sale of wildlife.

The legal and illegal trade in exotic pets are closely intertwined, introducing legal, reputational and financial risks for animal-based businesses, financial and transport firms. Criminals acting in both the legal and illegal spheres, along with corrupt officials, play a key role in laundering pets into the legal trade (Outhwaite, 2020).

The following infographic gives a simplified overview of how the legal and illegal supply chains of live pets can intertwine:

The following section describes the illegality and intermingling of supply chains in more detail.

In source locations, illegality in the capture phase involves:

After export – whether via smuggling or as part of a “legal” shipment – trafficked pets can often be openly sold. Repeat offenders are prevalent at every stage of the live wild animal trafficking supply chain (Crook & Van der Henst, 2020 ). Criminals working in legitimate animal-based businesses facilitate the transnational sale of live wild animals for the pet trade (and to supply zoos and aquariums) by committing document fraud, among other crimes. This includes for CITES-protected species (ENDCAP, 2012).

• Documents modified after issue: Information is altered to allow trade that has not been authorised.
• Unofficial payment for documents: Exporters pay more than the official price to guarantee obtaining a permit or to obtain it faster.
• Counterfeit documents: Fake permits, sometimes of very high quality, are used fraudulently to trade specimens.
• Re-using or photocopying documents: The same permit is used multiple times or duplicated.
• Expired documents: Permits are used beyond the date of expiry.
• Stolen documents: Stolen permits can be used to trade CITES-listed wildlife. Permits may be declared as lost, damaged or stolen, and the replacements used to trade wildlife. Government employees may even steal or falsely declare permits to be lost, then use or sell them.
• Mislabelling shipments: This happens in terms of both the species and the number of animals or animal parts. CITES Appendix I species that look similar to those which receive fewer protections are particularly vulnerable, as are wild-caught species certified as captive bred.

Illegalities upon imports include importing animals with falsified CITES certificates or lacking the required CITES documents entirely, and importing and trading Appendix I species for commercial purposes.

Most countries do not provide legal protections for non-native species, including CITES protected species (Chng & Eaton, 2016). Once species are trafficked into the international market they can often be freely traded online, in retail shops and through trade shows, even when sourced illegally (Hruby, 2019). Traffickers may even target species that are not protected by CITES to take advantage of loopholes in protection, and for the opportunity to work in the “legal” realm (Auliya, 2016).

Red flags associated specifically with CITES Appendix I exports are:

• CITES import permits issued after or on the same date as a CITES export permit.
• CITES import permits not signed or dated.
• CITES permits not endorsed/cleared/stamped at ports of export.
• CITES permits issued for a specific number or type of animals in the shipment does not match the number or type within the shipment.
• Documents lack the ages of exported animals.
• Exporting facilities listed are not registered with CITES.
• Exporting facilities are exporting animals they are not registered to breed or trade.

Trade fairs for the sale of live animals serve to popularise and legitimise the purchase of live wild animals. They also provide a convenient cover for wildlife traffickers to expand their client base among unscrupulous animal collectors.

An example is the Terraristika Reptile Fair in Hamm, Germany, one of the largest trade shows in Europe. It is considered a magnet for wildlife criminals, where collectors, smugglers and traffickers meet to buy and sell protected and trafficked species (Hruby, 2019).

Individuals accused of past involvement in wildlife crime regularly take part in animal sales at Hamm. Repeat offenders may prefer to meet clients online and arrange for the transfer of species in nearby hotels and parking lots to avoid any scrutiny in the fair.

The most expensive animals for sale at Hamm are CITES-protected species that cannot be exported for commercial trade.

Despite the high risk of trafficking involved in the import and sales of such species, sellers only need to provide a self-generated “proof of origin” letter to document the sale and certify that the specimen was bred in captivity. This is easily manipulated to conceal wildlife trafficking.

Photo: Chameleon in the forests of Lushoto, Tanzania. Chameleons and other reptiles are threatened by the pet trade. Photo by Patricia Raxter.

While most captive breeding and wild animal farming businesses obey laws, rules and regulations regarding the breeding and sale of wildlife, some provide opportunities for traffickers to launder wildlife into the legal trade. Laundering through captive breeding facilities occurs in a number of ways. Captive breeders have been known to:

• falsify or forge authorisations and certificates;
• tamper with identification mechanisms;
• make false declarations;
• mix wild-caught and captive-bred species within shipments;
• illegally procure wild animals to boost the genetic diversity of stocks, including egg stealing and baby animal smuggling (Charity & Machado Ferreira, 2020).

Because they operate in the open and typically hold some sort of government or industry issued license, permit or accreditation, evidence of their “legality” provides cover for illegality (World Animal Protection, 2020).

Brazilian dyeing poison frog ‘morphs’, found only in Brazil, are targeted by cross-border poaching networks in Suriname, trafficked to Europe, and then laundered through captive breeding facilities for “legal” sale within the EU.

Red flags include:

• Captive breeding of high-value, non-native species: Additional scrutiny should be applied to any captive facility engaged in the breeding and sale of high-value species. CITES Appendix I species bred in captivity and their offspring can be sold under CITES Appendix II permits. This loophole allows unscrupulous traders to capture, breed and sell CITES Appendix I protected animals.
• Repeat offenders: Wildlife traffickers regularly re-engage in the trade even after being caught multiple times. When breeding facilities are owned by or employ individuals accused of past involvement in IWT, extra scrutiny should be applied.

Breeding facilities can also “ranch” wild animals. This involves hunters capturing pregnant females, eggs or juveniles and transferring them to facilities for rearing. It may involve:

• illegal capture of animals;
• over-harvest of animals where quotas exist;
• hunting in protected areas;
• targeting of all species, not just pregnant females or eggs (Van Uhm, 2018; UNODC, 2020).

Species are often mislabelled as ranched when they are actually captured in the wild as adults, and sold under mislabelled documents.

In many cases it is easier and cheaper to launder wild-caught animals than to rear or breed them, such as in the case of cheetahs. It is particularly easy when wild animals of the same species are abundant, and chances of being caught engaged in illegal activity are slim. The practice of wildlife breeding, farming or ranching may actually increase pressure on wild-caught species because of the ease of laundering wild species through the system (Van Uhm, 2018).

Wildlife seizures typically occur during customs checks at international borders, but significant impediments hamper efforts to disrupt IWT. In too many cases, customs officers may believe that seizing wildlife is a burden and the crime will not be taken seriously. Challenges include:

• Difficulty for customs officers to determine species or their body parts.
• Confusion over who to report instances of wildlife crime to.
• Identifying the difference between real, faked or illegally altered CITES certificates.
• Corruption.
• Inadequate checking of paperwork as animal welfare considerations often make thorough checks unfeasible.
• Scarce resources and knowledge of officers tasked with enforcing wildlife crime legislation at points of entry.
• Low reporting of offences due to a lack of follow-up or penalties for offenders.
• Lack of information on the scope and scale of the trade domestically or internationally, making it difficult for officials to take crime seriously.

Proactive efforts by the private sector to prevent illegally trafficked animals from entering transport chains are essential to supplement the work of customs agencies and law enforcement (Wannenwetsch & Guy, 2020). Among those leading these efforts is the United for Wildlife Transport Taskforce and the ROUTES Partnership.

Australia is both a source and destination country for illegal wildlife trade, particularly the trade in live animals to be used as pets. High demand from reptile and pet collectors in Europe and North America, and increasing demand in China, Japan and other Asian countries, is intensifying pressure on Australian wildlife. Over 80 percent of Australian flora and fauna are endemic (Alacs, 2008).

Wildlife seizures have been increasing in Australia, with lizards, snakes and other reptiles making up the majority of animals seized alive (Wyatt, 2013)

Within Australia, a multitude of actors engage in wildlife trafficking. This includes criminals acting undercover in the legal wildlife industry, opportunists and overseas syndicates, some acting alone or in small semi-organised groups.

The specificity and variety of wildlife involved in seizures suggests that wildlife is illegally procured by specialist hunters to fulfil specific orders from local collectors, dealers and overseas syndicates. Unscrupulous licensed wildlife breeders launder wild-caught animals though their facilities and illegally export “designer breeds”, including morphs of common species.

International syndicates likely interact with urban dealers who direct poaching activities and coordinate with unscrupulous breeders, consolidating wildlife for packaging and onward shipment via mail or air passenger luggage.

Australia’s largest seizure of illegal wildlife occurred in April 2018 and included 198 reptiles, 58 venomous snakes, 16 marsupials, two spiders and three cockroaches across various species. This illustrates the breadth of wildlife targeted by traffickers.

Traffickers receive payments for wildlife with transactions in the thousands of dollars either via wire or through bank transfers, and in some cases barter Australian species for other exotic species. The criminals hide money in overseas accounts and launder illicit proceeds through front companies. As in wildlife crime more generally, repeat offenders are common, even after multiple convictions.

Within Australia, the Department of Sustainability, Environment, Water, Population and Communities oversees the CITES permit system. All import and export of wild animals is prohibited without a licence, and a permit system is in place for captive breeding and native flora collecting and growing (Wyatt, 2013). In addition, states and territories have their own system of licensing, enforcement and sentencing of offences.

While strong laws exist, in practice custodial sentences have typically been rare and fines are often less than the value of wildlife seized (Wyatt, 2013; Alacs, 2008). Wildlife traffickers take advantage of varying legislation and lack of enforcement to get away with smuggling wild animals.

According to multiple studies, wildlife crime in Australia remains a low priority, typically perceived as related to individual transgressions, not as an organised crime.

The following infographic offers a simplified view of the pet trafficking chain between Australia and Asia.

Syndicates recruit couriers to smuggle wildlife in air passenger luggage and use mail services to directly ship wildlife to destination points soon after capture. Traffickers may use addresses at hotels to avoid having wildlife sent to their homes. When trading wildlife as “legal” goods, traffickers falsify documentation to facilitate import and export of wildlife. Unsurprisingly, most wildlife seizures occur at airports and mail centres and during raids (Wyatt, 2013).

Smugglers disguise live animal shipments in electronics including speakers, deep fryers and rice cookers. Animals may be hidden inside children’s toys, potato chip tubes, powdered drink tins or plastic boxes. They have also been found in socks inside suitcases, in coffee mugs or rolled up in towels or other clothes. Animals are often taped or bound to restrict movement, and can be wrapped in aluminium foil or plastic wrap to evade scanning equipment.

Live animals can also be sent by mail. For example, a smuggler was arrested in September 2018 for attempting to smuggle live native lizards out of Australia to Hong Kong. Eleven parcels containing lizards were found at various Australian Post outlets between August and September 2018.

Australian wildlife can increase in value exponentially once exported. For example, shingle back lizards purchased locally for AUD 100 can be sold for AUD 5,000 in Asia, and when paired can fetch AUD 20,000.

Alongside growing markets in China and Japan, the EU is a primary market for wildlife smuggled out of Australia (Crook & Van der Henst, 2020). Loopholes in EU legislation facilitate species laundering and enable green-collared crime (ENDCAP, 2012; Musing, 2020):

• Species not native to the EU or listed by CITES can be freely traded within the EU, even if they are threatened or strictly protected in their native range.
• Animals identified as captive bred, even those listed under Appendix I (or A for EU legislation), can also be freely traded within the EU.
• Some of the most expensive animals traded in Europe are protected by national laws in their country of origin but have no legal protection in the EU. The rarity of these species outside of their homelands drives up prices, while the absence of penalties for selling them creates a cover of legality (Auliya, 2016).

Other law enforcement challenges include varying and weak laws across member states, lack of knowledge on wildlife trafficking amongst law enforcement, prosecutors and the judiciary, the low priority afforded to wildlife crime, and a lack of cooperation amongst law enforcement agencies (Sina et al, 2016).

Once again, the message for private firms and financial institutions is that relying on the criminal justice system alone is not enough to tackle the illegal pet trade.

• Part 1: Illegal wildlife trade and financial crime
• Part 3: Forest crime and the illegal timber trade
• Part 4: Corruption in marine wildlife trafficking

A free introductory online training programme (two hours) on how to identify and mitigate financial risks related to illegal wildlife trade in general. Co-developed by ACAMS (the largest international membership organisation for anti-financial crime professionals) and WWF with Basel Institute on Governance support. Go to course.

An introductory course to wildlife crime designed for Financial Intelligence Unit staff, law enforcement and supervisory authorities. Go to course.

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Auliya, M. et al. 2016. ‘Trade in live reptiles, its impact on wild populations, and the role of the European market’. Biological Conservation 204(A), 103-119, https://doi.org/10.1016/j.biocon.2016.05.017

Charity, S. and Machado Ferreira, J. (2020.) Wildlife Trafficking in Brazil. TRAFFIC

Chng, S. and Eaton, J. 2016. In the Market for Extinction: Eastern and Central Java. TRAFFIC

Crook, V. and Van der Henst, E. 2020. Stop Wildlife Cybercrime in the EU – Online Trade in Reptiles and Birds in Belgium and the Netherlands. TRAFFIC

Earth Journalism Network. 2020. Investigating the murky trade in aquarium fish and coral.

ENDCAP. 2012. Wild pets in the European Union

Hall, J. 2019. ‘Exotic pet trade’, explained. National Geographic

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Kitade, T. and Naruse. Y. 2020. Crossing the Red Line: Japan's exotic pet trade. TRAFFIC

Musing, L. 2020. Falling through the system: The role of the European Union captive tiger population in the trade in tigers. A TRAFFIC and WWF report.

Nijman, V., Shepherd, C., Mumpuni and Sanders, K. 2012. ‘Over-exploitation and illegal trade of reptile in Indonesia’. Herpetological Journal 22(2):83-89.

Ortiz-von Halle, B. 2019. Bird’s-eye view: Lessons from 50 years of bird trade regulation & conservation in Amazon countries. TRAFFIC

Outhwaite, W. 2020. Addressing corruption in CITES documentation processes. Targeting Natural Resource Corruption

Sina, S. et al. 2016. Wildlife Crime. Study commissioned by the European Parliament. European Union

Sollund, R. 2016. 'Wildlife Trafficking in a Globalized World: An Example of Motivations and Modus Operandi from a Norwegian Case Study'. In: Anegelici , F. (ed.) Problematic Wildlife: A Cross-Disciplinary Approach. Springer

UNODC. 2020. World Wildlife Crime Report 2020: Trafficking in Protected Species .

Van Uhm, D. 2018. ‘Wildlife and laundering: interaction between the under and upper world’. In: Spapens, T., White, R., van Uhm, D. and Huisman, W. (eds.) Green Crimes and Dirty Money. Routledge

Wannenwetsch, S., and Guy, M. 2020. Collective Action against illegal wildlife trade: Engaging freight forwarders and logistics providers . Basel Institute on Governance.

World Animal Protection. 2020. Suffering in silence: Uncovering the cruelty of the global trade in Ball pythons .

Wyatt, T. 2013. A comparative analysis of wildlife trafficking in Australia, New Zealand and the United Kingdom. TEC Working Paper 6/2013, Australian National University.