This is a flexible and practical learning resource developed by the Green Corruption programme at the Basel Institute on Governance. It is aimed at:
Private-sector companies exposed to risks of illegal wildlife trade and related crimes, including financial institutions, transport companies, traders and wholesale retailers
Practitioners in both conservation and anti-corruption fields
The aim is to broaden understanding of the threats that wildlife crimes pose to sustainable development and clean business. It provides relevant information, statistics and background knowledge to help enhance policies and processes aimed at curbing wildlife crime and associated risks. The focus is on financial crimes and supply chain vulnerabilities that facilitate the illegal trade in wildlife and thereby increase companies’ legal, financial and reputational risks.
This learning resource and many more are available as interactive learning tools on the Basel Institute’s LEARN platform as well as in PDF format.
The Green Corruption programme at the Basel Institute on Governance applies anti-corruption and governance tools to address environmental crime and degradation.
have made reasonable efforts to verify the information in this publication, we cannot
take responsibility for its accuracy or reliability or for decisions taken by
readers as a a result. We would be grateful for any corrections, suggestions
and other feedback via our Green Corruption team, Twitter or LinkedIn.
This publication was funded by PMI IMPACT, a grant award initiative of Philip Morris International (PMI). In the performance of their research, the authors maintained full independence from PMI. The views and opinions expressed in this document are those of the authors and do not necessarily reflect the views of PMI. Neither PMI, nor any of its affiliates, nor any person acting on their behalf may be held responsible for any use which may be made of the information contained herein.
The work is licensed under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (CC BY-NC-ND 4.0).
It is based on content provided by Patricia Raxter with editing by Monica Guy, infographic creation by Alexander Berman and Shane McLean, and contributions by Manuel Medina, David Ward and Juhani Grossmann.
CITES: Convention on International Trade in Endangered Species
of Wild Fauna and Flora
ESG: Environmental, Social and
FITI : Fisheries Transparency
Unreported and Unregulated (fishing)
NGO: Non-governmental organisation
UN: United Nations
Part 4: Corruption in marine wildlife trafficking
1. At a glance
trafficking includes the illegal collection, transport and sale of a
huge array of marine-dwelling wildlife.
Quantifying the illegal trade in marine species
as a whole is challenging due to the range of species involved and value in
relation to weight and number in the trade.
proceeds from the
marine trade can be significant, attracting organised crime groups and
criminals operating in legal companies and industries.
are in demand globally for food, medicine, as jewellery, decorative objects,
the pet trade, and for zoos and aquariums.
and enforcing regulations to protect marine wildlife from trafficking face numerous challenges,
including poor data, poor traceability, the involvement of serious organised
crime networks and surging demand.
Impacts of marine species trafficking
include severe over-exploitation of marine species, destruction of habitats,
disruption of ecosystems and consequences for communities dependent upon
fishing for livelihoods and protein.
A host of criminality
pervades marine species supply chains. Key risks include smuggling,
document fraud, tax evasion, bribery, money laundering, forced labour and other
human rights abuses. The trade often converges with drug and human smuggling.
crime groups and legitimate individuals and businesses, sometimes in collusion, operate at
every level of the supply chain, undermining efforts to trace, regulate or
control the trade.
Where parallel legal and illegal trades exist,
products can be quickly laundered into the legal supply chain.
2. Introduction to trafficking in marine species
trafficking covers a range of illegal activities around the collection,
transport and sale of protected marine-dwelling wildlife. Similarly to illegal
wildlife trade generally, it takes place in contravention of national laws and
particularly laws under the Convention on International Trade in Endangered
Species of Wild Fauna and Flora (CITES).
trafficked species include: corals, tropical fish, giant clams, seahorses,
shark fins, sea cucumbers, marine turtles, fish swim bladders, eels, baby
lobsters, abalone and caviar.
Marine species are in demand globally for
food, medicine, as jewellery, decorative objects, the pet trade and for zoos
wildlife crime, the legal and illegal trade in marine species are closely
intertwined. Opportunities for laundering illegally collected and transported
species into the legitimate trading sector abound. At the point of consumption,
the true origins of marine products can be difficult, if not impossible, to
increases for marine products, and supply networks stretch across the globe to
meet it, opportunities for illegality to seep into the supply chain will
increase. The high profits and low risk associated with marine trafficking attract
transnational criminal networks and criminals working undercover in legal
companies and industries.
A host of criminality pervades the marine species trade, including smuggling, document fraud, tax evasion, bribery, money
laundering, forced labour and other human rights abuses. The trade converges
with drug and human smuggling.
While this chapter will not address
illegal, unreported, and unregulated (IUU) fishing more broadly, marine
trafficking networks often commit IUU offences and may work in tandem with
fishing fleets regularly accused of IUU practices.
The Netflix documentary Seaspiracy
recently drew international attention to some of the issues involved in IUU
fishing, including highly negative implications for climate change. For more
information about IUU fishing, see resources from the:
Quantifying the illegal trade in marine species as a whole is challenging, yet it is known to occur globally
and to be expanding as demand increases.
Harvest levels are unsustainable.To take just a few examples:
quantities of CITES-protected marine turtles appear to be trafficked to China.
A 2014 seizure in Vietnam involved more than 10 tons of hawksbill turtles,
approximately 7,000 individual turtles.
Seizures of seahorses and other small marine
species can easily reach into the millions of animals, especially when their
weight is reduced through drying. For example, one 3 kg seizure catalogued by
marine conservation group Project Seahorse contained 1,000 seahorses. In
another instance, an air traveller was caught with 20,000 seahorses in his
luggage. Peruvian authorities seized 8 million seahorses from Chinese-flagged
ships in 2016 in a single operation, and another 12.8 million in 2019.
caviar labelled for export as farmed – more than 70 percent – is actually
illegally harvested and processed for export. The result? Large-scale poaching
is driving Beluga sturgeon to
value of 20,000 totoaba swim bladders seized in China in 2019 exceeded USD 110 million.
Marine species are in demand for food, medicine, as jewellery,
decorative objects, the pet trade and for zoos and aquariums.
The following infographic gives a brief overview of the main drivers:
Luxury food. An expansion of the middle class in some countries has
resulted in an increase in demand for exotic foods that may signify economic
prosperity in the local culture. These include shark fin soup and sea cucumbers,
which are eaten both whole and dried. Sea turtles are used both for food and as
decoration, through a process to chemically taxidermy the creatures while they
are still alive. Trafficked eels have been known to find their way into sushi
in North America.
Traditional Chinese medicine may use species such as dried
seahorses for medicine.
Decorative objects. Corals and giant clams are carved into jewellery, used
in decoration or sold live into the aquarium trade.
Pets and aquariums. Hobbyists and professionals create miniature
ecosystems in both home fish tanks and commercial aquariums, populated with
Demand for some species stretches across each of these categories,
stressing populations from multiple angles.
3. Impacts on ecosystems and sustainable development
in marine species imperils endangered marine wildlife and can quickly lead to
the collapse of wildlife stocks. Destructive capture and harvest methods can
contribute to the degradation and destruction of entire ecosystems.
to existing stresses on marine populations from pollution, development and
Over-exploitation consists of exploiting a species beyond biologically
sustainable levels – i.e. fish populations are exploited at a rate much faster
than the rate needed for them to recover.
Sea cucumber traffickers wipe out entire
populations very quickly before moving on to new and more fertile grounds. The totaoba trade has directly led to the near
extinction of vaquita populations in Mexico. All marine turtles are endangered,
and populations of most shark species are declining.
fishing methods are the main drivers not only of over-exploitation but also of
long-term damage to marine ecosystems. These methods, such as trawling and the
use of explosives, which are forbidden in several coastal states, are known to
devastate marine ecosystems beyond their natural recovery point. It is very
important to note that these methods are a flashpoint in terms of social
conflict between local artisanal fishing communities and industrial fishing.
is the use of banned or harmful equipment such as seine nets or destructive
processes like bottom trawling to harvest as many wild species as possible. Ornamental fish and
clam poachers destroy environments to immediately access marine species. For
clam poachers loosen the clams from reefs using boat
propellers. In the process, they destroy the reefs, seriously degrading or
destroying the entire local ecosystem.
Other illegal fishing
methods, such as using dynamite or cyanide to harvest corals and fish, have
Over-exploitation of certain species has significant knock-on effects on
other fish populations. For example the over-exploitation of a predator leads
to an over-population of lesser species, which will in turn cause an imbalance
in marine ecosystems.
Illegal fishing and over-fishing of reef fish have also led to the loss
of corals worldwide, as fish grazers help keep corals healthy.
serious impacts of marine trafficking fall on communities dependent on marine
resources for protein and economic opportunities. These communities suffer from
food insecurity and loss of sustainable livelihoods.
4. Regulatory and enforcement challenges
Major challenges in protecting
marine wildlife include:
A lack of scientific data on non-CITES listed species
Weak or non-existent regulatory regimes in source countries
Expanding sourcing networks
The emergence of serious organised crime within the supply chain
Surging demand for a growing number of species
Lack of enforcement capabilities in coastal states
provides trade protections for some species,
most are not protected at the international level. In many cases, they also
fall outside the law of any country. As a result, much of the trade in coastal
marine species in particular remains unregulated.
For example, sea cucumbers across much of their range and
North American eels receive no protections from trade and are harvested and
shipped to Asia without oversight. Almost all ornamental marine fish are wild caught – only 25 marine
ornamental fish species are captive-bred commercially – and most species in the
trade are not assessed. In addition, insufficient data exists to evaluate
appropriate levels of trade.
The lack of
traceability creates opportunities for illegal activity
throughout the supply chain.
Approximately 37 million individual
seahorses are traded each year, mostly to China via Hong Kong for use in
traditional Chinese medicine. This occurs
despite national and international laws and export bans.
Approximately 95 percent of seahorses are exported from countries with
All seahorses are listed under CITES Appendix II, meaning non-detrimental trade
can in theory continue. However, several countries have banned the trade
outright, while others are under recommendations by CITES to suspend trade.
An important import hub, Hong Kong
does not provide legal protections to seahorses but only
requires an export permit from the country of origin. According to NGO reports,
the authorities rarely examine export permits to determine legality.
As a result of the
huge demand, seahorse traffickers are expanding their geographic scope,
targeting populations in Europe, Africa and Latin America after depleting
populations in Asia.
The scope and scale of environmental
destruction associated with seahorse trafficking present companies engaged in
the production of medicines and other products using seahorses as ingredients,
as well as investors, with significant ESG risks. Legal risks related to the
largely illegal nature of the trade present further risks to exporters,
importers, production facilities, transporters and financial institutions.
5. Marine wildlife trafficking supply chain
chain for illicit marine products involves a range of actors including fishers
(individuals or commercial vessels), wholesalers, intermediaries,
trans-shippers, manufacturers, artisans, exporters and importers, wholesalers,
crime groups and individuals operating legitimate businesses, sometimes in
collusion, operate at every level of the supply chain, undermining efforts to
trace, regulate or control the trade. Where parallel legal and illegal trades
exist, products can be quickly laundered into the legal supply chain.
from IUU fishing, poaching and forced labour to document fraud, drug smuggling
and human trafficking.
The following infographic gives a simplified
overview of the supply chain and its vulnerabilities:
source marine species globally, co-opting local supply chains to harvest species for the international
trade. When local suppliers and local markets become embedded in global supply
chains, depletion occurs very quickly, particularly for
species and in source locations with few controls.
Illegal harvest involves both individual
local fishers and large
commercial fishing vessels. In
some cases illegal harvest is coordinated and intensive, such as in coral
poaching, while in other instances, such as seahorse trafficking, species are
consolidated over time and sold to traders.
Individual collectors are often small-scale fishers engaged in harvesting to supply intermediaries
and wholesalers. They may be witting or unwitting participants in the
Commercial fishing vessels, sometimes as part of large fleets, may opportunistically poach by keeping animals caught through bycatch for illegal sale. They may also be configured specifically to harvest protected species to traffic, such as Chinese and Philippine vessels in the South China Sea, Coral Sea and just off the exclusive economic zone of Japan.
species popular in Asia, trafficking often follows a “roving bandit” pattern.
Traffickers fan out across the globe to identify plentiful populations of
wildlife, tap into local networks and begin trading species internationally.
Harvest often follows a boom and bust cycle, where new populations are
discovered leading to a boom before they are very quickly exploited.
pattern occurs time and again, from coral to sea cucumbers to giant clams.
The illegal European eel trade is thought to be worth more than a billion dollars annually.
All exports of European eels, whether alive or dead, are prohibited through CITES and
within European law. Because the eels cannot be bred in captivity, this means all
European eels traded outside of Europe are products of trafficking, and all proceeds from
their sale is illicit.
The trade in eels often involves ranching, a process which uses wild-caught juveniles
raised in farms to supply the trade. Legitimate traders/businesses and wildlife traffickers
often interact to harvest wild animals to supply ranches.
Baby eels (elvers) are illegally caught in Europe and trafficked to Asia in air passenger
luggage in oxygenated bags. The live eels are often falsely labelled as non-endangered
fish if they are declared at all. One suitcase can carry 50,000 elvers, making eels the
most trafficked animal globally.
Once they reach farms in China, the eels are grown to their full size – up to a metre and
a half – and can then be sold on the market for the equivalent of over USD 10 each.
Trafficked European eels are regularly mislabelled and exported to Europe or to North
America as packaged, processed eel products.
Once harvested, marine species are quickly consolidated for processing and packaging
in preparation for onward transport. Live species such as eels, ornamental fish, invertebrates, and corals are separated and stored alive. In the case of corals or molluscs destined for the jewellery or curio trade, they may be dried or otherwise processed.
Criminals operating in legal businesses play a key role at this stage, laundering wildlife
into the supply chain through legitimate marine processing facilities and marine products
trading companies. At the same time, organised crime groups have become adept at
large-scale wildlife processing, as evidenced by sophisticated abalone and shark fin
processing. Warehouses, restaurants and even homes can serve as illegal marine products
Transhipment at sea has received growing attention in relation to IUU fishing, and the
same mechanism could allow marine species traffickers to evade port controls.
Unscrupulous marine products traders obtain or forge fraudulent documentation to trade
wildlife as legal before arranging shipment through front companies or within combined
legal/illegal shipments to markets.
Organised crime groups similarly obfuscate wildlife for clandestine shipments at this phase,
smuggling high-value species in luggage or via air freight, and shipping large
consignments of goods hidden within containers of cheap commodities.
Live fish and corals are typically exported via air freight and laundered into the legal trade though falsified permits and other export documents.
Bulk shipments of dried corals are often shipped by sea freight.
European eels are typically trafficked in several ways: hidden within passenger luggage inside oxygenated bags or shipped as cargo, mis-declared as fresh fish, or hidden amongst live seafood to avoid detection. Importers are said to earn between EUR 800-1,500 upon arrival.
Marine turtles are off-loaded from commercial vessels at trading hubs in China or Vietnam, where they are locally processed before being exported or sold into local curio markets.
Species such as sharks and sea cucumbers that can only be traded from certain jurisdictions are often smuggled into those jurisdictions then mislabelled for export, though large-scale smuggling persists.
areas where neighbouring states
do not provide the same level of protection for a species that exists
states’ territorial waters, traffickers can easily harvest and transport
wildlife for export.
For example, sea
cucumber networks heavily poach species in protected waters in Southern
India, where the trade in all sea cucumbers is fully restricted. They work
through local fisherman to harvest the creatures, then either move them onshore
for clandestine processing and shipment to Asia or move them via small boats
directly to Sri Lanka upon capture. Sri Lanka’s thriving marine products export
sector provides numerous laundering opportunities, allowing tonnes
cucumbers to exit the region mixed in with legal shipments.
Once imported, shipments pass to wholesalers and
distribution to manufacturers and retailers.
destination points, particularly in Asia, trafficked species can often be
openly traded. However, even where laws on importing restricted
strong, complex global supply chains and local situations present serious
challenges to traceability and enforcement.
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.
introductory course to wildlife crime designed for Financial Intelligence Unit
staff, law enforcement and supervisory authorities.Go to course.