Main Image Credit Photo by Dick Hoskins from Pexels
It is a sad fact that enforcement action against the illegal wildlife trade (IWT) usually begins and ends with the seizure of illegal wildlife products. Financial investigations – routine for other serious crimes – are seldom undertaken for IWT. In recent years, however, a growing consensus has emerged that financial approaches need to be incorporated into all IWT investigations. This includes not just the identification of illegally acquired assets and the possibility of forfeiture, but the use of financial intelligence in ongoing investigations.
This project addressed this neglected component of the fight against IWT, focusing on the lack of capacity in source countries to investigate wildlife-linked illicit financial flows. The project worked in 2016–18 to build capacity in Kenya, Tanzania and Uganda to detect wildlife-linked money-laundering activity, which stalls development and entrenches poverty. It did so by piloting a new approach: a strategic threat- and needs-assessment around wildlife-linked illicit financial flows, followed by multi-agency training offered to law-enforcement, banking, wildlife and justice authorities.
Foreign, Commonwealth and Development Office (then Department for International Development) and Department for Environment, Food and Rural Affairs.
Associate Fellow; Independent Consultant
Director, Organised Crime and Policing
Organised Crime and Policing
Centre for Financial Crime and Security Studies
Neil Bennett, Illicit Finance Expert and Trainer, independent
Aims and objectives
This project aimed to address a lack of capacity in East Africa to investigate the illicit financial flows underpinning IWT. Limited awareness of anti-money laundering (AML) risks among law-enforcement agencies has typically impeded financial approaches to IWT. In investigating IWT, the financial leads available to track high-level facilitators have rarely been followed; arrests are generally limited to low-level actors caught with wildlife in hand. In prosecuting IWT, wildlife acts are used almost exclusively, with opportunities to use weightier penalties and asset forfeiture provisions offered by AML legislation generally not enforced.
To address this situation, the project aimed to improve knowledge and capacity to disrupt the illicit financial flows that make IWT profitable.
An in-depth literature review was supplemented by 100 interviews with experts in IWT and financial crime. The findings informed the delivery of tailored multi-agency capacity building, bridging public and private sectors. 22 days’ training were delivered to 43 delegates from eight government agencies and 14 banks in Kenya; 55 delegates from 10 government agencies and 12 banks in Tanzania; and 51 delegates from nine government agencies and 10 banks in Uganda. Best practice, recommendations and lessons learned were generated on investigating wildlife-linked financial flows to inform future programming.
Access key publications produced as part of this project.
The project achieved its objective of advancing government capacity to investigate financial crime connected to IWT in Kenya, Tanzania and Uganda. Prior to this project, no dedicated training had been provided to relevant agencies. In all countries, wildlife management authorities and financial intelligence units were found to have no regular contact with each other. Law-enforcement officers lacked the skills and knowledge to conduct financial investigations in IWT cases.
Training participants demonstrated significant learning capacity in using tools required to initiate financial investigation. In all countries, post-course surveys showed improved awareness of the methods and money flows requiring investigation, as well as knowledge of alternative legislation that can be used to prosecute IWT cases.
As noted in the project’s independent final evaluation by the UK government:
‘The project has equipped public government institutions with financial tools to investigate and prosecute IWT cases… There is notable evidence that gender was at the core of the project… not only [in] participation to the trainings but also by active participation of both genders in delivering of the actual training.’
‘The project filled a big knowledge gap in application of financial tools and techniques in IWT cases in Kenya, Uganda and Tanzania partly attributed to limited training, limited interactions between wildlife agencies, prosecution agencies and financial institutions… The piloting [of] anti-money laundering training and capacity-building in Kenya, Uganda and Tanzania, the first project of its kind, has clearly demonstrated demand and interest for multi-agency training in the financial dimensions of IWT. As a result, a similar project “Following the Money II: Disrupting Wildlife-Linked Illicit Financial Flows in East and Southern Africa” has been launched to build capacity in Malawi, Zambia and Mozambique.’
The Follow the Money report is extensively cited in policy documents on IWT, including the OECD’s analysis of wildlife trafficking in Southeast Asia and FATF’s 2020 review of IWT. It is also cited in academic journals including Conservation and Animal Studies Journal. It is cited in Policing Transnational Crime: Law Enforcement of Criminal Flows and Green Crimes and Dirty Money, both from Routledge.