Using Closed Case Reviews in Financial Investigation of the Illegal Wildlife Trade

In 2019, RUSI’s Organised Crime and Policing team, working with the government of the Lao People’s Democratic Republic (Lao PDR), TRAFFIC and the World Wide Fund for Nature (WWF), pioneered a new technique in the environmental crime domain to support capacity building in this area: the use of multi-agency reviews of closed IWT cases – the Closed Case Method.

Based on the pilot exercise’s success, this novel capacity-building methodology was subsequently adopted as a recommendation by the Financial Action Task Force, which urged affected countries to ‘undertake (multi-agency) case reviews of historic/closed IWT cases that focus on the unexplored financial elements of a case’, arguing that such reviews can identify typologies of IWT-related financial crime, develop risk indicators, and potentially reveal new leads.

The RUSI team has since refined the Closed Case Method through multi-agency capacity-building workshops held in Malawi, Namibia, Uganda and Zambia in 2022–23. These workshops were designed and delivered as part of the RUSI project, ‘Case Closed? Using Historic Cases to Enable New Financial Investigations’, funded by the UK government under the Illegal Wildlife Trade Challenge Fund.

This Whitehall Report summarises the lessons learned from this workshop activity, presenting a best practice guide for the use of closed case reviews to support financial investigation in IWT cases. This approach involves the retroactive analysis of previous IWT cases to identify fresh opportunities to gather and act on financial intelligence.

The team’s methodology for using closed case reviews in capacity building can be broken down into three different stages:

• First, the ‘research and preparation stage’ involves context-specific literature reviews, targeted stakeholder engagement, case criteria development, case selection and development of training materials.  
   
• Second, the ‘capacity building stage’ comprises delivery of multi-agency workshops, involving baseline financial investigative skills training and small group case reviews, in which all relevant agencies are charged with re-examining the details of the case and developing missed opportunities to follow financial leads.
   
• Third, the ‘learning and dissemination stage’ involves the development of red flags (risk indicators for suspected money laundering activity), the dissemination of financial intelligence to both the private and the public sector, and monitoring and evaluation.

The most recent experience using RUSI’s Closed Case Method in Malawi, Namibia, Uganda and Zambia permitted the identification of the following lessons and best practice principles:

• Adaptability: The Closed Case Method is applicable to national entities possessing significantly different levels of financial investigative experience. Notably, relevant agencies in the four focal countries demonstrated different baseline competencies in conducting financial investigations in IWT cases prior to the intervention, which could be mitigated by tailoring the methodology. The malleability of the method is one of its greatest strengths, guaranteeing universal applicability. This was evidenced by measurable and demonstrable improvements in workshop participant capacity and knowledge across all four countries, despite significantly varied context-specific baseline competencies.
   
• National ownership: The Closed Case Method is best implemented when workshop activities are led by in-country stakeholders. Efforts should be made to ensure that ownership of closed case activities is vested in national entities, with co-creation of case selection criteria being key to the exercise’s success.
   
• Multi-agency approach: Experience of using RUSI’s Closed Case Method clearly demonstrates that multi-agency capacity building in this area must span the full breadth of the public sector institutions tasked with countering IWT, and include other parties that can affect an IWT investigation or subsequent prosecution. Crucially, judicial actors, including judges and magistrates, should not be excluded from IWT closed case reviews.
   
• Private sector involvement: Information held by private sector financial institutions is vital in detecting suspicious transactions and supporting effective financial investigations. It is therefore crucial that the role of the private sector in combatting IWT-related money laundering is communicated to workshop participants, including through guest speakers or trainers representing national banks and international money transfer platforms and services. This will help ensure an effective closed case review and future cross-sector collaboration.
   
• Financial intelligence unit (FIU) engagement: The specific type and role of the relevant national FIU must be clearly understood and accounted for in designing and delivering closed case review exercises in any given country. The buy-in and support of the national FIU, among other key agencies, is key to the sustainability of the approach.

 

The Closed Case Method was originally piloted under a partnership between RUSI, TRAFFIC, WWF and the government of Lao PDR, more details of which are included in the Whitehall Report.

This web page was amended on 24 January 2024.