Is wildlife trafficking being treated as serious crime?
Is wildlife trafficking being treated as serious crime?
A review of criminal offences, penalties, and implementation of the United Nations Convention against Transnational Organized Crime
Discussion Paper, September 2025
The Wildlife Justice Commission (WJC) is a civil society organisation that supports and collaborates with law enforcement agencies to investigate and prosecute serious and organised wildlife crimes. Focusing on the most endangered species and prolific offenders, our mission is to disrupt and dismantle the transnational criminal networks trafficking wildlife, timber, and fish by collecting evidence and turning it into accountability so that organised crime is not driving species to extinction. Our investigation approach is modelled on recognised law enforcement methodologies to combat organised crime, using a combination of undercover operatives, covert surveillance, and networks of trusted informants to collect intelligence and evidence across the supply chain. Our unique on-the-ground insights and findings from our investigations can help inform policymaking and law enforcement at the multilateral level to close legal and implementation gaps.
About the Wildlife Justice Commission Acknowledgements
The WJC is grateful to the Brook Foundation for the generous financial support provided to make our work on treating transnational organised wildlife crime as serious crime and this report possible.
The WJC also gratefully acknowledges the valuable support of the International Lawyers Project and the partner teams at law firms, including Ropes & Gray, whose expertise and technical review helped ensure our findings are rigorous and robust.
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Acronyms
CBD Convention on Biological Diversity
CCPCJ Commission on Crime Prevention and Criminal Justice
CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora
CMS Convention on the Conservation of Migratory Species of Wild Animals
ECOSOC Economic and Social Council
FATF Financial Action Task Force
ICCWC International Consortium on Combating Wildlife Crime
NGO Non-Governmental Organisation
IEG Intergovernmental Expert Group (on crimes that affect the environment falling within the scope of UNTOC)
UNCAC United Nations Convention against Corruption
UNODC United Nations Office on Drugs and Crime
UNTOC United Nations Convention against Transnational Organized Crime
WJC Wildlife Justice Commission
1. Statement of purpose
This discussion paper seeks to provide insight and perspectives on the extent to which wildlife trafficking is being treated as a form of serious crime. It aims to build on existing research to help narrow the knowledge gaps on how the United Nations Convention against Transnational Organized Crime (UNTOC) has been incorporated in domestic legislation and implemented in relation to wildlife trafficking. This paper provides a targeted analysis of the criminalisation and penalisation of wildlife offences, and as-
sesses the extent to which key UNTOC provisions are incorporated in domestic legislation. It further examines selected case law examples to illustrate the enforcement of those laws in practice, highlighting best practices and challenges, and offering targeted recommendations. It is hoped that this paper will inform multilateral policy discussions on how to effectively prevent and combat serious forms of wildlife trafficking.
2. Introduction: Wildlife trafficking as serious organised crime
The UNTOC was adopted in 2000 in response to the growing global threat of organised crime. It provided a new legal framework for international cooperation to combat transnational criminal activities, including measures against money laundering and corruption, confiscation of criminal proceeds, mutual legal assistance, joint investigations, and the use of special investigative techniques. The United Nations General Assembly resolution adopting the UNTOC envisaged that it would be an effective tool to address various forms of transnational organised crime, including wildlife trafficking1 – recognised today at the multilateral level as a “crime that affects the environment”. However, the effectiveness of the UNTOC in this regard depends on State Parties incorporating its provisions into their domestic legal frameworks and undertaking strong and targeted enforcement actions to prevent and deter organised criminal activity.
In 2001, wildlife trafficking was one of the first crimes that affect the environment to be specifically recognised in the international policy framework. 2 Over the ensuing two decades, wildlife trafficking has evolved and increasingly grown as a major global threat, generating billions of dollars annually, 3 affecting thousands of species and virtually every country, 4 facilitated by corruption across global supply chains, 5 and increasingly converging with other forms of serious organised crime, such as human and drug trafficking. 6 Although wildlife trafficking is estimated to be the fourth-largest form of transna-
tional organised crime after drug trafficking, counterfeit crimes, and human trafficking, 7 it is not consistently treated as such. For organised criminal networks, trafficking in endangered species in many jurisdictions remains a highly profitable enterprise with low risks of detection or serious punishment.
The impacts of wildlife trafficking are broad. These crimes not only decimate ecosystems and biodiversity but also contribute to climate change, 8 undermine governance and the rule of law, 9 jeopardise livelihoods, and heighten public health risks, including the likelihood of zoonotic disease transmission from illegal wildlife trade.10 The ecological and social harms persist across generations, directly hampering the achievement of the 2030 Agenda for Sustainable Development.11 Unlike other illicit commodities, the environment has finite limits: once a species is extinct or an ecosystem destroyed, there is no reversal. Prioritising the prevention and disruption of wildlife trafficking is therefore essential for protecting people, the planet, and future generations.
To effectively address the most serious forms of wildlife trafficking and other crimes that affect the environment, the UNTOC must be applied across global illegal supply chains. While momentum is growing at the multilateral level, significant knowledge gaps remain regarding how far the Convention has been incorporated into national legislation and implemented in practice.
1 United Nations General Assembly (UNGA) Resolution 55/25 on United Nations Convention against Transnational Organized Crime , PP 10.
2 United Nations Economic and Social Council (ECOSOC) Resolution 2001/12 on Illicit trafficking in protected species of wild flora and fauna
3 Nelleman, H. et al (Eds) (2016), The Rise of Environmental Crime: A Growing Threat to Natural Resources, Peace, Development and Security , United Nations Environment Programme (UNEP), p.20.
4 United Nations Office on Drugs and Crime (UNODC) (2016), World Wildlife Crime Report , p.13.
5 Wildlife Justice Commission (WJC) (2023), Dirty Money: The Role of Corruption in Enabling Wildlife Crime
6 WJC (2023), Convergence of wildlife crime with other forms of organised crime: A 2023 review , p.7.
7 United Nations Environment Program (UNEP) and International Criminal Police Organization (INTERPOL) (2016), The rise of environmental crime
– A growing threat to natural resources, peace, development and security , p.7.
8 U NODC and World Wildlife Fund (WWF) (2022), Crimes that Affect the Environment and Climate Change , pp.10-14
9 U NEP (2018), The State of Knowledge of Crimes that have Serious Impacts on the Environment , p.VIII.
10 Ibid. p. 5.
11 Ibid. p. 6..
3. Scope of this paper
This paper presents research conducted by the Wildlife Justice Commission (WJC) on how wildlife offences are criminalised and penalised in the domestic legislation of 19 of the most prominent jurisdictions along the global rhino horn supply chain,12 and whether this legislation incorporates key UNTOC provisions.13 It also presents a selection of 10 rhino horn trafficking cases from open-source research and WJC investigations to provide some insight into how legislation has been implemented in practice and how UNTOC provisions are being applied to prevent and combat wildlife trafficking.
The research focused on the rhino horn trafficking supply chain as it is one of the most recognised and well documented wildlife trafficking supply chains. While not representative of all supply chains or the full picture of wildlife trafficking, rhino horn is a high-value commodity targeted by organised crime networks and is emblematic of serious, transnational wildlife crimes within the scope of UNTOC. Its supply chain involves multiple criminal components across numerous jurisdictions and continents from source to destination markets. The information available therefore allows lessons to be drawn on best practices and challenges, which are relevant not only to the rhino horn supply chain but also to the broader issue of wildlife trafficking and crimes that affect the environment.
By comparing legislation across jurisdictions commonly linked as source, transit, and destination locations in rhino horn trafficking routes, this research assesses the extent of harmonisation among jurisdictions that may need to collaborate on joint investigations, mutual legal assistance, or extradition when cross-border trafficking cases arise, potentially requiring dual criminality14 and the UNTOC as a legal basis for cooperation.
This paper primarily focuses on wildlife trafficking, as referenced in the UN framework of policy commitments and resolutions on this issue. Furthermore, the trafficking stage of the wildlife supply chain –linking the supply of commodities at source locations with the distribution to demand markets – is dominated by organised crime networks. This is due to the significant financial capital required to consolidate large enough volumes of product to ensure a profitable shipment, as well as the requisite access to business infrastructure and corrupt connections to facilitate the cross-continental movement of these shipments. Consequently, the wildlife trafficking stage is where law enforcement can most effectively target high-level offenders, shipping facilitators, and corrupt enablers to significantly disrupt transnational organised criminal networks.
12 WJC (2022), Rhino horn trafficking as a form of transnational organised crime , 2012-2021, p.63.
13 The UNTOC is not a self-executing treaty, requiring States to pass domestic legislation to give it legal effect and operationalise its provisions
14 Dual criminality is a principle in international law that requires an act to constitute an offence under the legislation of both jurisdictions, to enable mutual legal assistance, extradition, transfer of criminal proceedings, or other international cooperation measures.
4. Research methodology
Research for this discussion paper focused on 19 of the most prominent source, transit and destination jurisdictions along the rhino horn supply chain, as identified in the WJC’s previous analysis of 10 years of global rhino horn seizure data from 2012 to 2021 (Table 1).15
Table 1: Jurisdictions implicated in the seizure of 100 kg or more of rhino horns as either source, transit, or destination locations along the trafficking routes, 2012-2021.16
For each jurisdiction, relevant wildlife and criminal legislation was identified through online searches. We focused on wildlife laws in relation to terrestrial animals (rather than forestry or fisheries laws), including laws and regulations to implement CITES requirements, other wildlife protection legislation such as hunting and protected area laws, penal codes and criminal procedure laws, customs anti-smuggling laws, and anti-money laundering laws. As we relied on open-source research to identify legislation, it is possible we may have missed some relevant laws or amendments. The research was also supported and reviewed by two international law firms.
To compare the levels of fines provided across jurisdictions, all currencies specified in the legislation were converted to United States dollars using exchange rates provided on 29 July 2025. When converting the values of fines and confiscated assets in the rhino horn trafficking cases, exchange rates at the time of sentencing were used.
Although the rhino horn supply chain has received significant attention, with many of the most-affected
jurisdictions updating their legislation in recent years to broaden the range of offences and increase penalties and enforcement powers, comprehensive prosecution data for many of the 19 jurisdictions was not publicly available.17 This prevented us from determining how many wildlife cases reached the court stage and highlights a critical gap in the ability to fully analyse UNTOC implementation in wildlife trafficking cases.
Consequently, our assessment of the application of wildlife legislation is limited, based on case law identified through online searches and cases where the WJC supported enforcement efforts. The selection of case studies presented in this paper are therefore illustrative examples of successful law enforcement and prosecution outcomes, which highlight how cases involving the same commodity were handled at different stages of the supply chain. Together, they serve as examples to highlight best practices and challenges to further inform ongoing discussions at the multilateral policy level, rather than a comprehensive representation of prosecutions across the supply chain.
Image 1: Various rhino horn products including nine horn tips, 14 unprocessed pieces, 27 carved pieces, 10 bangles, approximately 10 bracelets, and 22 libation cups (at the back).
Source: Wildlife Justice Commission.
5. Multilateral context to address wildlife trafficking
Several treaties regulate aspects of wildlife conservation, use, and trade, most notably the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), along with the Convention on the Conservation of Migratory Species of Wild Animals (CMS) and the Convention on Biological Diversity (CBD). These agreements play an important role in regulating wildlife-related activities, but none provides a single, legally binding framework to comprehensively address wildlife trafficking.
CITES is the most relevant treaty in this regard, although it does not provide for criminal matters. The CITES framework distinguishes between permitted and prohibited trade via a licensing system and three appendices assigning different degrees of protection, to ensure that international trade in wildlife specimens does not threaten their survival.18 It requires Parties to prohibit and penalise any trade conducted in violation of the Convention (Article VIII); and although it does not specifically require criminalisation, it does not prevent Parties from adopting stricter domestic measures (Article XIV). The scope of CITES is limited to around 40,000 species listed in the appendices,19 representing a relatively small proportion of the world’s biodiversity and leaving significant gaps in protection and enforcement.
On the other hand , the adoption of the UNTOC in 2000 established a broad legal framework for international cooperation to prevent and combat a wide range of organised criminal activities. From the out-
set, it was envisaged that the UNTOC would be useful to address wildlife trafficking, 20 although neither wildlife crime nor environmental crime are specifically mentioned in the Convention. UNTOC provisions apply to offences that are transnational in nature,21 involve an organised criminal group,22 and are “serious crimes”, defined as conduct constituting an offence punishable by a maximum deprivation of liberty of at least four years or a more serious penalty. 23 All three conditions are critical to trigger the full range of UNTOC mechanisms. 24 Thus, unless wildlife trafficking is penalised with at least four years imprisonment in domestic legislation, States cannot apply UNTOC provisions to address it. This makes the adoption of strong penalties for high-level traffickers not only a matter of deterrence but also a prerequisite for engaging UNTOC mechanisms to prevent and combat wildlife trafficking.
Despite these agreements, there remains no universal definition of wildlife crime or set of activities that are required to be criminalised in domestic legislation. However, since 2001, momentum has steadily grown within the UN framework to recognise wildlife trafficking as a “serious crime” in domestic legislation, in accordance with the UNTOC threshold. Through successive non-binding policy commitments and resolutions of the UN General Assembly, Economic and Social Council (ECOSOC), Commission on Crime Prevention and Criminal Justice (CCPCJ), UNTOC Conference of the Parties, and CITES, Member States have been urged, then strongly encouraged, to criminalise
18 Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) (n.d.), How CITES works
19 CITES (n.d.), The CITES species
20 UNGA Resolution 55/25 on United Nations Convention against Transnational Organized Crime , PP 10.
21 UN Convention against Transnational Organized Crime (UNTOC) Article 3(2) sets out the conditions whereby an offence is transnational in nature. This includes when it is committed in more than one State; when a substantial part of its preparation and control takes place in another State; when it involves an organised crime group that engages in criminal activities in more than one State; or when it is committed in one State but has substantial effects in another State.
22 UNTOC Article 2(a) outlines four key elements that define an “organised criminal group”: a structured group of three or more persons, existing for a period of time, with the aim of committing one or more serious crimes, to obtain a financial or other material benefit.
23 UNTOC Article 2(b).
24 UNTOC Article 3(1)(b) specifies that the Convention shall apply to the prevention, investigation and prosecution of serious crimes where the offence is also transnational in nature and involves an organised criminal group.
wildlife offences, 25 adopt appropriate penalties and sanctions, and make full use of UNTOC provisions to prevent and combat wildlife trafficking. (See Table 2 in Appendix).
To assess the extent to which these commitments have been translated into domestic legislation, the United Nations Office on Drugs and Crime (UNODC) conducted a global analysis of how Member States have criminalised actions that harm the environment and whether penalties conform to the UNTOC definition of serious crime. It found that wildlife trafficking had the highest levels of criminalisation of all the environmental crime types, with 169 out of 193 Member States (87%) having criminalised offences against wildlife in their national legislation. 26 However, less than half (48%) provided maximum penalties of four years or more in prison, in line with the UNTOC definition of serious crime.27 The analysis concluded that further research was needed to understand how legislation is being implemented and whether the penalties imposed were effective in preventing and deterring offending. 28 It also recommended further examination of criminalisation and penalties within (sub)regions to identify the extent of harmonisation
and any potential loopholes where countries with the least stringent penalties may be targeted.29
Building on this trajectory, and as part of the growing recognition of wildlife trafficking as a transnational organised crime threat, a new intergovernmental process has recently commenced to review the application of the UNTOC to crimes that affect the environment, including wildlife trafficking. 30 An open-ended intergovernmental expert group (IEG) has been established to take stock of current efforts to apply the UNTOC in this field, to identify any gaps in the international framework, and to consider possible responses, including the feasibility of any additional UNTOC protocol specifically addressing environmental crimes. 31 The first meeting of the IEG took place in June-July 2025, 32 which may be followed by a second meeting before reporting back at the 13th Session of the UNTOC Conference of the Parties in October 2026. 33 This marks an important step in consolidating international efforts to strengthen the legal and institutional response to crimes that affect the environment, and in particular, to wildlife trafficking as a form of transnational organised crime.
25 Significantly, in May 2025, the United Nations Commission on Crime Prevention and Criminal Justice (CCPCJ) Resolution on Tackling illicit trafficking in wild fauna and flora, including timber and timber products, the illegal mining of and illicit trafficking in minerals and precious metals, the illicit trafficking in waste and other crimes that affect the environment, for the first time identified a concrete list of acts against wildlife that States are encouraged to criminalise in domestic law. These include unlawful capture, collection, exposure for sale, acquisition, import, export, purchase, sale, delivery, transportation, transfer, receipt, possession or holding in custody, as well as forgery or unlawful alteration of documents related to those crimes.
26 UNODC (2025), Global Analysis on Crimes that Affect the Environment – Part 1: The Landscape of Criminalization , p.30.
27 Ibid, p.31.
28 Ibid, p.37.
29 Ibid, p.36.
30 UNTOC Resolution 12/4 on Enhancing measures to prevent and combat crimes that affect the environment falling within the scope of the United Nations Convention against Transnational Organized Crime , OP 5.
31 Ibid.
32 UNODC (n.d.), Open-ended intergovernmental expert group on crimes that affect the environment falling within the scope of the United Nations Convention against Transnational Organized Crime and related offences covered by the Convention
33 Global Initiative Against Transnational Organized Crime (GI-TOC) (2025), A New Protocol for the UNTOC? p.3.
Wildlife offences along the supply chain
Although not all wildlife violations constitute a criminal act, it is important that criminal offences and penalties are available in domestic legislation to enable a criminal justice response for high-level offenders and those operating as part of an organised criminal group. Jurisdictions have taken various approaches to criminalise wildlife offences, such as by introducing specialised wildlife laws or by including wildlife offences in criminal laws, customs laws, or other relevant legislation.34 The range of acts that are recognised as offences and how they are penalised also varies depending on a jurisdiction’s social, economic, cultural and geographic conditions.35
Wildlife supply chains are often long and complex, crossing many jurisdictions from the original source location to the end consumer market. It is worth noting that while some offences such as illegal hunting or killing occur at the beginning of the supply chain, other downstream offences such as illegal trade, possession, transportation or processing can occur at any
point along the supply chain, or at multiple points, as wildlife consignments change hands from suppliers to brokers, traffickers, shippers, and so forth. In this way, wildlife crimes are often transnational in nature, as defined by UNTOC Article 3, because different stages of preparation to obtain or create a wildlife-based commodity (such as jewellery, medicine, fashion, pets, etc.) take place in different jurisdictions; and acts carried out in one jurisdiction (such as illegal sale, purchase or trade at a market) can have a substantial impact on another jurisdiction (for example, poaching to supply the market). 36 These cross-border links make consistency and harmonisation of offences across jurisdictions essential – both to meet the dual criminality principle for cases requiring international cooperation, 37 and to prevent displacement of crime to countries with weaker laws or enforcement.
Figure 1: Simplified depiction of the connection between different offences and the stages of the wildlife supply chain where they can occur.
34 UNODC (2018), Guide on Drafting Legislation to Combat Wildlife Crime , p.2.
35 Ibid.
36 UNTOC Article 3 sets out the conditions whereby an offence is transnational in nature. This includes when it is committed in more than one State; when a substantial part of its preparation and control takes place in another State; when it involves an organised crime group that engages in criminal activities in more than one State; or when it is committed in one State but has substantial effects in another State.
37 GI-TOC (2025), A New Protocol for the UNTOC? p.12.
6. Comparative analysis of domestic legislation
The following sections of this paper provide key findings from the WJC’s comparative analysis of how 19 jurisdictions along the global rhino horn supply chain have criminalised and penalised wildlife offences and incorporated key UNTOC provisions in their domestic legislation.
While our research did not systematically examine the extent to which jurisdictions along the supply chain have criminalised and taken measures against corruption, which are key UNTOC provisions, 38 corruption remains a principal enabler of wildlife crime.39 Accordingly, it is highlighted in the illustrative case studies and ensuing recommendations, as targeting corrupt actors is essential for disrupting criminal networks.
6.1. Status of criminalisation of wildlife offences
This analysis focused on seven major categories of offences that can occur along the wildlife supply chain: trafficking (illegal import, export, re-export, and/or smuggling), illegal hunting (poaching, killing, capture, harvest, or similar activities), illegal trade (sale and purchase), illegal possession (keeping, control, utilisation, or similar activities), illegal captive breeding (farming, ranching, or similar activities), illegal transportation, and illegal processing or manufacture.
It found that all 19 key jurisdictions in this supply chain criminalise offences in four major categories: trafficking, illegal hunting, illegal trade, and illegal possession.
38 UNTOC, Articles 8 and 9.
39 WJC (2023), Dirty Money: The Role of Corruption in Enabling Wildlife Crime
For illegal transportation of wildlife, 17 jurisdictions (89%) have specific “transportation” offences in their legislation, while two jurisdictions have other provisions and offences that are applicable to the conduct of illegal transportation activities.40
In most jurisdictions, captive breeding (or farming, ranching, or related activities) is regulated, requiring registration and a licence to operate. Captive breeding can become an offence when breeding activities occur without a licence or outside of licence conditions; and these offences can have transnational links if the facilities are supplying wildlife for international trade. Captive breeding facilities can also be associated with other offences such as laundering species that are illegally obtained from the wild or using fraudulent CITES permits or other documentation, and organised crime networks can capitalise on and exploit these facilities to facilitate trafficking operations.41
This analysis found that 89% of jurisdictions have offences related to illegal captive breeding. This includes 13 jurisdictions that have specific offences for unauthorised captive breeding activities, and four jurisdictions that have provisions to regulate captive breeding activities alongside broad terminology and offences that can be applied to unauthorised captive breeding activities. 42 Two jurisdictions do not appear to have provisions to regulate captive breeding activities or criminalise captive breeding offences.
Processing or manufacturing encompasses activities whereby raw wildlife parts are turned into products or derivatives for the consumer market, which can occur at any stage of the supply chain. Examples include carving raw rhino horns into libation cups, tea
40 For example, these two jurisdictions had legislation providing powers to search any conveyance suspected to be carrying wildlife and offences relating to unauthorised control of specimens, which in combination would be applicable to the conduct of illegal transportation.
41 WJC (2022), To skin a cat: how organised crime capitalises and exploits captive tiger facilities
42 Examples of the broader legislative approaches taken by these four jurisdictions include defining wildlife “specimens” as including those from captive bred sources and defining “acquired” to include through captive breeding activities, along with broad offences for unauthorised possession and unauthorised control, which in combination would be applicable to illegal captive breeding activities.
sets, and jewellery; or butchering a tiger and cooking the bones down to form tiger bone paste. This analysis found that 12 jurisdictions (63%) have specific offences for illegal processing or manufacturing activities. The other seven jurisdictions (37%) do not expressly criminalise the act of processing, but they define wildlife specimens as including processed parts, products and derivatives, thereby enabling offences such as illegal trade and possession to apply to processed wildlife.
The analysis identified 13 jurisdictions (68%) that criminalise attempts to commit wildlife offences, incomplete acts, conspiracy, or similar activities. Four jurisdictions (21%) partially criminalise attempts, specifying certain specific offences such as illegal hunting, import or export, while two jurisdictions do not appear to criminalise attempts.
All jurisdictions recognise corporate liability for wildlife offences. A range of legislative approaches are taken, such as a specific provision stating that all offences are applicable to legal persons; providing different penalty levels for legal and natural persons for the same offence; or broadly defining “person” to include legal persons, and all offences applying to “any person”. This is an important aspect of wildlife legislation, as corporations are often involved in trafficking offences as consignors or consignees of wildlife shipments. Corporate liability is also required under the UNTOC for participation in serious crimes involving an organised criminal group (Article 10).
These findings suggest a high level of harmonisation across the 19 jurisdictions in criminalising major wildlife offence categories, although approaches differ for certain offences. This aligns with the UNODC’s findings that 87% of Member States have criminalised offences against wildlife in their national legislation. 43 However, it is noted that many jurisdictions affected by rhino horn trafficking updated their legislation in the last 10-15 years in response to the rhino poaching crisis and the heightened attention it garnered, 44 so the degree of harmonisation observed in this research may not necessarily be reflected in jurisdictions linked to other wildlife supply chains. Nevertheless, this research identified minor gaps for the criminalisation of captive breeding, processing, and attempts to commit an offence, which could be due to these activities receiving less recognition as areas for potential criminal conduct.
Consistency in the types of offences recognised is particularly important for facilitating international cooperation, as it helps ensure that the dual criminality principle is more easily satisfied. Such alignment may enable jurisdictions to more effectively use UNTOC provisions for joint investigations, mutual legal assistance, or extradition in cross-border trafficking cases, reducing legal obstacles and strengthening enforcement against transnational wildlife crime.
43 UNODC (2025), Global Analysis on Crimes that Affect the Environment – Part 1: The Landscape of Criminalization , p.30.
44 A new wave of rhino poaching began in southern Africa in 2006 and swept across the African continent. By 2012 it had unfolded as a crisis in South Africa at an unprecedented scale that had not been previously observed. Refer to: WJC (2022), Rhino horn trafficking as a form of transnational organised crime, 2012-2021 , p.41.
Figure 2: Comparison of the criminalisation of key wildlife offences across 19 jurisdictions along the rhino horn supply chain.
6.2. Mandate of criminal justice actors
A review of the law enforcement structure and mandate to implement wildlife legislation indicated that all 19 jurisdictions have at least one agency with full law enforcement powers to conduct investigations, intelligence analysis, seizure, arrest, and initiate prosecutions. In most instances, the law enforcement mandate is shared across several agencies such as police and/or an environmental authority, as well as customs agencies at points of entry and exit, and a prosecution authority. This shared mandate points to the importance of clear and well-defined roles, responsibilities and enforcement powers in legislation, and a well-coordinated interagency response to wildlife trafficking investigations at the national level.
Given the involvement of organised crime networks in some types of wildlife trafficking (and other crimes that affect the environment), such as rhino horn trafficking, it is important that the mandated investigation agency (or agencies) has the necessary powers, expertise and resources required to investigate transnational organised crime. This is usually the domain of traditional law enforcement agencies, which have deeper crime-focused skillsets and enforcement tools than environmental authorities, so it is vital that they are also given the mandate and necessary resources to lead investigations in serious wildlife trafficking cases.
6.3. Status of penalisation for wildlife trafficking
For a consistent point of comparison across the jurisdictions, this analysis focused on the highest level of penalties provided for trafficking-related offences involving CITES Appendix I species (illegal import, export, or re-export, or illegal trade). 45 Trafficking offences were prioritised because they are central to global wildlife supply chains and the transnational organised crime networks targeted by the UNTOC framework: addressing trafficking allows authorities to reach high-level traffickers, disrupt criminal networks, and tackle the most serious and impactful wildlife crimes, as opposed to low-level or incidental offences.
Significant variation was observed in the maximum terms of imprisonment and fines provided across the 19 jurisdictions for this offence category. Penalties in most jurisdictions are prescribed in terms of maximum (“up to”) levels, with no floor or minimum level. However, seven jurisdictions (36%) provide a penalty range between a minimum and a maximum level or stipulate a mandatory minimum (“no less than”) level with no ceiling or maximum level.
All jurisdictions provide imprisonment as a penalty option for wildlife trafficking offences, ranging from a maximum of six months imprisonment in the United Arab Emirates, 46 up to life imprisonment in China47 and Uganda. 48 In Kenya, the law provides a minimum penalty level of not less than 20 years imprisonment, but does not stipulate a maximum level. 49 The median imprisonment penalty across the 19 jurisdictions is 10 years.
45 CITES Appendix I lists species that are threatened with extinction, strictly prohibiting international commercial trade in these species except under exceptional, tightly regulated circumstances.
46 United Arab Emirates Law No. 11 (2002) Concerning Regulating and Controlling the International Trade in Endangered Species of Wild Fauna and Flora, Article 25.
47 Criminal Law of the People’s Republic of China, Article 151.
48 Uganda Wildlife Act (2019), section 62.
49 Kenya Wildlife Conservation and Management Act (2013), section 99(3)(a).
Fines can be issued in addition to, or instead of related offences in 15 jurisdictions (79%). 50 The maximum level of fines that can be imposed range from NGN 5 million in Nigeria (approximately USD 3,265) 51 up to HKD 10 million in Hong Kong SAR (approximately USD 1,273,905). 52 Again, Kenya’s law provides for a minimum fine of not less than KES 100 million (approximately USD 773,822), but it does not stipulate a maximum level. 53 In Mozambique, the law provides for an unspecified “corresponding fine” in addition to imprisonment, allowing judicial discretion to determine the appropriate amount.54 The median maximum fine penalty across the 15 jurisdictions is USD 30,770.
All jurisdictions enable authorities to seize and confiscate wildlife exhibits involved in the offence. In at least 13 jurisdictions (68%), additional penalty measures can be imposed such as additional fines covering costs related to storage, care, disposal or repatriation of wildlife specimens, or compensation for damages caused by the offence. At least three jurisdictions (16%) provide for alternative penalties such as community service in cases where certain conditions are met.
The considerably uneven approach to penalisation across the 19 jurisdictions could reflect various factors such as the differing impacts of wildlife crime and prioritisation afforded to addressing it and the age of the legislation currently in force.
Image 2: Harvested horns seized in Victoria Falls, Zimbabwe in December 2018. Source: Wildlife Justice Commission intelligence.
50 It is noted that no fines were provided in four jurisdictions as part of the maximum penalties available for their highest category of wildlife trafficking (illegal import/export) offences, which is the focus of this analysis, but they do provide fines for other types of wildlife offences.
51 Nigeria National Environmental (Protection of Endangered Species in International Trade) Regulations (2011), section 7.
52 Hong Kong Protection of Endangered Species of Animals and Plants Ordinance (2006), sections 5-9.
53 Kenya Wildlife Conservation and Management Act (2013), section 99(3)(a).
54 Mozambique Law on Protection, Conservation and Sustainable Use of Biodiversity, article 62(1).
UNTOC definition of serious crime: Offences punishable by a maximum deprivation of liberty of at least four years or more
Figure 3: Comparison of maximum imprisonment terms and maximum fines available for wildlife trafficking-related offences involving CITES Appendix I species across 19 jurisdictions along the rhino horn supply chain.
* Note on Kenya: 20 years imprisonment and/or KES 100 million fine is the minimum penalty level for a trafficking offence; no maximum level is provided for this offence type.
** Note on “no fines”: While these four jurisdictions do not provide fines as part of the maximum penalties available for wildlife trafficking offences, they do provide fines as part of penalties for less serious trafficking offences and/or other types of wildlife offences.
6.4. UNTOC serious crime threshold
Three jurisdictions (16%) have maximum penalties of less than four years imprisonment, meaning they do not meet the threshold for the UNTOC definition of serious crime and therefore cannot use UNTOC as a legal basis for investigating and prosecuting transnational, organised wildlife crimes (Article 3). The lower penalties in these jurisdictions (Nigeria, Qatar, and United Arab Emirates) could potentially reflect a lower prioritisation afforded to these crimes compared to other forms of transnational organised crime, or the fact that they are operating under older legislation. Notably in this regard, Nigeria is revising its wildlife legislation. The draft Endangered Species Conservation and Protection Bill is set to increase penalties for wildlife offences and will meet the UNTOC serious crime threshold when it is adopted and approved.55
Of the 16 jurisdictions (84%) that do meet the UNTOC serious crime threshold with maximum penalties of four years imprisonment or higher, nine jurisdictions (47%) have maximum penalties of four to 10 years imprisonment; and seven jurisdictions (37%) have maximum penalties of more than 10 years imprisonment. This finding shows that more than one third of jurisdictions along the rhino horn supply chain have severe penalties available for very serious cases.
Figure 4: Comparison of maximum imprisonment terms for wildlife trafficking offences involving CITES Appendix I species across 19 jurisdictions in the rhino horn supply chain.
The UNTOC requires State Parties to criminalise the laundering of the proceeds of crime (Article 6) and implement measures to combat money laundering (Article 7); while the Financial Action Task Force (FATF) further recommends applying anti-money laundering measures to all serious offences, with a view to including the widest possible range of predicate offences. 56 As serious forms of wildlife crime can generate vast amounts of illicit profit, 57 it is important that legal frameworks recognise wildlife crime as a predicate offence to enable the application of anti-money laundering tools to these crimes.
56 Financial Action Task Force (FATF) is the global international policy setting body for combating money laundering and terrorist financing. Refer to FATF International Standards on Combating Money Laundering and the Financing of Terrorism and Proliferation , Recommendation 3.
57 For example, based on price data collected during WJC investigations, rhino poaching numbers, and global rhino horn seizure data, the WJC estimated the potential gross illicit income generated from the wholesale trade of raw rhino horn over the ten years from 2012 to 2021 was worth between USD 874 million – 1.13 billion. Refer to: WJC (2022), Rhino horn trafficking as a form of transnational organised crime, 2012-2021 , pp.144-147.
The analysis found that all 19 jurisdictions in this research recognise wildlife offences as predicate offences for money laundering, although the legislative approach varied across the group. Eight jurisdictions (42%) use an “all crimes” approach, whereby any offence under any national law can be considered a predicate offence for money laundering. Seven jurisdictions (37%) define wildlife crime as a relevant offence for money laundering by listing it in a specific schedule of predicate offences, serious offences, unlawful acts, or indictable offences that are applicable to anti-money laundering legislation. Two jurisdictions (10%) recognise all offences in their Criminal Code as predicate offences for money laundering, which includes wildlife offences. Another two jurisdictions take a penalty threshold approach, recognising offences that are punishable by a certain penalty level as being predicate offences for money laundering, which is met by wildlife offences.
While this research found a high level of alignment among this group of jurisdictions, a different recent analysis based on 61 jurisdictions found that at least 45 (74%) reported that they recognised wildlife trafficking as a predicate offence for money laundering, indicating some gaps do remain elsewhere in this regard.58
Figure 5: Different legislative approaches taken by jurisdictions in recognising wildlife crime as a predicate offence for money laundering.
6.6. Special investigative techniques
Special investigative techniques are essential tools for penetrating and mapping organised crime networks, identifying high-level offenders and key corrupt actors, assembling the details of large, complex cases and ultimately build an irrefutable brief of evidence for successful prosecution in court. Under the UNTOC, these techniques include undercover operations, electronic or other forms of surveillance, and controlled deliveries.59 Their usage is encouraged for investigations of serious crimes and offences covered by the Convention, in line with the possibilities and conditions prescribed by domestic legislation (Article 20).
58 UNODC (2023), Report pursuant to CCPCJ Resolution 31/1 on Strengthening the international legal framework for international cooperation to prevent and combat illicit trafficking in wildlife , https://www.unodc.org/documents/commissions/CCPCJ/CCPCJ_Sessions/CCPCJ_32/CRPs/ ECN152023_CRP3_e.pdf
59 Article 2 (i) of UNTOC defines controlled deliveries as ‘the technique of allowing illicit or suspect consignments to pass out of, through or into the territory of one or more States, with the knowledge and under the supervision of their competent authorities, with a view to the investigation of an offence and the identification of persons involved in the commission of the offence’.
The analysis reviewed the authorisation of special investigative techniques in domestic legislation, and whether they can be applied in wildlife trafficking cases. It found eight jurisdictions (42%) do not appear to explicitly authorise the use of these techniques in their legislation. While provisions for enforcement powers in some jurisdictions are broad enough that the use of special investigative techniques is not materially prohibited, 60 the absence of clear legislative guidance could create uncertainty or inconsistency in their application. It is noted that some jurisdictions have taken alternative approaches, such as adopting a specific policy or operating procedure authorising the use of special investigative techniques, 61 or recognising the valid use of these techniques by the courts under common law.62
While special investigative techniques are more commonly applied to investigate other forms of transnational organised crime, particularly drug trafficking, their application in wildlife trafficking cases appears to be ad hoc and inconsistent. In particular, there are very few known examples of the use of controlled delivery for wildlife investigations. This could at least partly be a consequence of the lack of robust legislative provisions stipulating their use, and points to a gap that should be addressed to ensure effective enforcement and prosecution of serious wildlife trafficking cases.
60 For example, Kenya’s Wildlife Conservation and Management Act authorises wildlife officers to “conduct investigation and undertake intelligence gathering as appropriate” (section 110(1)(f)) and “take all reasonable steps to prevent the commission of an offence under this Act” (section 110(3)(c)).
61 For example, the Philippines Department of Environment and Natural Resources adopted the “Wildlife Law Enforcement Manual of Operations” (via Memorandum Circular No. 2010-17), which authorises undercover operations, controlled buys, and the use of informants in its wildlife crime investigations.
62 For example, in Namibia, although special investigation techniques are recognised in common law and are used in practice, the Namibia Financial Intelligence Centre is proposing an amendment to the Criminal Procedure Act to legislate their use and that evidence collected can be admissible in court: https://www.fic.na/uploads/Acts/Bills/Second%20Round%20of%20Consultation/Amendments%20to%20Criminal%20 Procedure%20Act%20OPG.pdf
Image 3: Harvested rhino horns offered to the Wildlife Justice Commission by traders in South Africa in July 2021.
Source: Wildlife Justice Commission.
7. Implementing the law
7�1� Financial investigations and seizure of proceeds of crime
Following the money and conducting financial investigations while investigating the predicate wildlife offence are critical to uncover the full extent of criminality, detect other members or entities in the criminal network, and identify the proceeds of crime for confiscation and seizure. 63 Financial investigations and asset seizure and forfeiture are powerful measures to strengthen law enforcement efforts to combat wildlife trafficking; by leading to high-level offenders, depriving criminals of the proceeds of crime, and directly disrupting the financing of further criminal activity, they can change the risk/reward dynamics associated with these crimes. Financial investigations can also provide alternative avenues for prosecution such as money laundering, which often carry higher sentences, thereby enhancing deterrence against serious offenders.
The FATF recommends that proactive parallel financial investigations should be conducted in all cases related to major proceeds-generating offences, 64 and that legislative measures and operational frameworks should enable the confiscation of the proceeds of crime. 65 Measures that enable the confiscation and seizure of proceeds of crime are also a requirement under the UNTOC (Articles 12, 13, and 14).
The analysis identified at least eight of the 19 jurisdictions (42%) have undertaken financial investigations related to wildlife trafficking, and at least four jurisdictions (21%) have confiscated assets or illicit proceeds related to wildlife trafficking. It should be
noted that this research was limited to open-source information, so this finding may not fully represent the use of financial investigations and asset forfeiture among the sample group. However, it indicates there could be limited application of these measures to wildlife trafficking and points to a potential gap in law enforcement efforts. Other recent analysis based on 61 jurisdictions found that at least 67% had reported using financial investigation techniques to prevent, investigate, prosecute, and punish wildlife trafficking. 66
7.2. Joint investigations and international and multiagency cooperation
The UNTOC encourages the development of agreements between jurisdictions that can facilitate joint investigations on a case-by-case basis, or the development of more formal bilateral or multilateral agreements (Article 19). In the absence of such agreements, the UNTOC itself can provide a legal basis for law enforcement cooperation for serious crimes and offences covered by the Convention (Article 27). It also provides for other important international cooperation measures, including mutual legal assistance (Article 18) and extradition (Article 16).
International cooperation is indispensable for addressing wildlife trafficking, as supply chains often span multiple jurisdictions from source to destination. At the national level, joint multiagency investigations are beneficial to bring together expertise and resources from different specialised law enforcement authorities, particularly those that may be better suit-
63 FATF (2020), Following the Money of the Illegal Wildlife Trade to Stop the Trade in Endangered Species and the Laundering of Profits , p.5.
64 FATF International Standards on Combating Money Laundering and the Financing of Terrorism and Proliferation, Recommendation 30.
65 Ibid, Recommendation 4.
66 UNODC (2023), Report pursuant to CCPCJ Resolution 31/1 on Strengthening the international legal framework for international cooperation to prevent and combat illicit trafficking in wildlife , https://www.unodc.org/documents/commissions/CCPCJ/CCPCJ_Sessions/CCPCJ_32/CRPs/ ECN152023_CRP3_e.pdf
ed to complex, transnational investigations. This approach can offer alternative legislative options and alternative law enforcement powers to explore all angles of the criminal scenario. 67
Multistakeholder partnerships between law enforcement agencies, civil society organisations, financial institutions, the transport sector, and academia can also provide valuable technical assistance and capacity building support to assist with investigating transnational wildlife trafficking networks. 68 The importance of such multistakeholder collaboration in preventing and combating transnational crimes that affect the environment has been recognised and encouraged in multiple UN resolutions. 69
The analysis identified a multitude of examples of joint investigations at national and international levels, and international cooperation measures that have been undertaken by jurisdictions for wildlife trafficking cases. At least 17 jurisdictions (89%) have established national coordination bodies such as task forces or inter-ministerial committees to facilitate multiagency joint investigations at the national level. At the international level, many instances of case-specific bilateral cooperation can be identified, such as a controlled delivery between South Africa and Vietnam of a consignment of 138 kg of rhino horn and 3.1 tonnes of suspected lion bones,70 joint cross-border rhino horn trafficking investigations between South Africa and China that resulted in arrests in both countries, 71 and the extradition of suspects from Ugan-
da,72 Kenya,73 and Thailand74 to face wildlife trafficking charges in the United States, to name a few. Most of the 19 jurisdictions in this supply chain have also participated in major regional and global operations such as the Operation Thunder series, Operation Mekong Dragon, and Operation SAMA, and participate in intergovernmental law enforcement bodies such as the Lusaka Agreement Task Force, ASEAN Working Group on CITES and Wildlife Enforcement, and so forth.
Although it is positive that there are increasing examples of joint investigations at the national, bilateral, and multilateral levels, evidence on the ground suggests there is still much more to be done. Intelligence sharing and joint investigations across borders are vital to tackle these crimes holistically across the supply chain, due to the transnational nature of wildlife trafficking, constantly evolving criminal dynamics, and crime displacement. Yet international cooperation is one of the most challenging areas for jurisdictions to navigate due to language barriers, differences in legislative and enforcement approaches, and many times a lack of trusted contact points in jurisdictions from different regions. Platforms for international collaboration and information exchange such as the Wildlife Inter-Regional Enforcement (WIRE) meetings coordinated by UNODC and the Regional Investigative and Analytical Case Meetings (RIACMs) organised by INTERPOL provide essential support in this regard and have given rise to various examples of successful cooperation.
67 WJC (2021), Convergence of Wildlife Crime with Other Forms of Organised Crime , p.46.
68 WJC (2025), Disruption and Disarray: An Analysis of Pangolin Scale and Ivory Trafficking, 2015-2024 , p.69.
69 UNTOC Resolution 10/6 on Preventing and combating crimes that affect the environment falling within the scope of the United Nations Convention against Transnational Organized Crime, OPs 13-14; UN General Assembly Resolution 76/185 on Preventing and combating crimes that affect the environment, OP 9.
Establishing criminal offences for acts that cause serious harm and incorporating provisions for effective investigation and prosecution is the first step in the criminal justice chain, but the effectiveness of the law in meeting its objectives depends on how it is implemented and enforced in practice. The present research attempted to identify examples of prosecuted wildlife trafficking cases in each jurisdiction to understand how legislation is implemented in practice, including whether serious offenders receive penalties meeting the UNTOC threshold of four years imprisonment or more. A selection of 10 rhino-related case law examples illustrates how cases involving the same commodity have been handled at different stages of the supply chain. Working with the cases we could find and recognising that for many jurisdictions relevant case law was unavailable, these examples provide some insight into the practical application of UNTOC provisions and highlight some good practices in addressing wildlife trafficking. Challenges and broader considerations, including issues related to law enforcement effectiveness and sentencing, are discussed in the sections following these case studies.
7.3.1. South Africa
Two former rangers in Kruger National Park were arrested in January 2019 for their role in facilitating rhino poaching. They were detected by South African National Parks (SANParks) following information that both rangers were involved in the transportation of poaching suspects to rhino locations in their field section. Vehicle tracking device analysis placed them near the crime scene, and ZAR 41,000 cash was found in one of the ranger’s rooms, which was determined to be payment for his participation in the commission of the crime.
In September 2024, both suspects were sentenced to 20 years imprisonment each,75 with the following sentences running concurrently:76
• Conspiracy to commit a crime – four years imprisonment.
• Hunting two rhinos in a national park – 20 years imprisonment.
• Killing two rhinos in a national park – 20 years imprisonment.
Supply chain role Source
Wildlife commodity Two rhinos
Offence
Conspiracy to commit a crime; hunting two rhinos in a national park; killing two rhinos in a national park
Role of offender Corrupt field rangers
Penalty issued 20 years imprisonment
Maximum penalty in law 10 years imprisonment and ZAR 10 million fine
Good practice: Trusted insiders and corrupt officials play a fundamental role in facilitating wildlife trafficking across the supply chain. They may provide information to criminal groups about the location of wildlife to poach or tip-offs on planned patrols or enforcement efforts, or they may assist in providing permits unlawfully, smuggling shipments through checkpoints and borders, or turning a blind eye. Identifying and rooting out such individuals is crucial to address the collusion and corruption that underpin the wildlife trafficking supply chain.
75 By applying multiple terms of imprisonment concurrently, the court imposed a total penalty that exceeded the maximum sentence stipulated in the legislation.
Offence Poaching of specially protected game (rhino); theft of rhino horn; trespassing
Role of offender Rhino poachers
Penalty issued 13.5 years imprisonment
Maximum penalty in law
77
25 years imprisonment and NAD 25 million77
Five suspects were arrested in December 2016 for rhino poaching on a private farm. Two rhinos (a bull and a pregnant cow) were killed and their horns removed, and two more rhinos were wounded, with only one surviving. One of the suspects died in custody before the trial was concluded. He was also subject to two other pending criminal cases at the time – one related to rhino poaching in Etosha National Park, the other to a robbery involving murder.78 A second suspect was an employee at the farm where the incident occurred.79 In October 2023, the four surviving suspects were each sentenced to serve 13.5 years imprisonment, with the following sentences ordered to run consecutively:80
• Poaching of specially protected game (rhino) –15 years imprisonment; with 5 years suspended for 5 years
• Theft of rhino horn – 6 years imprisonment; with 3 years suspended for 5 years
• Trespassing – 1 year imprisonment; with 6 months suspended for 5 years.
Good practice: The judgement took into consideration the six years and seven months that the suspects had already spent in custody between arrest and verdict. 81 The Namibian Government has recognised several challenges in its criminal justice system, including the increasing backlog of cases each year causing lengthy delays at court, 82 high rates of repeat offenders amongst arrested rhino poachers, 83 and a high degree of variability in the sentencing of rhino cases, particularly between actual poaching cases and conspiracy cases that are detected and intercepted prior to the poaching act occurring. 84 In response, a specialised Environmental Crimes Court was recently established to improve the speed, response, and consistency in handling wildlife crime cases. 85
77 Namibia Nature Conservation Ordinance 1975, s 26(3)(a) on Hunting of specially protected game.
Offence Buying and selling prohibited species; criminal association; money laundering
Role of offender Poaching boss
Penalty issued 27 years imprisonment; 16 years of fines; MT 11 million compensation; MT 9 million of assets forfeited
Maximum penalty in law
16 years corresponding imprisonment and a fine
Simon Valoi, also known as “Navara”, was one of the most notorious and prolific rhino poaching bosses operating in southern Africa. He recruited and armed Mozambican poaching teams and organised their incursions into Kruger National Park in South Africa to hunt and kill rhinos. Intelligence suggests Navara was responsible for hundreds of rhino deaths in South Africa over years of operation and supplying the horns
to traffickers for smuggling to Asia. Despite being wanted in South Africa in relation to previous murders and theft, he could move freely across the border, protected by his connections with police and immigration authorities. The WJC supported the National Criminal Investigation Service (SERNIC) in Mozambique with an intelligence-led investigation into Navara, resulting in his arrest in July 2022 in Maputo in possession of 2.9 kg of rhino horn. 86 In August 2024, he was convicted for buying and selling prohibited species, criminal association and money laundering, and sentenced to 27 years imprisonment, as well as ordered to pay 16 years of fines and MT 11 million in compensation to the state (USD 172,000), in addition to forfeiting assets worth MT 9 million (USD 140,000).
87
Good practice: This case involved collaboration between a law enforcement agency and a civil society organisation to share intelligence and conduct a joint investigation, which can be an effective approach to collect robust evidence in complex transnational cases. In addition to the wildlife offence, Navara was charged and convicted for additional offences of money laundering and criminal association, enabling authorities to address the full scope of criminality in this case. Furthermore, additional penalties of compensation and asset forfeiture were applied, which are enabled under Mozambique’s legislation.
Wildlife commodity 7.1 tonnes of pangolin scales and 850 kg of ivory
Offence Illegal possession, dealing, assembling, storing, smuggling and trading CITES Appendix I species
Role of offender Principal
Penalty issued 6 years imprisonment or NGN 4.7 million fine
Maximum penalty in law 3 years imprisonment and NGN 5 million fine
Phan Viet Chi is a Vietnamese national and was the principal of a well-known and prolific wildlife trafficking network that operated primarily in South Africa, Mozambique, Nigeria, and Vietnam. Intelligence indicates this network was responsible for trafficking many tonnes of rhino horn, ivory, pangolin scales, and tiger and lion products from Africa to Asia over at least a decade of operation. The WJC supported the Nigeria Customs Service (NCS) with an intelligence-led investigation into Chi and his two most trusted lieutenants. In May 2022, NCS arrested the trio in relation to the trafficking of 7.1 tonnes of pangolin scales and 850 kg of ivory, a shipment that had been previously
seized in July 2021. 88 Following their arrests, WJC supported NCS with the analysis of Chi’s seized mobile phones, which led to the identification of other key members of his network who were based in Mozambique. NCS shared this intelligence with SERNIC, resulting in the arrest of Chi’s senior broker and shipper in Mozambique. This suspect was arrested in possession of 9.75 kg of rhino horn, 279 kg of ivory, and 340 kg of lion bone products that he was storing for Chi. In July 2023, Chi and his two lieutenants were convicted in Nigeria on four counts of wildlife trafficking charges and sentenced to six years imprisonment or NGN 4.7 million fine (USD 6,000). 89 They paid the fine and returned to Vietnam, having spent 14 months in custody. In Mozambique, the senior broker was convicted in March 2024 and sentenced to 30 years imprisonment and two years of fines for charges of illegal possession and storage of wildlife products, criminal association, and money laundering.90
Good practice: This case involved collaboration between a law enforcement agency and a civil society organisation to share intelligence and conduct a joint investigation, which can be an effective approach to collect robust evidence in complex transnational cases. Analysis of the seized mobile phones enabled the identification of evidence connected to the primary offence, but it also identified intelligence for further investigations. International cooperation and intelligence sharing between Nigeria and Mozambique led to the arrest of an additional network member and the seizure of more wildlife products belonging to this network.
Offence Unauthorised disposal of protected wild fauna and flora intentionally
Role of offender Pseudo hunter
Penalty issued 1 year imprisonment, with a probationary period of 18 months, and CZK 100,000 fine
Maximum penalty in law 8 years imprisonment
The suspect in this case was a Czech national accused of participating in a rhino horn pseudo-hunting scheme in South Africa. He was found to have taken part in an organised, all expenses paid trip to South Africa in October 2011, where he shot a rhino under the patronage of a local professional hunter. After the hunt, the suspect was paid a modest amount of cash and returned home, leaving the rhino horn hunting trophy behind in South Africa as a “gift”. Subsequent-
ly, in July 2012, the rhino horns were detected by customs officials when they were imported in the name of the accused suspect to Bratislava, Slovakia, with a deliberately low declared value of USD 100.91 Operation Rhino, the Czech investigation that uncovered the pseudo hunting scheme, identified that the horns were to be handed over to a Vietnamese organiser in the Czech Republic, who would smuggle them to Vietnam.92 In February 2023 the suspect in this case was sentenced to one year imprisonment with a probationary period of 18 months, and a CZK 100,000 fine (USD 4,400). The accused appealed against the judgement, with the Supreme Court in November 2023 rejecting the appeal and upholding the penalty issued by the first instance court.93
Good practice: Operation Rhino was a joint investigation between the Czech Republic Police and the General Directorate of Customs from 2010 to 2013, which resulted in the arrests of 12 participants and four organisers involved in the pseudo-hunting scheme.94 The Czech cases have been protracted and complex, with more than 10 years lapsing between detection and conviction, but these efforts have effectively dismantled the network on the Czech side. This case led to the tightening of hunting regulations in South Africa in June 2014 to prevent criminal exploitation and abuse of the trophy hunting industry.95
91 Case file number 7 Tdo 936/2023, Supreme Court of the Czech Republic, accessed at: https://rozhodnuti.nsoud.cz/Judikatura/judikatura_ ns.nsf/WebSearch/2B070A9BD17D98D0C1258AB3001B7EEA?openDocument&Highlight=0
92 Nozina, M. (2020) ‘The Czech Connection: A Case Study of Vietnamese Wildlife Trafficking Networks’ Operations Across Central Europe’, European Journal on Criminal Policy and Research (v.27), pp.272-274.
93 Case file number 7 Tdo 936/2023, Supreme Court of the Czech Republic.
94 Nozina, M. (2020) ‘The Czech Connection: A Case Study of Vietnamese Wildlife Trafficking Networks’ Operations Across Central Europe’, European Journal on Criminal Policy and Research (v.27), pp.272-274.
95 Rademeyer, J. (2016), Tipping Point: Transnational Organised Crime and the ‘War’ on Poaching, Global Initiative Against Transnational Organized Crime , pp.42-47.
7.3.6. Singapore
Supply chain role Transit
Wildlife commodity 34.7 kg of rhino horn
Offence Illegal possession during transit
Role of offender Courier
Penalty issued 2 years imprisonment
Maximum penalty in law 2 years imprisonment96
96
In October 2022, a South African national was arrested at Changi Airport in Singapore transporting two boxes containing 34.7 kg of rhino horn. He was travelling from South Africa to Lao PDR, transiting via Sin-
Image 4: The seizure of 20 pieces of rhino horns weighing 34 kg.
Source: Singapore National Parks Board.
gapore. The investigation identified that this suspect was acting as a courier for an accomplice in South Africa who had organised the consignment and financed the travel. The suspect pleaded guilty to two charges under the Endangered Species (Import and Export) Act for possession of a CITES Appendix I specimen transiting through Singapore without a valid CITES permit. In January 2024 he was sentenced to 24 months imprisonment, which was the maximum sentence available under the edition of the law that was in force at the time of his arrest. This case involved the largest seizure of rhino horn in Singapore to date and received the heaviest sentence issued by Singapore for wildlife trafficking.97
Good practice: This case involved joint investigation between the National Parks Board and Singapore Police Service, and international cooperation with the South African Police Service and INTERPOL to share information and identify other criminal associates connected to the offence at the supply side.
96 Two years imprisonment was the maximum penalty under Singapore’s Endangered Species Act 2006 at the time of this offence. It increased to six years imprisonment and/or a fine not exceeding of SGD 100,000 per specimen (but not exceeding SGD 500,000 in total or the market value of the specimens at the time of the offence), effective as of 1 November 2022.
Penalty issued Five years imprisonment; THB 330 million asset forfeiture
Maximum penalty in law 10 years imprisonment and/or a fine equivalent to 5 times the value of the goods98
Boonchai Bach is a Vietnamese and Thai citizen who allegedly ran a large wildlife trafficking network on the Thai-Lao border, dealing in rhino horn, ivory, pangolin scales, lion and tiger parts, and rosewood timber. He was arrested in January 2018 for allegedly smuggling a shipment of 11 kg of rhino horn into Thailand on a flight from Ethiopia.99 The case was
dismissed from court in January 2019 due to lack of evidence, after the key witness changed his testimony linking Boonchai to the crime.100 Thai authorities continued to pursue the case with follow-up operations targeting non-conviction based asset forfeiture, while prosecutors from the Attorney General’s Office appealed the court decision. In March 2021, the Thai Anti-Money Laundering Office (AMLO) announced that it had seized a hotel, vehicles, land, and other assets, and frozen Boonchai’s bank accounts, suspected to be the proceeds of crime and valued at more than THB 330 million (USD 10.5 million).101 In September 2022, the Thai Supreme Court sentenced Boonchai to five years in prison, although he was not present for the sentencing hearing and is now considered to be a fugitive with a warrant out for his arrest.102
Good practice: The investigation involved a controlled delivery, with Thai police allowing the suitcases containing rhino horn to pass through airport screening and following them to a Thai government official and a relative of Boonchai Bach, who were both arrested.103 Thai authorities also pursued non-conviction based asset forfeiture proceedings to target the proceeds of crime, a powerful tool that will have a significant impact on Boonchai even if authorities are unable to re-arrest him.
98 Thailand Export and Import of Goods Act, section 20 – applying to any person importing restricted or prohibited goods. At the time of this offence, African rhino horns were not recognised under Thailand’s wildlife legislation, so authorities relied on Customs laws to seize African rhino horn shipments.
Maximum penalty in law 5 years imprisonment and USD 20,000 fine
Teo Boon Ching (also known as the Godfather) is a Malaysian national who was a high-level global transporter of large-scale wildlife shipments. Intelligence indicates that he rose to control the transport market from around 2014, providing transportation services for multiple criminal networks in Africa and Asia.104 He used Malaysia as a transit location, and would clear shipments and provide an onwards transfer service to other locations in Asia.105 Ching was arrested by the Royal Thai Police in Thailand in June 2022 as part of a joint operation with the United States Fish and Wildlife Service, and with support from the WJC. He was then extradited to the United States in October 2022 to face charges of one count of conspiracy to commit wildlife trafficking and two counts of money laundering.106 In September 2023, Ching was sentenced to 18 months imprisonment for conspiring to traffic at least 219 kg of rhino horns.107
Image 5: 12 rhino horns purchased from Teo Boon Ching during the undercover investigation. Source: United States Department of Justice.
Good practice: This case involved a joint operation and international cooperation to extradite Ching to the United States to face charges, which was executed under a bilateral treaty between Thailand and the United States, and collaboration between a law enforcement agency and a civil society organisation to share intelligence and conduct a joint investigation. This investigation was made possible partly due to United States legislation that prohibits the trade in wildlife products that were illegally sourced or obtained in violation of another jurisdiction’s laws.108 Money laundering charges were initially laid in addition to the wildlife trafficking conspiracy offence, although eventually Ching was only convicted for the wildlife offence. Considering the use of alternative legislation where relevant is a good practice to address the full scope of the criminal scenario and tackle transnational organised crime.
104 WJC (2022), Rhino horn trafficking as a form of transnational organised crime, 2012-2021 , p.102.
108 United States of America, Lacey Act section 3372.
7.3.9. Vietnam
Supply chain role Transit/destination
Wildlife commodity 204 kg of ivory
Offence Illegal trade of ≥ 90 kg of elephant tusks
Role of offender Lead broker
Penalty issued 11 years imprisonment
Maximum penalty in law 15 years imprisonment and VND 200 million fine
Nguyen Van Nam (known by his criminal alias Ah Nam) was one of Vietnam’s top wildlife criminals and lead broker for a major criminal network. WJC investigations identified him as being responsible for trafficking a minimum of 477 kg of rhino horn and 17.6 tonnes of elephant ivory from Africa to Vietnam between 2016 and 2019.109 Ah Nam sourced his products from various supply networks in South Africa, Malawi, Angola, Mozambique, Nigeria, and Zambia, and cooperated with specialist transporters (including Teo Boon Ching) to move the shipments to Asia. His customer base was primarily Chinese wholesale traders, and he provided delivery of products from Vietnam to China as part of his service. He was arrested in Hanoi in September 2019 along with two associates in connection with the illegal trade of 204 kg of ivory, and in July 2020 he was sentenced to 11 years imprisonment.110 Ah Nam is one of the highest-level wildlife criminals to have been arrested and convicted in Vietnam.
Good practice: Special investigation techniques were used to investigate Ah Nam’s criminal network and secure his eventual arrest, including undercover investigations, covert surveillance, and buy-bust operations. In total, 13 members of his criminal network were arrested and convicted in Vietnam (including Ah Nam himself) and 129.9 kg of rhino horns and 1,632 kg of ivory seized, causing significant disruption and financial loss to the network. Further arrests and seizures connected to the network also occurred in China.111
Image 6: In August 2017, Ah Nam offered the WJC 76 rhino horns in a single transaction, highlighting the huge volume of product he was able to move.
Source: Wildlife Justice Commission.
109 WJC (2022), Ah Nam: The Downfall of Vietnam’s Wolf of Wall Street , p.19.
111 WJC (2022), Ah Nam: The Downfall of Vietnam’s Wolf of Wall Street , pp.46-50.
7.3.10. China
Supply chain role Destination
Wildlife commodity 245 kg of rhino horn
Offence Smuggling precious and rare wildlife
Role of offender Principal
Penalty issued 15 years imprisonment and RMB 3 million personal property confiscated
Maximum penalty in law Life imprisonment and confiscation of property
In June 2019, following six months of investigation, Xiamen Customs Anti-Smuggling Bureau seized a shipment of 245 kg of rhino horn that was hidden in the auxiliary fuel tank of a deep-sea fishing vessel and arrested five suspects.112 It is the world’s largest reported rhino horn trafficking case. The seizure included 110 whole horns and 35 horn pieces, of which 70 horns contained microchips, indicating they originated from legal stockpiles.113 This case is significant not only for its size, but also for its sophisticated modus operandi previously unseen in wildlife trafficking. The fishing vessel was deployed for the sole purpose of smuggling wildlife products from Mozambique to China, travelling a direct route between the two countries and carrying no other goods. To avoid monitoring, the vessel kept its navigation system and communications turned off for most of the voyage. The five suspects were sentenced in December 2022 as follows:114
• Chen X Ren - the vessel owner and principal of the network, sentenced to 15 years imprisonment and confiscation of RMB 3 million of personal property (USD 430,000).
• Qiu X Ju – recruited the crew members and financed the voyage costs, sentenced to 14.5 years imprisonment and confiscation of RMB 2.8 million of personal property (USD 402,000).
• Wang X Ming – sourced the rhino horns through his contacts in Mozambique, sentenced to 12.5 years imprisonment and confiscation of RMB 2 million of personal property (USD 287,000).
• Liu X Qun – commanded the ship, sentenced to 10 years imprisonment and confiscation of RMB 500,000 of personal property (USD 71,750).
• Ruan X Cheng – supported the sourcing of wildlife products in Africa, sentenced to 4.5 years imprisonment and confiscation of RMB 150,000 of personal property (USD 21,525).
Good practice: Chinese law enforcement authorities conducted a comprehensive and methodical investigation using special investigation techniques including undercover investigations, surveillance, big data analysis, and financial investigation to uncover the workings of this criminal network. This led to the identification and arrests of all key members who played fundamental roles in facilitating the crime. The court judgement indicated that this case led to a number of proactive linked investigations and arrests targeting other associates in the broader network, effectively disrupting and dismantling the entire network.
113 Legal stockpiles of rhino horn can be acquired through dehorning procedures (cutting off the horn at its base from live rhinos), horns collected from natural mortalities, as well as from law enforcement agencies confiscating rhino horns from illegal trade incidents.
114 Full case details were obtained via China Judgements Online: https://wenshu.court.gov.cn
7.4. Application of UNTOC provisions in selected case studies
As noted above, the UNTOC provides valuable tools to facilitate international cooperation in the investigation and prosecution of serious and transnational crimes. Implementing its provisions can assist authorities to collect evidence against hign level criminals and build strong cases, leading to more effective law enforcement efforts. Understanding how and to what extent the UNTOC is being applied to address serious wildlife trafficking cases is a lens through which the effectiveness of law enforcement can be assessed, or to identify where there may be gaps.
The 10 case law examples of rhino-related crimes suggest application of the following UNTOC provisions:
• Article 7 on Measures to Combat Money Laundering – applied in two cases (Mozambique and Thailand/United States), although money laundering was only successfully prosecuted in one case (Mozambique).
• Article 9 on Measures Against Corruption – applied in one case (South Africa).
• Article 12 on Confiscation and Seizure – applied in three cases (Mozambique, Thailand and China).
• Article 16 on Extradition – applied in one case (Thailand/United States). A bilateral treaty was used as the basis for cooperation in this case. The UNTOC encourages States Parties to conclude bilateral and multilateral agreements or arrangements to strengthen cooperation, and Article 16 presumes the existence of extradition treaties.115
• Article 19 on Joint Investigations – applied in at least two cases at the international level (Nigeria and Thailand/United States) and applied in at least three cases at the national level (Singapore, Czech Republic, and Thailand).
• Article 20 on Special Investigative Techniques – applied in at least six cases (Mozambique, Nigeria, Thailand, Thailand/Untied States, Vietnam and China).
• Article 27 on Law Enforcement Cooperation –applied in at least two cases (Singapore and Nigeria).
• Article 28 on Collection, Exchange and Analysis of Information on the Nature of Organised Crime –multistakeholder cooperation between States and a civil society organisation was applied in four cases (Mozambique, Nigeria, Thailand/United States, and Vietnam), and cooperation with an intergovernmental organisation in one case (Singapore), contributing to this measure.
As noted in the Research Methodology, comprehensive prosecution data was unavailable for many of the 19 jurisdictions. The case studies therefore serve as examples of good practices and challenges to inform ongoing multilateral discussions, but do not allow for definitive conclusions on the application of UNTOC across all jurisdictions in this supply chain.
7.5. Case study insights on sentencing
These 10 case law examples of rhino-related crimes demonstrate an array of wildlife offences across the supply chain including illegal hunting, poaching, possession, trade, unauthorised disposal and import, as well as ancillary offences including smuggling, conspiracy, criminal association and money laundering. The quantity of rhinos or rhino horns involved, as one indicator of the seriousness of the offence, ranged from 6 kg of rhino horns (representing a single rhino) to 245 kg of rhino horns (representing more than 55 rhinos). The offenders involved in the cases spanned the spectrum of criminality, from low-level courier and pseudo hunter to mid-level poaching boss and colluding rangers, and high-level traffickers, transporters and criminal network leaders.
115 UNTOC Article 16(1) specifies that extradition shall apply to the offences covered by the Convention, namely Article 5 (participation in an organised criminal group), Article 6 (laundering of proceeds of crime), Article 8 (corruption), and Article 23 (obstruction of justice), as well as serious crimes as defined by Article 2. Article 16(3) further specifies that “each of the offences to which this article applies shall be deemed to be included as an extraditable offence in an extradition treaty existing between States Parties”.
Penalties in these cases ranged from one year to 27 years imprisonment. Three cases applied multiple terms of imprisonment that resulted in the total penalty being higher than the maximum stipulated in the legislation (South Africa, Mozambique, and Nigeria); although in the Nigeria case, the option of a fine in lieu of imprisonment meant that it was ultimately sanctioned with a fine. Six cases applied penalties that were below the maximum level provided in legislation, and one case received the maximum penalty (Singapore). In three cases, confiscation and forfeiture of assets were ordered in addition to prison penalties (China, Thailand, and Mozambique). Overall, six of the 10 cases applied penalties that met the UNTOC threshold for serious crimes of at least four years imprisonment (South Africa, Namibia, Mozambique, Thailand, Vietnam and China).
Sentencing is a complex matter, and judges must consider and weigh various mitigating and aggravating factors unique to each case when deciding the degree of punishment within the minimum and maximum limits of the offence as defined by law. A wide range of sentencing outcomes is therefore to be expected across this sample of 10 cases. Nevertheless, some disparity can be observed in approaches to penalisation across the supply chain, demonstrating a concern that penalties for high-level wildlife traffickers are often disproportionately low compared to the scale of their operations and the profits derived from wildlife crime, falling below what is needed to deter organised criminal activity.
Among the four cases that were penalised below the UNTOC threshold, two cases (Nigeria and Thailand/ United States) demonstrated clear characteristics of serious crime. Both cases involved high-level offenders at the helm of well-established criminal enterprises, operating transnationally as part of organised crime groups, and trafficking large-scale quantities of contraband. However, both cases were finalised with comparatively low penalties: NGN 4.7 million
fine in Nigeria (USD 6,000 equivalent at the time) in lieu of six years imprisonment, and 18 months imprisonment in the Thailand/United States case. This stands in stark contrast to the poaching-related cases in South Africa, Namibia and Mozambique, which received some of the highest penalties across the 10 cases (20 years, 13.5 years and 27 years imprisonment respectively) despite involving comparatively lower-level offenders and smaller quantities of contraband than the trafficking-related cases.
This disparity is at least partly a symptom of the uneven approach to penalisation in the legislation among these jurisdictions, as noted earlier in this paper. Even if the maximum terms of imprisonment were applied in the Nigeria and Thailand/United States cases, the penalties would still be significantly lower than those in the South Africa, Namibia and Mozambique cases, which have much higher penalty levels in their legislation. However, allowing fines to substitute for custodial sentences in cases with high-level offenders significantly weakens the proportionality of the penalty given the vast profits that can be derived from wildlife trafficking. Directly related to the Thailand/United States case, other analysis identified that penalties for wildlife offences are often far lighter than those imposed for other forms of transnational organised crime, such as drug trafficking or money laundering, even when the illicit products involved are of comparable monetary value, which fails to reflect the organised, transnational nature of wildlife trafficking.116
The disparity observed in the case law examples also points to the challenge of disproportionately punitive measures in addressing wildlife crimes, particularly if law enforcement efforts are misdirected at lower-level offenders, which can lead to overcriminalisation and adversely affect Indigenous Peoples and local communities.117 In several southern African countries, law enforcement efforts have traditionally focused on the poaching level rather than higher
116 International Wildlife Trust (2024), Effective Federal Sentencing in Wildlife Trafficking Cases , pp.2-3. For example, in the United States, a wildlife trafficker responsible for USD 10 million worth of illegal products might face a guideline sentencing range of 46 to 57 months, while a drug trafficker handling the same value of cocaine would likely face 108 to 135 months.
117 GI-TOC (2025), A New Protocol for the UNTOC? p.15.
up the criminal value chain. In many cases, poachers have been sentenced harshly for their crimes,118 while there are various examples of cases involving higher-level suspects that have been delayed in the court system for many years.119 It can be observed that high sentences for lower-level offenders in rhino poaching cases have done little to slow down the poaching problem,120 while there are also reports of high rates of re-offending amongst arrested rhino poachers in some jurisdictions.121 This misalignment in focus means that those who sustain and profit most from the trade – the high-level traffickers – are not held to account. Lasting disruption and deterrence require consistent application of strong custodial sentences and asset forfeiture against high-level actors, ensuring both the removal of key figures from criminal networks while simultaneously dismantling the financial incentives that sustain the trade.
These dual aspects of sentencing disparity – between high-level and low-level offenders, and across jurisdictions – are further exacerbated if prosecutors or the judiciary lack awareness of the criminal dynamics in wildlife supply chains to differentiate between more serious and less serious crimes and apply sentences proportionate to the gravity of the crime.
Several jurisdictions have introduced measures to try to resolve this challenge, such as establishing specialised courts for environmental crimes,122 introducing specialised teams of prosecutors to handle environmental cases,123 and using tools such as species victim impact statements to assist with presenting cases in court.124 Specialised environmental courts can strengthen the effectiveness of adjudications by ensuring that judges are environmentally literate, possessing specific knowledge of and experience in environmental issues and legal and policy responses.125 Similarly, the appointment of specialised prosecutors can improve the presentation of complex and technical evidence at court by ensuring that prosecutors are trained and experienced in the technicalities of environmental issues and laws.126 Species victim impact statements can be a useful expert evidence tool to assist prosecutors with preparing prosecution statements and in explaining harms and damages related to the case to inform sentencing decisions.127 These types of measures could also result in fewer delays at court, decreased costs of litigation and greater uniformity in jurisprudence.128 Lengthy delays at court increase the risk of defeating justice, such as through the loss or destruction of evidence, assets being moved beyond the reach of the law, and increased complexity and costs of the trial caused by the delays.129
118 For example, three poachers who were sentenced to a combined 105 years imprisonment in South Africa in September 2021 for killing three rhinos: https://earth.org/3-poachers-received-combined-105-years-sentencing-for-rhino-poaching-in-south-africa/
119 For example, game farmer Dawie Groenewald who was first arrested in 2010 and again in 2021, and former police officer Joseph “Big Joe” Nyalunga who was first arrested in 2010 and again in 2011, 2012, 2018 and 2023. Refer to: https://oxpeckers.org/2021/02/sas-rhino-convictions/ ; WJC (2023), Convergence of Wildlife Crime with Other Forms of Organised Crime: A 2023 Review , pp.19-23.
121 Namibia (2023), National Report on Wildlife Protection and Law Enforcement , p.16.
122 For example, specialised environmental courts have been established in China, Kenya, Malaysia, Namibia, South Africa and Uganda, among others. Globally, more than 2,100 specialised environmental courts and tribunals have been established in 67 countries; see: UNEP (2022), Environmental Courts and Tribunals: A Guide for Policymakers , p.i.
123 For example, specialised teams of prosecutors to handle environmental cases are deployed in China and Mozambique, among others.
124 For example, species victim impact statements have been used in Hong Kong SAR, South Africa and Zambia, see: Gl-TOC (2024), Species Victim Impact Statements: Giving a Voice to Unheard Victims of Environmental Crime , p.4.
125 Preston, B.J. (2013), Characteristics of Successful Environmental Courts and Tribunals , p.17.
126 WJC (2022), Rhino horn trafficking as a form of transnational organised crime, 2012-2021 , p.169.
127 GI-TOC (2024), Species Victim Impact Statements: Giving a Voice to Unheard Victims of Environmental Crime , p.6.
128 UNEP (2016), Environmental Courts & Tribunals: A Guide for Policy Makers , p.v.
129 Dyson, J. ‘Delay too often defeats justice’, in Handbook for Judicial Officers , Judicial Commission of NSW (2021), p.234.
7.6. Law enforcement effectiveness
Ultimately, one of the main objectives of law enforcement is to prevent and deter crime. Criminological research suggests that strong sentences on their own cannot deter crime; there must also be sufficient probability that the punishment will be incurred if the crime is committed.130 It is for this reason that perceptions of the certainty of being caught and punished are a more powerful deterrent than increasing the severity of the punishment.131 132 133 Consistent and well-targeted law enforcement efforts therefore play a vital role in deterring crimes, to build that perception of certainty.134
However, a range of issues can impede law enforcement effectiveness, including under-resourcing and lack of capacity of investigation agencies; wildlife traf-
ficking not being taken seriously enough by policy makers and the criminal justice sector compared to traditional organised crimes; and a lack of awareness of the dynamics or extent of wildlife trafficking, contributing to low rates of detection.135 Other analysis has also found that many law enforcement agencies investigating crimes that affect the environment face capacity constraints, lack sufficient personnel, specialised training, funding and equipment.136 Furthermore, when several agencies have shared mandates for investigating wildlife crimes, a lack of clarity in the roles and powers of each agency can create “grey areas” and inhibit law enforcement effectiveness.137 When these factors are combined, they can significantly impact the ability of legislation to yield a deterrent effect.138
Image 7: Malaysian customs officers with a rhino horn seizure, March 2017. Source: FP Photo/Manan Vatsyayana, https://theaseanpost.com/article/rhino-horn-seizure-thailand-leads-major-trafficking-syndicate.
130 Nagin, D.S. (2013) Deterrence in the Twenty-First Century, Crime and Justice (42), p.206.
131 Wellsmith, M. (2011), Wildlife Crime: The Problems of Enforcement, European Journal on Criminal Policy and Research (17), p.140.
132 National Institute of Justice (2016), Five things about deterrence, https://nij.ojp.gov/topics/articles/five-things-about-deterrence
133 Wilson, L. and Boratto, R. (2020), Conservation, wildlife crime and tough-on-crime policies: Lessons from the criminological literature, Biological Conservation 251, p.3.
134 National Institute of Justice (2016), Five things about deterrence, https://nij.ojp.gov/topics/articles/five-things-about-deterrence
135 Wellsmith, M. (2011), Wildlife Crime: The Problems of Enforcement, European Journal on Criminal Policy and Research (17), p.134.
136 UNODC (2025), Guide for the thematic discussion on addressing new, emerging and evolving forms of crime, including crimes that affect the environment, smuggling of commercial goods and trafficking in cultural property and other crimes targeting cultural property , paragraphs 13, 15, and 82. Accessed at: https://docs.un.org/en/E/CN.15/2025/7
137 UNEP (2022), E nvironmental Courts and Tribunals: A Guide for Policymakers , p.9.
138 Wellsmith, M. (2011), Wildlife Crime: The Problems of Enforcement, European Journal on Criminal Policy and Research (17), p.139.
Making the case for deterrence through consistent and targeted law enforcement action
Measuring deterrence and the impact of law enforcement efforts is complicated. Wildlife seizures, arrests, prosecutions, and convictions are commonly used metrics, but quantitative data alone provides a limited picture. For instance, seizure data only reveals the detected and reported instances of illegal trade where there has been law enforcement effort, representing an unknown fraction of the real quantities of wildlife products being trafficked. On the other hand, not all arrests carry equal strategic value, and the removal of one principal at the head of the network far exceeds the impact of arresting numerous low-level offenders. Qualitative assessments are invaluable as another form of data that can provide more context on the criminal dynamics. Qualitative data can include monitoring shifts in criminal methodologies as a reaction to law enforcement efforts, crime displacement patterns, the withdrawal of actors from illicit trade, market price fluctuations, and testimony from the traffickers themselves. Triangulation of the quantitative and qualitative data can build a more comprehensive understanding of the law enforcement impact and any deterrence effect.
Using this more nuanced measurement approach, findings from the WJC’s investigations align with those from the criminological research. The WJC’s findings indicate that consistent and strategic law enforcement efforts in hotspot trafficking locations can trigger changes in the perceived level of risk associated with wildlife crime and generate a meaningful deterrence effect. One of the clearest examples of deterrence in the wildlife trafficking landscape can be observed in Nigeria, which is a significant exit point for pangolin scale and ivory trafficking from Africa to Asia. Thanks to concerted efforts in recent years involving national law enforcement authorities and support from multiple stakeholders, including international organisations and civil society, Nigeria is turning the situation around. By overlaying quantitative and qualitative data collected during investiga-
tions, we can build a picture of the impact of these law enforcement efforts.
The WJC commenced a partnership with NCS in July 2021, providing intelligence analysis support, mentoring for conducting undercover investigations and using other special investigative techniques provided for under the UNTOC, and evidentiary assistance for prosecutions. Through long-running intelligence-led investigations and joint operations, the NCS-WJC partnership has strategically targeted the crime bosses and other high-value individuals playing key strategic roles in the criminal networks, such as shipping facilitators and corrupt contacts. This has yielded tangible results: as of August 2025, 42 suspected wildlife traffickers have been arrested with 12 convictions so far, 13 major criminal networks have been disrupted, and over 25 tonnes of pangolin scales and more than one tonne of ivory have been seized.
Despite the relatively low penalties available under the current Nigerian law, consistent law enforcement pressure of arrests and seizures is leading traffickers to view their operations as increasingly dangerous and re-evaluate the risk/reward equation. Current intelligence indicates the ability of Lagos-based organised crime networks to ship significant quantities of ivory and pangolin scales from Apapa Port to Asia has been severely disrupted. The networks are in turmoil, with a culture of fear and distrust permeating all points of the supply chain.139 Analysis of wildlife seizure data provides another data point to indicate the level of disruption. Globally, pangolin scale and ivory seizures have plummeted since the peaks in 2019, and there has not been a major pangolin scale seizure at any seaport for more than three years or airport for more than five years. The relative absence of seizures at the demand side of the supply chain is further indication that organised crime networks could have a diminished capacity to move their goods out of Africa.140
139 WJC (2025), Disruption and Disarray: An Analysis of Pangolin Scale and Ivory Trafficking, 2015-2024 , pp.61-63.
140 Ibid, pp.38-39.
8. Conclusions and recommendations
This paper analyses the extent to which the UNTOC has been incorporated in domestic legislation and implemented in relation to wildlife trafficking among the 19 jurisdictions most involved in the rhino horn trafficking supply chain, to provide insight and perspectives on the extent to which wildlife trafficking is treated as a serious crime. While considerable progress has been made in criminalising wildlife offences, harmonising legislation across jurisdictions, and strengthening penalties, gaps remain in legislation, enforcement, sentencing, and capacity to address high-level traffickers and organised networks operating across borders. Much of the progress observed may be attributable to the heightened attention to this supply chain following the rhino poaching crisis leading to many of the most-affected jurisdictions updating their legislation in recent years. The information available therefore provides valuable lessons on best practices and challenges, which are relevant not only to the rhino horn supply chain but also to the wider fight against wildlife trafficking and other environmental crimes.
The analysis underscores that effective responses require not only strong legislation aligned with the UNTOC framework but also consistent and coordinated implementation. However, the limited jurisprudence available in some jurisdictions indicates that implementation continues to be a key challenge. Strategic application of investigative and financial tools, international cooperation mechanisms, robust judicial capacity, and proportionate sentencing – especially the consistent imposition of strong custodial penalties on high-level traffickers – are all critical to disrupting and dismantling organised wildlife trafficking networks and creating meaningful deterrence. Systemic challenges – including the limited species coverage of CITES, the absence of a universal definition of wildlife crime at the international level or comprehensive list of offences to criminalise, and the lack of explicit reference to wildlife or environmental crime in the UNTOC – highlight the need for more targeted legal and institutional frameworks. Because UNTOC’s provisions do not automatically extend to wildlife trafficking, their application depends on whether States
have classified such offences as “serious crimes” in domestic law and committed the political will and resources needed for enforcement. In practice, this creates uneven implementation: where penalties fall below the UNTOC threshold, States cannot invoke its mechanisms, even against well-organised, transnational criminal networks.
Building on these findings, this paper sets out key recommendations to close legislative and operational gaps, enhance enforcement, and ensure more effective, proportionate, and consistent responses to wildlife trafficking globally:
1. Strengthen domestic legislation (including incorporation of key UNTOC provisions) and ensure harmonisation
• Key offences that should be criminalised in domestic legislation include activities related to illegal hunting/killing, trade (sale and purchase), trafficking/smuggling (illegal import, export, and re-export), possession, captive breeding, transportation, and processing, as well as attempts to commit such offences. Corporate liability is another critical area, and given that corporate actors are often linked to more serious crimes committed at a commercial scale, jurisdictions should consider provisions that allow for higher penalties for offences committed by corporations. Harmonisation across jurisdictions, particularly among main source, transit, and demand locations, on these offences is essential to satisfy dual criminality requirements and facilitate the use of UNTOC provisions for joint investigations, mutual legal assistance, and extradition, as well as to prevent displacement of crime to countries with
weaker laws or enforcement. This research found a high degree of harmonisation across 19 jurisdictions, although there were some minor gaps for the criminalisation of captive breeding, processing, and attempts to commit an offence. These findings suggest that these areas may require additional attention from governments when reviewing their legislation, and additional assessments including other jurisdictions and supply chains would be necessary to identify additional gaps.
• Domestic legislation should criminalise serious forms of wildlife trafficking in line with the UNTOC definition of “serious crime” (offences punishable by at least four years’ imprisonment), enabling the use of UNTOC provisions for investigation, prosecution and international cooperation. While most jurisdictions in this research already meet this threshold, a small contingent are operating with older legislation where penalties are less than four years imprisonment. Moreover, beyond this research, UNODC data indicate that fewer than half of UN Member States provide maximum penalties of four years or more.141 It is noted that even if most jurisdictions along a wildlife trafficking supply chain have legislation aligned with UNTOC standards, gaps in a few jurisdictions can significantly hinder international cooperation and limit the effective use of UNTOC international cooperation mechanisms. Thus, jurisdictions should consider revising their legislation to ensure the penalties meet this threshold, thereby enabling coordinated, cross-border action against wildlife trafficking, strengthening both deterrence and the ability to engage UNTOC mechanisms.
• Consider adopting legislative provisions that prohibit the trade in wildlife products that were obtained in contravention of another jurisdiction’s laws.142 Such provisions reflect the principle of legal comity, under which jurisdictions recognise and give effect to each other’s laws.143 They are important to close a critical loophole that currently allows
criminals to profit from illegally sourced specimens once they are exported, and can help to safeguard nationally protected species that are not necessarily protected by CITES, while reinforcing accountability in transnational wildlife trafficking.
• Domestic legislation should clarify mandates and enforcement powers of relevant agencies to avoid duplication or “grey areas” when multiple bodies share jurisdiction. Agencies responsible for investigating serious wildlife crimes should have the necessary powers, expertise, and resources to investigate transnational organised crime. This often requires the leadership of traditional law enforcement agencies alongside environmental authorities in serious wildlife trafficking cases.
• Wildlife trafficking should be recognised as a predicate offence for money laundering, allowing the application of anti-money laundering frameworks. Jurisdictions could consider adopting an “all crimes” approach to predicate offences, to enable the broadest possible application of the legislation.
• Special investigative techniques such as undercover operations, controlled deliveries, and covert surveillance should be expressly authorised in legislation for serious wildlife trafficking cases, to ensure that they are used consistently and that evidence obtained through the use of these techniques is admissible in court. At a minimum, legislation should not prevent the use of such techniques in relevant cases.
• Domestic legislation should provide for additional penalties against high-level offenders involved in serious crimes, ensuring that sanctions directly contribute to remedying the harm caused by their activities. For example, this could include fines to cover costs related to storage, care, disposal or repatriation of wildlife specimens, or compensation for the damage caused by the offence.
141 UNODC (2025), Global Analysis on Crimes that Affect the Environment – Part 1: The Landscape of Criminalization , p.31.
142 For examples of legislative provisions, see Wildlife Conservation Society (2025), Drafting guide: Preventing illegal trade in nationally protected, non-CITES-listed species
143 GI-TOC (2025), A New Protocol for the UNTOC? p.20.
2. Strengthen implementation
and use of UNTOC provisions
• While legislation has improved significantly in recent years, implementation and enforcement remain the weakest links. Jurisdictions should make full use of UNTOC provisions to support investigations, evidence collection, and prosecution, helping achieve more appropriate sentencing outcomes.
• Strategic and consistent law enforcement efforts are essential to create deterrence and ensure interventions are prioritised effectively. Law enforcement and judicial systems must ensure that high-level offenders face a genuine risk of arrest, prosecution, and conviction, so that the threat of significant punishment is credible and consistent, while avoiding overly focusing resources on lower-level offenders.
• Greater and more consistent use of special investigative techniques (including controlled deliveries, of which there are very few known examples of use) is needed for serious wildlife trafficking cases.
• Expanded use of financial investigations, asset confiscation, and non-conviction-based forfeiture (where legislation allows), is needed to target illicit profits and dismantle the economic incentives driving wildlife trafficking. Limited application of these measures was identified among the jurisdictions studied, suggesting gaps in law enforcement practice.
• Where relevant and possible, high-level offenders should also be charged for money laundering and criminal association.
• Given the central role of corruption and collusion by trusted insiders, measures should be taken to detect, prevent, and prosecute corruption in wildlife trafficking supply chains.
• States should strengthen the use of international cooperation mechanisms under UNTOC, including joint investigations, intelligence sharing, and mutual legal assistance. While examples of cooperation exist, greater systematic efforts are required. Platforms for collaboration and information exchange such as regional or inter-agency meetings can play a critical role in facilitating rapid coordination, supporting ongoing investigations, and fostering trust among law enforcement agencies. Successful prosecutions have been inconsistent and far fewer than the scale of trafficking would suggest. In this regard, promoting prosecution outcomes and ensuring that prosecution information is publicly accessible can play a key role in evaluating how effectively legislation is implemented, while also supporting prevention efforts and raising public awareness of the gravity of the threat of serious wildlife offences.144
• States should continue leveraging Article 30 of UNTOC (technical assistance and economic development) to strengthen law enforcement capacity, provide adequate resources, and improve coordination between agencies, including through the UNTOC Working Group of Government Experts on Technical Assistance.145 Many law enforcement agencies investigating wildlife trafficking face capacity constraints, lack sufficient personnel, specialised training, funding and equipment. Multistakeholder partnerships between law enforcement agencies, civil society organisations, financial institutions, the transport sector, and academia can also provide valuable technical assistance and capacity building support to assist with investigating transnational wildlife trafficking networks.
144 UNTOC Article 31(5) encourages States Parties to promote public awareness regarding the existence, causes and gravity of and the threat posed by transnational organised crime.
• Sentences should reflect the seriousness of the offence, degree of harm caused, and culpability of the offender. An appropriate penalty should be fair and just, while aiming to rehabilitate the offender, reduce the risk of reoffending, and deter other people from committing similar offences.
• High-level traffickers should face proportionate custodial sentences, with the possibility of additional penalties (compensation, asset forfeiture) if relevant to the case, without the option of substituting fines in lieu of imprisonment. Low fines risk being treated merely as a cost of doing business rather than a meaningful penalty, given the vast profits that high-level traffickers can derive from the trade, significantly undermining proportionality and deterrence. Penalties for high-level offenders should be comparable to those imposed for other forms of transnational organised crime, such as drug or arms trafficking, to reflect the organised, profit-driven, and highly damaging nature of wildlife trafficking.
• At the same time, over-criminalisation of low-level offenders (e.g. subsistence poachers) should be avoided, ensuring fairness while maintaining focus on disrupting the higher levels of criminal networks. Restorative justice or alternative penalties (such as community service) may be more appropriate in such cases, where legislation allows.
4. Support the judiciary to improve adjudication of cases
• Specialist training for prosecutors and judges is essential to build environmental literacy and strengthen the handling of complex wildlife cases.
• The establishment of specialised environmental courts or appointment of specialised prosecutors can improve the consistency, efficiency, and quality of case outcomes.
• The use of sentencing guidelines, expert witnesses, and species victim impact statements can assist courts in assessing the seriousness of harm and tailoring proportionate sentences.
• These measures can also reduce litigation costs, improve jurisprudential coherence, and ensure more effective deterrence across jurisdictions.
It is hoped that these recommendations will inform multilateral policy discussions, including the IEG process, on how to more effectively prevent and combat serious forms of wildlife trafficking. Implementing these measures would enable States and the international community to build a more coherent, coordinated, and effective response, embedding wildlife trafficking firmly within the framework of transnational organised crime.
While some recommendations could be operationalised through existing mechanisms, others may benefit from the development of a dedicated legal instrument with provisions explicitly applying to crimes that affect the environment (including wildlife trafficking), such as an additional protocol to the UNTOC.146 Such an approach could ensure that crucial UNTOC provisions apply to transnational organ-
146 For examples of draft provisions, see Global Initiative to End Wildlife Crime, Form and content of a possible Protocol on the illicit trafficking of wildlife.
ised wildlife crime regardless of the penalty level in domestic legislation, thereby addressing limitations such as the “serious crime” threshold, and ensuring that UNTOC application and implementation is not solely dependent on political will. A dedicated protocol would automatically trigger and enhance the application of all UNTOC mechanisms in tackling crimes that affect the environment, including wildlife trafficking. It could also provide a clear definition of wildlife crime and a comprehensive list of offences to be criminalised domestically, promoting legislative harmonisation and strengthening international cooperation. However, even in this context, it will be important to retain flexibility to accommodate diverse national contexts. In this regard, the ongoing work of the IEG provides a timely platform for consolidating these efforts and identifying opportunities to strengthen the international framework for crimes that affect the environment, including wildlife crime.
In parallel, interim measures such as a permanent review process, working group, or through an extension of the IEG’s current mandate, to monitor UNTOC implementation for wildlife trafficking and other crimes that affect the environment would be beneficial to assess gaps, provide technical assistance, and support further research. This could also maintain momentum, inform more comprehensive analyses of UNTOC implementation across different jurisdictions and commodities, and support sustained political and operational engagement.
Together, these approaches could offer both immediate and long-term pathways to strengthen legislation, enforcement, and prosecution outcomes in wildlife trafficking cases, reinforcing a global, coordinated effort, and helping to address one of today’s most pressing conservation and security challenges.
9. Appendix I
Table 2: Some examples of the international policy framework guiding efforts to strengthen legislation and enforcement measures, and to impose appropriate penalties for wildlife trafficking.
UN body
UN General Assembly
Relevant resolutions and commitments
The General Assembly has adopted seven resolutions on tackling wildlife trafficking: 69/314 in 2015, 70/301 in 2016, 71/326 in 2017, 73/343 in 2019, 75/311 in 2021, 77/325 in 2023, and most recently 79/313 in 2025. In all resolutions, Member States committed to adopt effective measures to prevent and counter wildlife trafficking, including strengthening legislation and recognising wildlife offences involving organised crime groups as serious crimes in accordance with their national legislation and in line with the UNTOC definition. Resolution 79/313 further urges Member States to use special investigative techniques, consistent with Article 20 of UNTOC, to prevent, investigate, prosecute and punish wildlife trafficking crimes.
The General Assembly has also adopted resolutions on crimes that affect the environment, which also includes wildlife trafficking, such as Resolution 76/185 in 2021. This resolution highlights UNTOC and UN Convention against Corruption (UNCAC) as important instruments to combat these crimes. It also calls on Member States to recognise crimes that affect the environment as serious crimes in accordance with their national legislation and the UNTOC definition, and to build capacity of law enforcement and criminal justice authorities to effectively prevent, detect, investigate, prosecute and punish these crimes.
ECOSOC
In 2001, Resolution 2001/12 urged Member States to ensure wildlife trafficking is established as a criminal offence in their national legislation. This was followed by Resolution 2003/27, which urged Member States to ensure that wildlife offences are punishable by appropriate penalties that take into account their serious nature. In 2011, Resolution 2011/36 invited Member States to consider making wildlife trafficking a serious crime in accordance with their national legislation and the UNTOC definition. In 2013, Resolution 2013/40 encouraged Member States to ensure that relevant criminal laws are in place, including appropriate penalties and sanctions, and that wildlife trafficking involving organised crime groups is recognised as a serious crime in accordance with the UNTOC definition.
CCPCJ
The CCPCJ has adopted several resolutions related to wildlife trafficking, including Resolution 16/1 in 2007 and Resolution 23/1 in 2014, which both called on Member States to strengthen legal frameworks and make use of UNTOC tools. More recently, Resolution 28/3 adopted in 2019 called upon Member States to strengthen legislation, enforcement and criminal justice responses, and in appropriate cases to make wildlife trafficking a serious crime in accordance with their national legislation and the UNTOC definition. In 2022, Resolution 31/1 invited Member States to provide their views to UNODC on possible responses, including the potential of an additional protocol to the UNTOC, to address any gaps that may exist in the current international legal framework to prevent and combat illicit trafficking in wildlife. Resolution “Tackling illicit trafficking in wild fauna and flora, including timber and timber products, the illegal mining of and illicit trafficking in minerals and precious metals, the illicit trafficking in waste and other crimes that affect the environment” in 2025 encourages Member States to criminalise a range of wildlife offences in their domestic legislation, including inter alia the unlawful capture, sale, acquisition, import, export, transportation and possession of wildlife; and to contribute to the Intergovernmental Expert Group on Crimes that Affect the Environment.
UNTOC
Resolution 10/6 in 2020 affirmed that UNTOC is an effective tool to combat crimes that affect the environment and called on States parties to make such crimes serious crimes in appropriate cases, in accordance with their national legislation and the UNTOC definition. Resolution 11/3 in 2022 reiterated those commitments. In 2024, Resolution 12/2 reiterated recommendations on the criminalisation of crimes that affect the environment; while Resolution 12/4 urged States parties to adopt effective measures to prevent and combat crimes that affect the environment by strengthening inter alia legislation, criminal justice responses and law enforcement efforts. It also established the Intergovernmental Expert Group on Crimes that Affect the Environment as a new process to review the implementation of UNTOC in addressing crimes that affect the environment, identify gaps in the international legal framework, and consider potential responses under the UNTOC to prevent and combat such crimes.
CITES
Resolution Conf. 11.3 (Rev. CoP19) on Compliance and Enforcement recommends Parties to adopt and apply sanctions that are appropriate to the nature and gravity of violations, ensuring they are sufficient to address the challenges of investigating illegal wildlife trade and punishing the perpetrators. It also recommends making wildlife trafficking involving organised criminal groups a serious crime, in accordance with their national legislation and the UNTOC definition.
