Stopping the Selling: Examining the Shortfalls of the Fight against the Illicit Ivory Trade

Marissa Bruder, Michelle Kaplun, Rob Maxey, and Breana Stringer, ILLICIT FINANCE

September 20, 2020


The Counterterrorism Group continues to assess the growing concern related to illicit ivory trade as it poses a global threat to many important ecological and humanitarian efforts, including species conservation, local and regional development projects, and international security infrastructure. This is an extremely lucrative business by nature, which serves to protect the identity of money launderers and smugglers from the eye of law enforcement officials. The secrecy of the ivory market creates an appeal for terrorist groups to partake in trafficking ivory as a way to finance their operations. However, this presents an obstacle for combatting the trade, as well as for governments and law enforcement officials seeking to prevent such activities within and across borders. While laws and developments have been made by some countries to deploy harsher punishments, the fight to stop financing schemes through illicit ivory trade is a long way from being solved at domestic and international levels because of the persisting demand for ivory.


The illicit ivory trade, like other wildlife trafficking, poses an extreme threat to both species conservation efforts, and to the development and security of areas in which it takes place. Much of this is the result of the illicit financial profits made by ivory traffickers, whose gains constitute a danger to the livelihoods of locals. For instance, poaching elephants robs communities of a species that plays a vital role in maintaining the local ecosystem, as well as support of ecotourism industries, which often comprise a significant portion of a region’s economy.[1] This is especially devastating to regions of the world that continue to rely on the informal economy as a primary source of revenue. Since the illicit ivory trade takes place primarily in such regions, it is important to note that the consequences, when applied to countries struggling with infrastructure, corruption, and other factors, are heightened. The revenue produced from the ivory trade is harmful because it removes the chances  for funding that could otherwise be used to facilitate growth projects in evolving communities. The opportunity cost for those affected by the illicit ivory trade is great, especially in the case of indigenous communities, which often rely on wildlife as a key resource to sustain their livelihoods and are put at an increased risk by the trade.[2] It is clear that, to some extent, the funds generated in the illegal trading of ivory generate a humanitarian crisis which impacts local populations moving forward.


Ivory trafficking transcends ecological issues because its effects are not solely limited to the environment and species conservation. Rather, illegal ivory trading negatively impacts local and regional economies as well as resource supply chains by exploiting the resources of local areas and generating a scarcity. In fact, there is a direct correlation between the poaching of elephants and negative societal consequences, such as poverty and corruption.[3] The ivory trade also exposes vulnerabilities in domestic and international border security since it defies national boundaries, and its existence reveals border weaknesses, especially in less fortified geographic areas. These factors give traffickers power to continue in their illicit activities, and consequently, reduce the power of local communities.


In order to deter ivory trafficking and wildlife trafficking overall, it is important to consider the reasons why they are on the rise globally. The illicit ivory trade is extremely lucrative, making it an attractive market for groups looking to make enormous profits. This high profitability and the underground nature of the ivory trade are a compelling source of revenue for funding other criminal and terrorist activities. The illegal wildlife trade, as a whole, receives an estimated $5-$23 billion USD in illicit financial flows annually, making it one of the world’s most profitable illicit markets. It is often less risky to traffic ivory than drugs like cocaine or heroin because penalties for these actions are more forgiving for smugglers if they were caught and the pricing per kilogram is relatively similar.[4] Therefore, it is logical that traffickers proceed with ivory trade as their source of income from the trade market because they do not want to face a sentence as harsh as one for drug trafficking. Within a three month period in 2019, $12-24 million USD was seized in ivory profits alone, showcasing the need for law enforcement to better coordinate a response that focuses on the demand as much as it does on the supply.[5]


Under the “Global Anti-Poaching Act,” the United States classifies illegal wildlife trade and drug trafficking as a part of the same category, making wildlife trafficking a money laundering crime that can be punished under the law.[6] Since the United States recognizes that wildlife and drug trafficking come from the same circle of smugglers, it shows that the government is enhancing its communication with experts in both illegal drug and wildlife trade. It is critical to share relevant information regarding trade routes, which can then be compared in order to determine potential similarities in supply chains or destination routes.


It is critical to foster cooperation among various governmental and nongovernmental groups to effectively deter the ivory trade and tackle its societal and economic impacts. External research has concluded that, although a bolstering of law enforcement presence would help weaken the ivory trade, meaningful solutions must also address the societal impacts, as well as the root of ivory’s demand.[7] Currently, evidence suggests that the level of coordination between the public and other sectors is weaker than is needed to successfully combat the illicit ivory trade.[8] Additionally, many ivory and other illegal wildlife-related transactions take place using front companies located in different countries.[9] Personnel across sectors must have access to up-to-date  information in order to avoid repetitive actions and apply surveillance to a wider area. Enhanced coordination would allow groups tackling drug and wildlife trafficking to conduct joint operations more powerful and effective than individual sectors or organizations acting alone.


The illegal ivory trade has been a problem for many years and remains difficult to solve due to the complexity of the trade market. International wildlife protection organizations, in general, attempt to protect certain species by deeming them to be “endangered.” However, once this occurs, the value of that animal often increases significantly within the illegal market.[10] Endangered species can then become a popular target due to their scarcity and the higher profits that can be made from trading them. Even though the ivory trade has been on the decline over the last few decades, the prices have still risen by 1000% since the global bans on the ivory market.[11] Furthermore, the attraction to this market goes beyond just the profit margin, since another key benefit for illicit ivory traders is the mysterious methods of payment that conceal the traders’ identities. Illicit traders sometimes resort to using anonymous shell companies to traffick ivory in efforts to elude authorities from tracing the movement of both illicit funds and illegal wildlife commodities.[12] This method allows traffickers to mask their identities behind the shell company, which shields them from legal liability, prosecution, and creates difficulty in tracing origins. For this reason, it is critical that international conservationist groups utilize new advances in technology, like DNA testing on seized ivory products to pinpoint the location where they originated, as well as discover patterns between poachers, brokers, traffickers, and buyers.[13] However, when countries have unfocused legislation toward illegal ivory trade or an inability to enforce existing laws, traffickers continue to pursue their activities undetected, which further complicates the hardships in tracking trade.


Eliminating the ivory trade would significantly reduce the opportunity for numerous criminal groups to both operate efficiently and turn profit. One of the most successful ivory trafficking networks in Central Africa was linked to Boko Haram; it provided them with ivory and capital to fuel their operations.[14] This seemingly small, family-owned operation had the capability to fund a terrorist group while its activities went undetected. There is potential for more criminal and terrorist groups to use this method or a similar one as a way to continue to increase their funds. Because of the ties between the illegal ivory and terrorist networks, it is crucial to detect and disperse these networks in order to permanently remove a major method of illicit funding to terrorist groups.


Criminals and terrorists trade ivory not only for cash, but also for firearms and other militia equipment.[15] Somali terrorist group al-Shabaab has been shown to traffick ivory, acquiring it from poachers or brokers in Eastern Africa, as well as facilitating the transit and resale in foreign markets.[16] U.S. State Department official Marty Regan claimed in 2015 that “ivory operates as a savings account for [Joseph] Kony,” the leader of the Ugandan terrorist group Lord’s Resistance Army (LRA).[17] Given some of the more recent successes in deterring ivory trade and their impact on the decline of the LRA’s threat in the region, it is clear that efforts to eliminate the ivory trade and the illicit wildlife trade are a powerful tool to combat terrorist groups’ access to funding and weapons.


al-Shabaab and the LRA are not alone; terrorist organizations as a whole are uniquely capable and incentivized to act as intermediaries in the ivory trade. The key incentives include, for example, that ivory is highly valuable and relatively easy to transport. Furthermore, it is easy to erase information pertaining to transportation and exchange of money, and the consequences for getting caught are minimal in many nations where ivory trafficking is a major problem.[18] The unique capability of terrorist organizations is that they have the resources, weaponry, and transnational networks to act as the perfect middlemen between poachers and buyers in foreign markets. Terrorist groups are also able to increase their profits by bolstering the success of poachers. They have the ability to provide strong weapons and tactical gear like night-vision goggles, which often are much more powerful than the equipment that rangers have to protect wildlife.[19] Due to the lack of preparation from wildlife protection authorities, there has been considerable human bloodshed, as at least 1,000 park rangers have lost their lives while on duty in the last ten years.[20] Successfully countering the ivory trade would almost certainly reduce both casualties and access to illicit funding for terrorist groups.


Ivory traffickers often look to countries that house endangered species as a way to gain a competitive advantage in the market. After obtaining  more valuable animals such as elephants, traffickers trade with whomever will offer the highest amount of money, even terrorists. This continues engagement in the illegal trade market and puts countries’ civilians at risk to outside threats that are gaining more revenue. Elephants, in particular, are extremely valuable because their worth extends far beyond their economic value. The African Elephant is the third largest animal in the world at around 7 tons, which allows it to be able to provide many resources with it’s skins, meat, and tusks.[21] However, some countries experiencing the most severe issues with ivory trade do not have sufficient resources to effectively combat the trade. Many areas of the world use wildlife as a source of food, medicine and clothing for themselves.[22] However, these places inherently use these animals as a part of their culture to manufacture such products, which makes it even more difficult to be able to combat the trade. Due to the desirability and amount of economic wealth that elephants  are able to bring makes them even more valuable than in countries with diverse economies.


Despite difficulties in tackling illegal elephant poaching and ivory trafficking, there have been a number of laws passed by major actors over the past few years which have provided an effective roadmap to other countries combating the issue of the illegal ivory trade. On July 6, 2016, the United States, one of the world’s largest markets for illegal ivory, imposed a near-total ban.[23] China, another massive ivory market, instituted a ban on ivory trading that took effect at the end of 2017, followed later by the United Kingdom which passed a total ivory ban in December 2018.[24] [25] The bans from countries who once made up a significant portion of demand in the ivory market have begun to produce positive results. However, in countries such as the Democratic Republic of Congo, legislation can be created and not enforced. The success of the new regulations in China and the United Kingdom rely on lawmakers and law enforcement and their ability to uphold ivory trading laws.




2018 Conference in London Pertaining to Illegal Wildlife Trade[26]


The World Wildlife Fund (WWF), an organization that monitors illicit wildlife trading around the world, has found through annual surveys performed in China that nearly 80% of respondents support the ivory ban. Furthermore, the WWF has discovered that “wholesale prices of ivory in the country have dropped.”[27] This shows that, although international coordination is difficult and countries are currently focused on internal problems exacerbated by COVID-19, effective domestic policy and enforcement can demonstrate serious progress. The high amount of support from the public generated from China’s self-imposed ban indicates that domestic bans on illicit wildlife products can be a compelling method of swaying public support to end wildlife trafficking. The success of these bans allows international organizations and governments to focus their efforts on the countries that create the remaining demand for ivory, as well as the range of issues that cause suppliers to turn to illegally poaching elephants and trafficking ivory in the first place.


It is recommended that continuing targeted efforts be made by governments, law enforcement, and communities to work towards combating what remains of the global demand for ivory. By reducing and ultimately eliminating this demand, the incentives for elephant poachers and ivory suppliers will eventually reduce and even disappear. In the wake of the major bans from the United States, China, and the United Kingdom, international efforts and public pressure can now be directed at the region that makes up the remaining majority of ivory demand: southeast Asia. Countries such as Thailand, Laos, Hong Kong, Japan, and Vietnam still maintain robust ivory markets with frequent importing and sales of the illicit product.[28] These countries also create an opportunity for the remaining Chinese citizens who want to participate in the ivory trade and circumvent Chinese law to do so.[29] For this reason, CTG recommends that all countries fighting to defeat their own domestic ivory trades implement stronger border controls.


Attention must also be paid to the supply side, especially in Africa where poaching and illegal ivory trade is expected to increase due to the number of existing illegal traders as well as increased unemployment  from the pandemic which has led many to seek alternative income opportunities.[30] While the majority of illegal ivory comes from Africa, some tusked male Asian elephants are also poached for their ivory.[31] Therefore, CTG recommends that all African and Asian countries designate wildlife and ecological preservation professionals as essential workers so that they can proceed with their duties while taking appropriate precautions. All of the above measures will create a considerable positive impact on the illicit ivory trade, which will reduce financing of terrorist groups and ultimately aid in the detection, deterrance, and defeation of terrorism.


__________________________________________________________________The Counterterrorism Group (CTG)

[1] “Wildlife Trafficking Generates Up to US$23 billion in Illicit Financial Flows Each Year”, Global Financial Integrity (GFI), September 2016, https://gfintegrity.org/press-release/wildlife-trafficking-generates-us23-billion-illicit-financial-flows-year/#:~:text=Wildlife%20Trafficking%20Generates%20Up%20to,Each%20Year%20%C2%AB%20Global%20Financial%20Integrity

[2] “Money Laundering and the Illegal Wildlife Trade”, Financial Action Task Force (FATF), June 2020, http://www.fatf-gafi.org/media/fatf/documents/Money-laundering-and-illegal-wildlife-trade.pdf

[3] “African elephant poaching rates correlate with local poverty, national corruption and global ivory price”, Nature Communications, May 2019, https://www.nature.com/articles/s41467-019-09993-2

[4] “Money Laundering and the Illegal Wildlife Trade”, Financial Action Task Force (FATF)

[5] Ibid.

[6] “Poaching and wildlife trafficking placed in same category as drug and weapons smuggling by new US law”, Independent, November 2015, https://www.independent.co.uk/environment/nature/poaching-and-wildlife-trafficking-placed-same-category-drug-and-weapons-smuggling-new-us-law-a6720341.html

[7] “African elephant poaching rates correlate with local poverty, national corruption and global ivory price”, Nature Communications, May 2019, https://www.nature.com/articles/s41467-019-09993-2

[8] “Money Laundering and the Illegal Wildlife Trade”, Financial Action Task Force (FATF), June 2020, http://www.fatf-gafi.org/media/fatf/documents/Money-laundering-and-illegal-wildlife-trade.pdf

[9] Ibid.

[10] “Illegal Wildlife Trade”, U.S. Fish and Wildlife Service, February 2020, https://www.fws.gov/international/travel-and-trade/illegal-wildlife-trade.html

[11] “The price of ivory is up 1000% since global ban on ivory trade, but is slowly decreasing”, ZME Science, July 2019, https://www.zmescience.com/science/ivory-prices-ban-155222/

[12] “Wildlife Trafficking Generates Up to US$23 billion in Illicit Financial Flows Each Year”, Global Financial Integrity, September 2016, https://gfintegrity.org/press-release/wildlife-trafficking-generates-us23-billion-illicit-financial-flows-year/#:~:text=From%20a%20forthcoming%20report%2C%20to,development%20and%20security%20as%20well.

[13] “DNA Test Helps Conservationists Track Down Ivory Smugglers”, NPR, September 2018, https://www.npr.org/2018/09/19/649546126/dna-tests-helps-conservationists-track-down-ivory-smugglers

[14] “Gabon Says It Busted a Major Ivory Smuggling Network”, The New York Times, January 2018, https://www.nytimes.com/2018/01/18/world/africa/gabon-ivory-smuggling.html

[15] “High-value natural resources: Linking wildlife conservation to international conflict, insecurity, and development concerns,” Biological Conservation, March 2014, https://www.sciencedirect.com/science/article/pii/S0006320714000391

[16] “The White Gold of Jihad: al-Shabaab and the Illegal Ivory Trade”, Elephant Action League, October 2016, https://earthleagueinternational.org/wp-content/uploads/2016/02/Report-Ivory-al-Shabaab-Oct2016.pdf

[17] “How Killing Elephants Finances Terror in Africa”, National Geographic, August 2015, https://www.nationalgeographic.com/tracking-ivory/article.html

[18] “At CGI, a Commitment to Stop the Bloody Slaughter of African Elephants”, Time, September 2013, https://science.time.com/2013/09/26/at-cgi-a-commitment-to-stop-the-bloody-slaughter-of-african-elephants/

[19] Ibid.

[20] Ibid.

[21] “Top 10 Biggest Animals in the World”, OneKind Planet, n.d., https://onekindplanet.org/top-10/top-10-biggest-animals-in-the-world/

[22] “Combating Wildlife Trafficking”, US AID, March 2020, https://www.usaid.gov/biodiversity/wildlife-trafficking

[23] “What Can I Do With My Ivory?”, U.S. Fish and Wildlife Service, n.d. https://www.fws.gov/international/travel-and-trade/ivory-ban-questions-and-answers.html

[24] “China’s Ivory Ban: A Work in Progress”, The Diplomat, March 2019, https://thediplomat.com/2019/03/chinas-ivory-ban-a-work-in-progress/

[25] “As the UK Bans the Sale of Elephant Ivory, What Will it Mean for Museums and the Antiques Trade?”, Artnet News, December 2018, https://news.artnet.com/art-world/uk-elephant-ivory-ban-1426009

[26] Illegal Wildlife Trade Conference: London 2018 by Foreign, Commonwealth & Development Office, licensed under Creative Commons

[27] “Two years after China bans elephant ivory trade, demand for elephant ivory is down”, World Wildlife Fund, December 2019, https://www.worldwildlife.org/stories/two-years-after-china-bans-elephant-ivory-trade-demand-for-elephant-ivory-is-down

[28] Ibid.

[29] Ibid.

[30] “‘We can’t afford to scale back’: S. Africa faces poaching threat amid Covid-19 lockdown”, France 24, May 2020, https://www.france24.com/en/20200504-we-can-t-afford-to-scale-back-s-africa-faces-poaching-threat-amid-covid-19-lockdown

[31] “Asian Elephant”, World Wildlife Fund, n.d., https://www.worldwildlife.org/species/asian-elephant

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