Takeaways on Dissecting the environmental-financial crime nexus: delving into a case from the Canadian Financial Intelligence Unit

Speakers: Aimee Hanson, Programme Coordinator, Environmental Crime Initiative at WWF-UK and Patrick Moreau, Team Leader, Terrorist Financing, Threats, International Unit at Financial Transactions and Reports Analysis Center of Canada (FINTRAC)

• National anti-money laundering/anti-terrorist financing regimes can play an important role in combatting illegal wildlife trade: As demonstrated by Project Anton, financial transactions associated to the illegal wildlife trade can be identified by regulated reporting entities and reported effectively in STRs/SARs when reporting entities are provided with analytically sound indicator guidance. In a the majority of cases examined by FINTRAC, the financial activity involved in illegal wildlife trade networks often followed the same methods of money laundering as other types of profit generating crimes. Regulated reporting entities are therefore well-positioned to identify and report on this activity. For this model to work however it is critical that jurisdictions treat offences associated with the illegal wildlife trade as predicate offences to money laundering. Relevant stakeholders in national AML/ATF regimes should also take steps to identify and assess the ML risks associated to the illegal wildlife trade in their jurisdiction, particularly in the context of the national risk assessments on ML.

• Relevant red flag indicators and other information on the financial activity fueling the illegal wildlife trade is readily available: Somewhat unique in comparison to other significant types of financial crimes, there is a wealth of high quality information on what the financial activity associated to the illegal wildlife looks like. Financial institutions and other relevant organizations can therefore take advantage of these resources to adopt a follow-the-money perspective to the illegal wildlife trade in their jurisdictions. This knowledge base can also be used by regulators as a starting point to develop guidance products relevant to their own jurisdictions. Beyond the WWF report discussed in this webinar, just a small sample of other relevant resources include:

• Operational alert: Laundering the proceeds of crime from illegal wildlife trade

• Illegal wildlife trafficking financial crime guide | AUSTRAC

• SAMLIT – FIC

• Dissecting the environmental–financial crime nexus: A spotlight on the illegal wildlife trade

• Environmental crimes financial toolkit

The full recording of the presentations from the 16 April Follow-the-Money working group meeting is available here: