2 International Wildlife Crime |
8. Due to its clandestine nature, the scale of
the international illegal trade in wildlife is difficult to quantify.
For example, when United States Congress considered the overall
value of international wildlife crime in 2008, it found that it
was worth at least $5 billion a year, but might total in excess
of $20 billion. Another
estimate valued the illegal international wildlife trade at between
$7.8 billion and $10 billion a year.
Wildlife has been estimated to constitute the world's fourth largest
criminal market, behind drugs, counterfeiting and human trafficking.
9. As with any trade, the illegal wildlife market
requires supply and demand. The 2012 UN Rio+20 Summit declaration
We recognize the economic, social and environmental
impacts of illicit trafficking in wildlife, where firm and strengthened
action needs to be taken on both the supply and demand sides.
Since our predecessor Committee's Report in 2004,
increased demand for illegal wildlife products has helped to drive
the rhino, tiger and elephant to the verge of extinction. In our
latest inquiry, we took detailed evidence on the supply of and
demand for illegal wildlife products derived from those species,
although other animalsnotably reptiles and amphibiansare
10. The supply chain for trafficked illegal products
derived from elephants, rhinos and tigers begins with poaching
in Africa and Asia. The main source for illegal ivory is central
Africa, where the elephant population is rapidly declining due
to poaching. For example, the Democratic Republic of Congo was
once home to more than 100,000 elephants, but now there are only
four separate groups of more than 500 elephants and the entire
population may be as low as 2,500 elephants.
The Elephant Trade Information System (ETIS), which monitors the
elephant trade on behalf of parties to CITES, observed
a steadily increasing trend in levels of illicit
ivory trade from 2004 onwards, with an exceptionally sharp upsurge
Data demonstrate that seizures of ivory reached
record levels in 2009 and that these levels were largely sustained
In 2011, ETIS recorded the largest number of ivory
seizures in its 23-year history.
The gangs profiting from the lucrative illegal ivory trade in
central Africa reportedly include militias such as the Janjaweed.
11. There are five species of rhinoceros, three
of which are native to southern Asia and two to Africa.
All are to a greater or lesser extent threatened by extinction
in the wild. Rhino deaths from poaching have increased markedly
in recent years. In 2010, 333 rhinos were illegally killed in
South Africa, including 10 critically endangered black rhinos.
In 2011, 448 rhinos were killed, of which 19 were black rhinos.
Over the past 100 years, tigers have lost 93% of their historic
range, and all six sub-species of tiger are classified as endangered.
The global population in the wild is estimated to number between
3,000 and 4,000 individuals, mostly in small pockets that are
isolated from each other. The area occupied by tigers is estimated
at less than 1.2 million square kilometres, a 41% decline since
the mid-1990s. The
operation of 'tiger farms' in south-east Asia, which supply products
derived from captive tigers, does not appear to have affected
the decline of tigers in the wild.
12. Perhaps surprisingly, the UK is also a source
for illegal rhino horn and ivory. Criminals are purchasing or
stealing antique items, such as carved rhino horn libation cups
and elephant ivory billiard balls, which are sometimes ground
down before being re-sold on the black market.
In September 2010, the Animal Health and Veterinary Laboratories
Agency detected a surge in the number and value of rhino horn
products being exported from the UK. Defra told us:
As a result of concerns about the increasing level
of re-exports of antique rhino horn, and that sales appeared to
be based on the weight of the horn rather than on antiquity, and
that these activities mirrored increased poaching across Southern
Africa, the AHVLA recommended that stricter controls be introduced
on such re-exports and sales. This was adopted by the UK and subsequently
also by EU member states.
Analysis by the International Fund for Animal Welfare
(IFAW) indicates that antique ivory and rhino horn products are
being advertised and sold on the internet in the UK and being
illegally shipped to south-east Asia and China.
We discuss later the need for the NWCU to be tasked and funded
to monitor wildlife crime on the internet (paragraph 69).
13. In the past decade, the increased poaching
of rhinos, elephants and tigers has largely been driven by the
demand for illegal wildlife products in Asian countries, mainly
China. We investigated
whether this might be a function of Traditional Chinese Medicine,
but found that it was not a significant factor.
Instead, increased demand in China and south-east Asia appeared
to be a function of a newly affluent society, where purchasing
illegal wildlife products had recently developed both as an investment
essentially, the closer an endangered species is to extinction,
the higher its investment valueand
as a form of conspicuous consumption.
focus of UK CITES enforcement on trafficking related to traditional
may be misplaced, because our findings on the nature of demand
in south-east Asia and China for illegal wildlife products suggest
that wildlife crime driven by investment and conspicuous consumption
is more significant.
14. IFAW's Asia Regional Director commented:
There are people in China, the class with extreme
who may have connections with criminal syndicates.
They have power, they have connections. They often have anonymity,
and they may order ivory, large shipments of ivory, from Africa
on the internet or via the phone. They are conducting this illegal
trade and hiding behind it.
In the past decade, the profits that can be made
from investing in illegal ivory in China have expanded because
of the increased strength of renminbi.
IFAW's Asia Director pointed out:
If the Chinese buy ivory anywhere else in the world,
they have to buy it in US dollars. For the Chinese, that makes
buying ivory anywhere else in the world cheaper and the profit
margin on that ivory, once it is smuggled into China and sold
on the marketit is very easily sold illegally on the market
because it is covered by the legal tradeis huge. That is
a great incentive for people who are engaging in this illegal
15. Southern African elephant range states
conducted two one-off, CITES-approved sales of stockpiled seized
ivory in 1999 (50 tonnes) and 2008 (100 tonnes) to approved buyers
in Japan and China. The aim of both sales was to reduce ivory
prices and therefore undermine illegal trade, but our witnesses
told us that instead it exacerbated demand for ivory products
and undermined the CITES regime in China.
The sale of ivory is generally illegal in China, but the two one-off
sales of legal ivory appear to have stimulated the illegal market
by promoting interest in carved ivory. IFAW's Asia Director explained:
China imported 62 tonnes of ivory in 2008 from this
stockpile sale, so China has a legal ivory market
law enforcement officers could not distinguish what is legal from
Ivory in the second one-off legal sale, in 2008,
was bought for an average price of $157 a kilogramme by approved
buyers such as the Chinese State Forestry Administration, which
sold its ivory to traders for up to $1,500 a kilogramme. That
mark-up is reflected in the prices of ivory products in retail
outlets such as the Chinese Government-owned Friendship Store,
which is accredited by the Chinese Government to sell ivory products.
Recent reports indicate that the price of illegal ivory in China
has increased ten-fold since 2005 in response to the stimulus
from the legal market.
Indeed, we even heard about a Chinese bank that runs an investment
fund based on elephant ivory.
16. China is a signatory to CITES, which means
in theory that all other trade in elephant ivory is illegal. In
practice, those international commitments have been undermined
by contradictory domestic laws and weak enforcement. IFAW's Asia
Director emphasised that "wildlife enforcementeffective
enforcementhas to be aided by clear policies and laws
In terms of legal versus illegal, it is very murky for a consumer".
Similarly, the Environmental Investigation Agency, an environmental
There is no proactive enforcement and there is no
intelligence-led enforcement. The Chinese authorities are aware
of the level of illegal ivory available on the market, and doing
nothing about it. Trade is going on in front of police.
17. Rhino poaching is driven by increased prices
for horn in China and south-east Asia in general and in Vietnam
in particular, where demand has been compounded by the growth
of a damaging rumour that rhino horn is a cure for cancer.
IFAW's Asia Director pointed out:
The auction records in 2011 show that 2,750 pieces
of rhino horn carving were sold in mainland China, total sale
price US $18 million, which was an increase of 90% and 111% respectively
from the previous year.
Individuals who hold large stockpiles of rhino horn
have an interest in the species becoming extinct in the wild,
because this will increase the scarcity value of their investment.
In China, people are buying rhino horn as an investment.
That is why it is comparable with the price of gold but being
more than gold; the rarer the animal, the higher the value of
that animal's product
they are banking it, basically like
they are banking gold. It is one of the secure things that you
can bank in.
18. The illegal poaching of tigers is also driven
by demand for wildlife products in south-east Asian countries
in general and in China in particular, but demand for tiger products
appears to be purely a function of conspicuous consumption rather
than a type of investment. The Environmental Investigation Agency
China is still the primary consumer, and that is
evidenced from the seizures from neighbouring countries. Tiger
and other Asian big cat skins are used for luxury home dcor, taxidermy,
among the business, political and military elite, and for personal
purchase as gifts.
Similarly, TRAFFIC observed:
A lot of it is for status, it is for show, so it
is going to be difficult for us to combat that, because we need
to try to get a change in the motivation behind individuals in
China. They are buying items, like tiger bone wine, which are
conspicuously expensive, as gifts to their superiors, as gifts
to others. It is very much a social status thing.
19. Quantifying the demand for trafficked wildlife
products in the UK is problematic due to the way in which wildlife
crime is currently recorded (paragraph 71). However, it is clear
that some people more or less innocently import illegal wildlife
souvenirs, that a
minority of practitioners of Traditional Chinese Medicine utilise
illegal wildlife products
and that there is a degree of conspicuous consumption of the kind
seen on a much larger scale in China and south-east Asia.
It is clearly important that wildlife crime law enforcement is
maintained in the UK, because the UK must have its own house in
order if it is to provide effective international leadership and
set standards in this field.
20. CITES is the key instrument for international
co-operation against the illegal wildlife trade. CITES accords
varying degrees of protection to some 5,000 species of animals
and 28,000 species of plants. Species are added to or removed
from the two CITES appendices on a rolling basis depending on
their current conservation status, and listed species can only
be traded with a CITES permit.
Only one CITES-protected species has ever become extinct as a
result of illegal trafficking, which supports claims for the past
efficacy of the regime.
21. The 2012 UN Rio+20 Summit declaration highlighted
the importance of international co-operation on CITES enforcement:
We recognise the important role of the Convention
on International Trade in Endangered Species of Wild Fauna and
Flora, an international agreement that stands at the intersection
between trade, the environment and development, promotes the conservation
and sustainable use of biodiversity, should contribute to tangible
benefits for local people, and ensures that no species entering
into international trade is threatened with extinction. We recognise
the economic, social and environmental impacts of illicit trafficking
in wildlife, where firm and strengthened action needs to be taken
on both the supply and demand sides. In this regard, we emphasise
the importance of effective international co-operation among relevant
multilateral environmental agreements and international organisations.
We further stress the importance of basing the listing of species
on agreed criteria.
22. Every two to three years, CITES signatories
meet at a Conference of the Parties to review the implementation
of the Convention. The next meeting will be held in March 2013,
which will provide the UK Government with an opportunity to demonstrate
leadership on the international issues raised by our inquiry.
European Union countries vote as a bloc at CITES meetings, which
means that the Government will need to build European consensus.
It is a
matter of grave concern that increased poaching, driven by demand
for illegal wildlife products, threatens the rhino, tiger and
elephant with extinction. The Government must take a leading role
in exerting robust diplomatic pressure in favour of the development
and enforcement of wildlife law at the next CITES Conference of
the Parties in March 2013. In particular, the Government should
focus attention on the damaging effect of 'one-off' sales of impounded
ivory, which undermine the international CITES regime and fuel
demand for ivory products, and seek an unequivocal international
ban on all forms of ivory trade. Such commitments
are essential but may not be sufficient to protect those species
that are most endangered because of the persistent demand for
products derived from them. Ultimately, rhinos, tigers and elephants
will only survive as wild species if attitudes change. In the
run-up to the 2013 CITES Conference, the Government should seek
international support for an exploration of new ideas to challenge
demand for such illegal wildlife products.
UK implementation of CITES
23. CITES controls within EU countries are set
out in the Wildlife Trade Regulations and implemented in UK law
by the Control of Trade in Endangered Species Regulations (COTES).
The most direct way in which the UK can contribute to international
action against the illegal trade in wildlife is by itself running
an effective internal CITES regime. This is especially important
if the UK is to provide international leadership on addressing
wildlife crime, but some provisions of the COTES Regulations do
not appear to be facilitating effective enforcement:
- Under COTES Regulation 5, the
UK Border Agency (UKBA) has the power to seize items it believes
to have been imported unlawfully and to require the owner to show
evidence of lawful importation. The police also often come across
similar situations in the course of their investigations, but
they do not have a similar power and must rely on UKBA to agree
to use its powers in such cases on its behalf. This is repetitious,
wastes time and resources and may result in serious wildlife crimes
not being investigated.
- An authorised member of the Animal Health and
Veterinary Laboratory Agency Wildlife Inspectorate has the power
under COTES Regulation 9(4) to enter any premises to inspect a
specimen, but police officers can do so only if they suspect that
an offence has been committed and they have obtained a search
warrant, which takes time and resources.
On the other hand, the Wildlife and Countryside Act 1981 allows
the police to enter any land that is not a dwelling to obtain
evidence of suspected offences without a search warrant.
- COTES Regulation 9(3) stipulates that a vet must
be present where samples are taken in CITES cases.
That appears reasonable in cases involving living animals, but
it does not include an exemption for plants, and it also applies
to dead specimens. As a result, a vet might have to be called
out to take a sample from, for example, a table constructed from
- In addition, questions have been raised about
the regulations covering the sale of caviar,
which do not include a sanction for non-compliance, and the certification
system covering changes in ownership of specimens of protected
species, which may
form a loophole for wildlife traffickers.
24. Such criticisms of the COTES regime have
been voiced by both the police and NGOs.
Defra informed us that it was reviewing the operation of COTES,
but it did not provide details of the timescale, focus or scope.
to ensure the efficient operation of the CITES regime in the UK,
Defra must amend the COTES Regulations, focusing on the effectiveness
of Regulations 5, 9(3) and 9(4) and their scope for consistent
application by the various wildlife crime enforcement agencies.
12 Congressional Research Service, International
Illegal Trade in Wildlife: Threats and U.S. Policy, August
2008, p 2. Back
Jeremy Haken, "Transnational Crime in the Developing World",
Global Financial Integrity, February 2011. Back
Ev 88 Back
United Nations, Rio+20 Declaration, para 203. Back
Ev w41 Back
Ev 104 Back
Ev 104 Back
Q 92 Back
White Rhinoceros, Black Rhinoceros, Indian Rhinoceros, Javan Rhinoceros
and Sumatran Rhinoceros. Back
Ev w41 Back
International Union for the Conservation of Nature, Red List
of Threatened Species. Back
Qq 163, 169 Back
Q 94 Back
Ev 121 Back
Ev 107 Back
Ev 100 Back
Q 123 Back
Ev 104 Back
Q 160 Back
Ev 149 Back
Q 161 Back
Chinese currency. Back
Q 161 Back
The 1999 sale included ivory from Botswana, Namibia and Zimbabwe.
The 2008 sale included ivory from Botswana, Namibia, Zimbabwe
and South Africa. Back
Ev 101 Back
Q 163 Back
Ev 101 Back
Q 175 Back
Q 163 Back
Q 118 Back
Ev w41 Back
Q 160 (That is a 90% increase in the number of rhino horn items
sold and a 111% increase in the value of those items). Back
Q 123 Back
Q 127 Back
Q 128 Back
Q 100 Back
Q 303 Back
Q 281 Back
Appendix I lists species faced with imminent extinction in the
wild. Appendix II lists species that would face extinction if
trade were not tightly controlled. Back
Spix's Macaw. Back
United Nations, Rio+20 Declaration, para 203. Back
Q 294; Ev 152 Back
Ev 152 Back
Ev 118 Back