FinCEN and South African Financial Intelligence Center Host First Meeting of Task Force on Combatting the Financing of Wildlife Trafficking and Terrorist Finance Dialogues

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Treliant Takeaway:

The establishment of the U.S.-South Africa Task Force on Combating the Financing of Wildlife Trafficking demonstrates an acknowledgment of the severe consequences of wildlife trafficking, including its impact on the environment and its use as a source of illicit funding for criminal and terrorist activities. Just as financial institutions play a pivotal role in the various avenues of financial crime, they also play a crucial role in combating wildlife trafficking. As emphasized in FinCEN’s Financial Threat Analysis, wildlife trafficking is a significant transnational organized crime that relies on the international financial system to move, conceal, and launder proceeds generated from these illicit activities.

With the assistance of Treliant’s Financial Crime and Fraud Solutions (FCFS) team, financial institutions will be able to leverage advanced technology, develop robust fraud programs, and implement effective customer best practices to identify and prevent transactions associated with wildlife trafficking. Treliant offers a range of subject matter experts and outsourcing solutions to augment your team and streamline your processes, ensuring compliance with all Financial Crimes Enforcement Network (FinCEN) guidance.


Amid growing concerns over wildlife trafficking, the U.S. Department of the Treasury, led by FinCEN, embarked on a significant mission to South Africa in mid-June for the inaugural meeting of the U.S.-South Africa Task Force on Combating the Financing of Wildlife Trafficking. This task force, established based on Secretary Janet L. Yellen’s commitment earlier this year, brings together representatives from the U.S. and South African Treasuries, along with law enforcement officials from the United Kingdom, to combat the illicit finance associated with wildlife trafficking. In conjunction with the meeting, a three-day workshop focused on countering terrorist financing was conducted, involving participants from all three nations.

Wildlife trafficking is a practice that not only endangers the environment and all of its inhabitants but also provides funds for criminal syndicates and terrorist organizations. The primary objective of the task force is to disrupt the financing channels of wildlife trafficking. Through collaboration with South Africa and the United Kingdom, the U.S. government aims to protect wildlife populations and combat the illicit trade. In a demonstration of commitment, attendees representing non-profit entities, financial institutions, law enforcement, and government agencies pledged to foster ongoing cooperation and harness the power of existing public-private partnerships to advance the objectives of the task force. Additionally, discussions touched upon the role wildlife trafficking plays in supporting regional and global terrorist groups, with a particular focus on emerging terrorism trends in Africa. The aim was to identify avenues for intensified collaboration between the parties involved in the Task Force.

Wildlife Trafficking Red Flags

In December 2021, FinCEN published a report titled “Illicit Finance Threat Involving Wildlife Trafficking and Related Trends in Bank Secrecy Act Data,” which highlighted the following red flags regarding wildlife trafficking:

  • Prevalence of Import-Export and Logistics Companies
    • International trade companies, including import-export, freight forwarding, customs clearance, logistics, and travel agencies, may have associations with wildlife trafficking.
    • These companies may unknowingly or knowingly facilitate the movement or laundering of illicit proceeds related to wildlife trafficking.
  • Transactions Involving Wildlife-associated Entities
    • Private zoos, animal importers, breeders, pet stores, exotic parks, circuses, safari parks, and hunting-related businesses have been mentioned in SARs related to wildlife trafficking.
    • References to hunting, safaris, and zoos were found in SARs related to wildlife trafficking.
  • Transactions Referencing Wildlife-associated Care
    • Illicit actors involved in wildlife trafficking conduct transactions related to enclosures, aquariums, poaching-related equipment, and wildlife-related medication or veterinary services.
    • Transactions related to the purchase or maintenance of food, large game equipment, and harnesses are also associated with wildlife trafficking.
  • Equipment Convergence with Gold, Jewelry, Precious Metals, and Antiquities
    • Payments for wildlife shipping may be disguised as payments to gold, diamonds, or precious metals dealers or trading businesses.
    • Gold, diamonds, and other precious metals may be used for payment or to conceal proceeds of wildlife trafficking.
    • The antiquities trade is also linked to wildlife trafficking, with fraudulent claims made about the age of animal-related items or parts to evade trade restrictions.
  • References to Wildlife, Wildlife Parts, or Wildlife Products
    • SARs indicate that illicit actors may openly mention wildlife or wildlife trafficking in chats, messages, or information fields of funds transfers.
    • Covert methods, such as using images, symbols, or icons associated with animals or animal parts, may be used to mask wildlife trafficking activities.

This Takeaway was authored by Richard Lee, Analyst