Canada launches international public-private partnership targeting illegal wildlife trade: Project Anton

Canada’s financial intelligence unit, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), recently helped launch Project Anton, a new international public-private partnership aimed at improving awareness and understanding of the global threat posed by illegal wildlife trade, and targeting the laundering of proceeds from this despicable crime domestically and internationally.

Project Anton is led by Scotiabank in Canada and supported by The Royal Foundation’s United for Wildlife network, which was founded by Prince William, FINTRAC, AUSTRAC’s Fintel Alliance in Australia, the South African Anti-Money Laundering Integrated Task Force, the United Kingdom Financial Intelligence Unit, Western Union and numerous other government, law enforcement and non-governmental organizations in Canada and around the world with unique knowledge, expertise and tools in combatting illegal wildlife trade.

The devastating impact of the illegal wildlife trade
Wildlife crime refers to the trade of wild plant and animal species in contravention of national and international laws and regulations. Wildlife crime can include commercial, import, export, and re-export activity and can occur at any stage in the supply chain, including but not limited to sales, delivery, transport, purchase, and possession of protected species of flora and fauna. The Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) regulates the legal wildlife trade and ensures the protection of animal and plant species from over-exploitation and poaching.
Illegal wildlife trade is a major and growing threat to the global environment and biodiversity, imperilling endangered species already on the edge of survival, and threatening fragile habitats, communities and livelihoods. It has been estimated that 55 African Elephants are poached on the African continent every day. In Canada, bears are killed for their bile, paws and other parts, which are then sold for a large profit domestically and internationally. Moose, wolves, reptiles and narwhals, among others, are also considered species at risk for the Canadian illegal wildlife market.

Illegal wildlife trade can also have significant public health impacts, as the circulation of animal parts increases the chances of disease transmission and can be a path for future pandemics. According to the World Health Organization, close to 75 percent of emerging infectious diseases over the past three decades that have affected humans originate in animals. Illegally sourced and traded wildlife lacks sanitary measures and increases the risk of human infection.

The Financial Action Task Force (FATF), the global money laundering and terrorist financing watchdog, has identified illegal wildlife trade as a major transnational organized crime, which generates billions – some have estimated approximately 20 billion (USD) – of criminal proceeds each year.

According to the Wildlife Justice Commission, illegal wildlife trade is considered a lucrative, low risk and high reward criminal activity, and often involves fraud schemes, tax evasion and other serious crimes that facilitate the illicit enterprise. The Commission has also found that organized crime groups involved in wildlife crime are often involved in other domestic and internationally connected criminal activity such as human trafficking, drug trafficking, firearms trafficking and money laundering.

Corruption is one of the most important facilitators of illegal wildlife trade and enables every stage in the illegal trade chain from poaching and illegal harvesting through to transportation, processing and export, to sales and the laundering of proceeds.

A 2020 report by the United Nations Office on Drugs and Crime highlighted that suspected illegal wildlife traffickers from 150 countries had been identified, illustrating that wildlife crime is a transnational issue. This demonstrates the importance of establishing a committed global network of public and private sector entities to combat this appalling crime.

Project Anton: International Collaboration
Project Anton was named in honour of Anton Mzimba, Head of Security at the Timbavati Private Nature Reserve and a Global Conservation Technical Advisor, who was murdered in front of his family in 2022 for his passionate commitment to protecting and conserving wildlife.

This innovative new international public-private partnership focuses on improving awareness and understanding of the threat posed by illegal wildlife trade in Canada, and targeting the laundering of proceeds from this crime domestically and internationally. By following the money and generating actionable financial intelligence for law enforcement in Canada and around the world, Project Anton will assist in identifying, pursuing and prosecuting perpetrators – and broader networks – linked to illegal wildlife trade.

Project Anton is facilitating the ongoing engagement and sharing of information between partners domestically and internationally, where authorities permit. It further enhances the collective knowledge of money laundering methods, typologies and indicators that will enhance detection and reporting from businesses to their respective Financial Intelligence Units (FIUs).

In support of this initiative, FINTRAC published an Operational Alert, Laundering the Proceeds of Crime from Illegal Wildlife Trade, meant to assist businesses and partners in identifying and reporting financial transactions related to the laundering of proceeds of crime from this cruel criminal enterprise. This, in turn, will facilitate the production of actionable financial intelligence in support of law enforcement investigations in Canada and abroad.

In addition to providing money laundering indicators, FINTRAC’s Operational Alert also describes the general money laundering methods associated with illegal wildlife trade, including the use of nominees, front companies and the layering of funds between accounts, as well as the types of transactions suspected of being related to the illegal importation of wildlife into Canada and exportation from Canada.

With the reporting that FINTRAC has received to date, the Centre has already disclosed actionable financial intelligence to law enforcement under the umbrella of Project Anton.

The Australian Transaction Reports and Analysis Centre recognized the support that FINTRAC’s financial and open data analysis provided to the Australian Department of Agriculture, Water and Environment’s understanding of an international wildlife trafficking network linked to Australia, Canada, Spain and Malaysia. AUSTRAC mentioned that FINTRAC’s information provided additional insight into the nature, duration and status of particular relationships and generated a number of new intelligence leads.

Project Anton is modelled after Canada’s other successful, ongoing public-private partnerships, which are aimed at combatting the laundering of proceeds related to human trafficking for sexual exploitation (Project Protect), online child sexual exploitation (Project Shadow), trafficking of illicit fentanyl (Project Guardian), romance fraud (Project Chameleon), illicit cannabis activities (Project Legion) and money laundering in British Columbia and across Canada (Project Athena). In total last year, FINTRAC provided 757 disclosures of actionable financial intelligence to Canada’s law enforcement agencies in relation to these existing public-private sector partnerships, with disclosures often containing hundreds or even thousands of financial transaction reports in each package.

The role of border services in detecting illegal wildlife trade
Illegal wildlife trade poses a serious environmental, economic, security and public health threat in Canada and around the world. Border services and officials across the globe play a crucial role in helping to detect and combat this heinous illicit activity.

The Canada Border Services Agency (CBSA) is a key partner in this initiative. It is responsible for providing integrated border services that support national security and public safety priorities, while also facilitating the free flow of persons and goods across the border. At the Canadian border, all goods entering the country are carefully screened and any illegal wildlife products discovered are held and referred to Environment and Climate Change Canada for further analysis and direction. CBSA’s officers use a variety of risk assessment tools to identify people, goods and conveyances that may pose a threat to the security and safety of Canadians.

FINTRAC is able to disclose actionable financial intelligence to the CBSA in support of enforcement efforts at the Canadian border when the Centre has reasonable grounds to suspect that the information would be relevant to a money laundering offence, terrorist activity financing offence or a threat to the security of Canada.

Following an analysis of suspicious transaction reports relating to illegal wildlife trade received between 2011 and 2022, FINTRAC identified the suspected illegal importation of wildlife into Canada, particularly from China and Sub-Saharan Africa and the suspected exportation of wildlife from Canada to other jurisdictions, such as the United States and China. These transactions highlight the international scope of illegal wildlife trade, including the use of animal traders around the world, and the importance of sound border controls.

The illegal importation of exotic wildlife into Canada often starts with a Canadian trader who orders wildlife through a coordinator located, for example, in Australia, Asia or Africa. The coordinator manages all aspects of an illegal trade operation required to source wildlife for the Canadian trader including the engagement of poachers, breeders, traders, money mules and couriers located in their country.

The Canadian trader sends funds directly to the trader, poacher and breeder located abroad for wildlife sourcing, and indirectly to the coordinator through a money mule in order to mask their role in managing operations. Poachers, breeders, or traders transport wildlife to the coordinator through legitimate or illicit channels. In the case of the legal domestic trade of live animals, breeders and traders may be unaware of their participation in the illegal wildlife trade.

Wildlife is transported to a courier who is paid to ensure transportation of animals to the Canadian trader. Transportation can be indirect, through the postal service or transportation companies often funded with cash, or directly by couriers who conceal wildlife in their luggage or their person when travelling to Canada. The Canadian trader may advertise the trafficked animals for sale on a website or through social media. Advertisement can take place for the sale of animals on the domestic market or for their re-export overseas. Contact information such as addresses, phone numbers and email addresses found on online and social media platforms may provide useful leads for identifying suspicious financial transactions linked to traders in illegal wildlife trade.

The same roles and trade dynamics seen in import networks are also present in illegal export networks for Canadian wildlife. Overseas traders, much like Canadian traders, will source Canadian animals for sale on their foreign markets. In Canada, coordinators manage breeders, poachers, traders, couriers, and money mules in moving money and wildlife abroad. Though many of these similarities are present, export networks do not appear to include a re-export component, as seen in illegal importation networks.

Through its analysis, FINTRAC developed money laundering indicators that could enhance the awareness and understanding of illegal wildlife trade operations and assist border officials in identifying animal goods potentially linked to this illicit activity, including:

• Media and/or law enforcement information links client or transacting parties to the illegal wildlife trade.
• An individual is the owner, operator, employee or associated with an industry that could be used to facilitate illegal wildlife trade (e.g., import/export of goods, fisheries wholesaler, pet store, freight company, animal control).
• Individual or an entity has open source information linking them to the possession and/or advertising the sale of species of concern for illegal wildlife trade, particularly endangered species (e.g., geckos, turtles, and tortoises).
• Individual or entity provides misleading or falsified documentation concerning wildlife trade (e.g., incorrect permits).
  The full list of money laundering indicators associated with illegal wildlife trade can be found in FINTRAC’s Operational Alert.

By Barry MacKillop, Deputy Director, Intelligence, Financial Transactions and Reports Analysis Centre of Canada