ACAMS - WWF Webinar

Opening Remarks by 

Dr. Marcus Pleyer
FATF President

18 September 2020

[as delivered]

Good morning, good afternoon an good evening, ladies and gentlemen, hello around the globe,

I would like to thank ACAMS for organising this event, and for inviting me to provide some opening remarks. My name is Dr Marcus Pleyer and I am the President of the Financial Action Task Force.

The illegal wildlife trade is a crime with a devastating impact on our precious ecosphere. Each year, criminals generate billions of profits from the illegal wildlife trade. This includes illegal trade in iconic African mammals, such as elephants and rhino, but also lesser-known endangered species of reptiles, birds and amphibians. It has become one of the most profitable criminal activities, and has driven some species to the brink of extinction.

Taking the profit out of the illegal wildlife trade is an important issue for the FATF. Many colleagues may already be familiar with the FATF’s work. We are an intergovernmental body that sets global standards to fight money laundering, the financing of terrorism, and the financing of the proliferation of weapons of mass destruction. More than 200 countries and jurisdictions have committed themselves at the highest political level to implement our standards. These same standards provide a useful framework for countries and the private sector to help them tackle threats from the illegal wildlife trade.

In July 2020, we published the first global report on money laundering from the illegal wildlife trade. The report lays out a clear path that national authorities and the private sector can take to effectively identify and disrupt financial flows from this crime. Today, I would like to speak to you about three topics in particular:

1. Key findings from the FATF’s illegal wildlife trade report
2. The important role of the private sector in the fight against this crime
3. Next steps, including FATF’s broader work on environmental crimes

The FATF report represents a pivotal moment in the fight against the illegal wildlife trade. This illicit trade is not just a problem for countries where wildlife is harvested, caught or sold. Criminals involved in this activity are highly organised, and are moving and trading around the world, wherever the demand, and the price, is highest. As a result, money laundering from the illegal wildlife trade is a global problem.

Importantly, the FATF’s work highlights that countries and the private sector are not doing enough to detect and disrupt the financial flows from this crime. Many countries are carrying out few financial investigations into wildlife trafficking networks. As a result, both the private and public sector are less familiar with the trends, methods and techniques used to launder proceeds from this trade than for other major transnational crimes. This then means that very few private sector entities are detecting or filing suspicious transactions related to wildlife trafficking.

This is significant. Only by following the financial flows can countries identify the “king-pins” that are profiting from this crime.

The FATF report is therefore a call to action for both public and private sector to increase our vigilance and response to the financial threats posed by the illegal wildlife trade.

The private sector in particular has an important role to play. This includes financial institutions, such as banks and money remitters, but also non-financial entities, such as company service providers, and dealers in high-value goods.

Compliance officers in these businesses have access to information on client profiles and financial activity. They are well placed to identify and report suspicious transactions related to the illegal wildlife trade to the public sector.

This starts with a good understanding of customer behaviour, and of the common trends wildlife traffickers use to disguise and conceal their illicit activity. To help with this, the FATF report identifies red flag indicators, and sectors that may be particularly vulnerable. For example, criminals are frequently misusing the legitimate wildlife trade, as well as other import-export type businesses, as a front to move and hide their illicit gains. Similarly, criminals are increasing using online market places, and mobile and social media-based payment platforms to raise and move funds from this illicit trade.

These trends highlight the increasing importance of a co-ordinated and whole-system response, from risk monitoring, to intelligence gathering, and financial investigations and prosecutions.

For this reason, initiatives such as the recent ACAMS and World Wide Fund for Nature (WWF) partnership are vital to ensuring that there is a clear communication channel across the public, private and non-profit sectors on threats and emerging trends.

So what are the next steps?

While the FATF’s report has helped to increase our understanding of the wildlife trafficking flows, it is our response that will matter most. To ensure that countries and private sector take action, the FATF plans to review their progress in around one year’s time.

Sadly, our environment faces many other threats, including highly lucrative environmental crimes such as illegal logging, illegal land clearing, and unlawful waste disposal. As shown by the WWF’s new living planet report, humans are now overusing the earth’s biocapacity by at least 56%. The value of illegal extraction and trade with natural resources and waste alone was estimated at between 91 to 259 billion USD annually in 2016. Therefore, under my presidency, the FATF is expanding its focus to other forms of environmental crimes. Over the next year, we will develop guidance to help public authorities and the private sector understand the money laundering threats posed by other environmental crimes, and measures they can take to combat them.

This work is underway, with strong support from across the FATF global network.

The private sector has a crucial role to play in combatting the financial flows from environmental threats, as well as many other serious crimes. Private sector engagement on a range of work, from typologies to policy development ensures that FATF’s work remains anchored to reality. Under the two-year Germany Presidency, I plan to continue this important dialogue with the private sector, in particular as we explore the opportunities of new technology, such as data pooling and analysis, to improve the detection of illicit financial transactions.

Thank you very much for your attention and have a great conference.

Money Laundering and the Illegal Wildlife Trade