Transcription
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Penny Crosman (00:04):
In the illegal wildlife trade, animals are kidnapped or killed for money with devastating effects on the ecosystems in which they live and on the broader world around them. Some banks are helping to detect and thwart this activity. We are here today with Geraldine Fleming, financial task force manager at United for Wildlife and Jonny Bell, director of EMEA at LexisNexis Risk Solutions. Welcome, Geraldine and Jonny.
Jonny Bell (00:31):
Pleasure to be here.
Geraldine Fleming (00:33):
Thanks for having us. Really excited to have this conversation.
Penny Crosman (00:36):
Thank you. So first I just want to ask you how you both got into this whole world of illegal wildlife trafficking, starting with you, Geraldine.
Geraldine Fleming (00:48):
Thanks, Penny. Well, I was privileged enough to find myself working for a bank on a rhino conservation project project called Investec Rhino Lifeline. And what started off as a small initiative by the executive to try and do something to stem the rhino crisis grew into a much broader conservation initiative. And about 10 years in, we joined United for Wildlife's Financial Task Force. We were a founder member, and that was in 2018. And just knowing that we were a bank, we were based in London, South Africa, and we were interested in conservation and trying to preserve our natural heritage. And so we joined United for Wildlife's Financial Task Force. When it's set up, about two years later, United for Wildlife told us that they were going to come to South Africa and they were going to get together law enforcement, the transport and finance sectors, some conservationists, and they would like to have a meeting.
(02:01):
So we offered to host them in our building. And that really was a light bulb moment for me, for someone who had been working on amazing projects, educating children about conservation and working with people in Rhino Rescue, wild Dog Rescue, pangolin Rescue skirting the illegal wildlife trade issues. From my perspective, we suddenly opened our eyes to the possibilities of what we as a bank could do to make a real impact using our resources, our skills, our experience, our systems. And it was really just so exciting for us to be able to then work together with our compliance team, our financial crimes compliance team, and a public private partnership called Emli, which is a South African anti-money laundering integrated task. And that had literally just been set up. So we were the first working group to be established under SAM Lit, and we focused on the illegal wildlife trade. And that brought together the Financial intelligence unit. It brought together serious organized crime investigators as well as banks. And we got started on looking at their legal wildlife trade. So a really exciting initiative, but for me, the realization that we could do so much to have real impact on organized crime, connected to wildlife trafficking through our existing infrastructures as a bank.
Penny Crosman (03:42):
Sure. And I want to unpack what some of that work specifically is, but just to set the stage for you, Jonny, how did you get interested in this whole area?
Jonny Bell (03:53):
Yeah, so I guess my background is really financial services orientated and more specifically the world of financial crime compliance. So when I joined LexisNexis Risk Solutions about two years ago, I was just amazed at technology capabilities and the data capabilities we had in the world of financial crime compliance. And then had some contacts through Rob Campbell at the Royal Foundation and United Wildlife. And I wanted to put two and two together. I knew we had these amazing data insights at LNRS, and I wanted to make sure that we could leverage those for something good. And the topic of wildlife trafficking came up. There's obviously a lot of overlap with financial crime compliance when you talk about a predicate crime like wildlife trafficking. And so established a partnership with United Wildlife and haven't looked right back.
Penny Crosman (04:57):
Really interesting. Came at it from a pretty different angle. So interesting partnership there. So Geraldine, for those who may not know much about illegal wildlife training, can you kind of paint a picture for us of what's happening today? I mean, you do hear once in a while about poaching and there's just an article recently about donkeys being used for various products in China. What are some of the things that are going on today?
Geraldine Fleming (05:30):
Thanks, Penny. Well, I always say I'm not always very good dinner party conversation. It can get quite depressing at times. But really when we think about wildlife trafficking, we tend to think about rhinos or rhino horns or elephant ivory or perhaps pangolins or Pangolin scales. And those traditionally have been the keystone species flagship products that have been traditionally had a lot of awareness and a lot of effort put in terms of countering that wildlife trade. But recently we started to see a lot more activity happening. The exotic pet trade has taken also a lot of snakes and lizards and frogs and various kind of insects, spiders that are starting to move. And that goes sometimes through Europe, through the big pet trade fairs there, or sometimes directly, and that goes to Southeast Asia, but also to the states and as I say, through Europe as well.
(06:44):
So quite widespread. Glass eels are another product where it's protected in Europe. And these tiny little eels are caught in rivers and smuggled to the east where they are farmed. They can't be bred in captivity, but they are grown and then re-exported to the rest of the world as sushi. And it's a PR expensive dish. And some of us may not even be aware that when we are eating certain types of sushi that we are actually consuming something that has been trafficked illegally. We are also seeing a massive increase since covid in succulent plants, little cactuses or little small succulent plants that people have started to collect initially within their houses. But now they're starting these beautiful succulent gardens. And unfortunately, some of these plants take 80 a hundred years to grow and once they're removed from a particular area, can't really be put back because when they seized, for example, in an arrest, one can't always identify exactly where that plant came from. And sometimes they'll come from a really small contained area the size of a school hall.
(08:17):
So some of these plants, I think they said today that already eight species in South Africa have gone extinct in the last couple of years just from the succulent trade. So I'm sad to say there is anything and everything that is being traded, the donkey skim trade that you were talking about earlier is really concerning, not just because you're talking in the region of 5 million donkeys a year, donkey skins that are being sent to China. That means 5 million donkeys are being slaughtered and their skin is boiled and used to make eja, which is like a type of glue or ingredient that is being used and is supposed to give really youthful properties and other things. And the consequences of this donkey skin trade are devastating because in many rural areas and many poorer areas, the donkeys are the means to someone's livelihood. And a lot of these donkeys are being stolen and removed, which means that people can't farm, they can't transport their goods to the town that they live in to sell them.
(09:38):
So there's massive social consequences to these donkeys being traded, donkey skins being traded. I won't get into the animal rights part of it, but the other thing is that when the skins are moved, they sometimes are dried but often are not. And because they become really smelly and distasteful, other wildlife products may be hidden inside them like lion bones or rhino horn or ivory or other products. And when somebody opens a container to have a look at it, it's just really too disgusting and you can't blame them if they wouldn't look very much more closely at it to try and see if there was anything else hidden within the skin. So yeah, quite a sad picture to paint just by way of numbers. The illegal wildlife trade at the moment is valued between seven to 23 billion annum. It's a big range because it's very hard to get a handle on the exact numbers.
(10:53):
It's all based on seizure data. But if you look at broader environmental crime at a value of about 260 billion per annum, it's about 75% of the value of the drugs trade, but obviously gets a lot less attention. So there's a lot that needs to be done and for many different reasons, there's convergence with drugs trade where you find marine products moving with the drugs trade as well. So there really is a lot to be done with more consequences than just losing plants and animals to our natural heritage. There's a lot of social and just organized crime implications that need drastic attention.
Penny Crosman (11:43):
Sure. You just answered several of my questions, so thank you. And you didn't want to mention animal rights, but I have no doubt there's tremendous brutality involved as there is in our factory farm system in the U.S. and many other countries. And all of that just seems to continue to escalate every year. But I know that's not our topic right today. So we want to get into what exactly your organizations are doing to try to curtail some of this. And you started talking about it before, but just to start back at the beginning, what is United for Wildlife? What were they set up to do and what are some of the things that they are doing with banks to try to address this issue?
Geraldine Fleming (12:34):
Well, United for Wildlife is a program that is part of the Royal Foundation of the Prince and the Princess of Wales. And in 2013, prince William, who is quite passionate about wildlife and wanted to do something to try and disrupt or put a stock to this illegal wildlife trade. And so he formed United for Wildlife and really with a view to kind of trying to bring the private and public sector together in some way. And a couple of years later, having done some research and some homework, they started what they called the Transport Task Force, which looked at bringing together all airlines, shipping lines, airports, customs authorities, courier services, postal services, and the transport task force was born. And really, I kind of think of it, if you look at the illegal wildlife trade, first, you need to move a product, you need to move a product from A to B.
(13:47):
And these, if you look at it, it's organized crime. These are massive international logistics businesses that are shipping products, that are flying products. They have massive logistics networks. And to bring that transport sector together to actually try and inhibit and try and prevent those products from being shipped or transported in the first place was critical. But having successfully done that, and today we have over almost 240 different airlines, shipping lines, organizations, transport companies in our network, they then set up the financial task force. And really that was kind of to say, well organized crime, it's a logistics business, we can stop the product moving, but we still need to try and prevent access to financial systems. And even more, we have a unique opportunity to actually use the financial systems to gather evidence, to collect information around transactions, around individuals, and to start building a picture of what a network looks like.
(15:03):
And in doing that, it enables us to get a bit of picture of what that network looks like and then to gather evidence to arrest, prosecute, and convict. And we found today that actually when we start looking, we can come back to it later when we start looking at adding financial crimes, money laundering charges to wildlife trafficking charges, you are getting far more onerous sentences, longer sentences, harsher sentences. And that kind of takes us back to making the crime more of a higher risk. So it's currently a low risk, high reward crime, but the more risk and more stringent penalties that we place on people who are caught the, I guess, less inclined people will be to take part in that. So really United For Wildlife, we are what we say we are, we have partnerships with all the big law enforcement organizations like Interpol and FBI, Homeland Securities, fish and Wildlife Services, Europol, the un, ODC.
(16:28):
We have a lot of the big organizations and then often work regionally with national law enforcement as well. So we bring together the private sector, law enforcement, conservation organizations who play a very important role, some of the bigger ones in terms of research and information around wildlife trade and trends and the illegal trade and the legal trade. And then some of the smaller ones who are on the ground who are often able to provide law enforcement with information or intelligence that can lead to tip-offs and potentially seizures or interdicts. So bringing those private and public sectors together, we encourage people to work in public private partnerships. It it creates a framework for people to share information on investigations legally.
(17:32):
And it can just allow us to be more effective. And we really just organize ourselves in regional chapters. You can imagine we've got over 61 financial institutions who've committed to do what they can to prevent wildlife trafficking or any kind of wildlife trade infringements within their organizations. And by breaking them up into regional teams, we are able to be more effective. So we bring people together in Southeast Asia and Hong Kong, in North America, south America in east and Southern Africa. And we are soon to launch chapters in India as well as West Africa and Europe. So by organizing regionally, we can then connect one region with another where appropriate, and we would not be involved in investigations, but we have a network that we are able to connect people so that they can continue on an investigation where it crosses borders.
Penny Crosman (18:42):
Sure. That's well put. And it kind of reminds me, we've done a couple of podcast episodes about human trafficking and how banks are trying to help detect some of the signs of that, and it seems like it's a parallel effort in some ways. So Jonny, you came at this from the financial crime point of view and that ability to look at anti-money laundering data, transaction data and try to find the signs of this activity. Can you kind of share anything you've learned about what kinds of signals might banks be able to find in their data that there is wildlife trafficking happening and those transactions are going through their walls?
Jonny Bell (19:40):
Yeah, absolutely. So the majority of financial institutions, or if not all financial institutions, will do something called screening in their operations. And really what they're trying to do is they will screen any new customers, be that individuals or entities, and they'll also screen payments. So when a payment is processed, they will screen various identifiers on that payment chain to understand whether there's any risk exposure there. As part of that, they will look at utilizing lists or data from around the world and key attributes to this data. Now, one of the things they will look for is predicate crime exposure. So if you think of what FATF outlined when it comes to predicate crimes, financial institutions around the world will want to understand their exposure to these predicate crimes, wildlife trafficking, human trafficking, narcotics trade, these are all types of predicate crimes. So within our data, we are able to look at all of those screening lists from around the world.
(20:57):
We consolidate it into a single file, and we're able to see trends related to what we would call adverse media data and enforcements data. So we can pick out keywords from those data sets and we can see what the trend is in terms of the number enforcements related to certain species that are being trafficked around the world. And the financial institutions that are using that data will have access to all of that information as well. So they can see if they are onboarding a new customer that has been exposed, or a new customer that has committed wildlife trafficking or being convicted of wildlife trafficking, that our data will feed into the financial institution's workflow and they will be made aware that that customer is trying to bank with them. But they've been convicted of wildlife trafficking before. And ultimately, what financial institutions are doing, and I think Geraldine alluded to this, is that they're trying to use the World Financial Services system to launder the proceeds of any illicit activities that they're doing. So the data that we provide and the cuts of the data on predicate crimes essentially gives them the tools and data to stop those individuals or entities transferring money through the world's financial services system.
Penny Crosman (22:24):
What if it's an existing customer that somehow is playing a role in some of this? Is there any way your data could be used to catch them?
Jonny Bell (22:34):
Yeah, absolutely. Great question. So that really comes down to the technology that the financial institutions are using. Now, again, most large multinational financial institutions will use what we call screening software, which is set up for ongoing monitoring. But essentially what that means is they will monitor their existing customer base. So if we then provide them with updated data that an existing customer has been convicted of wildlife trafficking or is associated with wildlife trafficking, yeah, absolutely. The financial institution will be notified of an existing customer that has been recently convicted.
Penny Crosman (23:18):
And it sounds like you can't name any banks that are actually involved in this work today, but are there some US banks involved?
Jonny Bell (23:29):
So, I mean, probably a question for Geraldine, but I'm pretty sure the partnerships of United for Wildlife are all public signatory. So if you can go onto the United for Wildlife website, and there should be a section there which outlines all of the banks around the world and financial institutions that have signed up to be official partners with United Wildlife.
Geraldine Fleming (23:55):
So you were asking which banks were involved in supporting or counter Wildlife trade?
Penny Crosman (24:08):
Yes.
Geraldine Fleming (24:09):
Any, okay. Yes, Jonny's a hundred percent. Right.
Penny Crosman (24:12):
Okay. And are there U.S. banks involved?
Jonny Bell (24:16):
Yeah, and all the big US banks and international banks, they're all very supportive of it. And I mean, standard Chartered we're involved in setting up the financial task force and have taken a very active role, but so have all the other big international banks as well. So they're great partners to us and they're very supportive and they work very closely with the financial intelligence units and law enforcement to do what they can to prevent wildlife trafficking.
Penny Crosman (24:55):
So last question for both of you. If someone who's listening wants to get involved in this effort and wants to help and they're not a member of this task force today, what are some things they might be able to do to help?
Geraldine Fleming (25:10):
Yeah, so I will jump in. So the first thing I would say is navigate to the United for Wildlife website. There's lots of information on there. The other thing I'd say is if you're working in the world of trade, transport, financial services, financial institutions, and you're interested in seeing whether the firm you work for is a member of United for Wildlife or a signatory, then just navigate to the website and you'll find out there. And if they're not, then have a conversation with people in your organization to see how you can become a signatory.
Penny Crosman (25:49):
Alright, great. Well, Geraldine and Jonny, thank you both so much for coming and to all of you, thank you for listening to the American Banker Podcast. I produced this episode with audio production by Adnan Khan. Special thanks this week to Geraldine Fleming and Jonny Bell. Rate us, review us and subscribe to our content at www.americanbanker.com/subscribe. For American Banker, I'm Penny Crosman and thanks for listening.