Wildlife Crime

Written evidence submitted by INTERPOL

1. BACKGROUND  

INTERPOL and its Environmental Crime Programme  

INTERPOL  

1. INTERPOL is the world’s largest international police organisation, with  190 member countries190 member countries. Created in 1923, it facilitates cross-border police cooperation, and supports and assists all organisations, authorities and services whose mission is to prevent or combat international crime. As the only organisation with the mandate to share and process criminal information globally, INTERPOL is able to lead efforts developing an international strategy to deal with criminal activity and aims to facilitate international police cooperation even where diplomatic relations do not exist between countries. Action is taken within the limits of existing laws in different countries and in the spirit of the Universal Declaration of Human Rights.

Environmental crime

2. Environmental crime is defined as a breach of a national or international environmental law or treaty that exists to ensure the conservation and sustainability of the world’s environment, biodiversity, or natural resources and includes but is not limited to illegal trade in wildlife, illegal logging or fishing, pollution of air, water and soil and theft of natural resources [1] .

3. INTERPOL recognizes that environmental crime is a serious growing international problem, threatening not only the world’s biodiversity but also the global economy and security. It is not restricted by borders and is often interconnected with other types of criminal activities, such as corruption, fraud, theft and even murder. In addition, there are examples where environmental crime is linked to issues such as the arms trade and conflict; and the spread of diseases including zoonosis. For these reasons, INTERPOL addresses these issues as matters of "environmental security" which affect not only the natural world, but also human health and welfare.


INTERPOL Environmental Crime Programme  

4. INTERPOL’s work against wildlife crime dates back to 1992 with the creation of the Environmental Crime Committee to assist INTERPOL in identifying emerging patterns and trends in the field of environmental crime. The Committee acts as a forum in which law enforcement officials can meet face to face in order to discuss new strategies and practices, share experience and expertise, and build bridges of international cooperation vital to the fight against international environmental crime. Two working groups, the Wildlife Crime Working Group (WCWG) and the Pollution Crime Working Group (PCWG) further focus the Committee’s activities in specific areas.

5. INTERPOL’s efforts were further strengthened in 2009 with the formation of the INTERPOL Environmental Crime Programme (ECP) which brought all forms of environmental crime under the management of one dedicated unit. The mission of the ECP is to assist member countries in the effective enforcement of national and international environmental laws and treaties. Through this we can contribute to the ongoing conservation of the world’s environment, biodiversity and natural resources.

6. Since its creation the ECP has coordinated global and regional operations, delivered training on standard communication techniques, secure system procedures and intelligence gathering and analysis, developed law enforcement guides, coordinated intelligence campaigns, and hosted and managed international conferences.

7. The negative effects of environmental crime are not limited to individual nations thus there is a fundamental need for international cooperation and coordination. INTERPOL therefore encourages participation from environmental experts across the world in order to maximize the global impact of current projects and to devise new initiatives. The overarching aim is to identify ways and methods to improve the flow and exchange of information between wildlife enforcement agencies, INTERPOL National Central Bureaus (NCBs) and the INTERPOL General Secretariat. 

8. The INTERPOL Environmental Crime Programme is funded entirely from external sources and is not eligible to receive core funding from the INTERPOL General Secretariat. As a result, the Programme is reliant on voluntary direct donations from NGOs and governmental departments to continue its work. However, following the unanimous resolution adopted at the 79th INTERPOL General Assembly in 2010 (Appendix 1), the Organisation’s member countries committed themselves to a sustainable Environmental Crime Programme through departmental support for the Programme’s goals and objectives.

2. UK - INTERNATIONAL ACTIVITIES  

9. Due to INTERPOL’s international scope, our evidence regarding the UK’s response to environmental crime will focus on its international dimensions, particularly within the scope of engagement with INTERPOL Environmental Crime Programme.

UK Engagement with INTERPOL  

10. A number of UK Government agencies concerned with wildlife crime have played a vital role in the development of the INTERPOL ECP and displayed leadership in a number of ECP projects and operations. Furthermore, some agencies have provided vital financial assistance to the ECP.

UK National Wildlife Crime Unit (NWCU)  

11. From 2010 and until February 2012, the UK NWCU’s representative was the Chairperson of the WCWG and the project leader of Wildlife Operations project. This WCWG project supports ECP coordinated operations and insures that recommendations from conferences on environmental crime are followed in accordance with the ECP’s strategic plan. In 2010, NWCU assisted with two successful cross-border operations coordinated by INTERPOL:

12. - Operation TRAM, which targeted the illegal trade in traditional medicines containing wildlife products, involved 18 countries across five continents and resulted in seizures of more than EUR 10 million worth of illegal medicines worldwide. The operation was developed and coordinated by the INTERPOL Environmental Crime Programme with strong support from the UK NWCU, in response to the increasing use of endangered and protected wildlife products in traditional medicines throughout the world.

13. - Operation RAMP, which involved participants from 51 countries across five continents in an effort to fight illegal trade in reptiles and amphibians. Internationally, this operation lead to more than EUR 25 million worth of animals and product being seized. In the UK, for the duration of operation RAMP, more than 60 inspections were completed at Heathrow, Gatwick and Manchester airports, and visits were made to reptile traders, importers and exporters across England, Scotland, Wales and Northern Ireland. This included the cooperation of 46 police forces across the UK, Animal Health’s Wildlife Licensing and Registration Service, the NWCU and the UK Border Agency (UKBA).

14. The NWCU, through the WCWG, is currently actively assisting in the development and establishment of Project PREDATOR, an INTERPOL lead initiative targeting the illegal trade in tigers and tiger products, and Project WISDOM, a project targeting the poaching and illegal trade in elephant ivory and rhinoceros horn.

UK Department for Environment, Food and Agriculture (DEFRA)  

15. DEFRA has cooperated closely with INTERPOL and has been an important partner throughout ECPs existence providing financial assistance despite the economic crisis affecting contributions. At the end of 2011, DEFRA granted £75,000 towards the establishment and development of Project PREDATOR and £90,000 for the development of Project WISDOM. With current engagement in ongoing operations, DEFRA is setting a prime example for other governmental organisations in combatting wildlife crime.

16. DEFRA has been active in conferences and meetings organized by the ECP and has also confirmed its participation in the forthcoming 1st International Chiefs of Environmental Compliance and Enforcement Summit to be held in Lyon, France, 27-29 March 2012. The summit, hosted by The INTERPOL General Secretariat and the United Nations Environment Programme (UNEP), will bring together world leaders in the field of environmental law enforcement with the aim of improving environmental compliance, and to take the first co-operative step towards an enhanced state of international law enforcement collaboration.

Environment Agency for England and Wales (EA)  

17. The Environment Agency provided funding in 2008 and 2009 to assist the nascent ECP in conducting a vital awareness raising campaign. This support enabled the ECP to produce marketing materials including posters, presentation templates, and a booklet in INTERPOL’s four official languages: Arabic, English, French, and Spanish. These materials were invaluable in securing international support for the ECP from both government and civil society. Following the launch of this awareness raising campaign, international engagement with the ECP’s projects and operations increased significantly from our member countries as did NGO interest in financially supporting the ECP. Without this support the ECP would not have achieved the breadth of international success, engagement, and support at the speed it has.

18. The Environment Agency was a key contributor to the 2009 INTERPOL report Electronic Waste and Organised Crime – Assessing the Links as part of its work with the PCWG. Inspired by EA’s intelligence led operational successes, the PCWG adopted the EA intelligence led approach on a global level within the framework of an INTERPOL project that assessed the links between organised crime and the waste sector since 2006. The EA generously offered to take the leading role in this project which has continued its mission under the name INTERPOL Global E-Waste Crime Group. The Group was launched in 2010 and aims to further investigate links with organised crime, perform tactical analysis, provide sustainable integrated solutions for awareness, intelligence, prevention and enforcement, and set up intelligence-led global joint operations.

Scottish Environment Protection Agency.  

19. The Scottish Environment Protection Agency (EPA) attended 23rd Wildlife Crime WG Meeting and 17th Pollution Crime WG Meeting in Bangkok, Thailand held in February 2012 and has confirmed its participation in the forthcoming 1st International Chiefs of Environmental Compliance and Enforcement Summit to be held in Lyon, France 27-29 March 2012. By engaging in international events and meetings organized by INTERPOL ECP, The Scottish EPA is showing an active participation in the global efforts to combat environmental crime.

UK Border Agency (Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) Team)  

20. Although the UK Border Agency has had only limited direct contact with the ECP, the Agency’s CITES Team contributed to the 2010 Wildlife Smuggling Concealment Case Study Handbook. This manual for law enforcement officers was produced principally by the New Zealand Wildlife Enforcement Group under the auspices of INTERPOL. The Border Agency provided a number of images of methods used by wildlife smugglers to conceal wildlife when crossing borders and also provided commentaries on how their officers detected the concealments.

21. The UKBA’s operational activities (as noted above) were prominent during Operation RAMP. Such operations highlight the importance of cooperation between the local and national authorities and the INTERPOL NCB for successful information exchange and communication. Unfortunately, as will be discussed further in this document, successful intelligence and information sharing between UK and INTERPOL is an area in need of improvement.

3. COMMUNICATIONS AND INFORMATION EXCHANGE  

22. While open sources indicate that the UK is responsible for a large amount of enforcement actions and successes against wildlife crime, INTERPOL records contain only limited information to reflect this. Between 1997 and 2012 only a quarter of information exchange between authorities in the UK and INTERPOL contained information related to wildlife crime, with the remaining three quarters predominantly concerning pollution crime [1] .

23. In 2011, the INTERPOL Environmental Crime Programme processed 41 transmissions from the United Kingdom, containing one or more intelligence report. On the basis of these transmissions, the criminal history of 172 persons and numerous companies (suspects, fugitives, convicted felons, associates) was recorded onto the INTERPOL Criminal Information System. The vast majority of these intelligence reports were provided by the Environment Agency of England and Wales related to electronic waste trafficking. Approximately 10 transmissions from the United Kingdom, related to environmental crime, are currently pending processing [2] .

24. While communication in general among the UK’s environmental agencies, the INTERPOL NCB in London and the INTERPOL General Secretariat has been efficient and effective in the recent years, the connection between the national and international environmental crime intelligence model does not seem to have been fully incorporated in standard procedures. This particularly concerns wildlife crime related intelligence. Furthermore, the use of INTERPOL’s recommended format for communication for environmental crime incidents, the Ecomessage, has not been implemented by the UK authorities. Apart from a single exception, no information received from the UK in 2011 was submitted using this format, which was designed and recommended by INTERPOL at the request of and in close cooperation with the member counties, gathered in the INTERPOL Environmental Crime Committee.

25. The Ecomessage system provides a uniform format to report all forms of environmental crime. The form is available in the four official languages of INTERPOL and is designed to facilitate the rapid, efficient and methodical entry of data into the INTERPOL data systems, where it can be cross-referenced with previous entries and become available as structured data for strategic and tactical criminal analysis.

26. Given the international nature of environmental crime and the necessity of cooperation between law enforcement agencies globally in order to successfully apprehend and deter criminals, there are a number of clear benefits for the use of the Ecomessage:

27. - The field structure of the format supports and guides the reporting officer to complete all necessary information accurately

28. - Information collected by Ecomessages can be recorded and structured more accurately and efficiently into the database. This allows INTERPOL criminal analysts to better study the data on a strategic level to discern such information as the structure, extent, and dynamics of international criminals and organisations involved. On a tactical level, the analyst able to make connections on a global between routes and elements of transnational organised crime groups that cannot be discovered at a national level.

29. - Swift cross-referencing of information can produce rapid and valuable feedback on similar charges in a different country, wanted status, prior convictions or other criminal history details that may be of great value to on-going investigations in the reporting country. Furthermore, through INTERPOL’s I-24/7 global police communications system, electronic Automated Search Facility (eASF) and MIND/FIND system, law enforcement officials on the ground will have immediate access to this information for so called ‘hit/no-hit’ checks.

30. - The Ecomessage form enables the reporting agencies to make well specified requests and receive accurate responses from other member countries and the INTERPOL General Secretariat. In doing so, countries encourage effective international cooperation between law enforcement agencies. In the case of smuggled wildlife, the Ecomessage system also allows countries to address such issues as the repatriation and preservation of seized wildlife.

31. To date, the UK has not adopted the Ecomessage system as an integral part of their national environmental intelligence model. This has two major consequences:

32. 1 - A large amount of relevant enforcement information that may be crucial for effective environmental law enforcement in other member countries and is vital for adequate criminal analysis at the INTERPOL General Secretariat remains unknown to the global enforcement community.

33. 2 - The processing and recording of the provided unstructured information onto the INTERPOL systems requires an unnecessary and disproportionate amount of the scarce capacity available at the INTERPOL Environmental Crime Programme, both in extracting the relevant data elements from the submitted reports and in follow-up efforts to request additional information. This information is often needed to be able to record the intelligence in accordance with the INTERPOL rules for processing enforcement information or to fill in crucial intelligence gaps.

34. For comparison, the Polish National Environmental Intelligence Model has adopted the Ecomessage format as an efficient and effective internal reporting tool from the local to the national level. Sharing these reports with relevant member countries and the INTERPOL General Secretariat requires therefore minimum effort and is included in standard procedures. The processing of the forms at INTERPOL is equally time efficient. 92% of the close to 100 transmissions received from Poland in 2011 contained one or more Ecomessage forms.

35. It is strongly recommended that the United Kingdom assess the opportunities to include the international sharing of relevant environmental enforcement information in the standard procedures of its National Intelligence Model and adopt, where possible, the Ecomessage for reporting.

4. ROLE OF NON-GOVERNMENTAL ORGANISATIONS (NGOS)  

36. The UK has a number of active and effective NGOs. It is predominantly these UK based NGOs that ensure the UK’s representation at international events, meetings, conferences and summits. Recent 23rd Wildlife Crime WG Meeting and 17th Pollution Crime WG Meeting in Bangkok, Thailand held in February were attended by representatives from TRAFFIC, Global Witness, TRACE Wildlife Forensic Network, and the UNU institute of advanced studies.

37. In addition, two NGOs in particular have been consistently engaged with the ECP’s activities:

38. - The International Fund for Animal Welfare (IFAW) has been supporting INTERPOL’s wildlife crime activities for over a decade and has been a strong and consistent donor with regards to ECPs projects. IFAW is currently providing funding in support of both Project PREDATOR and WISDOM and has actively participated in international meeting and forums. A vital contribution was made to the six-day training initiative in Botswana for law enforcement officials from 10 countries which comprised classes and exercises in how to combat illegal wildlife trade.

39. - The Environmental Investigation Agency (EIA) UK office has actively engaged in highlighting the role of INTERPOL at an international level, improving the exchange of information and outreach material and endorsing the creation of the International Consortium on Combatting Wildlife Crime (ICCWC), encouraging more parties to get involved. EIA’s advocacy in support of the activities and objectives of the ECP is also acknowledged and appreciated.

40. The number of UK based NGOs involved in the international arena, and particularly with INTERPOL, should also be seen as a motivation for governmental bodies to become more involved in providing similar support to INTERPOL’s efforts in combatting and preventing environmental crime activities.

5. CONCLUSION AND RECOMENDATIONS  

41. The UK’s involvement in the work of the Environmental Crime Programme since its formation in 2009 sets an example to other member countries. The support received from various agencies has not only been valuable in developing the ECP, but is also responsible for the creation of successful projects, increased cooperation with other countries, and assistance provided in a number of successful operations. The UK NWCU’s involvement in the Wildlife Crime Working Group, in particular, supports the notion that the UK government recognizes the seriousness of environmental crime and the financial support provided by the UK DEFRA and the EA is a leading example of the efficient and effective cooperation on the international level.

42. However, there are a number of weaknesses, as outlined above, informing a number of recommendations:

43. - The UK government is strongly encouraged to continue raising awareness of the importance of law enforcement and compliance response to environmental crime.

44. - The INTERPOL Environmental Crime Programme encourages greater governmental commitment to the UKs environmental crime agencies to support their responses to environmental crime on national and international levels.

45. - UK environmental crime agencies are encouraged to increase their engagement with the INTERPOL Environmental Crime Programme to strengthen their involvement in combatting environmental crime on the international level.

46. - The identified weakness in effective environmental crime related information and intelligence sharing between the UK and INTERPOL needs to be addressed. In order to improve this, it is strongly recommended for the UK to assess the opportunities to include the international sharing of relevant environmental enforcement information in the standard procedures of its National Intelligence Model and adopt where possible the Ecomessage field structure for reporting.

47. - The INTERPOL Environmental crime, in line with the 79th General Assembly Resolution, is urging the UK, as a member country, and partner organisations to support the work of the Programme by making voluntary financial contributions.

48. - Further in line with the 79th General Assembly Resolution, INTERPOL is urging the UK, along with the other member countries, to provide support by seconding specialized personnel.

49. Only by working together with common objectives will we truly have an impact on the activities of the individuals, networks and companies that illegally exploit our shared environment.

Appendix 1  

AG-2010-RAP-08

GENERAL ASSEMBLY RESOLUTION

Subject: Sustainable Environmental Crime Programme

The ICPO-INTERPOL General Assembly, meeting in Doha, Qatar, from 8 to 11 November 2010 at its 79th session:

DEEPLY CONCERNED about the impact that environmental crime can have on the planet, the environment, biodiversity and human life,

TROUBLED by the influence that environmental crime has on the global economy and security,

RECOGNIZING that environmental crime is not restricted by borders and involves organized crime which engage in other crime types including murder, corruption, fraud and theft,

BEARING IN MIND the long-standing commitment by INTERPOL to fighting environmental crime, evidenced by AGN/61/RES/12 recommending that INTERPOL form the Environmental Crime Committee,

ACKNOWLEDGING that environmental law enforcement is not always the responsibility of one national agency, but rather, is multi-disciplinary in nature due to the complexity and diversity of the crime type which can encompass disciplines such as wildlife, pollution, fisheries, forestry, natural resources and climate change, with reaching effect into other areas of crime,

TAKING INTO ACCOUNT that there is a vital need for a global response to combating environmental crime and that INTERPOL, as the largest international police organization, should play a leading role in supporting the international enforcement efforts,

CONSIDERING that not one national agency is responsible for enforcing environmental laws, that there is a need for these responsible agencies to be connected with INTERPOL and the National Central Bureaus and that these agencies contribute to the enforcement efforts alongside the international police community,

URGES the member countries and partner organizations of INTERPOL to support the Organization by making voluntary financial contributions or, in the case of member countries, by seconding specialized personnel in support of the INTERPOL Environmental Crime Programme;

URGES the National Central Bureaus to support the Environmental Crime Programme by connecting with the responsible national agencies and encouraging their involvement and support.

24 February 2012


[1] Environmental Crime Programme Strategic Plan 2011-2013

[1] According to records held in the INTERPOL Criminal Intelligence System (ICIS)

[2] INTERPOL Environmental Crime Programme, 2012, Quarterly Intelligence Report Quarter 4 October 2011- December 2011 Including annual overview , Lyon, INTERPOL – For Official Use Only

Prepared 5th March 2012