Wildlife Crime

Written evidence submitted by International Fund for Animal Welfare

1. The International Fund for Animal Welfare (IFAW) runs projects in more than 40 countries around the world and has over 400,000 supporters in the UK.

2. IFAW has more than 20 years’ experience campaigning on wildlife crime issues. We work closely with the National Wildlife Crime Unit (NWCU); we are members of Operation Charm, a joint collaboration of NGOs and the Metropolitan Police Wildlife Crime Unit to combat wildlife crime in London and raise public awareness of the scale of illegal activity; partners in the Coalition Against Wildlife Trafficking (CAWT) and internationally we undertake joint enforcement operations with Interpol’s Environmental Crime Programme and member countries of the Lusaka Agreement Task Force (LATF).

3. IFAW welcomes this inquiry into wildlife crime. Given the broad scope of the topic, we will focus the main body of our remarks on illegal wildlife trade.

4. Since the Environmental Audit Committee’s inquiry into Wildlife Crime in 2004, our view is that the scale of wildlife trafficking and subsequent impact on wildlife in range states has increased. Despite positive actions taken in the UK, including the creation of the NWCU, illegal wildlife trade in the UK remains significant. This is especially true of trafficking perpetrated using the Internet.

5. Legislation covering illegal wildlife trade is in need of revision, but the penalties currently in place are generally robust. However, the strong penalties available are rarely applied by the courts, and despite the good work of the NWCU and the Metropolitan Police Wildlife Crime Unit, wildlife crime is not given sufficient priority by many individual police forces. This problem will be exacerbated if the creation of the National Crime Agency sidelines the NWCU.

6. Increased resourcing by Government would increase the ability of enforcement agencies to tackle the problem, and IFAW encourages the UK to take positive steps in the EU and internationally to reduce wildlife crime around the world.

Illegal Wildlife Trade

The scale and impact of wildlife crime in the range states

7. Illegal wildlife trade is, according to the Global Financial Integrity Report ‘Transnational Crime in the Developing World’ published in February 2011, worth up to $10 billion (£6.3 billion) a year, has strong links to organised crime and terrorism and poses a serious threat to human health as well as an evident threat to endangered species and biodiversity around the world.

8. The Environmental Audit Committee recognised the threat posed by illegal wildlife trade in its 2004 Report into Wildlife Crime, which concluded that, "the link between wildlife crime and other serious crimes, the clear and growing involvement of organised crime, and the increased reliance on the Internet for illegal trade in protected species makes the argument for spending time and resources on this area of crime compelling".

9. Evidence IFAW has gathered suggests that since the Committee last examined this issue, illegal wildlife trade has increased, with a significant impact on animal species around the world, particularly African elephants. For example, according to the Elephant Trade Information System (ETIS), there has been "a steadily increasing trend in levels of illicit ivory trade from 2004 onwards, with an exceptionally sharp upsurge in 2009…data demonstrate that seizures of ivory reached record levels in 2009 and that these levels were largely sustained in 2010".

10. Indeed, 2011 witnessed a record number of large ivory seizures (classed as over 800kg), more than in any of the previous 23 years of ETIS records. These large seizures are indicative of the involvement of international organised crime syndicates. In at least 13 of these substantial hordes, the total seized was more than 23 tonnes. Once the records of hundreds of smaller seizures are included, the total amount seized is likely to exceed any previous year on record.

11. The most recent evidence of widescale criminality in relation to the killing of wildlife in range states is the ongoing butchering of elephants for their ivory in the Bouba Ndjida National Park in northern Cameroon. According to sources on the ground, from mid-January to mid-February 2012 more than 200 elephants were slaughtered, most likely by Sudanese poachers, with violence continuing at the time of writing. In the past poachers targeted elephants in Chad, but with that nation’s elephant population having dropped from several thousand to a few hundred in recent years, armed gangs are travelling further afield. It is now common for gangs of poachers from Sudan to cross into Cameroon during the dry season to kill elephants for their ivory, but the scale of the most recent attacks is unprecedented. There is evidence of militant groups being involved in the trade. The ivory is smuggled out of West and Central Africa for markets in Asia and Europe, and the money raised funds arms purchases for use in regional conflicts, particularly ongoing unrest in key hotspots across Africa.

12. In the last three years, more than 800 South African rhinos have been killed and it is clear we are facing the worst rhino-poaching crisis in decades. Last year alone a record 443 rhinos were killed, according to the South African National Park Service. Late last year the Western Black Rhino was declared extinct.

13. Recent monitoring of wildlife markets in China by IFAW indicates that the overwhelming majority of illegal wildlife products such as tiger bone wine and rhino horn are now exchanged for their investment, rather than medicinal value. Essentially, the closer an endangered species is to extinction, the higher its ‘investment’ value. For example, spot checks on the Taobao.com auction website during four weeks in January, May, July and November 2001 revealed 1,272 listings of wildlife products as collectibles, antiques and artefacts, but only 11 for traditional Chinese medicine products which included tiger bone gelatine and pangolin scale powder.

14. Trade in tiger bone and rhino horn is illegal in China but enforcement is challenging. In December, a large auction of tiger bone wine and rhino horn products in Beijing was shut down after IFAW alerted authorities but more needs to be done to tackle illegal sales. UK support for enforcement measures where demand is highest would be productive.

15. A month-long Independent on Sunday investigation in March 2011 found that "the snaring and slaughtering of animals is driving dozens of species to the brink of extinction… The world's tiger population has plummeted from 100,000 at the start of the 20th Century to below 4,000 today; 20,000 elephants are killed each year for their ivory; the number of rhino poached in South Africa doubled last year; sea turtles are being harvested at an astonishing rate; and, over the past 40 years, 12 species of large animal have vanished completely in Vietnam".

16. One obvious human cost of the illegal wildlife trade is the many rangers that are killed every year by poachers, but there are also other negative results of wildlife crime. The same investigation by the Independent on Sunday concluded that wildlife crime is "a major source of funding for terrorist and militia groups, including al-Qa'ida".

17. For example, the Janjaweed militia that carried out genocidal attacks in Darfur gained revenue from the slaughter of endangered species and the trade in their derivatives . From 2006-2008, they butchered hundreds of elephants around Zakouma National Park , according to authorities in Chad, carrying the tusks back to Sudan where they were s old onto ships bound mostly for Asia or traded for weapons. In 2007 Janjaweed militia carried out a n abortive attack on an ivory stockpile compound , where Chadian authorities had stockpiled $1.3 million (add GBP equivalent) worth of seized ivory.

18. In the Democratic Republic of Congo (DRC) 15,562kg of ivory has been seized in the last 20 years, with two-thirds of this collected in the last decade. Analysis from ETIS indicates three-quarters of this was obtained through organised crime rings. In Tanzania, the picture is even worse, with 68% of the 76,293kg of ivory seized during this period being smuggled by organised criminals.

19. According to The Independent, in 2008, the trades in bushmeat and ivory were found to be directly supporting rogue military gangs, and providing economic support for several persistent pockets of rebel activity in the DRC, including the Hutu rebels implicated in the 1994 Rwandan genocide. Arms and ammunition were provided in exchange for ivory and illegal bushmeat during the second Congo war of 1998-2003.

20. Loss of wildlife also has significant consequences for development. In 2006, tourism generated more than $800 million (add GBP equivalent) in Kenya, and whilst tourist numbers dropped following unrest in 2007, tourism remains Kenya’s highest foreign exchange earner. A significant proportion of this is based on Kenya’s wildlife.

21. Last year, Yuri Fedotov, the Executive Director of the United Nations Office on Drugs and Crime (UNODC) stated that the "illicit trade in wildlife is a form of transnational organized crime that, just like trafficking in illegal drugs, weapons and human beings, brings negative consequences to security and development".

The scale and impact of wildlife crime in the UK

22. It is important to make the point that, due to its illegality, it is impossible to assess the true scale of wildlife crime. Experts agree that seizures represent only a fraction of the real level (some Customs officials estimate that approximately 10% of contraband material is intercepted), but also represent the level of resources, for example staffing and training, that are put into tackling such crime. More resources will undoubtedly lead to more seizures, but obviously this does not necessarily mean that the level has increased – only that it has become more visible.

23. Nevertheless, the level of seizures does point to the scale of the crime and in the UK it is significant. For example, in 2008–2009 (the most recent figures publicly available), the UK Border Agency seized 61,402 endangered species items.

24. London is a major hub for Europe’s illegal trade in endangered species. Operation Charm, an initiative led by the Metropolitan Police Wildlife Crime Unit and involving NGOs including IFAW, has seized more than 30,000 endangered species items since 1995. The world’s largest seizure of rhino horns – 129 horns valued at several million pounds – occurred in Kensington in 1996, and the largest seizure of 138 shahtoosh shawls (made from the hair of the endangered Tibetan antelope) took place in Mayfair in 1998. No seizures as large as these have taken place in recent years, but smaller seizures continue to take place, suggesting the trade through the capital continues to be vibrant.

25. The trade in reptiles and amphibians in the UK is significant. In 2009, a man involved in the illegal tortoise trade was imprisoned for eight months. In May 2011, 15 live endangered tortoises worth up to £4,500 were seized at Stansted Airport. Operation RAMP (Reptiles & AMPhibians), a worldwide action in Autumn 2010, coordinated by Interpol, resulted in seven significant investigations in the UK – six of which are ongoing, with one already having resulted in a conviction. Likewise, a small scale action by Operation TRAM (TRAditional Medicines) in February 2010, again coordinated by Interpol, led to a conviction for the sale of leopard skin plasters being sold; a further major investigation is still ongoing.

26. The illegal trade of ivory online is a substantial issue in the UK as outlined below, but there continues to be evidence of significant offline activity. For example, in October 2011, two men were arrested and a substantial horde of ivory seized from a house in Cheltenham. A man in Bedfordshire was sentenced to eight months in prison in February 2012 for illegally trading birds of prey.

27. The China Association of Chinese Medicines reported an increase in prices of 700% in 2010, with rhino horn now selling for £60,000 per kilogram, twice as much as gold. This has led to a spate of recent thefts of rhino horn from museums in the UK, including in Suffolk, Surrey and Essex. The Natural History Museum and Horniman Museum (South London) have both removed their rhino horns from display. In September 2011, the NWCU issued a warning to all 15 British zoos and wildlife and safari parks that contain rhinos to tighten security and immediately report any suspicious behaviour to the police. Enforcement personnel agree that there is a clear link between demand for rhino horn in the UK and the illegal killing of endangered rhinos in Africa.

The extent to which UK legislation and regulations on wildlife crime are ‘fit for purpose’ and the penalties for offences are adequate

28. International wildlife trade is governed by the Convention on International Trade in Endangered Species (CITES) and implemented in the UK through the EU’s Wildlife Trade Regulations (which automatically become law in UK) and the UK’s Control of Trade in Endangered Species (Enforcement) Regulations (COTES) 1997 (amended in 2005, 2007 and 2009) which set out the offences and penalties relating to CITES trade.

29. Amendment in 2005 to COTES increased the maximum penalty for wildlife trade offences to five years imprisonment and/or an unlimited fine. This is welcome, and should be an adequate deterrent. However, penalties imposed are rarely close to this level, due primarily to the challenges faced by prosecutors and magistrates in understanding the severity of the offence and securing suitable penalties accordingly. This point is expanded on below.

30. The European Commission is finalising a review into European Law as it relates to wildlife trade. This will consist of changes to the current Regulations and accompanying guidelines (as outlined below) and so the UK will need to update its own COTES (Control of Trade in Endangered Species) Regulations accordingly. When COTES was last updated in 2009, the Government stated that the Regulations would be "the subject of an in depth review over the next two years, which is likely to result in significant changes".

31. IFAW’s understanding is that this review did begin under the last Government but has not progressed under the current Government due to budgetary constraints. We understand that a part-time member of staff joined the CITES team in October last year in order to take forward the project, and that informal consultation on the review will take place around Easter this year, with full consultation in autumn. According to Defra, the updated Statutory Instrument is expected by either April or October 2013.

32. Defra has been open in the past to input from voluntary organisations and we are confident that the updated COTES legislation will be fit for purpose. There is general agreement on many of the issues that require addressing. These include the need for new powers: for example the power to make test purchases to assess whether individuals are willing to sell illegal items, and the need to introduce new offences: for example surrounding the sale of caviar. The most important action is that the legislation be updated without further delay.

How policing of wildlife crime is coordinated in the UK and whether enforcement bodies have sufficient resources and powers

33. The UK Border Agency has a dedicated CITES team based at Heathrow Airport which has a UK-wide responsibility for enforcement of the endangered species laws at ports and airports. This team does a good job and works well with other enforcement bodies, most notably the National Wildlife Crime Unit (NWCU).

34. The NWCU is joint-funded by the Home Office and Defra and exists to coordinate intelligence and assist in investigations in order to target enforcement efforts at particular areas of wildlife crime. One of the National Wildlife Crime Unit’s (NWCU) priorities is the enforcement of CITES crime with a focus on ivory, tortoises and traditional medicines.

35. The NWCU does a good job with limited resources in providing support to Police Wildlife Crime Officers throughout the Police Service. IFAW’s view is that Wildlife Crime Officers do not always get the support they need from their forces in order to focus on tackling wildlife crime, where they have greatest expertise. Often, Wildlife Crime Officers will find their workload dominated by other ‘priority’ areas as senior officers do not recognise the importance of the work they are doing. IFAW recognises the leadership provided by the Association of Chief Police Officers (ACPO) and their Lead on Wildlife and Rural Crime, but this leadership is not always replicated at the constabulary level. Police forces should, in general, recognise the importance of wildlife crime.

36. The NWCU notes that the "lack of current quality intelligence" can make effective enforcement difficult. Greater resources for the NWCU would enable it to increase its level of intelligence gathering and give even greater support to local forces so that local forces feel able to devote more time to tackling wildlife crime. IFAW is very concerned by the lack of guaranteed funding for the NWCU beyond 2013. Given the good work the NWCU does, this situation must be resolved urgently, and the Government should guarantee funding for the foreseeable future.

37. According to the Home Office Structural Reform Plan, legislation to establish the National Crime Agency will be introduced this spring. Whilst the NCA Plan states that "the Border Policing Command will strengthen national security and crack down on the trafficking of people, weapons, drugs and wildlife" it is unclear whether the National Wildlife Crime Unit will be protected as a fully-resourced, distinct, specialised unit.

38. When wildlife crime was included within the Serious Organised Crime Agency (SOCA) it was often sidelined with resources diverted away into other more high-profile areas. This is a situation that must be avoided in future. The work of the NCA to tackle wildlife trafficking must be in addition to the work of the NWCU, not instead of it.

39. In London, the Metropolitan Police have a dedicated Wildlife Crime Unit. Again, this unit does good work with limited resources. Another voluntary organisation, the World Society for the Protection of Animals (WSPA), recently announced that it will be part-funding this unit. Clearly when a voluntary organisation has to supplement Government funding there are significant resourcing concerns.

40. To complement the work of CITES at a global level the UK also currently chairs the Coalition Against Wildlife Trafficking (CAWT) which aims to raise the political profile of the illegal trade in wildlife and wildlife products. Defra has stated that it is looking to hand over the chairmanship to another party in the immediate future. It is important that despite this move the UK continues to drive action against illegal wildlife trade at an international level, as outlined in more detail below.

41. IFAW works closely with INTERPOL’s Environmental Crime Division to tackle international wildlife crime by conducting joint operations. We are partners in Project WISDOM, an initiative to support and enhance the governance and law enforcement capacity for the conservation of elephants and rhinos. In the very near future there will be a significant operation in this field which, on completion, we will be happy to provide more information about in a supplementary note.

42. Defra and the NWCU also partner with INTERPOL to varying degrees. We recommend that the Government continues to fund and provide additional support for future INTERPOL wildlife crime operations to ensure this effective international co-operation continues.

43. Complementing our work with INTERPOL, IFAW trains national Customs and wildlife law enforcement agents to more effectively police the illegal trade in ivory and other wildlife contraband through our Prevention of Wildlife Trafficking Training programme. IFAW has trained more than 1,200 officials since the inception of this programme. We also train and equip rangers to protect elephants in range states. We would welcome support from the Government for similar initiatives.

How well Government and responsible enforcement bodies are responding to newer threats and challenges, including use of the Internet for wildlife trade

44. The online trade of wildlife is of particular concern to IFAW. Items available illegally on UK-based websites include many species of reptiles and amphibians, rare orchids and ivory.

45. In 2005 IFAW produced ‘Caught in the Web’, the first comprehensive report to investigate the online trade of wildlife in the UK. Over the space of several months IFAW found that every week thousands of animals and animal parts are offered for sale online, with a substantial amount of trade in species that are legally prohibited or strictly regulated. Items for sale included live primates, stuffed polar bears, giant ivory tusks and tiny dried seahorses. Within an intensive one-week period, IFAW found more than 9,000 wild animal products and specimens and live wild animals for sale, predominantly from species protected by law. A further 122 traders were identified, each advertising an unspecified number of items but often in sizeable quantities.

46. In 2008 IFAW undertook an extensive worldwide investigation and report entitled ‘Killing with Keystrokes’. Over the space of three months, six one-week surveys were conducted in various countries, the main results of which are summarised in the table below:

No. of websites tracked

No. of adverts

No. of adverts on eBay

No. of adverts for elephant products

No. of adverts for exotic birds

Advertised Monetary Value of all adverts ($)

Value of Final Sales Recorded ($)









































































47. The online trade of protected wildlife (CITES Appendix I and selected Appendix II items) in the UK was the most extensive in Europe, and was high compared with all other countries except the United States. The high volume pointed to an even greater problem as investigators only focused on a limited number of species. The significant trade in ivory was evident, as was the trade through large sites such as eBay. In 2007, eBay announced a ban on cross-border trade in ivory, yet the investigation identified a significant amount of ivory being shipped internationally through eBay. As a result of our investigation, in 2009, eBay announced a worldwide ban on sales of all animal ivory on its websites.

48. Most recently, a smaller scale IFAW survey in February 2011 of UK-based publicly accessible websites found a total of 61 listings of ivory, with none providing clear proof that they were being sold legally - either they were posted on sites that explicitly ban the sale of ivory or other products from endangered species, for example eBay and Gumtree, or the adverts contained no reference to legality. Websites that have banned trade in endangered species on their sites are to be commended for their positive stance, but clearly enforcement issues remain.

49. Legislation regarding online trade requires significant improvement if it is to be regarded as ‘fit for purpose’. The primary challenge is that it is extremely difficult to assess whether items are being sold legally or not. One option for the UK may be to adopt similar legislation to that introduced in the Czech Republic where onus is placed on the sellers and website owners to prove the legality of the items being sold online.

50. In 2009, following recommendation from IFAW, CITES formed a working group on e-commerce of specimens of CITES-listed species. NGOs including IFAW are members of this working group, along with a handful of countries including the UK, which chairs the group, providing it ample opportunity to drive forward change at the international level. In 2010, the Conference of the Parties approved a resolution calling on all parties to ensure that their domestic measures were sufficient to address the challenge of e-commerce in CITES-listed species. In IFAW’s assessment, this is one area in which the UK could do more to drive forward improvement in enforcement both nationally and internationally.

51. IFAW has commissioned an international wildlife crime prosecutor to provide legal advice on strengthening the UK’s legislation on Internet wildlife crime, which we are happy to share with the Committee as soon as it is available. In addition, by this summer, IFAW will be in a position to share the findings of a joint INTERPOL / IFAW investigation into the illegal online trade in ivory in the UK and other EU countries.

52. Another issue we encounter relates to antique ivory. Antique ivory can be legally traded in the UK but in our view dealers should only be able to certify ivory as antique if they are part of a registered team of experts: At present anyone can certify ivory as being antique, which presents significant difficulties in differentiating between illegal and legal ivory.

How fully wildlife crimes are recorded and how rigorously available penalties are applied

53. IFAW supports making all CITES crimes recordable offences. This would enable enforcement agencies to make greater use of databases, and make it easier to track trends and prioritise the most important issues. Making CITES and other wildlife crime recordable would enable police forces to monitor wildlife crime more effectively and target resources most efficiently.

54. Ensuring that available penalties are rigorously applied is an important issue, and one that needs addressing. Few prosecutors and magistrates understand the severity of wildlife crime or its impacts and, as a result, strong penalties available in law are rarely applied.

55. One solution would be to ensure that specialised wildlife crime prosecutors in every Crown Prosecution Service area are able to take wildlife crime cases through to court (as is the case in Scotland). At present specialised prosecutors often review the case, agree there are grounds for prosecution but then pass on the file to another prosecutor who may not have the expertise to sustain the case and reach a conviction in court.

56. To complement this step, IFAW considers that the Sentencing Council could provide appropriate guidelines to magistrates and judges to inform them of the complexities of wildlife legislation and the need for strong penalties to be applied.

How effectively behaviour-change and attitude-change is being promoted

57. As outlined above, Operation Charm, the joint initiative by the Metropolitan Police Wildlife Crime Unit and NGOs including IFAW, undertakes public awareness work in London. The Greater London Authority has in the past been a member of this coalition but has since dropped its support, and as stated, another NGO has now decided to part-fund the Unit. Increased Government support for Operation Charm and its public awareness programme would be much welcomed.

58. IFAW undertakes public awareness work in European airports and other airports across the globe, to encourage tourists and the travelling public to consider the negative impact on biodiversity when buying souvenirs abroad. Berlin Brandenburg Airport has already offered free advertising space to IFAW to promote these issues when the airport opens later this year. Similar advances to British airports have not been successful, with space not offered below a typical private rate. We would welcome encouragement from the Committee to airlines and airports to make tourists aware of the impact of their purchases abroad.

59. IFAW also hopes that awareness of the scale and impact of illegal trade in wildlife will be increased through this inquiry and publication of the Committee’s report. IFAW would welcome a debate on the Committee’s findings in Westminster Hall to further raise awareness and maintain the issue on the political and public agenda.

The UK’s role in influencing the EU and International agreements on illegal wildlife trade

60. The UK both independently and as a member of the EU has a tremendous potential to reduce and prevent illegal wildlife trade. Although the European Union is not a Party to CITES, its provisions have been implemented in Community law since 1982. CITES is currently implemented through Council Regulation (EC) No. 338/97 and specified in an implementing Regulation (Commission Regulation (EC) 865/2006).

61. The first and most obvious opportunity for the UK is in influencing the EU’s own CITES regulation. As has been stated these are currently being reviewed by the European Commission. This review will consist of the adoption of some limited changes to Commission Regulation 865/2006 and the publication of a guidance document which would assist national administrations and stakeholders in the interpretation of some provisions of the EU wildlife trade legal framework.

62. Rather than seek to secure large-scale changes to Commission Regulation 865/2006, the European Commission has decided to make minimum amendments to the regulation itself. It has instead chosen to focus its energies on drafting a set of 24 guidelines for Member States to use. The UK Government has taken a leading role in this process by volunteering to draft five of these guidelines. This is a positive step, but the Government must also ensure that it monitors the other guidelines and actively participates in all negotiations to ensure the resultant legislation is fit for purpose.

63. The CITES Conference of the Parties itself provides an opportunity for the UK to influence. The UK takes an active role in both the EU coordination process and global negotiations at CITES to strengthen enforcement of CITES controls and to tackle illegal trade. According to a May 2007 report by TRAFFIC, the EU tops the list of major importers by value for many wild animal and plant products, including tropical timber, caviar, reptile skins and live reptiles.

64. Given the size of this market together with the voting power of a 27-member bloc, the UK and EU should yield tremendous influence at CITES. Often however, the UK and EU have failed to influence the global agenda to the degree one would expect. This is because the EU spends too much effort - both before and during Conference of the Parties - trying to agree internally on a common position, rather than rallying third parties to its positions. The UK and its European partners must determine its priorities much earlier in future to ensure that it has sufficient time to influence other parties.

65. IFAW supports the Coalition Agreement outlining the Government’s commitment to ‘press for a ban on ivory sales’. Legal stockpile sales fuel demand for ivory that contributes to the killing of elephants, and so we commend the Government’s position. It must ensure that it works with EU partners to guarantee legal stockpile sales are not agreed at CITES, and that the demand for wildlife products is thus reduced.

66. The EU has also established an Enforcement Group consisting of representatives of each of the Member State's authorities which have responsibility for monitoring compliance with the Regulations, such as Customs, Police and Wildlife Inspectorates. The group is chaired by the European Commission. The task of the group is to monitor enforcement policy and practice in the EU Member States and make recommendations to improve the enforcement of wildlife trade legislation. Despite this, wildlife trafficking is still not seen as a priority issue amongst many EU member states, resulting in low penalties and enforcement priority.

67. As such, a Commission Recommendation identifying a set of actions   to improve enforcement was adopted in June 2007. These included the adoption of national action plans for enforcement, ensuring all enforcement agencies have adequate financial and personnel resources, ensuring penalties act as a deterrent and raising awareness of the negative impacts of illegal wildlife trade. Given the priority the UK Government has given to this issue, IFAW believes the UK should take a leadership role to ensure that these recommendations are fully satisfied.

68. The UK and EU, as a top importer of wildlife and through its policies and commercial activities, has the potential to assist other countries in combating wildlife trafficking. IFAW believes that the UK’s membership of the Commonwealth, the EU’s Cotonou agreements with developing countries (which come up for renewal in 2013), European Partnership Agreements and Free Trade Agreements provide just the mechanisms one could use to provide this assistance.

69. IFAW has begun engagement with a number of countries on trade issues with an eye towards affecting change on wildlife trade. Specifically, IFAW has encouraged governments to discuss illegal wildlife trade during free trade negotiations. The focus of that work is on mandating strong, enforceable standards, education programmes, and implementation and enforcement of international laws affecting wildlife.

70. Under Step 6 of its recent Biodiversity Strategy 2020, the EU has committed to: "Enhancing the contribution of trade policy to conserving biodiversity". In particular, the EU has formulated a detailed policy regarding how trade specifically should be used to further these goals. These commitments provide a solid platform for the UK to advocate impactful trade policy changes that will significantly reduce the threats to wildlife resulting from poaching, habitat destruction and illegal trade.

71. The United States has already begun introducing such provisions into its Free Trade Agreements, such as the US/Peru FTA which was signed in 2006. Indeed, in its "Green Paper on Conservation and the Trans-Pacific Partnership" the US Trade Representative states that:

72. "Each year, billions of dollars in illegally harvested or taken wildlife and wild plant products move across borders, often through the activities of global criminal networks that also trade in illicit arms and drugs. This global trafficking problem has implications for world trade and the environment, and the United States views the Trans-Pacific Partnership (TPP), a regional agreement that it is negotiating with Australia, Brunei, Chile, Malaysia, New Zealand, Peru, Singapore, and Vietnam, as a unique opportunity to tackle this issue and other trade-related environmental challenges."

73. IFAW urges the UK to ensure that future EU Economic Partnership and Free Trade Agreements enact and enforce laws to combat domestic and international illegal wildlife trade, bring national laws into compliance with CITES, address the need for wildlife rescue/rehabilitation centres, and work to prevent the killing and trade of endangered species.

Hunting with dogs

74. Recognising that the Committee has chosen to exclude hunting with dogs from its inquiry into wildlife crime as the focus will be on areas covered in its 2004 Report, IFAW will keep our submission in this area brief. Nevertheless, hunting with dogs is a wildlife crime like any other, and should be given the same priority by police and the Crown Prosecution Service as any other crime.

75. The most recent data released by the National Wildlife Crime Unit (NWCU) of incidents reported to it between September 2010 and May 2011 demonstrates that wildlife crime as covered by the Hunting Act is widespread. Using NWCU categories, there were 733 reported incidents of ‘hare coursing’, more than any other category, and 126 incidents of ‘fox hunting’. There were 205 incidents of ‘poaching – deer’, a crime often perpetrated using dogs and so prosecutable under the Hunting Act. Altogether, these accounted for almost 40% of all wildlife crime incidents.

76. Chief Constable Richard Crompton, the Association of Chief Police Officers (ACPO) lead for wildlife and rural crime, states in a letter to the RSPCA that "there have been a substantial number of convictions under the Hunting Act 2004. Such evidence, in my view, demonstrates that the act is enforceable." Indeed, more than 180 people have been successfully prosecuted under the Hunting Act, excluding figures from 2011 which are not publicly available, making it more successful than other wildlife legislation in the same period, including the Deer Act 1991, Protection of Badgers Act 1992 and the Wild Mammals (Protection) Act 1996.

77. The law covering hunting with dogs is clear and enforceable, and so the priority should be for police and the Crown Prosecution Service to ensure the law is upheld.

24 February 2012

Prepared 5th March 2012