Technical ReportPDF Available

Corruption and wildlife trafficking


Abstract and Figures

Wildlife trafficking is a growing global concern. It takes place in all regions of the world with those nations with high biodiversity being the source and the consumers of the wildlife as well as transit areas and hubs for smuggled wildlife. It is a significant contributor to biodiversity loss and species extinction. Many if not most developing nations are rich in biodiversity and therefore must contend with wildlife trafficking. It is a critical concern for these nations’ environment and economies. It has been documented that corruption is an essential component in the facilitation and perpetration of the illegal wildlife trade, but a comprehensive study into the scale, scope and structure has yet to be undertaken. This U4 Issue paper conducts a meta-study regarding corruption’s role in wildlife trafficking from the available literature, interviews with experts and a case study of Vietnam in an attempt to highlight concerns for bilateral donors in regards to conservation, environment and law enforcement programmes.
Content may be subject to copyright.
May 2015 No 11
Corruption and wildlife trafcking
Tanya Wyatt and Anh Ngoc Cao
Series editors: Aled Williams and Kendra Dupuy
U4 is a web-based resource centre
for development practitioners
who wish to effectively address
corruption challenges in their work.
U4 is operated by the Chr.
Michelsen Institute (CMI) – an
independent centre for research
on international development
and policy – and is funded by
the Australian Department of
Foreign Affairs and Trade, FPS
Foreign Affairs, Foreign Trade
and Development Cooperation/
BTC (Belgium), Danida (Denmark),
DFID (UK), GIZ (Germany), Norad
(Norway), Sida (Sweden) and the
Ministry for Foreign Affairs of
All views expressed in this Issue
are those of the author(s), and do
not necessarily reect the opinions
of the U4 Partner Agencies or CMI/
U4. (Copyright 2015 - CMI/U4)
Corruption and wildlife trafficking
Tanya Wyatt and Anh Ngoc Cao
U4 Issue
May 2015 No 11
U4 Issue 2015:11
Wildlife trafficking is a growing global concern. It takes place in all regions of the world with those
nations with high biodiversity being the source and the consumers of the wildlife as well as transit
areas and hubs for smuggled wildlife. It is a significant contributor to biodiversity loss and species
extinction. Many if not most developing nations are rich in biodiversity and therefore must contend
with wildlife trafficking. It is a critical concern for these nations’ environment and economies. It has
been documented that corruption is an essential component in the facilitation and perpetration of the
illegal wildlife trade, but a comprehensive study into the scale, scope and structure has yet to be
undertaken. This U4 Issue paper conducts a meta-study regarding corruption’s role in wildlife
trafficking from the available literature, interviews with experts and a case study of Vietnam in an
attempt to highlight concerns for bilateral donors in regards to conservation, environment and law
enforcement programmes.
This report would not have been possible without the help of the INTERPOL Environmental Security
Sub-Directorate, especially Nicki Mokhtari and PALF Enforcement’s Naftali Honig. Thank you to the
seven anonymous interview participants in Hanoi, who contributed valuable knowledge to the
understanding of corruption and wildlife trafficking in Vietnam. Further thanks go to Emily Cao for
her excellent transcription work. Finally, we thank Bruce Zagaris, Mary Rice and Phyllis Lee for their
insightful reviews.
About the authors
Dr Tanya Wyatt is a Principal Lecturer in Criminology at Northumbria University, UK. Her research
has focused on wildlife trafficking and has been published in various journals as well as her book
Wildlife Trafficking: a deconstruction of the crime, victims and offenders. She was Principal
Investigator on the Economic and Social Research Council (ESRC) funded Green Criminology
Research Seminar Series, which was a series of six seminars throughout the UK intended to increase
knowledge and interest around environmental crimes.
Cao Ngoc Anh is a doctoral candidate at Northumbria University. He is a lecturer in policing at The
People’s Security Academy in Vietnam. His current research combines a non-traditional security
approach with green criminology to examine the threats to states, humans and the environment posed
by timber trafficking in Vietnam.
U4 Issue 2015:11
Executive summary
Wildlife trafficking is one of the leading threats to the survival of species all over the globe. This has
impact upon the livelihood of people, particularly those in developing countries who are reliant on
wildlife for sustenance, income and shelter. Corruption can play a major part in facilitating this illicit
market. This makes the connection between corruption and wildlife trafficking relevant to bilateral
donors in three ways. First, bilateral donors have an important role to play in reducing corruption in
general and therefore wildlife trafficking in particular both directly and through national governments
and international organisations. Second, bilateral donors finance a number of conservation and
environmental programmes where corruption is a concern and work in or are based out of countries
that serve as hubs for the illicit financial flows stemming from wildlife trafficking. Finally, bilateral
donors finance a number of other projects that are likely to interact with corruption and wildlife
trafficking, such as law enforcement capacity building, rule of law and land administration or
agricultural projects. It is through these projects where recommendations can be made for how
bilateral donors can support efforts to reduce both corruption and wildlife trafficking.
Recommendations for bilateral donors:
Support states receiving aid to:
Criminalise money laundering, corruption and bribery
Promote transparent lobbying
Make evidence-based alterations to legislation and penalties
Have independent civil society organisations and mechanisms for whistle-blowing
Support criminal justice systems in aid-receiving countries to:
Strengthen law enforcement by increasing the status of wildlife and environmental officers,
building their accounting, technical and forensic expertise and providing better equipment
Create multi-agency task forces and international cooperation that involves money laundering
Make evidence-based alterations to work patterns that can help combat corruption
Implement accountability measures for law enforcement agencies and individual officers
Target corrupt officials for asset forfeiture and repatriation
Monitoring and transparency:
Support independent monitoring of crime prevention efforts for wildlife and banking
Support transparent banking systems with built-in audit trails
Have standards and criteria for combating corruption for states to continue to receive aid
Avoid cash donations or have these tightly controlled
U4 Issue 2015:11
Demand focus and attitudes:
Support or create initiatives to change people’s attitudes towards wildlife consumption
and corruption in a culturally sensitive way that does not marginalise groups of people
A coordinated effort to tackle corruption is crucial. This means addressing the state, criminal justice
system and the overall transparency and oversight of state institutions and donor programmes as well
as campaigns to change people’s acceptance of wildlife consumption and corruption all at the same
time. Donor agencies can be key players in driving these efforts through rule of law programmes as
well as role models of best practice by having robust monitoring and transparency in their own
projects, including of their finances and hiring processes. A missing piece that is crucial to better
understanding of the dynamics of wildlife trafficking and corruption is the unpicking of the illicit
financial flows and money laundering that run in parallel to these crimes. Donor agencies can help
support further initiatives and research into this essential area, which is important to improve success
in combating poaching and ultimately impacting on species survival and improved livelihoods.
CITES Convention on the International Trade in Endangered Species of Wild Fauna and
ENV Education Nature of Vietnam
EIA Environmental Investigation Agency
IFAW International Fund for Animal Welfare
INTERPOL International Criminal Police Organization International Police
IUCN International Union for the Conservation of Nature
NGO Non-governmental organisation
OECD Organisation for Economic and Cooperative Development
TRAFFIC Trade Records Analysis of Flora and Fauna in Commerce
UNCAC United Nations Convention Against Corruption
UNEP United Nations Environment Program
UNODC United Nations Office of Drugs and Crime
UNTOC United Nations Convention Against Transnational Organised Crime
WWF World Wildlife Fund
U4 Issue 2015:11
1. Introduction
Wildlife trafficking is one of the leading threats to the survival of species all over the globe. This has
an impact upon the livelihood of people, particularly those in developing countries who are reliant on
wildlife for sustenance, income and shelter. Research conducted into the nature and extent of wildlife
trafficking has shown that corruption can play a major part in facilitating this illicit market (Duffy
2014; Elliott 2007; EIA 2013; Brack and Hayman 2002; IFAW 2013; UNODC 2009; WWF/Dalberg
2012; Wyatt 2013c and others). This makes this topic relevant to bilateral donors in three ways. First,
bilateral donors have an important role to play in reducing corruption in general and therefore wildlife
trafficking in particular both directly and through national governments and international
organisations. Second, bilateral donors finance a number of conservation and environmental
programmes where corruption is a concern and work in or are based out of countries that serve as
hubs for the illicit financial flows stemming from wildlife trafficking. Finally, bilateral donors finance
a number of other projects that are likely to interact with corruption and wildlife trafficking, such as
law enforcement capacity building, rule of law and land administration or agricultural projects.
The illegal trade of live animals and plants and their products and derivatives, or wildlife trafficking,
is in contravention of national laws and international conventions, particularly the Convention on the
International Trade in Endangered Species of Wild Fauna and Flora (CITES) (Wyatt 2013c).
Trafficking includes the range of species diversity - caviar to coral; saiga antelope horn to sea
cucumbers; timber to turtles; walrus tusks to whale meat (Nurse 2014). The criminal profits are
estimated to be between USD 10 and 20 billion a year, but this figure does not account for illegal
timber trade and illegal fishing (Fison 2011). Illegal timber trade on its own is estimated to be worth
USD 30 to USD 100 billion annually (INTERPOL and UNEP 2012). This Issue paper will focus on
animals and start with a review of the literature beginning with a more detailed definition of wildlife
trafficking, how it can be categorised and the ways in which it intersects with corruption. It will then
analyse the literature regarding the nature and extent of the known role of corruption throughout the
supply chain in facilitating and perpetrating wildlife trafficking. The analysis will include an
investigation of the variety of corrupt operations that take place as well as the range of corrupt actors
that are involved in smuggling wildlife (Martini 2013). This includes examination of the role of law
enforcement, customs, the criminal justice system, corporations and individuals in circumventing the
legal trade and environmental laws intended to protect endangered wildlife. The study explores ways
in which payments and paperwork (Graycar and Felson 2010) throughout the supply chain can be
compromised. Whilst wildlife trafficking mostly begins in developing nations, the illicit financial
flows and the laundering of profits may take place in both developing and donor countries. The
current state of knowledge regarding this aspect of wildlife trafficking and corruption will be
investigated as best as possible though the available information is limited.
The literature review was supplemented by interviews with experts at INTERPOL’s Environmental
Security Sub Directorate and PALF Enforcement, a non-governmental organisation combating
wildlife trafficking in the Republic of Congo. For further evidence of the connections between
corruption and wildlife trafficking and what solutions may be created, a case study of Vietnam was
also completed. The case study combined the literature available about trafficking of wildlife in
Vietnam with seven semi-structured interviews of practitioners conducted in-country by one of the co-
authors. Vietnam is an ideal study site as it is a developing nation with high biodiversity, which also
has high levels of wildlife trafficking (Cao and Wyatt 2012), particularly import of rhinoceros horn
that is contributing to the threat of extinction of rhinos (Milliken and Shaw 2012). The aim is to try to
identify typologies of corruption at the various stages in order to advance prevention strategies.
Furthermore, the findings and analyses will be used to develop recommendations as to what role
donor countries might be able to play in reducing corruption and wildlife trafficking.
U4 Issue 2015:11
2. Overview of wildlife trafficking in the developing
world and the role of corruption
2.1 Literature review on wildlife trafficking
The illegal wildlife trade or wildlife trafficking is an environmental crime that has recently gained
international recognition as a serious concern for the global community. This is evident by the high
profile events taking place, such as the United for Wildlife Symposium sponsored by the British royal
family held in London in February of 2014, and both the European Union and the United States
seeking public comment on proposed policies about wildlife trafficking. Research on the illegal trade
in wildlife has been taking place for some time with academics and non-governmental organisations
(NGOs) investigating the nature and extent of the problem. This was predominantly done by
conservation organisations and biologists concerned with the impact of wildlife trafficking on the
survival of species (see the journal Oryx and the research of Vincent Nijman for instance). The
International Union for the Conservation of Nature (IUCN 2014) produces a Red List that categorises
species based upon their conservation status critically endangered, endangered, threatened and so
forth. In making these determinations, IUCN lists threats to species survival and trade (legal) and/or
trafficking (illegal) are contributing factors to many species facing reduced populations and possibly
extinction. Intentional hunting and trapping of terrestrial mammals is a threat to 2,536 species at the
time of this report (IUCN 2014). This does not include other vertebrates at risk.
The distinction between the legal and illegal trade and the complexities surrounding debates on if
trade bans and restrictions encourage illegality and create the conditions for black markets in wildlife
and wildlife products as well as the opposing view that legal trade provides a means of laundering
illegal wildlife - have drawn the attention of social scientists, particularly criminologists. They have
not reached a consensus though and this debate continues. Furthermore, wildlife trafficking’s
connections to other crimes such as smuggling of drugs and corruption have garnered even more
attention. Wildlife trafficking is a multi-stage crime that begins, in this case because of the focus on
animals, with the poaching or capturing of the target animal. They must then be transported by
smuggling or fraudulent means to the location where they will be sold. Depending upon the animal,
and if they are alive or not, this involves multiple various people, different forms of transportation and
various techniques for hiding the animal (Wyatt 2013c). Further actors will be involved if the animal
needs to be processed into a particular product to be sold.
Much of the literature focuses on and is critical of the way criminal justice systems across the world
fail to deal with wildlife trafficking effectively. This does not seem to be species dependent as there
are examples of the failure of international law to effectively deter illegal, unregulated and unreported
(IUU) fishing as seen in the continued poaching of Patagonian toothfish in the Southern Oceans
(Lutgen 2005) and the illegal trade of vascular plants like orchids (Flores-Palacio and Valencia-Diaz
2007). This also does not seem to be only a concern for developing nations as Lowther et al (2000)
found the United Kingdom’s approach to trafficking inconsistent and lacking cooperation between
agencies though this has potentially improved. Several researchers have pointed out that there is a
lack of seriousness given to (at least most forms of) wildlife trafficking. This is reflected in the
amount of enforcement resources allocated to combat it as well as the low penalties attached to most
convictions (Lowther et al 2000; Nurse 2011) though there are some exceptions, such as the death
penalty for tiger poaching in China. Schneider (2008) proposes that traditional crime control
techniques, such as routine active theory and market reduction approaches can be applied to wildlife
trafficking to decrease it. Other research by the International Fund for Animal Welfare (IFAW 2008,
2011) has investigated the challenges of monitoring and regulating sale of endangered species and
U4 Issue 2015:11
their products online. In particular, it was uncovered that there is a significant amount of ivory for sale
on the internet. This is clearly a challenge for law enforcement in regards to jurisdiction and
technological knowledge required to uncover these crimes.
Other literature has focused on the nature and extent of wildlife trafficking in terms of specific regions
Alacs and George’s (2008) study on wildlife trafficking within Australia for instance; Hongfa et al’s
(2007) research in China; Cao and Wyatt’s (2012) exploration of wildlife trafficking in Vietnam. Or
in regards to specific animals; Tapley et al (2011) investigate the trade of reptiles in the UK for the pet
industry; similarly Sollund (2013) explores reptile trade in Norway; Wyatt (2009, 2011) has
researched illegal fur and falcon trades. She has also undertaken a comparative study between
Australia, New Zealand and the UK, which details the range of animals targeted by traffickers. Even
more comprehensive research has been done by TRAFFIC (2013), a non-governmental organisation
which monitors wildlife trade, into the total number of seizures in Europe over the last decade.1 Focus
only on specific regions or specific species whilst useful may not expose larger patterns and methods
of trafficking that could be targets for wider prevention strategies. Cook et al (2002) attempt to
categorise wildlife trafficking as 1) specialist specimen collecting; 2) skins and furs, and traditional
Asian medicines; 3) activities linked to drug trafficking; 4) caviar trafficking; and 5) illegal timber
trade. This, too, is arguably overly focused on species, so again does not necessarily expose the larger
patterns. Wyatt (2013c) categorises wildlife trafficking based upon the motivations associated with
their demand. Her proposal is that across species and regions, the elements of why people want to buy
wildlife and wildlife’s characteristics will result in similar perpetration methods. This might prove
useful for identifying points along the trafficking chain that are prone to corruption and what form
that corruption might take. This will be discussed in more detail below when attempting to construct
typologies of corruption.
Several researchers have noted the involvement of organised crime in wildlife trafficking (Cook et al
2002; Davies 2014; Galster et al 1994; LeDuc 1996; Lin 2005; Lutgen 2005; Wyatt 2009, 2011,
2013c). This has implications for this discussion as it has been documented that organised crime is
closely tied to corruption (Guymon 2000). Also of relevance are the studies done analysing the
complexities regarding the consumption of animals as a natural resource and how this can be balanced
with their conservation (Stoett 2002; Wyatt 2013c). This has particular importance in the context of
developing countries, where reliance on wildlife as food and income is significant and where in some
cases Western environmental or conservation management regimes, which have wildlife conservation
at their core, may be met with resistance (Stoett 2002). Arguably, resistance is related to these regimes
prioritising sectioning off land for conservation over economic livelihoods as well as disrupting and
disregarding traditional practices of indigenous people.
2.2 Wildlife trafficking in the developing world
As research has shown, often nations in the developing world are the source areas that provide the
wildlife that fills the demand coming mainly from China, the United States and Europe (McMurray
2008). Many of these countries are located in biodiversity hotspots, which contain numerous species
targeted for wildlife trafficking. The literature highlights that developing countries struggle to combat
the illegal wildlife trade for a variety of reasons. One of the main concerns is lack of resources,
1 See also TRAFFIC reports searchable by region and species:
2 The responses from INTERPOL are a collection of answers taken from the numerous staff of the
Environmental Security Sub-Directorate and when referenced in this section are referred to as (INTERPOL).
The answers from PALF are from the organisations coordinator Naftali Honig, when referenced in this section
referred to as (PALF).
3 Respondents were all asked: Who are the corrupt actors that make trafficking of wildlife possible? Why are
U4 Issue 2015:11
including very few law enforcement officers dedicated to policing wildlife trafficking and a limited
amount of equipment for those officers. For instance, Far East Russia at one point only had two
rangers to cover thousands of square miles of remote forest and taiga (Wyatt 2011). Similar
circumstances have been noted in Cambodia (Wyatt 2013c) and Bolivia (Pires and Clarke 2011) and
are most likely the norm. Other concerns are weak enforcement, undefined or unclear property rights
(Brack and Hayman 2002), lack of political will (TRAFFIC 2008) and corruption. In fact, it has been
noted that transnational environmental crimes, like wildlife trafficking, are growing particularly in
developing countries where corruption is prevalent (Schmidt 2004).
Horne (2013b) notes though that developing nations like Vietnam are making strides against these
concerns. Ratification of key international treaties that may combat wildlife trafficking like CITES,
but also the UN Convention Against Corruption (UNCAC) or the UN Convention Against
Transnational Organised Crime (UNTOC), show evidence of efforts to tackle the illegal wildlife
trade. CITES is potentially an area for improvement though. In developing countries, CITES policy
implementation and delivery are sometimes unstructured, unstrategic and underfunded (Parr 2011).
Additionally, CITES focuses on two aspects of trade through two authorities Management and
Scientific and fails to adequately address enforcement (Parr 2011) or have ways to ensure
compliance when member countries fail or refuse to implement or enforce wildlife protection
measures (Reeve 2006). Further detail about wildlife trafficking in developing countries is found
below when discussing the role of corruption.
2.3 The role of corruption in wildlife trafficking
There is a fairly substantial body of literature that links corruption to wildlife trafficking though the
terminology, as demonstrated below, varies. Again, this is mostly the work of NGOs and intra-
governmental organisations with some research coming from academia. A majority of the research
recognises the link, but does not substantiate it with specific examples, though this does occur in some
cases as detailed shortly. For instance, the UK-based non-governmental organization Environmental
Investigation Agency (EIA) and colleagues (2013) say that illegal trade in wildlife is linked to
corruption. EIA (2013) in other publications has specifically linked political corruption to facilitating
the illegal trade. Warchol (2004) and IFAW (2013) in a similar vein, but using different terminology,
identify the connections between state corruption and wildlife trafficking. In regards to ivory in
particular, Naylor (2004) found the illegal trade is aided and abetted by corrupt officials. The
corruption of government officials and the further link to money laundering is essential to the
transnational smuggling and flow of illegal goods and services (Basu 2014). The exact connection and
mechanism though is not elaborated on. In yet other phrasing, Elliott (2007) cites institutional
corruption as being a key element of ivory trafficking in particular, but also to trafficking in
environmental black market commodities in general. Others, too, have found that institutional
corruption is integral to illegal wildlife trade (Holmes 2006; Lawson and Vines 2014; Lin 2005;
Milliken and Shaw 2012) and prevalent in developing countries (Klitgaard 1988; Rosen and Smith
2010; Lawson and Vines 2014).!!
Social and economic factors related to corruption
It has been pointed out that corruption itself is not the driver of wildlife trafficking, but poor
governance and corruption are commonly linked to this environmental crime as primary facilitators of
its increase and its existence (Albanese 2011; Nowell 2012; Wellsmith 2011). Understandably, in
research conducted by Dalberg in partnership with the World Wildlife Fund (WWF/Dalberg 2012)
into wildlife trafficking, officials interviewed did not want to answer questions regarding corruption.
The research found that ‘poaching tends to thrive in places where corruption is rife, government
enforcement is weak and there are few alternative economic opportunities’ (WWF/Dalberg 2012: 14).
TRAFFIC (2008) similarly has concluded that governance, corruption and the lack of rule of law are
U4 Issue 2015:11
fundamental factors in areas where wildlife is traded. In other words, ‘corruption flourishes where
there are few institutional checks on power, where decision-making is obscure, where civil society is
weak and where poverty is widespread’ (WWF/Dalberg 2012: 14). Klitgaard (1988) agrees that too
little transparency is connected to corruption and adds too much discretion as another contributor to
corrupt practices. This may well be linked to the finding that corruption plays a part in the failure to
combat illegal trade in wildlife products (TRAFFIC 2008). Furthermore, it is been found that
corruption can be more evident and serious when salaries of enforcement officials are low (Brack and
Hayman 2002).
In regards to the latter, raising salaries through higher base level pay to stop corruption (Van
Rijckeghem and Weder 2001; Pfaff et al 2014) and/or providing incentive pay for not being corrupt
(Olken and Pande 2012; Sundstrom 2014) are suggestions that have varying levels of support in the
literature. Whereas a higher salary may mean the corrupt actor would be less willing to engage and
possibly get caught and therefore lose their job, it may just lead them to more thoroughly hide their
activity. In terms of incentive pay, Sundstrom (2014) has found in South Africa that performance-
related pay schemes have been caught up in the existing corrupt networks. Non-corrupt officers were
isolated from those taking bribes and those line officers taking bribes were often colluding with higher
ranking officers, who even with the performance-related pay, encouraged corruption as they benefited
from it. Persson and colleagues (2013) have also found this to be true and suggest the need for
external monitoring systems for such programmes, which will be discussed later.
As mentioned, wildlife trafficking has recently become a focus of governmental and international
concern. In prominent speeches at United Nations General Assembly side events, international figures
have stated that wildlife trafficking is fuelling corruption and violence (Fedotov 2013; Hague 2013;
Kerry 2012). Press releases from the United States’ Office of the President have also said that the
illegal wildlife trade perpetuates corruption and more specifically that in order to traffic poached
wildlife, corrupt officials exploit borders and governments which are weak (White House 2014). The
British royal family through United for Wildlife (2014) have also stated through the Declaration from
the London Conference that poaching and trafficking encourages corruption. Many of these
discussions centre on specific regions or species as is documented below.
Regions and species where corruption and wildlife trafficking are linked
Similar to the general literature about wildlife trafficking, the literature linking corruption and wildlife
trafficking also can be categorised around regions and species. For instance, both Africa (Douglas-
Hamilton 2012; Hongfa et al 2007; Milliken and Shaw 2012) and Asia, the Southeast in particular,
(Balmford et al 2002; Lin 2005; TRAFFIC 2008) are singled out for having problems with corruption.
In the case of Southeast Asia, TRAFFIC (2008) has indicated that land administration centres in
particular are prone to corruption and corruption and poaching arise when people have no title to their
land. Lin (2005) connects the destabilisation of some Southeast Asian nations with the corruption of
customs agents. Occasionally, specific countries and sectors will be mentioned such as Russia’s
transportation officials (Wyatt 2011), Kenya’s enforcement officials (Naylor 2004) and South
Africa’s institutional corruption (Milliken and Shaw 2012). The latter is noted to be a means for Asian
crime groups to traffic rhino horn through sophisticated networks from South Africa to Vietnam
(Milliken and Shaw 2012). In terms of species, ivory trafficking is linked to corruption (Elliott 2007;
Naylor 2004) as is trafficking in rhino horn (Milliken and Shaw 2012), tiger parts (EIA 2011), fur and
falcons (Wyatt 2011).
Political, state or institutional corruption allows, in Africa for instance, armed non-state actors to
poach (Douglas-Hamilton 2012) and the conflicts of these non-state actors may be financed by the
poaching (Wyatt and Kushner 2014). In other contexts, criminal syndicates take advantage of the
significant amount of collusion and corruption between the private sector and government institutions
U4 Issue 2015:11
(EIA 2010). This may be possible because the collusion and corruption undermine law enforcement
(EIA 2010), which when weakened then enables criminal syndicates to poach and traffic wildlife.
Corruption then facilitates the range of transactions that need to happen throughout the trafficking
process (WWF/Dalberg 2012). This includes all the connections between the supply, transit and
demand countries (WWF/Dalberg 2012) and has significant negative consequences.
The consequences
Wildlife trafficking and other environmental crimes can result in both the loss of state revenues,
which negatively impacts on social services, and also impoverishment of rural communities reliant on
wildlife for their livelihoods (EUROPOL 2013). As stated at the London Conference, ‘The criminal
activity and corruption associated with trafficking restricts the potential for sustainable investment
and development which is needed in new economic activities and enterprises’ (United for Wildlife
2014). Research has also found that environmental crimes like wildlife trafficking undermine the
natural resource management efforts of developing nations, which again leads to economic loss for
governments (Rosen and Smith 2010). Corruption is also closely linked to money laundering and the
illegal flow of finances (Gerismova 2008; Økokrim 2008). This means the profits obtained from
wildlife trafficking are possibly funnelling into an illegal cash flow that could be supporting other
crimes. For instance, there is recent concern profits from ivory and rhino horn trafficking are being
used to fund terrorist groups (Wyatt and Kushner 2014). Of related concern is the threat of violence
coming from criminal gangs and militant groups, who are perpetrating these crimes (Rosen and Smith
2010; Wyatt and Kushner 2014).
Studies have shown that one of the main concerns of corruption linked to wildlife trafficking is that
corruption disrupts and challenges enforcement efforts to curb the illegal wildlife trade, so wildlife are
still threatened by poaching and possibly extinction (Rosen and Smith 2010). This may happen partly
through the redirecting of funding of surveillance and intelligence gathering initiatives by corrupt
actors (Leakey 2001). Survival of wildlife is also at risk from corruption when funds allocated for
conservation projects are improperly used (Lemieux and Clarke 2009). For example, corrupt practices
within projects to protect African elephants have been implicated in the threat to elephants as well as
the finding that greater levels of corruption are linked with greater elephant losses (Lemieux and
Clarke 2009). Smith and Walpole (2005) also cite the importance of addressing corruption in relation
to conservation initiatives. It should be noted though that unpicking the impacts of corruption is
complex and difficult (Ferraro 2005) since, as with other crimes, much is undetected.
The forms of corruption
That being said there is research that has uncovered some of the specific mechanisms and methods of
corruption that are employed in the trafficking of wildlife. There are a range of corrupt actors
identified such as the military, police, border guards, judiciary, customs officials, embassy staff, and
state diplomats (Douglas and Alie 2014). Klitgaard (1988) adds tax departments, procurers and food
distributors as well as any individual, public employee or otherwise, that illegally puts their own
interests above those that person is pledged to serve. Much of the literature that documents the
specific mechanisms of corruption cites bribery of these actors as the primary method (Guymon 2000)
and some would include gifts (money, but also of illegal wildlife products) as a form of bribery
(Holmes 2006; Klitgaard 1988; Passas 1998). The problem with bribery is that it undermines
governments, state structures and can threaten national stability (Guymon 2000). Bribery can buy a
variety of services or omissions of duties. For instance, in Latin America officials have been found to
authorise the illegal trapping of wildlife after receiving bribes (Guzman et al 2007). Also, criminal
organisations and exporters have enough money that they can bribe rangers, customs officers and
police officers in order to obtain false documents that make it appear the poached wildlife is legal, so
that it won’t be inspected at the borders (Lemieux and Clarke 2009). This falsification may be through
U4 Issue 2015:11
misclassification of the smuggled wildlife to a species that is legal to trade (UNODC 2010). Other
forms of falsification involve declaring lower values for the species under inspection or lesser
volumes (UNODC 2010). These techniques can reduce the chance of gaining the notice of inspectors
or falsely bring the wildlife into compliance with trade that is restricted by quotas. If successful, these
methods all result in the illicit being made licit (Wright 2011). Bribery can also take the form of
‘grand’ corruption, which involves large sums of money rather than ‘pettycorruption which entails
small sums of money to cut through bureaucracy (Doig and Theobald 2003). For instance, developing
countries have experienced contractors bribing Western companies in order for them to conduct
business (Klitgaard 1988).
Other mechanisms of corruption involve government officials abusing their position by trafficking
under diplomatic cover (Lemieux and Clarke 2009). For example, EIA (2013) has uncovered
videotaped evidence of a Vietnamese embassy employee in South Africa facilitating the trade of rhino
horn whilst in front of the Vietnamese embassy in Pretoria. Lemieux and Clarke (2009) cite
diplomatic officials trafficking ivory in the course of their travels. In the private sector, it is believed
that corruption of employees of trophy hunting companies (IBRD/World Bank 2005) allows for
trafficking of wildlife parts from the animals hunted. Also, the employees of transportation firms in
Russia are known to actively be involved in the smuggling of wildlife (Wyatt 2011).
In addition to bribes and diplomatic cover, corruption may also take the form of patronage. As Singh
et al (2006) report, patronage can occur within closely-knit social networks. Others refer to this as
clientelism (Passas 1998) or cronyism (Klitgaard 1988). It may happen, for instance, that the
employees of enforcement agencies are engaging in illegal and corrupt practices. They have a long
history of working with employees of the judiciary including the prosecutors, so the prosecutors and
the prosecuted know each other resulting in favouritism in deciding which cases go to court and how
those cases are handled (Singh et al 2006). Patronage also occurs between family networks where
offenders and enforcers may be related as will be seen in the case study. In another example, there is
strong evidence of collusion to poach between the network of ranch owners and veterinarians (Duffy
2014). Rhino horn is obviously very valuable (estimated at USD 100 per kilogram (Milan 2014)), but
the worth of live rhinos has decreased. This creates an ‘economic incentive for ranch owners to
‘allow’ their rhinos to be poached, take a portion of the profits from sale of the horn and then buy
another live rhino’ (Duffy 2014).
As mentioned, customs agencies around the world are actors that may be corrupted and facilitate the
illegal wildlife trade. The Organisation for Economic Cooperation and Development (OECD 2012)
proposes useful categories of how this works. There is routine corruption, which relates to how
service is received. As mentioned earlier this can pay for getting normal services or getting quicker
services. In instances where the goods being moved are a legal part of the economy, the person paying
the bribe would still pay taxes on the goods. Second, there is fraudulent corruption where forged and
falsified documentation facilitates trade and smuggling. This enables people with the fraudulent
documentation to pay less or no taxes. Finally, there is criminal activity where the customs agents
would simply permit illegal goods.
Money laundering and illicit financial flows
The question then is where is the money from the illegal wildlife trade going? In the cases where there
is a legal market (in Thailand for instance there is a national domestic legal market for ivory from
supposedly domesticated elephants), these provide a means to launder the proceeds from illegally
obtained wildlife into the legal economy. This is also true of wildlife-related industries, such as the
taxidermy, fashion and pet trades, which can launder or hide protected species in the licit market as
well as seemingly launder the money. The same appears to be true of open-air markets where wildlife
is sold as well as wildlife restaurants. These establishments can sell a mixture of legal and illegal
U4 Issue 2015:11
species thus laundering the illicit profits into the financial flow of legitimate businesses. Additionally,
as mentioned, a recent study attempts to document the use of the illegal proceeds of wildlife
trafficking as funding for terrorist and insurgents groups (Wyatt and Kushner 2014), but the
supporting evidence is thin and mainly from NGOs or media sources citing each other. Yet beyond
such circumstances, there is nothing in the literature investigating money laundering and illicit
financial flows stemming from wildlife trafficking. This is a key missing element in research to
combat the illegal trade.
There is substantial evidence linking corruption to wildlife trafficking. Whilst such socio-economic
factors as poverty, weak law enforcement and limited rule of law contribute to corruption being
prevalent in many developing countries that are sources of wildlife, Brack and Hayman (2002) point
out that corruption is not confined to developing countries. Demand countries (Lawson and Vines
2014) both developed and developing are subject to corruption in the same forms as documented
above. Unregulated markets where demand can be met with little oversight are easier to access
because of corruption (Lemieux and Clarke 2009). Such conditions mean that poachers, particularly
of ivory, can sell their products at a price that justifies the risk of poaching (Lemieux and Clarke
2009). In order to investigate further the findings in the literature, some primary data collection was
undertaken through interviews with experts regarding the connections between corruption and wildlife
3. Empirical findings
Drawing from the analysis of the literature, questions regarding the links between corruption and
wildlife trafficking were posed to international experts via email and to experts in Vietnam through
semi-structured interviews in Hanoi. Vietnam was chosen as the case study for this report as it is a
developing nation with high biodiversity that has been implicated as a source, transit and destination
country for illegal wildlife and wildlife products (Milliken and Shaw 2012), which means data for
each of these different aspects of trafficking can be gathered. It also has been found to have relatively
high levels of corruption (Transparency International 2012). The combination of the two makes
Vietnam an ideal location for a case study and for collecting data. The experts’ answers provide more
specific insights into the role corruption plays in wildlife trafficking as is detailed below. In particular,
the aim was to uncover more information about who the corrupt actors are, why they are corrupt, the
methods of corruption used and ways to combat corruption in wildlife trafficking.
3.1 INTERPOL and international wildlife experts2
The corrupt actors
The qualitative data confirms the findings of the literature in regards to the identity of the corrupt
actors who engage in trafficking wildlife. These individuals come from both the private and public
sector and are employed in a diverse array of jobs. In terms of the private sector, not only are
individuals involved, but also companies break laws to find, capture, smuggle and sell illegal wildlife
2 The responses from INTERPOL are a collection of answers taken from the numerous staff of the
Environmental Security Sub-Directorate and when referenced in this section are referred to as (INTERPOL).
The answers from PALF are from the organisations coordinator Naftali Honig, when referenced in this section
referred to as (PALF).
U4 Issue 2015:11
and illegal wildlife products (INTERPOL). It appears that most corruption in the private sector
enables the trafficking to take place. ‘For example, the counter clerk at an air freight office who
accepts some money while filling in forms he knows to be fraudulent’ (INTERPOL).
Law enforcement agencies are those implicated most in terms of public sector corruption. These are
individuals within police forces, the judiciary and the forest ministry (PALF) as well as customs and
legislators (INTERPOL). Depending upon the individual’s position and power, corruption manifests
in various ways. PALF Enforcement stated that corrupt actors use their position ‘to peddle influence
or justify the right to smuggle wildlife under conditions that are illicit under national legislation’.
Others, who are directly engaged with overseeing and/or implementing wildlife law, such as police
and so forth, are able to disrupt the rule of law (PALF). For instance, corrupt police officers and forest
or game rangers may not stop poachers from gaining access to endangered and/or protected species
(INTERPOL). Additionally, they may turn a blind eye to fraudulent permits. Similar to corrupt private
sector employees, corrupt customs officials may enable the smuggling of illegal wildlife and illegal
wildlife products (INTERPOL). Investigations may not be conducted or lenient sentences may be
granted if prosecutors and/or judges are corrupt (INTERPOL). Of particular concern is the corruption
of high-ranking government officials who may then draft weak laws and policies which allow
poachers to behave with impunity. Corrupt individuals at this level may also issue fraudulent permits
and licenses (INTERPOL).
For example, during the early 2000s, law enforcement efforts in Indonesia, undermined by corruption,
detected a relatively low number of cases, even less were pursued for investigation, and there was an
extremely low number of relative prosecutions and ultimately convictions (INTERPOL). In 2010,
Indonesia’s Anti-Corruption Commission undertook a ‘pre-investigation of 316 cases, prosecuted 139
of those cases and successfully executed 114 prosecutions. Their investigations uncovered high-
ranking officials that were involved in the corruption cases: 43 members of parliament, 10 ministers,
10 provincial governors, 20 mayors and heads of districts, 3 ambassadors and 1 judge’ (Gonclaves et
al 2012: 10). So corruption is seen in people with both lower and higher incomes from the range of
public and private services.
Why are the actors corrupt?
In support of the literature, interviewees also stated that in some instances officials are corrupt
because of small salaries that they try to supplement by taking or asking for bribes (PALF). This is
particularly the case in wildlife source countries in Africa, Asia and Latin America where traffickers
take advantage of this situation and offer bribes (INTERPOL). For example in some areas, ‘some
rangers assigned to the gates of national parks have been known to keep much of the money tourists
pay to enter the parks’ (INTERPOL).
As INTERPOL noted though, not all corruption is linked to poverty. There are those who are corrupt
simply because they are greedy and choose to make money illegally (PALF). This may come in the
form of more costly bribes in order for corrupt higher-level government officials to issue permits or
draft favourable policy to the traffickers (INTERPOL). In addition to greed, the qualitative data also
supported the role of clientelism or patronage as an aspect of corruption. For instance, ‘high-ranking
government officials could have personal interests or friends/relatives involved in illegal wildlife
trade activities. They may therefore be corrupt and engage in cronyism or nepotism in order to
unfairly allocate permits, licenses or concessions to their own companies or friends and families’
companies’ (INTERPOL).
There are other motivations and drivers besides money as to why people are corrupt. PALF (personal
communication August 2014) proposed that some people are corrupt due to pressures from their
families or other social groups to which they belong. Furthermore, government officials can be
U4 Issue 2015:11
coerced into corrupt acts out of fear. INTERPOL noted that officials have been known to receive
‘threats and warnings from armed gangs not to interfere in illegal activities’. This of course may lead
them to turn a blind eye to the activity. In other instances, ‘wildlife agencies in developing countries
have poor health care coverage for their employees, without insurance for widows and children when
officers are killed in the line of duty’. In order then for that ranger to ensure the welfare of his family,
he may be coerced into taking a bribe through the threat of violence.
Forms of corruption
Motivations for corruption correspond to the forms and techniques that corruption seems to take.
Again, respondents’ answers supported what was found in the literature. This means that bribery was
thought to be the most frequent expression of corruption though there was also traffic in influence and
abuse of power mentioned (personal communication with PALF Enforcement 2014; personal
communication with INTERPOL Environmental Security Sub-Directorate October 2014) as well as
extortion, embezzlement and state capture (personal communication with INTERPOL Environmental
Security Sub-Directorate October 2014). The forms elaborated on in this section are bribery and ill-
gotten or fraudulent paperwork as they seem to be the most prevalent.
Bribery can be prompted from both sides of the transaction. On the one hand, it may deflect pressure
from corrupt actors. For example, low paid front-line officers who are offered large sums of money to
allow illegal activity. On the other hand, the officer may request a bribe in order to allow the illegal
activity to take place. Such is the case sometimes with customs officials or officers at transport
checkpoints demanding bribes to allow the transport of illegal wildlife products (personal
communication with INTERPOL Environmental Security Sub-Directorate October 2014).
Furthermore, corrupt public officials are paid bribes to ignore fraudulent paperwork. This means
actively overlooking expired, reused or forged permits, export papers or certificates, tax documents,
and eco-certification or CITES permits (personal communication with INTERPOL Environmental
Security Sub-Directorate October 2014). Where permits and licenses are not issued, criminals rely on
corrupt front-line officers, forest and game rangers, to access the supply. There are known instances
of game rangers being paid bribes to lead poachers to wildlife. For example, the last rhinos poached in
Mozambique were pointed out to the poachers by a ranger who had been paid USD80 (personal
communication with INTERPOL Environmental Security Sub-Directorate October 2014).
If caught, poachers and traffickers can rely on bribes to the prosecution or judiciary for lighter
sentences or reduced punishments. Bribes can ‘also be made to lower-level officials, such as a clerk in
the evidence room, for intentionally mishandling evidence, and thus make it inadmissible in court’
(personal communication with INTERPOL Environmental Security Sub-Directorate October 2014).
Harder to prove is bribery that purchases omission of duties. For instance, when an inspection officer
does not count the actual number of birds in a shipment and therefore does not match that to the
number allowed on the permit (personal communication with INTERPOL Environmental Security
Sub-Directorate October 2014). Also difficult to prove are the cases in which patrol leaders are told to
take their teams to one part of a park when the park manager knows poaching gangs are operating in
the other areas. He has probably been bribed to arrange the patrols being elsewhere.
Fraudulent or ill-gotten paperwork
According to INTERPOL (personal communication October 2014) there have been multiple cases of
government employees stealing blank CITES documents. They take the documents from the
government permit office and then sell them to unscrupulous wildlife traders. The government
officials actually in charge of hunting permit allocation have been known to sell permits to the highest
U4 Issue 2015:11
bidder for personal profit. This also happens in order to gain influence or a favour. Additionally, in
instances of patronage, governmental officials will unfairly allocate permits to associates and/or their
family. Furthermore, ‘Permits can also be obtained through extortion, when criminals threaten those
in charge of allocation or threaten rangers who do not allow them access to the land or wildlife’
(personal communication with INTERPOL Environmental Security Sub-Directorate October 2014).
As mentioned, paperwork can be manipulated by misidentifying the species on permits or mis-
declaring the volumes and values.
As stated, permits may be stolen which would then corruptly grant access to protected and endangered
wildlife. In other cases, government employees rather than stealing permits simply steal wildlife
confiscated by law enforcement on behalf of wildlife traffickers. It is possible this is what occurred
when tons of ivory was stolen from government storage rooms in Africa (Uganda) that were dedicated
to securing confiscated ivory (personal communication with INTERPOL Environmental Security
Sub-Directorate October 2014).
These methods and forms of corruption will differ depending upon the species being trafficked.
‘For example, there is a difference in the corruption that occurs to allow for illegal trafficking
of protected wild animal species versus timber. Permits and licenses are given out for logging
and it is legal to harvest and export wood with the correct documentation. This is not the case
with protected wild animal parts and products because it is not legal to poach or trade them.
Illegal logging therefore requires corruption of the public officials in charge of permit and
license allocation and policy-making to obtain illegal concessions and paperwork needed to
log. This is less relevant for criminals that illegally poach protected animal species because
the paperwork to legally carry out the activity does not exist’ (personal communication with
INTERPOL Environmental Security Sub-Directorate October 2014).
Yet this also happens in trafficking of animals, where the trade is strictly regulated rather than
completely banned. CITES Appendix II species can be traded with an export permit often in
quantities established by quotas set by the CITES Scientific Authority of the country of origin. There
have been abuses of this system. For instance, corruptly obtained permits have been found in the
fashion industry for crocodile skins and in the pet industry for live tropical birds (personal
communication with INTERPOL Environmental Security Sub-Directorate October 2014).
Additionally, ‘there have been numerous cases of ‘legal’ animal dealers serving as laundering
mechanisms for protected wildlife, such as through falsified claims of ‘captive breeding’ animals that
were wild caught (personal communication with INTERPOL Environmental Security Sub-
Directorate October 2014).
Licensing and permits for hunting concessions may also be corrupt. In Africa, for instance, legally
sanctioned hunting concessions are frequently next to national parks. Corrupt selling of these
concessions may enable access to hunting in the national park. Corrupt licenses may also facilitate the
‘legal’ hunting of specific animals (personal communication with INTERPOL Environmental
Security Sub-Directorate October 2014). With the actors, their motivations and the forms of
corruption detailed, the experts were asked what can be done to help stop corruption and/or wildlife
Experts cite a number of steps that could help limit corruption in wildlife trafficking. Exposing
corruption and campaigning against it have some impact, but prosecuting corrupt officials for
violating national laws and international conventions is an extremely important step (personal
communication PALF Enforcement August 2014). A multi-faceted holistic approach that targets
U4 Issue 2015:11
several issues is required to maximise effectiveness and tackle corruption and wildlife trafficking
(personal communication with INTERPOL Environmental Security Sub-Directorate October
2014).This could include strengthening law enforcement, improving good governance, accountability
and transparency, and raising public awareness on corruption.
Strengthen law enforcement
INTERPOL concurs with the literature that law enforcement training and capacity building is very
important to stem corruption. This should include training of law enforcement officials about the best
practices being used to fight corruption in wildlife trafficking. It also means implementing procedures
within law enforcement agencies that minimise the opportunities for corruption to occur. For instance,
INTERPOL suggests such techniques as regularly transferring rangers from one work location to
another. This possibly prevents rangers from establishing closer relationships with local people as
well as separating them from potential patronage networks of family and friends. Agencies can also
institute unannounced times for shift changes for customs officers. This makes the location of officers
unknown and potentially unpredictable, so traffickers would have more trouble enticing particular
people or having the opportunity for extended contact with any one officer. Additionally, INTERPOL
recommends establishing internal affairs units. They investigate the integrity of officers and possibly
also their corruptibility through undercover operations to tempt officers with bribes.
Part of strengthening law enforcement, and also other civil services, is making available mechanisms
for whistle-blowing about those corrupt acts that people have witnessed in a way that can be used
safely and anonymously. There are some online secure platforms [such as] that can
facilitate wildlife crime whistleblowing, especially with links to acts of corruption (personal
communication with INTERPOL Environmental Security Sub-Directorate October 2014).
Further improvement for law enforcement would be to increase their knowledge and technical
capabilities to conduct financial investigations. Exploring the monetary dimensions of wildlife
trafficking ‘is also an important tool for law enforcement to capture the full scope of criminal activity
and stem private sector corruption’ (personal communication with INTERPOL Environmental
Security Sub-Directorate October 2014). Tracking the financial flows can lead to uncovering hidden
pockets of money and the actors involved. This can have larger societal benefits as these offenders are
probably laundering money for a variety of crimes not just wildlife trafficking. This information could
enable prosecutors to seize and recover illicit assets, which has the potential to act as a deterrent for
further similar criminal activity. Financial expertise does not necessarily have to be housed within
wildlife or environmental law enforcement units or even within the agency. Using a multi-agency
approach to tackle the crime would facilitate the inclusion of, for instance, financial law enforcement
and anti-corruption units in a multi-agency taskforce (personal communication with INTERPOL
Environmental Security Sub-Directorate 2014).
Improving good governance, accountability and transparency
As cited in the literature, some corruption of law enforcement and civil servants can stem from low
salaries. As part of a good governance strategy then, states should consider paying forest and wildlife
rangers as well as front-line officers of customs and border patrol agencies adequate salaries so they
are less enticed by small bribes (personal communication with INTERPOL Environmental Security
Sub-Directorate October 2014). In regards to salaries, more attention can be given to officers ‘who are
seen as living above their means either through their home, car or material goods’ (personal
communication with INTERPOL Environmental Security Sub-Directorate October 2014). This could
indicate that they are corrupt and accepting bribes. Creating mechanisms of accountability in agencies
for people’s income such as lifestyle audits may be used to detect this (personal communication with
INTERPOL Environmental Security Sub-Directorate October 2014).
U4 Issue 2015:11
Further good governance practice could come through improved and increased oversight and
monitoring of those combatting wildlife trafficking. For example, as mentioned, some officers such as
forestry rangers have low salaries particularly when compared to the value of the natural resources
that they are supposed to be protecting. Yet despite the incongruity of their salary and the timber and
wildlife, forestry rangers typically have significant discretionary powers with little oversight. This
creates circumstances where corruption prevails (personal communication with INTERPOL
Environmental Security Sub-Directorate October 2014). This is also the case for wildlife rangers. For
example, a typical elephant tusk is ten kilogrammes of ivory. This has a street value in most parts of
Africa of USD 600 per kilogramme, which is USD 12,000 for the two tusks. ‘This is commonly more
than a year’s salary for most African rangers’ (personal communication with INTERPOL
Environmental Security Sub-Directorate October 2014).
Additional improvements could be made to oversight and monitoring if independent anti-corruption
investigation teams could be created, so they could unbiasedly investigate cases of corruption in the
government. These units need to have specific mandates or campaigns to address corruption in the
wildlife and natural resources sectors (personal communication with INTERPOL Environmental
Security Sub-Directorate October 2014). In regards to donor agencies, they too should have robust
oversight and monitoring. In particular, for wildlife conservation programmes the support and finance
provided by the donor should be subjected to sufficient independent monitoring of corruption risks.
Ideally, the support offered should have limited amounts of cash, which will help reduce the risks of
corruption in the form of state capture by government officials. INTERPOL (personal communication
October 2014) recommends instead that donors ‘provide resources in terms of contracted officials,
equipment and capacity building for example to train low-level officials about best anti-corruption
practices’. In those instances, where cash is the best choice of the type of aid to give, then the donor
needs to set an ‘agreed upon standard of transparency with measurable indicators and a system of
monitoring and reporting for verification’.
Raising public awareness
If citizens are made aware of both corrupt acts and wildlife trafficking and then the connection
between the two, they may be less likely to turn a blind eye if they are a witness to corrupt activities.
It may also lead people to try to hold their governments more accountable for wildlife crimes and
corruption in the government (personal communication with INTERPOL Environmental Security
Sub-Directorate October 2014).
Conclusion the connections
In spite of being widely regarded as corrupt, some of the practices discussed above remain pervasive
and in some instances not punishable by criminal or civil law. Corruption enables the illicit export of
natural resources. This is at ‘the expense of biodiversity and the potential prosperity of peoples who
live in biodiversity hotspots’ (personal communication with PALF Enforcement August 2014).
Furthermore, ‘Without a sense of order, a vicious cycle ensues where natural resource exploitation is
unregulated and sustainability loses traction. Impunity reigns and further empowers other corrupt
actors who take advantage’ (personal communication with PALF Enforcement August 2014). As
PALF mentions, it is important to note that traffickers choose the path of least resistance, and
corruption is in the interest of criminals to maintain their profits.
Corruption links to many crimes and is a major cause of failures of criminal justice. There needs to be
significant punishment of wildlife crime in general and trafficking specifically as well as confiscation
and seizure of all criminal proceeds to demonstrate these are serious crimes that will not be tolerated
(personal communication with INTERPOL Environmental Security Sub-Directorate October 2014).
For example, across Brazil, Mexico, India and the Philippines the probability of illegal logging being
U4 Issue 2015:11
penalised is less than .082 per cent (Gonclaves et al 2012). As it stands, ‘corruption propels the
criminal organizations’ sense of impunity with which they operate’ (personal communication with
INTERPOL Environmental Security Sub-Directorate October 2014). Now that the recommendations
and data from these international experts have been detailed, the additional data collected from
Vietnam are presented.
3.2 Case study of Vietnam
In order to further uncover the specific mechanisms of who is corrupt as well as why and how they
employ corruption to traffic wildlife, semi-structured interviews were conducted in Vietnam with
seven people who are experts in various NGOs and government organisations in Hanoi.3 Their
answers have been anonymised for their protection and they have been assigned a code of the
numbers one through seven. Some brief context is given about Vietnam, the nature and extent of
wildlife trafficking there and the overall and specific role of corruption before the interview data are
Brief overview of Vietnam
Vietnam is located in Southeast Asia - a dynamic economic region. With more than 92.4 million
people, Vietnam is currently the world’s 14th-most-populous country (US Census Bureau 2013). Over
the last two decades, Vietnam has been undertaking economic reform and as a result the Vietnamese
economy has gained remarkable results. It has consistently high growth with an overall annual rise of
7 per cent since 1987, rendering it the third fastest growing developing economy in the world (World
Bank 2012). Civil society has been growing as well. Not only is Vietnam the home to offices of many
internationally known NGOs like WWF and the World Conservation Society, it also has grassroots
initiatives like Education for Nature Vietnam (ENV).
Being home to approximately ten per cent of the world's species, Vietnam has been recognised as
tenth in the world with respect to significance of endangered species with 11,458 animal, 21,017
plant, 3,000 micro-organism, 1,030 moss and 826 fungi species (Ha et al 2007; World Bank 2005).
Wildlife degradation, particularly of endemic and endangered species, is currently a critical issue in
Vietnam. Research by Milliken and Shaw (2012) is concerned that ‘most wildlife populations in Viet
Nam are now greatly reduced and facing a wide range of ongoing threats from destruction of habitats,
rampant wildlife trade and consumption, pollution and other factors. It is estimated that 28 per cent of
mammals, ten percent of birds and 21 per cent of reptiles and land amphibians are threatened or
recently extinct in Vietnam (Nguyen 2008). Additionally, by some indices Vietnam has high levels of
corruption (Transparency International 2012). As mentioned, the combined presence of corruption
and wildlife trafficking make it an ideal case study to investigate the nexus of the problems in a
developing nation.
Wildlife trafficking in Vietnam
The development of legal international wildlife trade and the establishment of large markets in Asia,
Europe and America in the late 1980s facilitated the flourishing of international wildlife trade in
3 Respondents were all asked: Who are the corrupt actors that make trafficking of wildlife possible? Why are
they corrupt? What are the ways in which they make wildlife trafficking possible? (fraudulent paperwork, bribes
etc) What can be done to stop corruption? Does the corrupt actor and his activities differ depending upon the
species trafficked? Overall, what is the nature and extent of corruption and how does it impact wildlife
trafficking? Other questions were asked as well due to the semi-structured nature of the interviews.
U4 Issue 2015:11
Vietnam, in which legal wildlife trade comprised the most significant part (Dang and Dang 2010). In
conjunction with the traditional use of wildlife and the legal trade, the illegal wildlife trade has
arguably been increasing, and it is suspected to be one of the most severe contributors to driving down
the number of rare and endangered species in Vietnam. The table below published by the Forest
Protection Department of Vietnam shows the number of violations of wildlife legislation in the last
five years, from 20092013 in Vietnam. The main types of violations are illegal poaching, captive
breeding, transporting, slaughtering and trading wild animals which are prohibited under the Forest
Management and Protection Act in 2004, Decree 32/2006/ND-CP on the Management of Terrestrial
Endangered, Precious and Rare Species of Wild Plants and Animals in 2006 and Decree 82/2006/ND-
CP on Management of Export, Import, Re-export, Introduction from the Sea, Transit, Breeding,
Rearing and Artificial Propagation of Endangered Species of Precious and Rare Wild Fauna and
Flora, in 2006.
Table 1 Types of wildlife violations 2009 - 2013
Figure 1 Number of violations and wild animals confiscated 2009 2013
20 000
15 000
10 000
5 000
2009 2010 2011 2012 2013
Wild animals confiscated Wild management violations
U4 Issue 2015:11
From the statistics, it can be seen that over the last five years, from 2009-2013, the operational
agencies detected a total of 4,630 violations of wildlife management, meaning that on average over
900 violations are detected every year. During the same period, the total number of wild animals
confiscated was 76,405 individuals, including 3,808 (5 per cent) rare and precious wild animals.
However, these are merely official figures. The Environment Justice Foundation (2011) suspects that
the investigated cases as well as the estimated profits represent only about five to ten per cent of the
total trade in reality. Nguyen (2008) even believes that only around three per cent of illegal wildlife
trade in Vietnam is recorded or discovered.
Wildlife trafficking has been taking place in Vietnam for a long time. Historically, Vietnam has
served as a source and consumer country, supplying illegal wildlife to international markets, but it has
also acted as a transit country (6). However in the last ten years, because of the increasing shortage of
wildlife available domestically, Vietnam is gradually losing its reputation as a centre of supplying
illicit wildlife, but becoming more known as a transit country where the volumes of smuggled wildlife
from overseas to Vietnam seem to be increasing (6). Previously, Vietnam transited wildlife mainly
from Southeast Asian countries. Pangolins, tigers, some species of reptiles and primates are, for
example, smuggled into Vietnam from Laos, Cambodia, Myanmar and Indonesia via busy border
crossings such as Lao Bao (Quang Tri province), Cha Lo (Quang Binh province) and Cau Treo (Ha
Tinh province) (1,3; ENV 2010).
Since about 2004, the transit of wildlife from other regions through Vietnam has gained particular
importance (6). Most noted are ivory and rhino horn that are trafficked from African countries,
especially South Africa, mainly via air (Noi Bai Airport and Tan Son Nhat Airport) and sea (Hai
Phong Port) (1, 3, 5, 6). Milliken and Shaw (2012: 145), for example, argue that Vietnam is ‘the
world’s leading destination and consumer of rhino horn. Moreover, this highly unfortunate status is
unlikely to change any time soon in spite of longstanding legal prohibitions outlawing its usage in the
country. There is domestic demand for wildlife in Vietnam, but it seems to be quite small compared to
the largest international market - China - where the demand for wildlife is more significant (6).
Overall, although some may observe that the scale of wildlife trafficking in Vietnam seems to be
declining, a survey by Roberton (2013) concludes that illegal wildlife trade in Vietnam ‘is vast and is
driving species to extinction’.
Corruption in Vietnam
Prior to examining corruption in the illegal wildlife trade in Vietnam, it is worth briefly looking at the
problem of corruption facing the country recently. It can be argued that corruption in general in
Vietnam is rampant. Though there are methodological challenges to the following perception indices,
they give a general overview that people are widely familiar with. For instance, in the 2011
Transparency International Corruption Perceptions Index, Vietnam performed below average with a
score of 2.9 on a 0 (highly corrupt) to 10 (highly clean) scale. The country ranked 112 out of 182
assessed countries worldwide and 21 out of 35 countries in the Asia Pacific region.
The World Bank’s (2010) Worldwide Governance Indicators confirm Vietnam’s poor performance on
the control of corruption, showing little or no improvement over the years. For instance, between
2004 and 2010 there was no significant change in any of the six areas of governance assessed.
Corruption in Vietnam ranges from bribery, theft of state assets, kickbacks, collusion in contracting,
to payments for services provided. It is worse in some fields including land and housing
administration, police, health, construction, customs and tax (Norad 2011). Despite some
improvement in reducing the level of administrative corruption ‘there is general agreement that fewer
corruption cases only means that corruption is becoming more complex, not that corruption is
U4 Issue 2015:11
declining’ (World Bank 2013). Consequently, almost two-thirds of the participants in the research by
Dao Le (2011) stated that corruption is ‘the most significant socio-economical problem facing
Vietnam’. Meanwhile a study by the World Bank (2013) revealed at least a third of the population
ranked corruption as among the most serious problems facing Vietnam. The Communist Party of
Vietnam (2012) acknowledges that corruption is one of the greatest threats to the party’s legitimacy
and the regime’s survival.
It is an encouraging sign that institutional changes have been made and a comprehensive set of laws
and policies have been developed over the past ten years (Nguyen 2013; Norad 2011). There are a
number of cases involving high-ranking officers, such as members of the Party Central Committee,
ministers, deputy ministers, secretaries of the provincial party committee, chairmen of the provincial
people’s committee and department directors, where corruption has been detected and sanctioned with
either disciplinary punishments or criminal prosecutions or both (Phan and Pham 2010). However,
irrespective of such efforts, both international organisations and Vietnamese institutions believe that
the improvement has been limited particularly due to a large gap between the political will of the
government to make the necessary changes and the practical implementation required to make such
changes (Nguyen 2013; Norad 2011; Phan and Pham 2010). In short, corruption in Vietnam, is clearly
a worrying problem, impacting all aspects of society. The problem could drastically erode public
confidence in the state, which is a vital aspect of political and human security.
Corruption in wildlife trafficking in Vietnam
Although both corruption and wildlife trafficking in Vietnam appear to take place in rampant
fashions, incidents of the involvement of corruption in wildlife trafficking are rarely mentioned in the
media and the official statistics; furthermore, in academia and the third sector this topic is under-
researched. Whilst many cases of wildlife trafficking as well as corruption are prosecuted in Vietnam,
review of the literature has not uncovered any single case of corruption linked to wildlife trafficking
where criminal proceedings have been initiated, let alone prosecutions or convictions. Likewise there
are not many stories or comments in newspapers addressing the connection. In order then to better
understand the links between corruption and wildlife trafficking, in general, but in Vietnam in
particular, seven semi-structured interviews were conducted asking about the connections. The
findings are presented below and supported where possible by media and secondary sources.
The corrupt actors
The qualitative data collected from Vietnamese participants supports the data from the literature and
international experts as to who the corrupt actors are who are trafficking in wildlife. An interviewee
gave the following summary:
Groups involved in the corruption in wildlife trafficking may be firstly the groups of law
enforcement at local levels. I think the risk of corruption may occur in any step and location
of wildlife trafficking and staff in any institution can get involved. From the guards of nature
reserves to the border army; from customs officers at border gates to authorities issuing
permits including permits for wildlife ranching and permits for wildlife importation and
exportation - all are at risk of corruption (1).
Corruption is a risk to all institutions that are vested in tackling wildlife trafficking in Vietnam. They
are specified below:
U4 Issue 2015:11
Table 2 Vietnamese wildlife management institutions
Depending on the scale of wildlife trafficking, different institutions are targeted for corruption. Small-
scale wildlife traffickers mostly need to have a relationship with local Kiem Lam (Forest Department)
officers, and sometimes with the local environmental police. In this scenario, the amount of the bribes
is small. In contrast, large-scale wildlife traffickers need connections with not only local Kiem Lam
forces, but also other authorities at higher levels such as district and provincial levels or even with
overseas authorities. For these connections, it takes longer to establish relationships with the senior
leaders and of course the value of bribes or gifts has to be much greater to be commensurate with the
official’s position (3). It is likely that for networks of wildlife trafficking that create illicit supply
U4 Issue 2015:11
chains with different steps for collecting, transporting, processing and trading, that if corruption
happens, it may happen in the entire chain, not only in any single step (5). However, it seems clear
that the likelihood and scale of corruption varies depending on the species trafficked. Presumably, the
more valuable the species or the size of the shipment, the more likely it is that corruption will play a
role as the reward will entice further risks, such as bribes and so forth. Also, possibly the extent of
corruption will be greater, such as fraudulent or forged permits as a means to procure the illegal
wildlife. Furthermore, differing species also may mean the involvement of higher levels of corrupt
authorities and higher values of bribes and gifts in order for the offenders to be successful.
An interviewee wondered if lax or corrupt law enforcement were the reasons that Vietnam
experiences high levels of wildlife trafficking whereas neighbouring countries like Myanmar and
Laos, which are equally close to China, have relatively low levels (3). Another interviewee speculated
In the border areas, there is no one carrying something that the border armies do not know
about. People coming to the border areas, which are three kilometres from the actual border
line, the forces already know exactly who they are, times and routes they go. So why can they
[wildlife traffickers] still escape? (1).
A survey by Roberton (2013) concerning wildlife smuggling along the border river Ka Long between
Vietnam and China, reveals that when carrying unlawful wildlife across the border, wildlife
smugglers usually invest tens of thousands of dollars to bribe the border officials there. In contrast,
another respondent thought that there are not enough border officers to stay along all parts of the
border throughout the days and nights, so Vietnam could be a transit country because of lax
enforcement. For instance, traffickers often use small, well-worn paths to carry wildlife across
isolated areas on the border. Thus although there is cross-border wildlife smuggling and there is
evidence to link it to corruption, it is difficult to confirm whether the border officers (army and guard)
are corrupt or not (5) and if so the extent of the corruption.
This highlights the negative side of many institutions engaging in the control of wildlife trafficking.
However, it is important to remember that not all wildlife officers are corrupt. There are many stories
of wildlife officers who bravely say no to bribes and make every effort to carry out proper
enforcement. The most recent incident is the case of traffic police officers in Thanh Hoa province who
rejected a bribe of VND 5 million (USD 232) when they discovered an illicit transport of pangolins
worth VND 2 billion (USD 93,000) (Thu Hoa 2014). These efforts should be raised and examined in
further research projects, to identify how the officers can maintain their integrity under conditions that
encourage corruption.
Why are the actors corrupt?
It is a strong consensus among the respondents that, in Vietnam, the salary for Kiem Lam officials is
notoriously low and that this is the reason for corruption. Indeed, in the early 2000s the average
official monthly salary of a Kiem Lam officer was about GBP 18 (Nguyen 2003); more recently it is
around GBP 60 (Do 2010). Senior officers who have university degrees with at least 10 years of work
experience may get GBP 100 a month plus a monthly allowance of GBP 7 (Nong Nghiep Vietnam
2012). An interviewee insists that ‘One of the causes of corruption among the officers is because the
level of salary does not meet the basic needs for living of officers who are entrusted with wildlife
management and protection’ (7). However, other interviewees assert that the level of salary is the
norm in public sectors in Vietnam, and that wildlife officers cannot complain.
U4 Issue 2015:11
If Kiem Lam forces justify that their corruption is because of low salary, then the entire
country will be involved in corruption. The salary of the President is at this level, and then the
salary of Kiem Lam is at that level; that is fair. They cannot demand higher salaries (5).
Whilst salaries may indeed be the cause, or at least correlated to corruption, there is evidence of other
factors playing a role in why people are corrupt. An interviewee observed that ‘sometimes a single
individual doesn’t want to be corrupt, but the whole collective is already corrupt; then he cannot stand
outside’ (1). This means ‘corruption is unavoidable for officers. If not corrupt, they may be moved to
other working locations’ (6). This implies some level of coercion or force for some who become
It is important to note that family relationships and larger social networks also are a factor in the
corruption taking place in wildlife trafficking in Vietnam. Phan and Pham (2010) recognise that the
rule of ‘human morality’ that is highly regarded by the Vietnamese has been abused for corruption. In
the domain of wildlife trafficking, if a family has an officer (especially a leader of a wildlife
authority), illegal wildlife traders may purposely establish connections with his family members (4).
Because of this relationship, the officer or leader may give certain support to the trader that helps him
to traffic wildlife. This means that in Vietnam not only officers, but also their relatives may be
subjects of corruption. This applies also to friendships and workplace relationships, which may be
also taken advantage of.
We are close friends or close colleagues, when my brother or I get in trouble, for example, we
need to obtain permits for wildlife farming and that is the domain you are in charge of. If I
call you, it is hard for you to completely ignore the plea, right? (4).
This indicates that patronage as a form of corruption is also present in Vietnam. Further corruption
that is linked to more social or cultural aspects of society is Vietnam’s ‘culture of envelope’ where
public servants are given small amounts of money in envelops to complete their duties. This can be
seen to be a form of ‘speed money’ (Passas 1998). As a respondent stated, ‘If you are an official, you
expect it and if you are an ordinary person, you expect to give it. So you have some kind of symbiotic
relationship. It is actually increasing and it is actually considered normal’ (2).
Additionally, unlike the consequences of some other crimes such as murder, robbery, theft, arson and
vandalism that are highly visible and directly affect the victims, very often wildlife as the direct
victim of wildlife trafficking is not visible to the public. Nor are they thought of as the property of
Kiem Lam or the public (3). This very nature of wildlife trafficking like other environmental crimes
strengthens the collusion of Kiem Lam and wildlife traffickers as they are virtually invisible.
What methods of corruption are used?
Again, as seen in the data from international experts and the literature, there are a variety of forms of
corruption used to facilitate the illegal wildlife trade. Those employed in Vietnam are similar yet
different to trends seen internationally, and can offer insight regarding solutions.
Overall there are many ways wildlife traffickers use bribery to corrupt officers. The most common
ways include giving cash, envelopes containing cash, gifts, material or spiritual benefits and wildlife
products themselves. For example because many senior staff in Vietnam enjoy products made from
rare and precious wildlife such as ivory, tiger glue, and rhino horn, illicit traders use these items as
gifts for bribing the staff (3, 4). An interviewee observed that giving gifts is now more blatant (4). For
example, a trader wants to cook a tiger to make tiger glue. This is one of the most valuable and
U4 Issue 2015:11
common traditional medicines in Vietnam, which costs around USD 380 for 100g and is used to cope
with a number of health problems such as paralysis and rheumatism (Nguyen and Nguyen 2008). He
brings the live tiger to his home, inviting the leaders or their subordinates to see the tiger and confirm
its authenticity. After the leaders agree, the cooking is carried out. The glue then will be collected
directly by the subordinate who will bring it to the leaders (4). The gift in this instance is the glue
Bribes facilitating wildlife trafficking in Vietnam may be made in fixed regular payments. This may
take place monthly, every several months or annually. It may also happen on particular occasions such
as Tet holiday (New Year Festival), weddings or funerals of the relatives of the corrupt officer (3, 4,
7). Bribes can go directly to individuals, but also through groups to buy favour. This can be seen in
the fundraising events for collectives such as the trade unions, women groups, and youth groups that
are in the wildlife agencies (4). Wildlife traffickers establish relationships with the corrupt officers in
these agencies. They then attend the public fundraising events for the collective. Whilst public venues
for fundraisers help to avoid speculation about the money given, often it is merely a pretext and some
or most of the funding goes into the personal pockets of those corrupt officers (4). Alternatively,
wildlife traffickers are sometimes asked to accompany officers in welcoming guests and visitors of
the officer. The trafficker then pays the bills for the expensive dinners and other entertainment. The
dinners also provide the opportunity for the traffickers to establish relationships with the guests who
are sometimes other wildlife officers.
Bribery can buy a variety of services or omissions. First, corrupt officers can help the traffickers by
turning a blind eye to the illicit activities. For example, a household is allowed to raise several tigers
for decorative purposes. However, the tigers are actually being illegally sold commercially and
replaced by other tigers. It then appears that there are continually tigers in the house for which they
have permission. In reality though, the people are farming tigers. The wildlife officers know this, but
turn a blind eye. If, for any reason, the illicit farming is detected, these officers have a convincing
excuse not to know since it can be argued that it is difficult to identify individual tigers (4).
A second way of helping is that corrupt officers leak information to the traffickers. They can tell the
traffickers in advance, for instance, about the enforcement agencies’ secret planned inspections or
raids (4, 7). Wildlife restaurant owners, for example, will be informed in advance about the plans to
inspect their restaurants, so that the owners have time to conceal illegal wildlife and related illicit
activities (4, 7). When the inspection teams arrive at the restaurants, no illicit wildlife is found. At the
end of the inspection, in front of the public, the inspection minutes will clearly conclude that ‘at the
time of inspection, no illegal wildlife is found’. During other inspections, if any illicit wildlife is
found, the officers defend themselves by saying that they cannot stay in the restaurants twenty-four
hours a day, seven days a week. It is difficult to hold them accountable in such incidents (4). In a
similar way, before smuggling traffickers telephone the corrupt officers asking them about the
possibility of transporting the wildlife. Usually, the conversations use hidden signals to avoid
detection. For example, the traffickers may ask ‘How are you? How is the weather in your town
today?’ If the corrupt authorities feel that the illicit transport would be successful, they may respond
‘Oh, I’m great. The weather is very nice. If you are free, come visit my family. We can have a drink
together’. If the enforcement agencies are particularly active or have operations planned though, the
officer may warn the trafficker saying that ‘I’m a bit tired. The weather today is not very nice’ (4).
Bribes can also purchase permits in Vietnam. This is particularly relevant to the ranching and farming
of wildlife that occurs there. Federal Article 10 in Decree 82 clearly states that animal breeding and
rearing farms must meet all six conditions set out in the legislation. Two of the conditions are that
‘cages and farms must be constructed in suitability to the characteristics of the reared species and the
production capacity of the farms’ and ‘ensure safety for humans and environmental sanitation under
the State’s regulations’. Some interviewees observed that the amount of wildlife being ranched in
U4 Issue 2015:11
Vietnam was not large and is born on the ranches. The process of granting the permits for these
operations is undertaken relatively strictly by panels of authorities and experts, which means it is
difficult for corruption to take place (5, 6). In contrast, some other interviewees in the research suspect
that some farms do not entirely meet the standards. They believe there are violations in regards to the
size of enclosures and barns and the condition of the semi-natural environments, but are still given
permits to ranch (3, 4, 7). A survey by ENV (2010: 1) shows that ‘many tiger farmers utilize their
influence and connections to avoid difficulties with the law, while selling the idea to the media and
public that they are saving tigers’.
Another way of helping wildlife traffickers is that the corrupt officers take advantage of their power
over frontline officers to interfere with normal operations. If a wildlife van or a timber truck is
stopped, the trafficker can telephone influential leaders in Kiem Lam forces, or even in the public
security agencies and the people’ committees, asking them for help. Because of their power, the
person called can then telephone the leader of the frontline officers or directly call the officers to
interfere with regular inspections. Often this results in the van being left alone. This explains the fact
that sometimes frontline Kiem Lam officers find it difficult to conduct normal operations. An
interviewee cited a statement of Kiem Lam officers: ‘We are not able to carry out our duties because
the circle of traders is more powerful than us. The power is in the use of a mobile to call a province
leader, and immediately the stopped truck will be released’ (1). Another interviewee shared a scenario
that if the corrupt officer is a leader, at for example the district level, on the day of the illicit transport,
the leader may order an unexpected meeting with all frontline officers in the whole district. This
means the trafficker will contend with a reduced number of or no frontline officers as they are sitting
in a meeting room. The higher the level of leadership of the corrupt officer, the stronger and more
effective support the traffickers can receive (4).
It is suspected that whole teams of Kiem Lam officers are involved in highly coordinated and
therefore costly smuggling of wildlife. There is no evidence, but it is believed that corrupt officers
will carry the illegal wildlife in their official vehicles through their jurisdiction and then transfer the
shipment to other corrupt officers at the next boundary or that they will drive alongside the transport
of the traffickers who are smuggling wildlife. Either way then if stopped by other enforcement
agencies, they can claim they are escorting the trafficker to the station for inspection or other
procedures. Again, the bribery involved must be significant if in fact this is taking place (4).
Fraudulent and ill-gotten paperwork
Paperwork, either fraudulent or illegally obtained, also features in corrupt practices in Vietnam. There
are numerous situations where document falsification can occur. For example, forged documents that
are then signed by the local authority or Kiem Lam can launder an illegally bought tiger into a legal
tiger (1). Alternatively, wildlife farmers will buy a small number of animals from a legal source that
supplies farms; they then re-use the legal documents from the legitimate purchase multiple times to
buy illegal wildlife. Despite knowing this technique, corrupt officers overlook or even help the farmer
adjust the documents and verify the legality of the information (4). Additionally, corrupt officers
during inspections of farms, holding areas and transports of endangered species traders have been
known to adjust the numbers and volumes of the animals so that the trader avoids criminal penalties
and will only bear some lenient administrative fines (7).
U4 Issue 2015:11
It is frequently observed that whatever the methods of corruption are, a common feature is that the
officers and traders always pay attention to preparing their defence against allegations of corruption.
To do so, it is important for the officers to show that they are maintaining ‘proper’ operations, and any
illegality is due to ‘external elements’. In the technique of ‘recycling’ legal documents to buy illegal
wildlife or substituting legal wildlife with illegal, for example, an excuse would be that it is
tremendously difficult to identify individual legal and illegal wildlife (4). Likewise if officers detect a
case of smuggling of endangered animals, after reaching an agreement between the officer and
transporters, the final solution would be that the animals will be destroyed since the species cannot be
identified. During the destruction, the endangered animals are secretly exchanged with common
animals such as cats. The result of this collaboration is that the transporters can still keep their
endangered wildlife shipments, while the officers are seen to be properly doing their duties, so cannot
be blamed (4).
An interviewee summarises that:
I think in essence the corruption that takes place is an outcome of the interaction of many
interrelated factors. The interaction involves policies, related actors, markets, culture, and the
availability of natural resources (1).
<8'+ &'38/%]*'+ .2+ %/2.(I)&%./+ 1%E&.(&%./+ %E+ \'0%','1+ &.+ &)4'+ 90)3'+ 1*(%/5+ -%010%2'+ %I9.(&)&%./+ )/1+
'D9.(&)&%./"+ Y/+ 'D)I90'+ %E+ &8'+ 3)E'+ &8)&+ %E+ ^./'+ .2+ &8'+ 0)(5'E&+ )/1+ I.E&+ E.98%E&%3)&'1+ 3)E'E+ .2+
%/,'E&%5)&'1+ %/+ 1'9&8+ \G+ &8'+ <%'/+ B8./5+ ?'-E9)9'(S+ )+ 9('E&%5%.*E+ /'-E9)9'(+ %/+ H%'&/)I"+ >&+ &..4+ 90)3'+
M)0)GE%)+ &.+ $).E+ 2.(+ ('L'D9.(&+ %/&.+ H%'&/)IS+ &8'+ 2)0E%2%'1+ 2%0'+ )00.-'1+ &8'+ %I9.(&+ .2+ =STTT+ I./4'GE+
%/30*1%/5+ 6STTT+ I)3)]*'E+ 2(.I+ $).E+ 1%('3&0G+ &.+ H%'&/)I"+ M')/-8%0'S+ &8'+ Q*/1'(+ ('9.(&'1R+ E&)&%E&%3E+
)/1+ V0.()+ QF><@JR+ %/1%3)&'+ &8)&+\'&-''/+!TTT+ )/1+ !TT=S+&8'+/*I\'(+ .2+ I./4'GE+%I9.(&'1+2(.I+ $).E+ &.+
H%'&/)I+ -)E+ =SUP6+ %/1%,%1*)0E"+ >/+ 3./&()E&S+ &8'+ /*I\'(+ &8)&+ -)E+ 9(.,%1'1+ \G+ &8'+ V.('E&(G+ B(.&'3&%./+
O'9)(&I'/&+ QVBOR+ .2+ H%'&/)I+ -)E+ %/3./E%E&'/&S+ \'%/5+ #NSUP6+ -8'/+ 2%(E&+ E8)('1+ )/1+ &8'/+ #:S#P!+ &8'+
2.(+')38+I./4'G+%00'5)00G+EI*550'1+&.+F8%/)+.(+ &8'+XJS+&8'+&()1'(+5)%/E+/.+0'EE+&8)/+XJO+6TT"+<8%E+I')/E+
&8)&+ %2+ &8'+ 1%22'('/3'+ %E+ ./0G+ E','()0+ 8*/1('1+ I./4'GES+ &8'+ &()1'(+ 3)/+ ),.%1+ &8'+ &)D+ Q!P+ 9'(+ 3'/&+ .2+
(','/*'R+ .2+ 8*/1('1E+ .2+ I%00%./E+ .2+ H%'&/)I'E'+ O./5"+ M.E&+ %I9.(&)/&0GS+ &8'+ %/,'E&%5)&%./+ E8.-E+ &8)&+
&.+ &8'+ K.*(/)0%E&+ \G+ &8'+ VBO+ .2+H %'&/)I+-)E +^,%(&*)00G+ '/&%('0G+ 38)/5'1_+ 2(. I+ &8'+ .(%5%/)0 +, '(E%./+ .2+ &8'+
9'(I%&+&8)&+-)E+9(.,%1'1+\G+ &8'+V.('E&(G+O'9)(&I'/&+.2+$).E+L'%58&+ .*&+.2+ &'/+9%'3'E+.2+ %/2.(I)&%./+)('+
1%22'('/&"+Y9)(&+2(.I+&8'+ 9'(I%&S+&8(''+.&8'(+1.3*I'/&E+&8)&+ VBO+ .2+ H%'&/)I+9(.,%1'1+2.(+&8'+ K.*(/)0%E&+
-'('+3./2%(I'1+ )E+ 2)0E'+1.3*I'/&E+ \G+ &8'+ V.('E&(G+O'9)(&I'/&+ .2+ $).E"+ <8'+ K.*(/)0%E&+ ]*'E&%./'1+-8G+
&8'('+-'('+ 38)/5'ES+ -8'&8'(+&8'+ 1.3*I'/&+ -)E+ 2)0E%2%'1+)/1+ */1'(+ -8)&+ I.&%,)&%./E"+>&+ %E+9.EE%\0'+&8)&+
U4 Issue 2015:11
By looking into interrelated factors that contribute to the current problem of corruption in wildlife
trafficking in Vietnam, the interviewees suggest a number of recommendations for dealing with the
problem more effectively.
More political will
A number of studies on wildlife trafficking in Vietnam are concerned that the crime often takes a low
priority among various authorities (Do 2010; Milliken and Shaw 2012; Nguyen 2008). Some
interviewees in the research propose that the first and perhaps most crucial solution to effectively
tackle wildlife trafficking as well as its close connection with corruption is more political will to
actually control the issues. An increased will of elite politicians will lead to other measures being
taken such as more severe punishments, stiffer enforcement and more effective awareness campaigns.
An interviewee in the research also expresses that it is vital to increase political will in the top state
structures such as the National Assembly, the Government and central bodies combating wildlife
trafficking. Once the top leaders are firmly committed, the local authorities will prioritise the crime
(5). In contrast, a lack of political will to stop wildlife trafficking and corruption results in lenient
punishments and lax enforcement. As indicated though sometimes in Vietnam it has been found or is
suspected that political authorities are involved. This means they have no motivation to tackle
corruption or the illegal wildlife trade as they may be profiting from it. Non-corrupt politicians,
particularly within the Communist Party, will need to drive change. Their motivations for doing so
may come from public pressure to decrease corruption and protect wildlife and from their own desire
to see these aims achieved.
Interviewees thought the Vietnamese legislation on wildlife trafficking and corruption overall is
relatively comprehensive, but quite often sanctions for both are still lenient. Roberton (2013) points
out that while in Vietnam smuggling endangered wildlife is a criminal offense, there are numerous
repeat offenders operating in the country. If caught, these smugglers are given fines, rather than being
criminally charged, and the fines are low compared to their illicit profits (Roberton 2013). Clearly, the
political will is lacking, but also this would be the reason that ‘wildlife offenders ignore the rule of
law. They are not afraid of laws at all. They aren’t scared of the punishments’ (1).
Strengthen law enforcement
In regards to enforcing the law and regulations for both wildlife trafficking and its connection with
corruption, often it does not seem to be effective and firm. As mentioned earlier, there has not been an
officer prosecuted for corruption related to wildlife trafficking. An interviewee believes:
Environmental law enforcement of any kind is very weak; it is not taken seriously. Everyone
is responsible, but no one is accountable; no one ever loses their job. No one is saying the
reason why you have a lot of corruption is because basically no one is fined. And maybe go to
prison for some crimes. But just getting fined in their job that could be pretty embarrassing.
But it just doesn’t happen. And I am afraid to say it just doesn’t happen and it is much worse
in the wildlife trade… Your risk is getting out of Africa or getting through Bangkok or
through Hong Kong or wherever your flight is. I suspect that if you are caught in the airport in
Hanoi, I wonder if anything would happen to you (2).
It is therefore strongly recommended that the Vietnamese government ‘should make it a priority to
launch a sustained campaign to prevent corruption of border officials by seeking out and applying
strong and effective punishments to anyone found taking bribes’ (Roberton 2013). This should be
taken seriously at both central and local levels (3).
U4 Issue 2015:11
To strengthen law enforcement, it is also vital to improve the capacity of law enforcement agencies.
On the one hand, the low capability of wildlife forces is always blamed as a major contribution to the
existence and increase of wildlife trafficking in Vietnam (GDF 2010; Vu 2010). Kiem Lam staff, for
example, seem to have a limited ability to identify what are common and what are endangered species
(GDF 2010). On the other hand, the limited ability is also exploited to justify corrupt activities. As
revealed in the techniques of corruption used, the officers always look to defend themselves if their
relationship with wildlife traffickers is questioned. One of the defences is the lack of supporting
equipment and professional training on making technical evaluations such as the exact species being
trafficked, especially hybrid ones. The lack of scientific knowledge and technical expertise not only
prevents the effectiveness of functional authorities, but also creates potential ways to cover up corrupt
behaviours. For example, snake farmers have to inform the functional authority about the number of
offspring born at their farm. The farmer says that there are 200 new babies. In fact there may only be
100 babies actually born there and 100 taken from the wild. Law enforcement does not have the
knowledge or technology to distinguish between wild and captive-bred (5). Likewise without
electronic chips attached to registered tigers or other species, it is too difficult to detect when legal
tigers are exchanged for illegal ones (4). More investment in supporting tools and training to enhance
the understanding of wildlife and its conservation can help hold the corrupt actors to account.
Additionally, effective international cooperation would strengthen law enforcement by helping to
establish mechanisms of dialogue and information exchange among countries and agencies in order to
identify document falsification perpetrated by wildlife officers. This solution is increasingly urgent in
the context that wildlife trafficking is no doubt a transnational crime and that most endangered
wildlife species currently trafficked in Vietnam are from overseas (3). Thus frequent cooperation at
different levels between Vietnamese authorities and neighbour countries such as Laos and Cambodia,
but also with African countries, with INTERPOL and UNDOC, is needed (1).
Good governance, accountability and transparency
In regards to wildlife trafficking, it was largely agreed by the interviewees that it is imperative to
increase transparency by determining which authorities vested in fighting wildlife trafficking are
accountable for what. Indeed, at the moment the problem of wildlife trafficking is very complicated
because the responsibility and accountability for controlling it is not clear (1). A study by Do (2010)
indicates that perhaps ‘a real mechanism of critical assessment’ on the accountability among wildlife
institutions is still lacking. At the state level, the Ministry of Natural Resources and Environment is
the primary department in charge of wildlife reserves, but they have no real power and no agencies
exclusively participating in this (1). At the frontline, there are now numerous overlaps and
ambiguities in responsibility of officers in Forest Protection, Forest Guard, Environmental Police,
Investigative Police, Customs, Border Guard, and Market Control who all participate in wildlife
management (3 and GDC 2010). The ambiguous responsibilities ‘will create opportunities for
corruption’ (Nguyen 2008: 106) and are believed to be a major factor restricting efforts to hold
corrupt officers accountable. Consequently, it is recommended to establish a mechanism that clarifies
the responsibility of each individual officer in each specific locality. If wildlife trafficking takes place
in his locality, he has to be held accountable (3). Furthermore, there needs to be mechanisms to
monitor the operations of functional forces and evaluate workplace efficiency. To do so, first the
incomes and assets of officers and agencies need to be monitored and the punishment of corrupt
officers increased (1). Second, it is necessary to create databases of activities and documents, which
can also be used to coordinate operations (1). The databases will help with oversight of documents
from the entire trafficking chain particularly at the border gates where smugglers are aided by corrupt
officers who launder illegal wildlife by supplying forged paperwork. Additionally, this may help
identify cases where domestically sourced illegal wildlife is brought to the border gates to be
laundered and then is carried back into Vietnam (1).
U4 Issue 2015:11
Demand reduction and public awareness
Wildlife trafficking in Vietnam is driven by high demand and big profits. For a majority of the
interviewees, reducing wildlife demand is one of the significant solutions to curb wildlife trafficking
as well as related corruption. This is because high demand leads to high profits, which is a key
condition to motivate a trafficker to establish relationships with authorities in order to bribe them (3).
An interviewee stresses that:
It’s super, super profits that make the crime beyond the normal crime. There must be
‘guarantees’, must be ‘heavy investments’ to overcome the law. Clearly they must gain huge
profits, so that even paying for bribes, it is still super profitable (1).
Furthermore, for a variety of Vietnamese people ranging from top politicians to ordinary people, the
rich and poor, well-educated to ill-educated, consuming wildlife is a normal habit (Drury 2009). It is
not stigmatised; there is a permissive attitude (2, 4).
An interviewee states:
People with the same education, similar IQ, in Vietnam they may appear to be modern and
they are very modern but deep down, there is the belief that actually there must be something
true… In Vietnam there is actually a deep belief particularly in medicinal properties there is
something there (2).
Another interviewee adds that virtually all senior officials like having some bear bile, tiger glue or
something related to rare wildlife. Many Vietnamese maintain the traditional belief that wildlife
belongs to the forests and to the mountains, which is not connected to people. Additionally, all wild
food is nutritious and healthy and that killing wildlife is not harmful, not serious, and not a crime. One
hobby for example is to soak a whole tiger in a large crystal bottle containing some 200 litres of
brandy. This brandy is not for drinking but just acts as a show of wealth (3). Such an ideology needs
to be radically altered to reduce wildlife consumption, thereby reducing profits and dropping financial
opportunities for corruption.
Finally, if corruption has become a normal phenomenon in Vietnam, it needs a comprehensive
solution that coordinates various fields other than just wildlife trafficking. First, Vietnam needs to
address its ‘culture of envelope’ that is an omnipresent fact in which ‘for almost all Vietnamese
people, returning favours and delivering envelopes are simply the way business is done’ (Sumrall
2009: 20-21). These ideas suggest that tackling corruption in wildlife trafficking is highly complex
and goes beyond the scope of the control of wildlife trafficking alone. It is also about dealing with
various economic, legal, political, social and cultural aspects.
For a Kiem Lam officer, he may be prevented from corruption in tiger trafficking but he can
be corrupt in timber trafficking or forestland management. For an environmental police
officer, he may be prevented from corruption in wildlife trafficking but he can be corrupt in
pollution management or environmental regeneration (1).
This means that since corruption in the whole society is still rampant and core causes of corruption
have not been eliminated, it is unlikely to be able to thoroughly stop corruption in wildlife trafficking.
In other words, a campaign to stigmatise wildlife consumption in Vietnam needs to be carried out.
This should be done in conjunction with a campaign to stigmatise corruption.
U4 Issue 2015:11
The case study suggests that corruption has an important role in facilitating wildlife trafficking in
Vietnam. However, it is not always necessary, particularly for offenders such as local hunters who
still poach small amounts of wildlife. In contrast, for wildlife trafficking on a larger scale that targets
endangered species and exists over a long time period, the need for corruption is far higher. Even with
relatively large scale wildlife trafficking, traffickers may not need to pay every time they smuggle
since they can use sophisticated techniques to avoid frontline officers and avoid bribes.
In Vietnam, corruption in wildlife trafficking may occur in any of the parts of the illicit chain with
various institutions at risk of corruption as seen in Table 2. Also, there is a wide range of ways in
which illicit wildlife traders use corrupt officers, and then obtain their assistance (Table 3). There are
two common features when examining the methods of corruption. First, the level of complexity of the
methods is proportional to the scale of the trade and value of the wildlife species traded. That said the
larger the scale of the trade and the more valuable the wildlife is, the more sophisticated the methods
are. Second, both traffickers and officers always prepare a defence to explain their relationship if it is
ever questioned.
The case study suggests a number of solutions to curtail corruption in wildlife trafficking in Vietnam:
enhancing political will to stop wildlife trafficking and its connection with corruption, increasing
transparency in wildlife management, launching an intensive campaign to stigmatise wildlife
consumption, improving international collaboration in controlling wildlife trafficking and providing
better equipment and professional training for wildlife officers. However, corruption throughout
society must be tackled in order to impact upon wildlife trafficking and Vietnamese society in
general. Many of these suggestions are generalizable to other countries, such as increasing political
will, increasing transparency related to wildlife management, improving international cooperation and
improving law enforcement knowledge and capability. Whereas public awareness campaigns
targeting wildlife consumption and corruption are possibly generalizable too, the cultural context of
these is very specific and would need extensive research to create properly focused solutions that fit
the culture. Overall, the case study provides meaningful insight into the concrete connections between
corruption and wildlife trafficking that can inform further prevention strategies and studies.
U4 Issue 2015:11
Table 3 The corrupt actors and acts in wildlife trafficking
4. Towards a typology of corruption in wildlife
Corruption occurs where weak governance and enforcement are evident as well as in poorer areas or
in sectors with low salaries. The latter though is controversial and whilst it may contribute to
corruption, raising salaries and providing incentives have not proved to change corrupt behaviour.
Additionally, there may be a cultural resilience to corruption in societies with long traditions of
patronage and gift giving. There is some exploration around the bribery, falsification of documents
and diplomatic cover that are used for trafficking some species, but there is no comprehensive
overview attempting to categorise the patterns of corruption linked to wildlife trafficking. Based upon
review of the literature and data collected, it is proposed that forms of corruption can be mapped on to
the three main activities making up wildlife trafficking poaching, smuggling and selling (Figure 3).
U4 Issue 2015:11
Corruption in the wildlife trade exists at different points along the enforcement and compliance chain
starting with the poaching (though also capturing or harvesting). At this point, bribes, forged or ill-
gotten permits, patronage and threats of force all may enable wildlife to begin to be trafficked. Then
the transportation/smuggling, combined with either or both exporting or processing are enabled by the
same forms of corruption, but may also be facilitated by diplomatic cover. This results in importing
and finally selling, which can take place with the help of bribes, forged permits and/or patronage. The
additional factors affecting demand proposed by Wyatt (2013c) level of profit, scarcity or
abundance, location of supply and demand, and cultural use of wildlife offer further insight as to
what form of corruption will be evident and where along the trafficking process it might happen.
Figure 2 Forms of corruption facilitating wildlife trafficking
Level of profit seems to affect the type of corruption at any point along the smuggling chain. For low
levels of profit, petty corruption in the form of smaller bribes or gifts may be used to, as mentioned,
have law enforcement or regulators look the other way. Patronage, where family or social
relationships are used as leverage to engage in corrupt activity, may also feature. All of these types of
corruption could also happen in terms of possession by the poacher, smuggler, market trader or
restaurant owner of illegal wildlife. Patronage, bribes or gifts may also purchase fraudulent national or
CITES paperwork that launders poached wildlife through capture and smuggling. When the profit
levels are much higher, bribes or gifts, but on a grand scale, facilitate trafficking. The difference is the
amounts of the bribe or gifts are much higher. Patronage may feature here as well where family
members or close friends are given significant tracts of land. Furthermore, when the profit levels are
higher, most likely the actors involved are more powerful. The person receiving the bribe may sit in a
much higher, influential position that enables them to facilitate the smuggling of, for instance, ivory
or rhino horn. Additionally, the people paying the higher bribe must have access to more wealth. This
may correspond to the involvement of organised crime. Trafficking of high profit wildlife may also be
facilitated by diplomatic cover where corrupt officials use their positions in embassies, consulates and
other diplomatic institutions to smuggle wildlife and wildlife products.
The abundance or scarcity of species being trafficked often correlates to low and high levels of profits
respectively, though there are some exceptions like pangolins. This means abundance and scarcity
also correlate to petty and grand corruption. Trafficking of abundant species may be facilitated by
U4 Issue 2015:11
patronage, small bribes and gifts, which allow access to poaching, and allow smuggling, market and
restaurant sales. Trafficking of scarce species on the other hand most likely requires significant bribes
and gifts as the wildlife is difficult to obtain, smuggle and sell. As with high levels of profits, scarce
species like rhinoceros may also be trafficked under diplomatic cover. Proximity of collection and
selling is also linked to levels of profit and therefore the type of corruption that is witnessed. For
trafficking where the location of the poaching or harvesting is close to the location of the final sale,
patronage, small bribes and gifts are all used to further the wildlife to market. If the wildlife or
wildlife product must travel over long distances to reach the location of demand, the type of
corruption would then most likely be grand larger bribes and gifts and diplomatic cover. This
again could be because the higher levels of profits to be gained warrant larger payments, but also
buying secrecy and remaining undetected for the long journey on a plane or ship may cost a
significant amount.
Culture around wildlife is the one factor that appears to depart from a connection to the level of profit.
As seen in the case study, some societies have a traditional use of wildlife that results in consumption
being a resilient part of the culture. Even though some of that consumption has been criminalised and
wildlife such as tigers and sharks are given protection under CITES and national legislation,
consumption continues. This is also made possible through corruption. Patronage, small bribes and
gifts may be used for more abundant species that may be closer to the demand location, which are
easier to obtain, but still prohibited. When species are scarce though, such as rhinoceros or sea
cucumbers, the bribes and gifts would be larger and diplomatic cover may also play a role.
Wyatt (2013c) proposes wildlife trafficking can be grouped into categories of demand processed
commodities, collector’s items, food and traditional medicines (Figure 3). A majority of processed
commodities are abundant, lower priced wildlife, where there is a fairly close proximity in terms of
where the animal was poached and where it was processed. It could be predicted then that there will
be petty corruption in the form of smaller bribes and gifts at the poaching and smuggling stages. For
those higher priced processed commodities, the amount of the bribes and gifts increases as well, as is
the case with timber, which was not discussed in detail here. Fraudulent paperwork can feature
prominently in processed commodities as it enables laundering of the illegal to the legal and then the
wildlife can be manufactured or altered to be sold. In contrast, collector’s items are nearly all high
profit items, which tend to be scarce and are smuggled over long distances. This then correlates to
grand types of corruption including significant bribes and gifts as well as diplomatic cover. Fraudulent
paperwork may facilitate the collection and smuggling stage, but to a lesser degree as this wildlife is
highly protected, so no paperwork may be available. Trafficking of wildlife for food is similar to the
structure of processed commodities. The wildlife tends to be abundant, lower priced and consumed
close to the location where it was captured or harvested. This type of trafficking is enabled through
patronage, small bribes and gifts. Fraudulent paperwork may be a way to obtain or smuggle the
wildlife. To a lesser degree it may also permit the sale of wildlife in markets or restaurants by
mislabelling the species or misreporting the volume of wildlife. Food is one of the categories of
demand where cultural tradition plays a role in the sustained consumption of the wildlife regardless of
its conservation status (some food items though may more closely resemble luxury items). The other
category of demand where this is the case is traditional medicines. This category features wildlife that
is both abundant and scarce as well as low and high priced and also near and far in proximity from the
supply location to the demand site. This means a range of types of corruption are employed from
small bribes and gifts to patronage, from fraudulent paperwork to diplomatic cover. The price and
complexity of smuggling the item to its final destination will inform which type of corruption is used,
but the unifying characteristic is the consumers’ commitment to the continued use of the wildlife in
spite of the threat that this may pose to the species’ survival.
U4 Issue 2015:11
Figure 3 Categories of demand Source: Wyatt 2013c
5. The role of donor countries and agencies:
Some solutions
corruption?! In! general,! corruption! takes! place! where! there! are! ‘criminogenic! asymmetries’,!
the! economy! and! the! law’! (Passas! 1998).! These! asymmetries!create! opportunities! for! illicit!
(1994)!particularly! argues!against! protectionist! programmes!as!they! create!unequal! economic!
exchanges!(further! asymmetries),!which! enhance! inequalities! or! reinforce! dependency! in! the!
Sea cucumber,
tiger bone/penis
Rare species,
companion animals
Processed commodities
skins, furs, timber,
vicuna, furniture
Caviar, bushmeat,
wildlife restaurants
bear bile/
Turtle meat/
shells, caviar,
Coral, ivory,
Rhino horn,
tiger wine
U4 Issue 2015:11
developing!world.! So! aid! programmes! to!tackle! poverty!and! other! inequalities!are! potentially!
in! relation! to! the! states! and! criminal! justice! systems! where! donor! agencies! work,! to! the!
5.1 States receiving aid
Key to reducing wildlife trafficking are initiatives to tackle corruption especially in state agencies
(Duffy and Humphreys 2014).!EIA (2012) argues part of this must be for states to institute laws to
make bribing foreign officials illegal. United for Wildlife (2014) agrees that corruption and bribery
need to be criminalized and this can be done by adopting or amending legislation related to
corruption, money laundering and wildlife trafficking. A step to work towards this would be for states
to have active engagement and implementation of legislation that complies with the United Nations
Convention against Corruption (Horne 2013a; United for Wildlife 2014). In order to make the
necessary additions or alterations to existing legislation, states must have a system of transparent!
lobbying! (Passas! 1998),! so! that! conflicts! of! interest! in! regards! to! wildlife! trade,! including!
interests! of! family! members! and/or! friends! do! not! interfere! with! passing! and! implementing!
international! conventions! as! well! as! initiatives! to! promote! transparent! lobbying.! In! projects!
with! wildlife! and! environmental! management! agencies,! donors! need! to! attempt! to! monitor!
increasing! the! penalties,! and! as! mentioned,! this! may! be! part! of! the! solution,! Passas! (1998)!
warns! that! the! danger! with! stricter! penalties! is! that! this! increases! the! probability! of! getting!
as!a!tool!(Passas!1998)!to!successfully!traffic!wildlife. Pires and Clarke (2011) agree that,!at!least!
in! Bolivia! where! poaching! of! parrots! is! widespread,! making! poaching! and! wildlife! crime! a!
priority!would! create!the! possibility!of!corruption! of! the!law!enforcement! officers!tasked!with!
policing!it.! That!is! not! to!say!stricter!penalties!are!not!part!of! the! solution,! but! to!caution! that!
implementation! of! these! measures! must! be! undertaken! with! cultural,! social! and! economic!
knowledge! and! sensitivity.! Donor! agencies! can! support! further! research! as! to! the! best! way!
forward! for! states! in! enforcing! existing! laws! more,! and/or! criminalising! or! enhancing! the!
States can help to combat corruption, and in turn wildlife trafficking, by maintaining the
independence of civil society and NGOs (Green and Ward 2004). This provides an essential external
monitor of the state and therefore of official and political corruption. Both CITES Management and
Scientific authorities should be vetted for their independence, so that the organisation at the heart of
wildlife trade is not contributing to the corruption that facilitates wildlife trafficking. All law
enforcement, civil servants and the public should have access to a safe and secure means of
whistleblowing, so that they can report wildlife trafficking, corruption and other crimes without fear
of reprisal.!Donor agencies can assist in the above suggestions through their rule of law programmes
and projects that promote and support civil society. They can also establish criteria where aid can be
suspended due to corruption or lack of reaction when corruption takes place.!
U4 Issue 2015:11
5.2 Criminal justice systems in aid-receiving countries
Many of the solutions to combat wildlife trafficking and corruption centre on strengthening law
enforcement, which could include improving the status of such positions, and building their technical
expertise. First, wildlife and environmental officers need to have more training regarding species
identification, crime scene evidence collection and expertise and uncovering fraudulent paperwork.
This will help to also discover corrupt practices that facilitate smuggling. The typologies proposed
here may also help law enforcement pinpoint the types of corruption that are utilised at the poaching,
smuggling, and selling stages. This, too, may assist them in their investigations. They could also be
supported by better equipment. Both of these may be achieved with the help of donor countries
through training initiatives and purchasing of such equipment as part of projects. Second, financial
officers with expertise uncovering money laundering and tracking the financial flows of illicit goods
need to trained and made a part of the teams that are battling wildlife trafficking. This can be through
the creation of specialised units or by creating multi-agency task forces within countries. Again, as
part of wider rule of law initiatives or law enforcement capacity building, attention could be focused
on creating and/or improving the knowledge base and expertise of law enforcement with regards to
accounting and financial crimes.
In terms of the way that law enforcement operates, the literature and data collected offer several
suggestions. For wildlife and environmental officers, it has been suggested that they should not work
in their home regions to avoid patronage; they should have irregular shifts, so that traffickers cannot
target specific people for bribing. Whereas in some contexts this may be a part of the solution, others
have pointed out there is a danger that frequent movement gives them the incentive and opportunity to
extort bribes from various local people they come in to contact with. Donor agencies should support
investigations into which type of the forms of corruption developed here exist in the aid-receiving
countries in which they work, so that more concrete recommendations in this regard can be
A key solution is to reduce the amount of discretion that officers have so that their actions are
monitored more closely and they are held more accountable for their choices (Klitgaard 1988). Part of
this may be to more strictly institute logbooks and/or personal cameras to record officers’ interactions
with the public. There also needs to be better coordination and cooperation between agencies that are
tasked with various wildlife management duties. For instance in Mexico,! Guzman! et! al! (2007)!
recommend!that!to! tackle!the!illegal!parrot!trade,!law!enforcement!needs!to!work!with!wildlife!
programmes.! This! would! help! with! instances! of! forged! paperwork! and! corrupt! tactics! using!
mislabelled! species! and! misreported! volumes! of! wildlife.! Naylor! (2004)! advises! more! use! of!
traditional!law!enforcement! tactics! such!as!the!use!of!informants.! He! suggests!wiping!the!slate!
also! be! part! of! the! initiatives! aimed! at! improving! the! knowledge! and! expertise! of! law!
For!financial! law! enforcement,!in!collaboration! with! wildlife!officers,!they! should! be!targeting!
corrupt! actors,! which! can! inform! investigations! in! regards! to! who! might! be! suspected! of!
corruption.! When! these! officials! are! identified! who! collaborate! with! wildlife! traffickers,! their!
assets!should! be! targeted!for!forfeiture! and! repatriation!to!the! states!that! are!affected! (White!
to! target! the! assets! of! wildlife! traffickers! and! corrupt! officials.! Donor! agencies! can! assist! in!
strengthening law enforcement and building their technical expertise again through their rule of law
U4 Issue 2015:11
programmes. This should be to share best practices in regards to discretion and building technical and
scientific capacity in regards to knowledge of wildlife and financial flows.
5.3 Monitoring and transparency
Monitoring of crime prevention efforts is a crucial element to detecting corruption in wildlife
trafficking. Donor agencies should support states in efforts to have this conducted independently.
Further, monitoring should take place through international or intra-governmental peer review
(Ayling 2013) of processes, systems and legislation. It is key to have non-state actors involved in anti-
corruption efforts. Monitoring should include the auditing of reports and registrations related to
wildlife management (Ayling 2013). For instance, wildlife farms in Vietnam should have a
registration system and it should be monitored by an independent assessor. Import and export permits
as well as trapping and hunting permits should all be subjected to this monitoring. Donor agencies can
demand these practices in their own projects as well as supporting training and implementation of
monitoring in wider society. This is particularly important for the banking and tax sectors, which need
proper monitoring and oversight to uncover and track the illicit financial flows (Passas 1998) and
money laundering (United for Wildlife 2014) stemming from corruption and wildlife trafficking.
Transparency needs to be an integral part of state institutions including banking and law enforcement.
This could in part be supported by use of systems where there is an in-built audit trail that logs actions
and thus increases transparency in the investigation. For rhino horn trafficking, Ayling (2013) argues
that transparency is also warranted in choosing managers of reserves and around the actions of owners
and employees of tours and safaris (Ayling 2013). This is good practice for any country where
wildlife trafficking is a problem. Having openness about the relationships of transportation employees
and anyone involved in wildlife management may help to prevent corruption. As Klitgaard (1988)
says, collecting and analysing better information can act as a partial cure of corruption. Donor
agencies should thoroughly vet all of their vendors and contacts to ensure they are working with
banks and individuals who are not corrupt. If they discover that they are indeed working with corrupt
actors, immediate steps should be taken to replace them with uncorrupted institutions or people.
It would be best practice for donor agencies to utilise civil society when implementing their
conservation programmes in particular, but other programmes as well (Stoett 2002). Again, the
independence of civil organisations may challenge corruption and other criminal behaviour. Others
suggest that aid needs to be tied to the absence of corruption (Senior 2006). Whilst this may be
difficult, especially in societies like Vietnam, donor agencies should consider the partners’ and
countries’ willingness to tackle corruption and wildlife trafficking. As mentioned, donor agencies
should limit the amount of cash given in their projects and instead rely on assistance through
personnel, equipment and knowledge exchange. When cash is unavoidable, there needs to be strict
monitoring and transparency regarding the spending of the money. Donor agencies should require
transparency in declaring conflicts of interest and/or family and social relationships in organisations
or sectors related to their projects. This may help fight patronage.
5.4 Demand-focus and attitudes
is!drive!the!targeted!business!further! underground,! raise! profit! rates!and! increase!corruption’!
(Naylor!2004).! As!mentioned,! criminogenic asymmetries are linked to the existence of corruption.
Passas (1998) agrees with Naylor that when states outlaw certain goods without reducing demand, this
creates a demand-supply asymmetry that results in corruption and black markets.
U4 Issue 2015:11
Essential then to tackling both wildlife trafficking and corruption are efforts to change people’s
attitudes towards consumption of wildlife and acceptance of corrupt practices. This is particularly
evident in the recent campaign in Vietnam by Humane Society International and other organisations.
A poll indicates demand for rhinoceros horn is possibly down by more than a third in the country to a
use rate of 2.6 per cent of the population (Milman 2014). Equally important is that currently only 25
per cent of Vietnamese now believe that rhino horn has medicinal value (Milman 2014). Efforts!to!
media!coverage!about! poaching! does! not! expose! the! key! role! of!corruption! on! which!poaching!
and! trafficking!rely! to! operate! (Duffy! 2014).! Arguably! though,! campaigns! also! need! to!
specifically! target! the! acceptability! and! negative! consequences! that! corruption! has! on! peop le,!
particularly! the! poor.!Donor! agencies! can! aid! in! changing! attitudes! by! supporting! campaigns!
against! wildlife! trafficking! and! corruption! as! well! as! supporting! the! independence! of! civil!
5.5 Conclusion
in!driving!these!efforts!through!rule! of!law! programmes!as!well!as!role!models! of!best! practice!
and!hiring!processes.!A!missing!piece!that!is!crucial!to! better!understanding!of!the!dynamics!of!
wildlife! trafficking! and! corruption! is! the! unpicking! of! the! illicit! financial! flows! and! money!
laundering! that! run! in! parallel! to! these! crimes.! Donor! agencies! can! help! support! further!
initiatives! and! research! into! this! essential! area,! which! is! important! to! improve! success! in!
U4 Issue 2015:11
Alacs, E., and Georges, A. 2008. ‘Wildlife Across Our Borders: A Review of the Illegal Trade in
Australia’. Australian Journal of Forensic Sciences. 40(2): 14760.
Albanese, J. 2011. Transnational Crime and the 21st Century: Criminal Enterprise, Corruption, and
Opportunity. New York: Oxford University Press.
Ayling, J. 2013. ‘Harnessing Third Parties for Transnational Environmental Crime Prevention’.
Transnational Environmental Law. Volume 2, Issue 2: 339-362.
----- 2012. “What Sustains Wildlife Crime? Rhino Horn Trading and the Resilience of Criminal
Networks. Transnsational Environmental Crime Project: Working Paper 2/2012. Online:
Balmford, A., Brune,r A., Cooper, P., Costanza, R., Farber, S., Green, R.E., et al. 2002.
ecologyeconomic reasons for conserving wild nature. Science. 297:950953.
Basu, G. 2014. ‘Concealment, corruption, and evasion: a transaction cost and case analysis of illicit
supply chain activity’. Journal of Transportation Security. DOI: 10.1007/s12198-014-0140-8.
Brack, D. 2003. ‘Lessons from the Control of the Illegal Trade in Ozone-depleting Substances,
Timber and Fisheries’. In Oldfield, S. (ed.). The Trade in Wildlife: Regulation for Conservation.
London: Earthscan: 16379.
Brack, D. and Hayman, G. 2002. International Environmental Crime: the nature and control of
environmental black markets. London: Royal Institute of International Affairs. Online:,%20Environment%
20and%20Development/environmental_crime_background_paper.pdf. Accessed 2 October 2014.
Cao, A. and Wyatt, T. 2012. “The Illegal Wildlife Trade in Vietnam”. Asian Journal of Criminology.
DOI: 10.1007/s11417-012-9154-y.
Communist Party of Vietnam. 2012. Resolution No.12/2012 of the Fourth Plenum of Central
Committee XI on a number of urgent issues in building up the Party in the present time. Hanoi.
Cook, D., Roberts, M. and Lowther, J. (2002) The International Wildlife Trade and Organised Crime:
A Review of the Evidence and Role of the United Kingdom. Online: Accessed 8 October 2005.
Currey, D. 2003. Timber Trafficking: Illegal Logging in Indonesia, South East Asia and International
Consumption of Illegally Sourced Timber. Online:
in-indonesia-south-east-asia-and-international-consumption-of-illegally-sourced-timber.pdf. Accessed
28 September 2014.
Dang, H., H, and Dang, H., P. 2010. Profits, management and the control over illegal wildlife trade in
Vietnam. Paper presented at the National Conference of Prevention and Combat the Offence Against
Wildlife, Biodiversity and Natural Preservation, Hanoi, Vietnam.
U4 Issue 2015:11
Dao Le, T. 2011. Bribery offences under Vietnamese criminal law in comparision with Swedish and
Australian criminal law. Lund University.
Davies, C. 2014. Insider Knowledge: Environmental Criminals’ Perceptions on Crime, Corruption
and CITES. Internet Journal of Criminology. Online:
014.pdf: 44-67. Accessed 5 March 2015.
Do, A. T. 2010. Measuring the effectiveness of the enforcement of organised wildlife trade crime: a
comparative assessment between Vietnam and England and Wales. (A thesis submitted in partial
fulfilment of the requirements of the University of the West of England, Bristol for the degree of
Doctor of Philosophy), University of the West of England Bristol.
Doig, A. and Theobald, R. 2003. ‘Introduction: Why Corruption? In Doig, A. and Theobald, R. (eds).
Corruption and Democratisation. Portland, OR: Frank Cass: 1-12.
Douglas, L. and Alie, K. 2014. High-value natural resources: Linking wildlife conservation to
international conflict, insecurity, and development concerns. Biological Conservation. 171:
Douglas-Hamilton, I. 2012. ‘Ivory and Insecurity: The Global Implications of Poaching in Africa’,
Statement at the United States Senate Committee on Foreign Relations, 24 May.
Drury, R., C. (2009). Identifying and understanding consumers of wild animal products in Hanoi,
Vietnam: Implication for conservation management. (The Degree of Doctor of Philosophy),
University College London, London.
Duffy, R. 2014. ‘Waging a war to save biodiversity: the rise of militarized conservation’.
InternationalAffairs. 90: 4, 819834
Duffy, R. and Humphreys, J. 2014. Mapping Donors: Key areas for tackling illegal wildlife trade
(Asia and Africa). Evidence on Demand.
Education for Nature Vietnam (ENV). 2010. Under the cover of conservation: breeding of tigers at
private farms must end. Education for Nature Vietnam, Hanoi.
Elliott, L. 2007. ‘Transnational environmental crime in the Asia Pacific: an ‘un(der)securitized’
security problem?’ The Pacific Review. Volume 20, Issue 4: 499-522.
Environmental Investigation Agency (EIA). 2013. Vietnam’s Illegal Rhino Horn Trade: Undermining
the Effectiveness of CITES. London: EIA.
----- 2012. Appetite for Destruction: China’s Illegal Timber Trade. London: EIA.
----- 2011. Enforcement Not Extinction: Zero Tolerance on Tiger Trade. London: EIA.
----- 2010. Open Season: The Burgeoning Illegal Ivory Trade in Tanzania and Zambia. London: EIA.
Environmental Investigation Agency (EIA), WWF and TRAFFIC. 2013. Wildlife and Forest Crime:
CCPCJ22. Joint Briefing. 21 April.
U4 Issue 2015:11
Europol. 2013. Threat Assessment 2013. Environmental Crime in the EU. Online:
nt_2013_-_public_version.pdf. Accessed 2 October 2014.
Fedotov, Y. 2013. ‘Poaching and Illicit Wildlife Trafficking: A Multidimensional Crime and Growing
Challenge to the International Community’, 26 September. UNODC Executive Director, remarks at
68th UN General Assembly side event.
Ferraro, P. 2005. ‘Corruption and conservation: the need for empirical analyses. A response to
Smith and Walpole’. Oryx. 39(3): 257259.
Fison, M. 2011. ‘The £6bn trade in animal smuggling’. The Independent. Available at:
2233608.html#. Accessed 11 February 2013.
Flores-Palacio, A. and Valencia-Diaz, S. 2007. Local illegal trade reveals unknown diversity and
involves a high species richness of wild vascular epiphytes. Biological Conservation. 136: 372-387.
Forest Protection Department (FPD). 2014. Operational Reports: Violations on the Forest Protection
and Management Act. Accessed 10 October 2014.
Four Corners. 2002. The Timber Mafia. ABC TV. Online: Accessed
10 November 2010.
Galster, S., LaBudde, S and Stark, C. 1994. Crime Against Nature: organised crime and the illegal
wildlife trade. An investigative report by The Endangered Species Project.
General Department of Customs of Vietnam (GDC). 2010. ‘Solutions to enhance the detection, the
combat and the treatment of wildlife smuggling and trading activities via borders of Vietnamese
Customs’, National Conference of Prevention and Combat the Offence Against Wildlife, Biodiversity
and Natural Preservation, Environmental Protection Department: Hanoi, Vietnam: 21-24.
General Department of Forestry of Vietnam (GDF) 2010. ‘Legal provisions on the management and
license for wildlife trade, transport, export and import- current situation and measures to improve the
management of the illegal wildlife trade’, National Conference of Prevention and Combat the Offence
Against Wildlife, Biodiversity and Natural Preservation, Environmental Protection Department:
Hanoi, Vietnam: 25-30.
Gerismova, K. 2008. Can corruption and economic crime be controlled in developing countries and if
so, is it cost-effective? Journal of Financial Crime. Vol 15, No 2: 223-234.
Graycar, A. and Felson, M, 2010. “Situational Prevention of Organized Timber Theft and Related
Corruption”. In K. Bullock, R. V. Clarke, & N. Tilley (Eds.). Situational Prevention of Organized
Crimes (pp. 81-92). Devon, UK: Willan Publishing.
Green, P. and Ward, T. 2004. State Crime: Governments, Violence and Corruption. London: Pluto
U4 Issue 2015:11
Gonclaves, M., Panjeer, M., Greenberg, T. and Magrath, W. 2012. Justice for Forests: Improving
Criminal Justice Efforts to Combat Illegal Logging. Washington, DC: World Bank. Online:
Accessed 19 October 2014.
Guymon, C.L.D. 2000. ‘International Legal Mechanisms for Combating Transnational Organized
Crime: The Need for a Multilateral Convention’. Berkeley Journal of International Law. 53: 61-62,
Guzman, J.C.C., Saldana, M.E.S., Grosselet, M. and Gamez, J.S. 2007. The Illegal Parrot Trade in
Mexico: A Comprehensive Assessment. Defenders of Wildlife and Teyeliz.
Ha, N. M., Dung, V. V., Song, N. V., Thang, H. V., Dung, N. H., Tuan, P. N., Hoa, T. T. and Canh,
D.2008. ‘Report on the Review of Vietnam’s Wildlife Trade Policy’. Hanoi: CITES Authorities of
Hague, W. 2013. ‘Poaching and Illicit Wildlife Trafficking: A Multidimensional Crime and Growing
Challenge to the International Community’, 26 September. UK Foreign Secretary, remarks at 68th
UN General Assembly side event.
Holmes, L. (2006) Rotten States? Corruption, Post-Communism, and Neo-liberalism. Durham, NC:
Duke University Press.
Hongfa, X., Kirkpatrick, C., Liou, C. and Wasser, R. 2007. The State of WildlifeTrade in China:
Information on the trade in wild animals and plants in China 2007. TRAFFIC East Asia China
Horne, D. 2013a. ‘Policy Responses to Transnational Wildlife Crime in the Asia-Pacific Part 1:
Global and Regional Policy Context and a Potential Framework for Optimal National Policy’.
Transnational Environmental Crime Project Working Paper 1/2013. Canberra: Department of
International Relations, Australian National University.
—— 2013b. ‘Policy Responses to Transnational Wildlife Crime in the Asia-Pacific Part 2: Policy
Responses at the National Level and Preliminary Gap Analysis’. Transnational Environmental Crime
Project Working Paper 2/2013. Canberra: Department of International Relations, Australian National
Humphreys, J. and Smith, M. 2014. ‘The ‘rhinofication’ of South African Security’. International
Affairs. Vol 90, Issue 4: 795-818.
International Bank of Reconstruction and Development (IBRD)/ The World Bank. 2005. Going, going
gone: the illegal trade in wildlife in East and Southeast Asia. Environment and Social Development
East Asia and Pacific Region Discussion Paper. Online: http://www-
161459/Rendered/PDF/334670PAPER0Going1going1gone.pdf. Accessed 30 September 2014.
International Fund for Animal Welfare (IFAW). 2013. Criminal Nature: The Global Security
Implications of the Illegal Wildlife Trade. Online: ttp://