Mitigating the threats of illegal wildlife trade flows

This blog was guest written with Russell Wallace, Senior AML Compliance Manager and Viola Qefalia, AML Compliance Manager from Vodafone Group.

The illegal wildlife trade (IWT) is a serious multi-jurisdictional crime that generates billions of dollars in proceeds every year. Laundering of such proceeds generally involves activity to conceal or disguise the source, movement, and ownership of those funds.

IWT is estimated to be the fourth biggest crime worldwide, after human trafficking, weapons trafficking, and drugs. The value of trade in illegal wildlife is estimated to be in the range of US$50-US$150 billion per year, and the global financial system remains an essential medium for the transfer of illicit proceeds. This trade is a massive threat to the ecosystems of the African continent and is indeed a global crisis that impacts the world, and financial institutions have a crucial role to play.

In September 2019, the United Nations reiterated its call for all members “to amend national legislation, as necessary and appropriate, so that offences connected to IWT are treated as predicate offences for money laundering”.

Mobile money providers comply with regulatory enforced transaction and account balance limits, which are guided by the country’s national risk assessments. Under these restrictions, mobile money is not an attractive channel for transferring significant sums of money for large-scale/wholesale trade of wildlife products. Despite this, mobile money providers are going above and beyond the standard practices to mitigate the risks of illegal wildlife proceeds trafficked through the mobile channel. 

As part of the mobile money industry’s continued resolve to mitigate all financial crime risks, the GSMA convened an anti-financial crime working group to build more significant synergies amongst the industry stakeholders to fight financial crime. Another step taken by some mobile money providers is to comply with the GSMA Mobile Money Certification criteria, a key framework for countering financial crime and mitigating the risks of illicit flows, including those linked to IWT.

For the Vodafone Group companies, the fight against IWT forms part of a wider strategic commitment to support the planet and address the global climate emergency.

In November 2020, M-PESA, owned and run by Safaricom, Vodacom Group and Vodafone Group, was the first mobile money platform to join the United for Wildlife (UfW) financial task force. Founded in 2012 by The Royal Foundation and spearheaded by His Royal Highness The Duke of Cambridge, UfW has brought together the public and the private sector with the goal to tackle illegal wildlife trade.

As a member of the Taskforce, M-PESA teams receive intelligence, which is embedded in due diligence and monitoring capabilities, enabling processes to deter and detect the use of M-PESA services for IWT purposes.  

The benefit of leveraging both in-house M-PESA expertise on threat and risk analysis and the considerable wealth of IWT knowledge within the UfW organisation has added significant value to the financial crime compliance programme.

There are many benefits to joining the UfW financial taskforce, not only does it provide a forum for mobile money providers to collaborate on ideas on how to address wildlife crime, but members also benefit from the strength and knowledge of the network of partners and therefore enhancements to our financial crime programmes. 

As the landscape is ever-changing, M-Pesa is continuously screening the horizon for new opportunities to tackle IWT. One idea at an early stage of development, is the creation of ‘IWT Country Threat Profiles’. These are envisioned to be “live documents” that collate dedicated risk indicators to assist anti-financial crime teams in detecting behaviour and activity that could point to IWT activity.  

Additionally, M-Pesa is also considering potential ideas that aim leveraging from its vast agent network to raise awareness regarding IWT. 

The fight against illegal wildlife trading is a key part of the mobile money industry’s fight against financial crime, and it will take all of us to make a change, but together we can.

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