Suspicious activity reports (SARs) flagging potential financial crime risks posed by wildlife trafficking are on the rise, according to a report published Monday by the Financial Crimes Enforcement Network (FinCEN).

SARs filed in 2021 regarding wildlife trafficking “are on track to meet or exceed the amount of SARs filed in 2020 based on current trends,” the agency said, citing Bank Secrecy Act data. This finding continues a three-year trend identified by FinCEN highlighting increased frequency of reports bringing attention to wildlife trafficking and its effect on the U.S. financial sector.

“While SAR filings have increased, they still appear low in comparison to the estimates of the scale of wildlife trafficking,” the agency stated in its report. “We assess that the SARs are likely capturing only a small percentage of all wildlife trafficking-associated illicit financial activity.”

Illicit proceeds from wildlife trafficking total between an estimated $7 and $23 billion per year, according to data cited by FinCEN. The illegal practice “involves the illicit trade of protected animals, animal parts, and derivatives thereof, including procurement, transport, and distribution, in violation of international or domestic law, and money laundering related to this activity,” the agency stated.

FinCEN provided several reasons for highlighting the uptick in wildlife trafficking SARs. Perhaps most of note, wildlife trafficking has a “strong association with corruption and transnational criminal organizations,” two of the agency’s anti-money laundering and countering the financing of terrorism (AML/CFT) priorities published in June.

As a result, there is a need to “enhance reporting and analysis of related illicit financial flows,” FinCEN said. Wildlife trafficking also contributes to “biodiversity loss, damage to fragile ecosystems, and the increased likelihood of spreading of zoonotic diseases.”

FinCEN found the 12 most trafficked animals or species included reptiles; big cats; turtles; and commonly trafficked animal parts, like ivory. The illegal trade uses many of the same routes and methods as drug smugglers, the agency added.

“Common smuggling techniques include concealing items in personal bags and falsely identifying goods as legal wildlife or other products,” FinCEN said, which can range from a single live animal to multi-ton commercial shipments.

FinCEN last month called attention to what it has identified as a rising trend in environmental crimes, of which wildlife trafficking is one.

Aaron Nicodemus covers regulatory policy and compliance trends for Compliance Week. He previously worked as a reporter for Bloomberg Law and as business editor at the Telegram & Gazette in Worcester, Mass.

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