Environmental Investigation Agency, UK (EIA)  - Written evidence (ZAF0016)


  1. The Environmental Investigation Agency UK (EIA) is an international non-governmental organization headquartered in London committed to investigating and exposing environmental crime and campaigning for more effective criminal justice response to address such crime. EIA investigations and analysis have documented the role of organized criminal networks and corruption in wildlife and forest crime, and exposed the threat posed by wildlife and timber trafficking to the environment, national security and socio-economic stability. Operating for over three decades, EIA currently focuses on addressing illegal trade in elephant ivory, pangolins and Asian big cats.
  2. EIA has a wealth of knowledge and expertise in addressing a wide range of environmental and criminal justice issues concerning Africa and we hereby submit comments for consideration under specific Terms of Reference for the International Relations Committee Inquiry on UK relations with Sub-Saharan Africa.
  3. Illegal wildlife trade (IWT) is in the top 5 lucrative transnational crimes, worth up to £17bn a year globally, along with drug trafficking, counterfeit crime and human trafficking.[1] As well as threatening species with extinction, IWT also fosters corruption, feeds insecurity, and undermines good governance and the rule of law.[2] The EU-funded programme for Enhancing Africa’s Response to Transnational Organised Crime (ENACT) recently published a study which found that African countries display very low levels of resilience to the threat posed by organised crime.[3] The study also found that trafficking in African fauna is the second largest criminal market in Africa (after human trafficking).
  4. IWT is having devastating impacts on elephants, pangolins, rhinos, lions and other species in Africa. While more than 1.3 million elephants roamed Africa in the 1970s, today the population is estimated to be as low as 419,000 having experienced the worst decline in 25 years, mainly due to escalation of poaching in 2006.[4]
  5. As the world’s most trafficked mammal, pangolin populations globally are experiencing major declines driven by demand for their scales and meat from consumers across Africa and Asia . Since 2008, there has been a dramatic increase in the inter-continental trafficking of pangolins from Africa to Asia. Between 2016 and 2019, an estimated 585,000 African pangolins were seized in illegal trade, which represents 65% of overall trade by number of pangolins[5]. In 2019, the conservation status of two African pangolin species (giant ground pangolin and white-bellied pangolin) moved from ‘Vulnerable’ to Endangered on the IUCN Red List.[6] The updated assessment concluded that habitat loss, poaching and trafficking from Africa to Asia are the three major drivers of African pangolin population decline.
  6. The trafficking of both African savannah and African forest elephants, and pangolins across their range in Africa is perpetrated by sophisticated trans-national organised criminal networks, often led by Chinese or Vietnamese nationals, which exploit corruption, weak legislation and lack of law enforcement in key African countries. The security concerns associated with wildlife trafficking have also been exacerbated with increasing links to militia and rebel groups in Africa. A joint study published by INTERPOL and other organisations in 2018 concluded that ivory trafficking is likely to be a source of funding for the Lord’s Resistance Army and other militia groups operating in the Democratic Republic of Congo and Central African Republic, and the  Sudanese  Janjaweed  and  other  horseback  gangs operating across Sudan, Chad and Niger.[7]
  7. EIA commends the UK for its leadership in tackling IWT at a global level by: adopting one of the world’s strongest ivory bans through the UK Ivory Act; hosting the London Conferences on Illegal Wildlife Trade in 2014 and 2018; providing significant aid under the Illegal Wildlife Trade Challenge Fund; providing financial support for the implementation of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES); and supporting other international initiatives such as the Global Tiger Initiative and the United for Wildlife’s Transport and Financial Task Forces.
  8. EIA strongly recommends that the UK strengthen its leadership role by prioritising wildlife and forest crime in developing future UK-Africa relations. This would be in line with the priorities identified in the Joint Communiqué on the African Union-United Kingdom Partnership which includes commitments to strengthen  resilience across Africa and to promote  and  protect an  equitable and  inclusive rules-based  international  system and co-operation  on  global  issues  such  as  climate  change and serious organised crime. This approach would also help achieve the United Nations Sustainable Development Goal 15 which includes a global commitment to halt biodiversity loss”, and to further strengthen implementation of CITES, an international treaty adopted by the UK as well as 53 African countries (covering nearly the whole of Africa except Sudan and Western Sahara).
  9. Further, at the continent level, there is a recognition of the urgent need to address wildlife trafficking in Africa. In 2015, the African Union developed the African Strategy on Combating Illegal Exploitation and Illegal Trade in Wild Fauna and Flora in Africaacknowledging that illegal trade in wildlife “is no longer a conservation issue alone, but is undermining security and wider sustainable development.”[8]

UK priorities in managing the relationship with Sub-Saharan Africa

  1.         EIA urges the UK to ensure that reducing wildlife and forest crime is a priority in the relationship with Sub-Saharan Africa. In particular, EIA recommends that the UK prioritise:

Encouraging and supporting Sub-Saharan African countries to strengthen the response to wildlife and forest crime

  1.         Organised wildlife trafficking groups perceive ivory and other wildlife trafficking as a high profit-low risk crime. Despite this, the application of a comprehensive multi-sectoral response to wildlife crime remains negligible. For example, across source, transit and  destination  countries,  financial  investigation  tools  are  not  used routinely to tackle wildlife crime.[9]
  2.         EIA research and investigations indicate that some organised criminal networks have shifted their operations to West and Central Africa to traffic in the more profitable African Forest Elephant ivory (numbering far fewer than the African Savannah Elephants). However very little domestic and international-level intelligence led effort is being made in this region to stop the continuing massive scale of illegal wildlife products being trafficked to Asian markets. For example, Nigeria is currently the world’s largest export hub for illegally traded ivory and pangolins with a vast amount of illegal wildlife products leaving Nigerian ports undetected.
  3.         EIA investigations also confirm our growing concern about poaching of allegedly “secure” elephant populations in southern Africa, particularly in Botswana, Namibia and Zambia. There is an urgent need for Southern African countries to acknowledge the threat posed by ivory (and other wildlife) trade to their elephant populations and to take appropriate action.
  4.         There has been an increase in ivory processing in Africa, particularly since it is easier to smuggle smaller carved items from Africa to Asian markets. There is also increasing convergence between ivory trafficking and pangolin trafficking, as well as illegal trade in other wildlife and timber species ranging from rhinos, big cats and hippos, to marine species such as seahorses and sea-cucumbers. The growth of Traditional Chinese Medicine (TCM) in Africa is also a potential threat bringing processing and consumption closer to the source not only of Africa’s wildlife, but also non-native species for which there is no legal protection (e.g. tigers and jaguars that are farmed for their body parts).
  5.         EIA recommends that the UK engage with Sub-Saharan African countries to take concrete steps towards strengthening bilateral/multilateral cooperation with key governments to tackle critical trade routes and conduct intelligence-led investigations along the wildlife trafficking trade chain, particularly Angola, Botswana, Cameroon, Democratic Republic of Congo, Gabon, Tanzania, Malawi, Mozambique, Nigeria, South Africa, Uganda, Zambia and Zimbabwe. A number of these African countries have already undertaken independent assessments of key gaps in their response to wildlife trafficking; the UK could provide support to address such gaps.[10]
  6.         EIA recommends posting law enforcement officers in UK embassies abroad with the mandate to liaise with national law enforcement agencies on wildlife and forest crime, particularly in those countries playing a key role in wildlife trafficking. Other countries such as the United States of America and China have had significant success in working closely with African counterparts to disrupt organised wildlife trafficking networks.[11] While the UK does currently provide training and capacity building support in several African countries such as Angola and Malawi, these efforts should be expanded to develop into active collaborative partnerships with key enforcement authorities in Africa targeted with disrupting wildlife trafficking.
  7.         It was with the UK government blessing that the United for Wildlife Transport Taskforce and Financial Action Taskforce was set up. EIA recommends that the UK provide support to enable Sub-Saharan African countries to investigate illicit finance flows associated with wildlife crime and to address the role of the transport sector in wildlife trafficking. The UK should advocate the use of existing legislation to look at illicit financial flows associated with wildlife crime and call for amending legislation where there are gaps.

Encouraging and supporting transparency and anti-corruption initiatives in Sub-Saharan African countries to combat illegal wildlife trade

  1.         Corruption is a key enabling factor at every stage of the ivory and other IWT trafficking chain: from game rangers who provide information on patrol patterns and the location of elephant herds, police officers who rent out weapons and transport ivory and other wildlife, customs officers who allow shipping containers of ivory and other wildlife to flow out of the country’s ports, to protection provided by high-level government officials.
  2.         Corruption is exacerbated by the threat posed to civil society freedoms in many African countries which in turn undermines the significant role that can be played by civil society organisations and local media to raise the alarm on corruption and government excesses. Sub-Saharan African countries with poor media freedom include Cameroon, Democratic Republic of Congo, Tanzania, Uganda, Zambia and Zimbabwe.[12] According to the Transparency International Corruption Perceptions Index Sub-Saharan African countries have been identified as some of the most corrupt countries in the world and include countries that play a key role in wildlife trafficking such as Angola, Cameroon, Congo, Democratic Republic of Congo, Mozambique, Nigeria, Uganda and Zimbabwe.[13]
  3.         EIA’s investigations in Africa have documented the wide-spread role of corruption in facilitating wildlife crime. For example, EIA’s “Vanishing Point” report exposed how corruption was one of the main factors for Tanzania losing over half of its elephant population to poaching from 2009-2014.[14] Tanzania’s government is suppressing any civil society opposition to a massive hydropower project which will likely destroy one of Africa’s largest protected wildlife areas in Tanzania which is also a renowned UNESCO World Heritage Site.[15]
  4.         EIA recommends that the UK government anti-corruption strategies, funding and support for strengthening governance frameworks abroad takes into consideration the critical role of corruption in enabling wildlife and forest crime. Further, EIA recommends that the UK prioritise a continuing leadership role to strengthen implementation of United Nations Convention against Transnational Organised Crime and United Nations Convention against Corruption and ensure they are better applied to combat transnational organised crime and corruption associated with wildlife and forest crime. Given that the key African countries implicated in wildlife trafficking are Parties to both UN Conventions, the UK could encourage better utilisation of these existing mechanisms in tackling wildlife trafficking.
  5.         EIA recognises that the UK is a party to the Aarhus convention and encourages the UK government to promote the role of civil society in environmental protection globally and empower civil society organisations in sub-Saharan African countries.

Leveraging the role of the UK as a major donor in Africa

  1.         The UK government plays a significant role in providing aid to Africa. For example, the UK government has provided over £23 million funding for 75 projects through the DEFRA “Illegal Wildlife Trade Challenge Fund Project”. EIA recommends that the UK government continue to provide funding through this fund to sustain and increase the capacity of organisations working to protect wildlife threatened by trade, including in Africa.
  2.         The significant financial and technical support being provided by the UK in Africa also offers an opportunity to target some of the pressing issues related to IWT. For example, a number of projects funded by the UK support initiatives to reduce demand for ivory and other wildlife products. EIA recommends that the UK leverage such support to encourage national laws and policies to include comprehensive bans to prohibit trade in wildlife that are threatened by poaching and trafficking. In this regard, the UK could play a key role in urging African countries to treat wildlife trafficking as a serious organised crime and to recognise that lethal consumptive use of wildlife is not the appropriate approach for species that are significantly threatened by illegal trade.

Received 14 January 2020



[1]DEFRA. 2019. Illegal Wildlife Trade Challenge Fund Project Funding. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/811381/iwt-project-list-2019.pdf


[3] ENACT. 2019. Organised Crime Index Africa 2019. https://ocindex.net/assets/downloads/enact_report.pdf.

[4] IUCN. 2016. African Elephant Status Report.

[5] Challender, D. et al (2019) Chapter 16 - International trade and trafficking in pangolins, 1900 – 2019. In Biodiversity of World: Conservation from Genes to Landscapes, Pangolins.

[6] EIA. 2019. Illegal trade pressure on pangolins pushes three species further up the risk register. https://eia-international.org/news/illegal-trade-pressure-on-pangolins-pushes-three-species-further-up-the-risk-register/

[7] RHIPTO -Norwegian Center for Global Analyses, INTERPOL & the Global Initiative Against Transnational Organized Crime. 2018. World Atlas of Illicit Flows. https://globalinitiative.net/wp-content/uploads/2018/09/Atlas-Illicit-Flows-FINAL-WEB-VERSION-copia-compressed.pdf

[8] African Union. 2015. African Strategy on Combating Illegal Exploitation and Illegal Trade in Wild Fauna and Flora in Africa. Available from: https://au.int/sites/default/files/documents/33796-doc african_strategy_strategy_africaine_au.pdf

[9] RUSI. 2017. Follow the Money: Using Financial Investigation to Combat Wildlife Crime. https://rusi.org/sites/default/files/201709_rusi_follow_the_money_haenlein.keatinge.pdf

[10] International Consortium on Combating Wildlife Crime (ICCWC) in Action. https://www.cites.org/eng/prog/iccwc.php/Action

[11] Global Initiative. Civil Society Observatory of Illicit Economies in Eastern and Southern Africa.

[12] Reporters Without Borders. https://rsf.org/en/ranking#; European Research Centre for Anti-Corruption and State-Building. 2019. Index of Public Integrity. https://integrity-index.org/?yr=2019.

[13] Transparency International. 2019. Corruption Perceptions Index 2018. https://www.transparency.org/cpi2018

[14] EIA. 2014. Vanishing Point - Criminality, Corruption and the Devastation of Tanzania’s Elephants. https://eia-international.org/report/vanishing-point-criminality-corruption-and-the-devastation-of-tanzanias-elephants/

[15] Xinhua net. Tanzania's ruling party warns int'l organizations against meddling with country's internal affairs. http://www.xinhuanet.com/english/2019-11/28/c_138590710.htm; The Citizen. Anyone against Stiegler's Gorge project will be jailed. https://www.thecitizen.co.tz/news/Anyone-against-Stiegler-s-Gorge-project-w/1840340-4575212-ijgpjz/index.html