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Financial Services Law Insights and Observations

FinCEN says wildlife trafficking threatens financial system integrity

Financial Crimes FinCEN Of Interest to Non-US Persons Bank Secrecy Act SARs Anti-Money Laundering

Financial Crimes

On December 20, the Financial Crimes Enforcement Network (FinCEN) issued a Financial Threat Analysis concerning suspicious activity reports (SARs) related to wildlife trafficking trend information identified in Bank Secrecy Act (BSA) data. FinCEN identified wildlife trafficking as a major transnational organized crime involving “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 proceeds related to wildlife trafficking is estimated to be between $7 and $23 billion annually. According to FinCEN, traffickers damage the integrity of the financial system. FinCEN also stated that financial institutions play a critical role in “identifying wildlife trafficking and protecting the U.S. financial system from associated illicit finance through compliance with their BSA obligations.”

FinCEN stated that the issues with wildlife trafficking are: “(1) its strong association with corruption and transnational criminal organizations, two of FinCEN’s national anti-money laundering and countering the financing of terrorism priorities published in June 2021; (2) a need to enhance reporting and analysis of related illicit financial flows; and, (3) wildlife trafficking’s contribution to biodiversity loss, damage to fragile ecosystems, and the increased likelihood of spreading of zoonotic diseases.”