On 18 November, a Notice from FinCEN was issued to call attention to an upward trend in environmental crimes and associated illicit financial activity.  FinCEN said that it was highlighting this trend because of:

  • its strong association with corruption and transnational criminal organisations, 2 of FinCEN’s national AML/CFT priorities;
  • a need to enhance reporting and analysis of related illicit financial flows; and
  • environmental crimes’ contribution to the climate crisis, including threatening ecosystems, decreasing biodiversity, and increasing carbon dioxide in the atmosphere.

The Notice provides financial institutions with specific SAR filing instructions and highlights the likelihood of illicit financial activity related to several types of environmental crime.  The crimes mentioned include – illegal logging, wildlife trafficking, illegal (IUU) fishing, illegal mining, and waste and hazardous substance trafficking.

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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