On 20 December, FinCEN advised a Financial Threat Analysis on wildlife trafficking threat patterns and trend information identified in Bank Secrecy Act (BSA) data.   The report aims to further inform efforts to combat wildlife trafficking and the associated movement of illicit proceeds, which are estimated to be between $7 and $23 billion per year and account for a quarter of all wildlife trade.  FinCEN said that it was calling attention to this threat 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
  • wildlife trafficking’s contribution to biodiversity loss, damage to fragile ecosystems, and the increased likelihood of spreading of zoonotic diseases.

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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