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Dirty Money and Wildlife Trafficking: Using the Money Laundering Control Act to Prosecute Illegal Wildlife Trade

April 2019

Citation: 49 ELR 10334

Issue: 4

Author: Vanessa Dick

The global community is awakening to the extent and sophistication of the illegal wildlife trade. With an estimated annual value of $5 billion to $23 billion, the seriousness of the problem increases when calculated with other illicit natural resource trade in timber and fish and totals more than $200 billion annually, ranking second only to international drug trafficking. The trade’s profitability depends on the existence of powerful transnational criminal networks connecting the supply, often in Southeast Asia and Africa, with consumer demand, largely in Asia, Europe, and the United States. Experts agree that efforts to stop wildlife trafficking must include disruption of the opaque global financial flows that propel and reward the traders. Existing money laundering statutes could serve as this disruption, but they are historically underutilized. This Comment explains the existing legal framework in the United States, one of the world's largest endmarkets for illegal wildlife traffickers, for integrating money laundering statutes into international wildlife trafficking prosecutions. It also unpacks the statutory and political weaknesses that are limiting this strategy’s effectiveness. 

Vanessa Dick recently graduated with an LL.M. in Environmental, Natural Resources, and Energy Law from Lewis and Clark Law School. She previously worked in Washington, D.C., on environmental policy, including as Deputy Director of Government Relations at World Wildlife Fund US.

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