Untangling the Net: U.S. Fish and Wildlife Service Efforts to Target Internet Wildlife Trafficking

World – Official Newsletter of the Parties Issue 19

Wildlife law enforcement authorities worldwide have been battling Internet-based wildlife trafficking for over a decade. In the late 1990s, special agents with the U.S. Fish and Wildlife Service, Office of Law Enforcement, first started spotting online sale postings for items that ranged from live tortoises and waterfowl mounts to seal oil pills and frozen tiger cubs.

Ever expanding public access to the Web gives almost anyone anywhere the opportunity to be a 'player' in the illegal wildlife trade. The Internet clearly offers many advantages as a vehicle for international commerce and crime. Benefits to 'e-marketers' include speed of transaction and communication, options for anonymity and a customer base that encompasses virtually every corner of the globe. The features that make the Internet a valuable trading tool for wildlife traffickers are also, of course, some of the very features that make it difficult to police and a new and unique challenge for the Service and other wildlife law enforcement agencies around the world.

The Service is committed to protecting U.S. and global wildlife and plant resources from unlawful exploitation regardless of the means used to commit such crimes. As a law enforcement priority, the Service investigates all trafficking in protected species – including trade conducted via the Internet.

The agency’s law enforcement programme has responded to the increase in wildlife cybercrime by using Internet technologies in its intelligence gathering and investigations. Service efforts also include capacity building (so that enforcement officers are better equipped and better prepared to address 'e-crime') as well as partnerships – with other agencies, other countries, and even with 'e-business' itself.

Intelligence and investigations

The Service and other wildlife law enforcement agencies were quick to recognize both the impossibility and the limited pay-offs of attempting to investigate every Web posting that offers some potentially prohibited wildlife item for sale or trying to police the Internet 24/7. The volume of trade is too large, the turnaround too rapid, the scope of the Web too extensive, the global array of laws too varied and complex, and the enforcement resources needed too massive for such an undertaking.

As part of a 'smart response' strategy, however, Service intelligence analysts use an Internet targeting plan and 'triage' procedures to locate ads and other online sales activity, assess the species and possible violations, and dispatch that information to 'end users' that not only include Service officers in the field and international partners, but also members of the Internet community, such as the eBay Fraud Investigations team (with whom Service intelligence analysts and special agents have established a good working relationship). As a result of this strategy, the Service has seized numerous wildlife items being unlawfully sold via the Internet.

The Service also processes 'leads' regarding wildlife for sale on the Internet that are received from the public, non-profit organizations and other groups. Efforts also include monitoring Web sites and collecting and analysing data to identify the scope and scale of the trade, and to provide intelligence for use in channelling and coordinating Service investigations.

These efforts support both Service and global wildlife-crime investigations. For example, analyses of Web sales of Asian arowanas (which cannot be legally imported or sold in interstate commerce in the United States) allowed national coordination of casework across the country. As a result, investigators were able to avoid duplication of effort and better utilize their time and resources in addressing this trafficking. Last fall, information about sales solicitations for a primate skull was passed on to Cameroon, resulting in the arrest of an Internet scammer in that country.

Service special agents routinely investigate Internet wildlife trafficking, focusing on commerce in high-priority wildlife species such as those listed on CITES Appendix I or protected under the U.S. Endangered Species Act. In fact, use of the Internet by officers working 'undercover' has often proved key to cracking cases involving Web-based wildlife sales.

In a recent joint U.S.-Thai investigation, for example, investigators monitored and documented sales of elephant ivory on eBay and PayPal, including sales arranged by undercover officers to substantiate key subjects’ involvement in the smuggling network. In the United States, this effort resulted in Service seizure of dozens of raw ivory pieces and ivory products and the January 2010 felony indictments of a U.S. businessman and Thai national. The Thai defendant, in this case (which traced raw ivory being funnelled from Africa to Thailand for carving and sale to Thai and global customers), had already been charged in Thailand along with another individual for wildlife smuggling in November 2009. Continued work on the case led to a January 2010 raid on ivory shops in Nakhon Sawan Province, Thailand; the arrest of two ivory dealers; and the seizure of six whole, raw African elephant tusks weighing 32 kilograms and valued at more than USD 30,000.

In another recent ivory trafficking case involving undercover Internet buys, the Service worked with Her Majesty's Royal Customs in the United Kingdom to secure evidence needed to bring charges against a man in that country using e-Bay to sell elephant tusks, whale teeth and ivory products. A Service agent also went undercover on the Web to deal with and document the smuggling activities of a Japanese butterfly collector, whose 'wares' included rare specimens of CITES-protected species.

U.S. capacity building

Over the past decade, the Service has worked to improve its ability to detect, document and disrupt Internet-based wildlife trafficking. The agency’s Intelligence Unit itself was created and expanded during this time. Both Service investigators and intelligence analysts have completed training on cybercrime techniques, open source information gathering, officer safety on the Internet, collecting Web-based evidence, and related topics.

The Service added computer forensics staff at its wildlife forensics laboratory in Ashland, Oregon, and trained select officers across the country in the seizure and analysis of computers and electronic media to bolster investigative capacity in the field. In 2009, the law enforcement programme established a new support unit staffed by special agents with both computer forensic and high-tech investigative skills to further improve the Service’s ability to identify, retrieve, analyse and utilize 'e-evidence' of wildlife crimes.


From the beginning, partnership has played an important role for the Service in combating wildlife cybercrime. Service outreach to eBay, PayPal and other auction site owners, for example, has raised corporate awareness about wildlife conservation and secured the development of better guidance for site users, the removal of hundreds of postings and assistance in wildlife crime investigations. In fact, the recent U.S.-Thai ivory investigation described above benefited from corporate cooperation: a PayPal representative travelled to Los Angeles at company expense to provide testimony to a Royal Thai Police investigator who had come to the United States as part of the cooperative work on the case.

The Service has worked with the United Kingdom, Canada, Australia, New Zealand, Germany, Belgium, Cameroon and other countries to share information and pursue investigations. In 2009, the Service launched a joint Internet intelligence gathering project with Canada to identify CITES species for sale on the web, emerging trends, possible violations and major players. Service law enforcement staff work closely with the U.S. National Central Bureau-Interpol and the Interpol Wildlife Working Group. Agency intelligence analysts and special agents coordinate their efforts with other U.S. Federal agencies that deal with cybercrime.

Partnership is also critical to improving enforcement capacity at the national, regional and global levels. As a member of the North American Wildlife Enforcement Group, the Service helped plan and participate in a video-conference on Internet investigative techniques in 2006, and Service law enforcement managers and field agents met last November with their Mexican and Canadian counterparts to better coordinate investigative efforts. Service law enforcement staff have provided training on cybercrime investigations and Internet wildlife trafficking to officers with State wildlife agencies and U.S. prosecutors.

Last February, Service law enforcement and international affairs staff represented the United States at the CITES Secretariat’s cybercrime workshop in Vancouver, Canada. In November, the Service hosted a meeting of the CITES Law Enforcement Experts Group at its forensics laboratory, where Internet wildlife trafficking and the Secretariat’s findings and recommendations were among the topics discussed.

The Secretariat’s commitment to facilitating efforts to combat Internet wildlife trafficking is clearly a call for increased global cooperation. Expanded country-to-country communication, intelligence sharing, and investigative coordination represent one trend that is bound to continue – and bound to benefit wildlife worldwide.

Sandra Cleva
U.S. Fish & Wildlife Service
Office of Law Enforcement
4401 N. Fairfax Drive, MS 3000
Arlington, VA 22203, United States
Tel.: 1 703 358 1949
Email: Sandra_Cleva@fws.gov

Christina Thornblom Kish
U.S. Fish & Wildlife Service
Office of Law Enforcement
4401 N. Fairfax Drive, MS 3000
Arlington, VA 22203, United States
Tel.: 1 703 358 1949
Email: Christina_Kish@fws.gov