Using Closed Case Reviews in Financial Investigation of the Illegal Wildlife Trade

By Anne-Marie Weeden, Mark Williams, Cathy Haenlein and Elijah Glantz

  The importance of ‘following the money’ in illegal wildlife trade (IWT) investigations is increasingly clearly recognised, given the need to isolate ‘upstream’ criminal actors – higher-level threat actors who control and drive illicit activity – as opposed to the low-level, downstream offenders who can easily be replaced. In 2019, RUSI’s Organised Crime and Policing team, working with the government of the Lao People’s Democratic Republic (Lao PDR), pioneered a new technique in the environmental crime domain to support capacity building in this area: the use of multi-agency reviews of closed IWT cases – the Closed Case Method. Based on the pilot exercise’s success, this novel capacity-building methodology was subsequently adopted as a recommendation by the Financial Action Task Force, which urged affected countries to ‘undertake (multi-agency) case reviews of historic/closed IWT cases that focus on the unexplored financial elements of a case’, arguing that such reviews can identify typologies of IWT-related financial crime, develop risk indicators, and potentially reveal new leads. The RUSI team has since refined the Closed Case Method through multi-agency capacity-building workshops held in Malawi, Namibia, Uganda and Zambia in 2022–23. These workshops were designed and delivered as part of the RUSI project, ‘Case Closed? Using Historic Cases to Enable New Financial Investigations’, funded by the UK government under the Illegal Wildlife Trade Challenge Fund. This Whitehall Report summarises the lessons learned from this workshop activity, presenting a best practice guide for the use of closed case reviews to support financial investigation in IWT cases. This approach involves the retroactive analysis of previous IWT cases to identify fresh opportunities to gather and act on financial intelligence. The team’s methodology for using closed case reviews in capacity building can be broken down into three different stages: • First, the ‘research and preparation stage’ involves context-specific literature reviews, targeted stakeholder engagement, case criteria development, case selection and development of training materials. • Second, the ‘capacity building stage’ comprises delivery of multi-agency

workshops, involving baseline financial investigative skills training and small group case reviews, in which all relevant agencies are charged with re-examining the details of the case and developing missed opportunities to follow financial leads. 

• Third, the ‘learning and dissemination stage’ involves the development of red flags (risk indicators for suspected money laundering activity), the dissemination of financial intelligence to both the private and the public sector, and monitoring and evaluation.    

  RUSI Whitehall Report 4-23,  

London: The Royal United Services Institute (RUSI) 2023. 43p.