 We're going to now turn to a problem that seems to me, from my perspective anyway, be getting a lot more media attention than it has in the past, wildlife trafficking. It's certainly a huge problem, multi-billion dollar problem, the third highest trafficking in terms of volume after narcotics and weapons. So certainly a scourge for developing countries. We're going to hear from three experts right now. I'm going to ask Gretchen Peters, Jackson Miller, and Sarah Prey to come forward, please. Can everyone hear me? I feel a little bit like Oprah, and I have to tell you, I love it. I hope you guys are ready to talk about your childhoods in addition to wildlife trafficking. Good morning, my name is Sarah Prey. I'm the senior policy analyst for Africa at the Open Society Foundation. Thank you all for being here and thanks to GFI for inviting me to participate in this. I do have to correct the record. I'm not an expert on wildlife trafficking. These two are, but I am happy to shepherd the discussion. Just a brief word on where Open Society Foundation is coming to this issue. Some of you may be familiar with the Open Society Foundation, where a global grant-making and advocacy organization founded by George Soros, we operate all over the world in about 50 countries, focusing on governance, accountability, and the rule of law. Many of you know, sort of, our traditional entry into this space was around transparency and accountability, particularly around natural resources. We were one of the early funders of the publish what you pay movement, and I think the natural evolution has now been to increasingly focus on illicit financial flows, and for example, our fiscal governance program, which is a grant-making program, is starting to look a lot more at these issues, and some of our regional work, most notably our West African Foundation, has been partnering with GFI and doing some great work, so take a look at that. But without further ado, I think we'll turn to our discussion. I think that the hope of this panel today is to look at wildlife trafficking, to be sure, but also to look at it in the broader context of transnational crime and illicit financial flows, and how this particular issue is part of a much bigger puzzle, what those connections are, and in light of those connections, what are the ways forward and the policy prescriptions they're in. So I think you have their bios, but just briefly, Jackson Miller is going to kick us off, and then we'll turn over to Gretchen. Okay. Thanks. May I use? You go for it. All right. Hi. Good morning, everyone. My name is Jackson Miller. I'm the lead analyst for Wildlife and Environmental Crimes at C4ADS. We are a DC-based nonprofit, and we specialize in data-driven research and analysis on illicit networks worldwide. I use the term illicit rather broadly, as our past work has dealt with a wide range of issues from tracking Russian arms shipments to Syria via Ukraine, along with examining the nexus of natural resource constraints and terrorism in the Sahel. And for the past couple of years, we've been delving into the drivers of transnational wildlife and environmental crime. But first, before I start, I'd like to thank Global Financial Integrity for not only hosting such a great event, but for also dealing with my slew of emails at 2 a.m. last night as I tweak this presentation. But to kick it off, so the global trade in illicit elephant ivory, which is what I want to focus on today, flows through a rather long and complex supply chain, primarily from Sub-Saharan Africa to markets in Southeast and East Asia. And depending on where one is positioned along this supply chain, ivory can acquire a variety of use values. For example, in the poaching leg of the supply chain, in the heart of the African bush, ivory for the most part takes the form of bush currency, right? Simply bartered in exchange for poaching weapons, ammunition, or in some extreme cases food and other means of subsistence. Moving up the value chain, if you will, along the trafficking leg, ivory has also taken the form of a financial or an investment vehicle for speculation. In fact, our research has suggested the existence of privately held stockpiles across the African continent and Southeast and East Asia, where investors are hedging a continually rising retail price. And finally, on the consumption side, ivory is a pretty unique retail item, right? With a consumer base all over the world with a variety of markets. And as you can see, from aggregating a series of ivory retail market studies from scholars like Esmond Martin, Lucy Vine, Vincent Nigeman, Daniel Stiles, along with countless interviews with people on the ground across the African bush, you'll see a vast differential of retail prices. For example, the price that you'll see in an African bush market for a small carved ivory item such as a bangle or a necklace in a market like in Dele in the Central African Republic is only a sliver of the price that you may find in an African urban center like Kissinggani in the DRC, which again is an even smaller sliver of the final retail price that you'll see in an Asian consumer destination such as Beijing, where auction houses last year witnessed prices skyrocket to $2,100 per kilo. And what you're also seeing is a trade that's characterized by value of these ivory products being extracted and also accrued by and large by consumers that exist thousands of miles outside of the African continent, largely at the expense of those local populations living in close proximity to elephant ranges. And Gretchen's work, of course, brings this point home, but wildlife crime does often converge with other forms of conflict and illicit activities. And I think moving forward, I think we both would like to bring the point home that wildlife trafficking and wildlife crime really does not exist in isolation as a purely conservation issue anymore. I'd love to talk about more specific details of these instances offline or maybe in the Q&A. But from our past research, we have found evidence to suggest that Sudanese-linked militias are involved in the ambush of not only park rangers but also mass poaching incidents of elephants. We've uncovered evidence suggesting that South Sudanese police forces are crossing transnational borders into places like the DRC and Garamba National Park to also secure ivory from endangered elephant populations. We've read accounts of Congolese army commanders providing weapons to rebel groups in exchange for ivory and gold. We've worked alongside Gretchen's firm building out allegations linking illicit timber operations with bush meat poaching in Central and West Africa, along with uncovering the nexus between ivory and copper smuggling in Tanzania and diamond and ivory smuggling in Botswana. Now apart from the fact that wildlife crime may exist and may converge with a series of illicit economies, when ivory flows out of the African continent, it by and large obfuscates itself within channels of licit maritime commerce and finance. So our global ivory seizure database, which has logged approximately 800 seizures, unique ivory seizure instances since 2009, suggests that by and large the global ivory trade nestles itself in licit maritime shipping lanes. So we estimate that annually the vast majority of the global ivory trade flows in as few as 100 to 250 containers per year, along a mere handful of key choke point container ports, along the Sub-Saharan African seaboard, Southeast and East Asia, along shipping lanes managed by a mere 10 to 15 companies. And as we've seen, wildlife traffickers actually use a very, a wide variety of means of physical obfuscation to actually, to cover their operations, to transport 500 kilos or several tons of this contraband across geographic boundaries, across these illicit supply chains. So we've seen ivory covered in shea butter, videography equipment, charcoal, peanuts, and even containers themselves physically altered to hide this contraband. Now if you will indulge me, let me provide a more specific example of a network of large scale ivory seizures that are loosely linked through a single logistics and transport network and also to provide you guys a bit of insight into how we approach this issue as an issue of transnational organized crime. So let's start off with April 25th, 2015. Overd officials at Lam Chibang Port in Thailand, which is a port right outside of Bangkok, seized 3.1 tons approximately of ivory products, obfuscated in tea leaves originally from Mombasa, destined for a company in Vietnam. Now when this ivory shipment was about to be transported from Mombasa, the consignee or the receiver of the shipment was actually changed multiple times, originally from a Dubai-based trading firm to a Laotian-based company to again a Vietnamese based, a Vietnam based firm. Now digging into our data sets using a variety of company, using a variety of public records such as company registers, trade documentation, customs reporting, and also local media insight along with I guess eyes on the ground, we actually were able to find that the vehicles that are used to transport this ivory to the port of Mombasa, the container freight station of Mombasa along with the exporters all match those logistic profiles of a seizure of 3.7 tons across two containers seized in Singapore a mere weeks later on May 16th this year. Now this same exporter at least shipped probably six containers in the past calendar year. The three containers that have been seized at this point all contained multiple tons of ivory per container. So there is a likelihood that what if you want to estimate probably three tons per container being unseized, we're looking at nine to ten tons of ivory products completely making its way through global shipping lanes undetected. Now digging through our past data sets we've also noticed that other vehicles and other transport mechanisms also match those that have facilitated the shipments of at least three large scale ivory seizures from 2015 seized at very distinct points of the ivory supply chain in places like Mombasa, Singapore, and Hong Kong. And it turns out that the consigner of the specific Hong Kong seizure that's referenced here of 1.3 tons also had previously been arrested and subsequently acquitted for their role in attempting to ship illicit copper products from Zambia to Tanzania in 2011. Now right here we're looking at a network that probably trafficked over 14 tons of ivory products from the single logistic and transport infrastructure. If we want to assume an average test weight of 3.7 tons along with if we want to assume that this quantity seized here represents approximately 10% of the total contraband being trafficked as in this 10% seizure rate being accepted by a variety of Western law enforcement officials, we're looking at elephant products coming from approximately 18,000 to 19,000 elephants. If we want to assume further that the three containers that were unceased also contain similar quantities of ivory then we're looking at up to 35,000 elephants killed and whose ivory products being transported in the course of two years. Now 35,000 is the majority of remaining elephant populations in key elephant corridors such as Mozambique. Now scaling back a bit looking at the 14 tons and assuming a retail value of approximately 14 USD per kilo taking the mean of several of the most recent mainland Chinese retail studies along with Hong Kong retail market studies and Vietnam market surveys, you know this contraband could be worth up to $20 million. Now I presented this network briefly in July but since then some interesting developments have taken place. Whatever this Vietnamese based consignee that had been the final recipient of the seizure that happened in Thailand in April 25th. Well just this past month in August after tracing the beneficial ownership of this company in August 13th approximately 600 kilos of ivory were seized along with 142 kilos of rhino horn originally from Mozambique were seized in the port of Da Nang Vietnam also consigned to this same firm. Now although the Vietnamese business register is incredibly easy to navigate and is incredibly comprehensive and easy to digest in terms of extracting information on you know directors and ownership of the company this identifying information was actually very scarce and it turns out several of these companies labeled here were actually established probably in March or April of this year. Now this leads us to assume potentially the use of shell or anonymous companies or establishing these commercial entities for the sole purpose of receiving these shipments. Days later after this ivory rhino horn shipment was seized in Da Nang another 2.3 tons of ivory obfuscated in timber was also seized in the port of Da Nang not originally from Mozambique but this time originally from Lagos, Nigeria and then days later a five ton wildlife product shipment was seized again in the port of Da Nang consigned to a company according to Vietnamese customs of having I guess a variety of business relationships with this original Vietnamese based consignee. Now this five ton wildlife product shipment contained approximately one ton of ivory products and four tons of pangolin originally from Malaysia shipped to Vietnam. Now stepping back a bit what can we do moving forward you know what can we do as Westerners or as Americans how can we approach how can we pursue action against this wildlife trade that largely flows along a Sub-Saharan Africa Asian supply chain. Well we have found that wildlife traffickers often maintain multiple bank accounts across disparate jurisdictions and what we're looking at here is the sales contract from a lay ocean based trading firm trafficking hundreds of thousands of protected species to another trade based firm or a trading firm in Vietnam. Now the lay ocean based firm is owned by a Vixay Kaosavang a loud based wildlife trafficker who actually has a one million dollar reward from the state department for quote I believe any information leading to the dismantling of his network. Now Kaosavang like this Vietnamese firm may have a global network of facilitators and also wildlife trafficking counterparts. If we want to look at this issue of wildlife crime is purely a conservation issue what's most compelling about this contract is the sheer quantity of animals that are being trafficked right but for our interests here that's not really the most compelling information right the most compelling information is this section here in the sales contract that states bank account information. So there's a number provided for an account at the Loud Development Bank of Paxon branch. Service level reading of this may suggest that all right it's just the nearest local bank nearby however this bank itself has approximately a dozen foreign core and spondent banking networks five of which are US based institutions if we want to now and if we assume that the majority of transnational financial flows especially from African Asia are denominated US dollars there is a high likelihood that this transaction that this capital did clear through a US financial or a Western financial system giving that jurisdiction a clear mandate to investigate these financial transactions further and it's this these financial flows and investigating into these financial flows even further that may yield a grander impact on diminishing the capacity of these key facilitators to continuing the trade because figures like chaos of on figures like this Vietnamese trading firm they may be operating several if not dozens of did of ostensibly disparate supply chains and if we focus tackling the financial angle then we can severely diminish their capacity to continue this trade and really make a dent an actionable dent in the state of wildlife crime today so I know I went a little over over time but thank you guys very much for indulging me and I look forward to your questions all right good morning I'm going to say many of the same things that Jackson just said in his excellent presentation my objective when I became involved in tracking wildlife crime was to follow the money and to and investigate the logistical and financial operations that were underpinning the major networks that are moving wildlife predominantly were focused on elephants and rhinos being poached in Africa and trafficked to Asian consumer markets now I want to just start by asking a hypothetical question why are traffickers smuggling wildlife and the answer of course is to make money yet this very simple point seems to be lost on somewhere in the range of 95% of the conservation community we found a huge amount of attention is being focused on putting up fences around national parks and private reserves putting more park rangers out to protect wild animals across vast areas of wild space and when we start of wild territory and very there are virtually no groups almost besides C4ADS and our team that are actually trying to follow the money and understand logistically how these trafficking operations are set up and the reason that this is important there's a number of reasons why it's important and as Jackson just said it's an area where the U.S. and the U.K. whose currencies dominate global trade can really start to impact this problem I believe but it's also important because there are so many so much fewer actors at this level when we started looking in we had a project last year that got off the ground twice and then twice got got 86 by the South African government we were going to be working with the South African government to help follow the money around rhino horn trafficking twice at the very last minute our project was cancelled when some uneasy politicians in the ANC government that currently is in power in South Africa decided they didn't want American financial investigators looking into the problem as closely as we were planning to so our project got cancelled not once but twice I still have the piece of paper if anybody wants to see it mandating me to work with South Africa's financial intelligence center on rhino horn trafficking but it's not even worth the paper that it's printed on so we've had we've actually had quite a lot of challenges trying to get governments in Africa and Asia to open up their financial records to us and help and let us help them look for what's going on but we've nonetheless working in open source and working very closely with Jackson's team at C4ADS found some quite interesting information I'm going to talk a little bit about some of the links that we've put together but but it's really important to look at the financial flows around wildlife trafficking if we intend to save these animals. Seizing ivory shipments of ivory is something that happens after the animals are already dead. One of the things that we have learned over and over again in virtually all the countries that we have done research on this issue in is that poachers can generally not finance poaching by themselves just as an example the bullets that you use to hunt great game like elephants and rhinos cost as much as twenty to thirty dollars per bullet your average poacher if you recall back to Jackson's doughnut that he presented in the last in the last presentation the average poacher is paid a pittance they can't afford to buy they can't afford to fill the tanks of cars they can't afford to buy cars to actually drive out to the parks where they're poaching so it has to be financed by somebody and we believe that if we can help cut the financing the poaching will stop second of all we are we are finding that traffickers are using the wildlife traffickers are using trade based money laundering and I want to give a shout out to my friends Rob Subirsky and John Cassara in the corner here because we we are all trying to help people who want to understand how transnational organized crime works in the world you must understand the extent to which value is moved through the global transport system in the form of commodities so we will we will regularly encounter traffickers who are in South Africa or Mombasa or Dar es Salaam or Zanzibar who are moving you who are also working as used car traders who also have import export firms moving agricultural products moving used clothing they're running hotels casinos cash based businesses that they can use to launder their proceeds and also and sometimes those import export firms are actually used to move the illicit commodities but as often as not it is a they operate these firms as a way to bring things of value back and those are their profits and there's very little understanding of how those systems work and we believe we can help African governments and Asian governments understand better how those systems work third of all another important thing that we're learning is that the traffickers engaging in wildlife crime are not just moving wildlife in fact most of them what we're finding are predominantly narcotics traffickers in some places like South Africa and Mozambique we're seeing a huge convergence with human trafficking to give you a really evil an example of a really evil case of trade based money laundering we've here have reports of women being trafficked into Africa from Asia and rhino horn moving from Africa to to Asia so Asian women being brought as sex workers and the value that is put on them is sent in rhino horn out to Asia so no money actually change hands and I can also say the other broad conclusion we can make from the from the work we've done so far is that is that corruption is probably the elephants biggest threat in Africa we have we're looking at this problem in a number of different countries in some places and and and everywhere we're looking at corruption is the single most important enabling factor for getting ivory for getting elephants or rhinos or other animals killed and getting the wildlife parts out of the country it might this might be the Park Rangers who get paid off to help poachers identify where the animals are it might be customs officers taking a payment to let a to let a container go through and in some places that we're working or we're investigating the the state itself is the primary criminal actor in moving wildlife and they're not just moving wildlife we the convergence with other narcotics with other illicit products in particular narcotics but also weapons is is profound I want to go through I don't have much time so I want to go through some of the incredible convergence that we have found as we've looked at our as we've looked into the networks across the continent we have we're looking at East Asian traffickers both Vietnamese and Chinese operating in South Africa's Mozambique Zimbabwe Tanzania and Kenya these networks have been found to be linked through multiple through seizure records through phone records through police reports that we've had a chance to look at we've got a drug kingpin in Mozambique that we're looking at who seems to be moving tremendous amounts of rhino horn and ivory in addition to multi-ton consignments of narcotics we're looking at a trafficker in Tanzania who's linked to money laundering uranium smuggling and drug trafficking we're looking at jailed kingpin for ivory in Kenya who is also wanted by narcotics agents he was actually found hiding out when he was arrested he was found in the home of drug traffickers who were arrested in December by the Drug Enforcement Administration the team that logistics team that led that drove the containers of ivory that Jackson was talking about that was later seized in Thailand and Singapore that drove the containers of ivory out of the packing center and then diverted them and packed them full of ivory that team is also connected to those drug traffickers and the ivory trafficker in Mombasa we've also got trafficking networks out of Uganda that play a critical role in moving drugs guns and ivory through the center of the continent often moving drug or sorry drugs and ivory that is coming out of Central Asia sorry Central Africa the CAR Gabon and the Republic of Congo that are moving through these very sophisticated logistical operations in Uganda we're looking at Chinese road building and timber firms that are moving ivory under the cover of their regular commercial operations that are operating across Central Africa and in East Africa we've had great collaboration again on this pro on that research with C4ADS because they have many excellent Chinese speakers including our two attendees here today when we originally started looking at some of these Chinese timber firms they appeared to be 40 or 50 different companies when we start when they started doing the research into the ownership structure back in Hong Kong and Macau they found it was actually just three three companies it wasn't wasn't 45 companies it was just three of them they were owned by the same three sets of people so what looked like many many different operations were actually a much larger criminal enterprise out of China we're also whoops that all moved forward a lot faster than it was supposed to we're also looking at Lebanese and Nigerian traffickers moving goods by sea up the western coast of Africa they appear to be linked to drug trafficking networks moving cocaine heroin and weapons as well as probably people that we based on earlier information we believe they're also involved in people trafficking and the other thing that's interesting is that in police reports have have shown us that that seizures that have been made on both the east and western sides of the African continent have selectors in common so phone numbers addresses and so we believe that some of the networks that are moving these multi-time consignments of ivory of ivory off the African continent are actually operating on both sides of the continent now I teach about convergence and I teach about how how focused or how small these networks are at the transnational level but even I am surprised at the amount of connectivity we're seeing among all of these networks that are operating all over the African continent I really believe that if US law enforcement in the US intelligence community were to support an effort to go after these networks in a comprehensive way we would not only reduce a lot of problems and threats emanating from the African continent but it would actually be a fairly manageable number of targets to go after in a well in a properly resourced operation I think I'm out of time I'm just going to really go through very close this is really moving quickly all of a sudden we also have looked into seizure records and the connectivity between them again we were surprised by the extent to which big multiple seizures from multiple countries in Africa had important linkages there was a seizure that took place in November 2013 in Dar es Salaam data found there or evidence found there led authorities 11 days later to make a subsequent seizure in Zanzibar that led them to a network that operates out of now it doesn't want to go at all oh that led them to make a seizure later or that connected them to an earlier seizure that had been made in Malawi in 2013 and there are the whoops well I'm just going to make the point that there are also multiple connections between some of these major seizures that were made this year I also believe if we were to take the records from all of those seizures and this is an analytic project that has never been comprehensively done C4 ADS and us rely on the scraps that we can get African and Asian law enforcement to pass us or what has been put out in the news we believe that if this could be done at a law enforcement sensitive level working with our partners in those countries and we could overlay that data with data around weapons and narcotics seizures that have been made that we will start to really be able to hone in on these networks and on that I will finish thank you both you managed to lay it out in a slightly overwhelming way in that you know the problem is huge but also able to sort of narrow it down so that if we wanted to move forward I think you gave some practical solutions so I thank you for that so we only have about five minutes I know I have a question wanted to see if anybody in the audience did as well okay maybe Porter I'll just ask you to ask your question and then the gentleman behind you all asked mine and then you guys will have the last couple minutes to wrap up one question I have just a real quick one do you have local partners that you're working with or is this sort of a travel in get information head back here and then the gentleman behind you we definitely both both have local partners that we rely on completely it it takes a network to do something like this and we have partners both in Asia and in Africa and other parts of the world that we work with very closely I mean on a daily basis and thank God for Skype and WhatsApp we can we are in touch very regularly with our partners around the world right I mean we do our best also to rely as much as possible on official documentation and kind of hold ourselves to you know the highest evidentiary standard is possible before making any claims but of course and you know the jurisdictions that we're working with not all those records are digitized or available to us in Washington so we definitely rely on a variety of local a slew of local partners not just in the African continent but in southeast in East Asia as well and Dave our other wildlife crime analysts who's here we're coordinating with approximately 80 NGOs worldwide but also you know simply providing them analytical support as well so yeah Gretchen Jackson in your efforts to follow the money and value trails have you uncovered any links to Chinese underground financial systems networks such as you fight Qing flying money systems I've seen I've heard reports in Vietnam of consumers buying rhino horn using flying money to or they're asked to make a payment to order the rhino horn through through a Huala like or flying money like system and we see a lot of informal systems being used to transfer value and to and to pay people whether it's something like in Pesa in Tanzania or Kenya to to systems where people are paid in as as Jackson said in some sort of bush currency so they're paid in some commodity that provides them value so we do see that I would say we are really not anywhere nearly as far along as we would like to be in terms of comprehensively following the money as I said we had a deal earlier this year to be working with South Africa's Financial Intelligence Center we've been trying to negotiate agreements with other African governments but we you can't look at the money as you well know you can't follow the money unless you're working with the government and if you do you can I've had a number of times had people in Africa offered to sell me bank records but if we go and buy them then it doesn't become admissible it would ruin somebody's case so we have we we have been focusing our energy on trying to get a partnership with the with the government so we can start helping them to do and we have a background we are experienced to doing this we've are cleared to do it we so it's just finding that partnership and somebody who actually cares to to to pull the trigger and let us let us go to work maybe just a follow-up on that I asked you this yesterday in our prep call what what do you do when the government is complicit you know how do you approach it if you're operating in a country and you know it's clear that the that the illicit action goes all the way up to the top we what then is that when you have to rely on the international actors I personally think that at this point the the big traffickers in Africa will need to be pursued or targeted in a transnational operation probably led by the United States in the and the British governments I don't believe there's a single African government with either the judicial or prosecutorial capacity to to take on any of these networks and we've what few efforts we've seen to go after the high level traffickers have failed and mainly because there isn't the political will so I do think the US is going to have to play a larger role if if this government is serious about trying to save animals or even if they're not these traffickers are not only moving wildlife they ought to be taken out for the range of crimes that they're committing but but we're having but I don't think at this point it will be led by this is a problem that will be handled by African states on their own and there's a number of reasons for that but but largely it's a it's a question of lack of political will and in many cases where we're looking the state is the primary criminal actor and so you're certainly not good but but even you know I learned to do this stuff working in Afghanistan and Pakistan so I like to tell people that I you know learned about corruption right in the belly of the beast and it it even in incredibly corrupt environments you can find good people trying to do the right thing and we've been able to find really amazing people to work with in virtually every country we've been in so I don't have any doubt that this can this can be done it's just a question of some agency and government taking the lead on it and we don't have that yet we don't have that happening right and Sarah if I may jump in I think your question sort of compels or should compel everyone to think a lot more creatively about simply just the functional steps required to facilitate these kinds of illicit wildlife transactions right so rather instead of you know expending energies on you know targeting someone that may on the surface level seem untouchable what about you know the logistic capacity what about their access simply at these container choke points right correct both the Kenyan Revenue Authority along with the slew of Tanzanian rev Tanzanian maritime agencies all publish a list of both licensed and suspended freight forwarders clearing agents and exporters at major seaports like Dar es Salaam Mombasa and Zanzibar and all of those are available in the open source and so if we're seeing one or two freight forwarders or even a private container freight station for example in the Port of Mombasa constantly being used simply for their access you know that could be another way to approach simply just extracting the physical capacity to actually transport this contraband but I think we would have to get the financial community involved as well if we're going to go that routing we have seen over and over that the traffickers in Africa have the trafficking networks in Africa have been incredibly responsive and adaptive to law enforcement intervention or perceived law enforcement intervention and so that we have watched them shift the activities from Dar es Salaam to Zanzibar to Malawi and we're probably going to see a shift again soon because of all the activity that's been taking place in Mombasa and I believe that they have not been impacted because nobody's gone after their money the financing has remained in place and therefore they've just shifted their physical operations so last question and I know that we we have a couple more for the audience but if you'll indulge me the the US government both administration and Congress has attempted to take some policy measures and I'm wondering if y'all can talk about that I was at the Africa Brain Trust on Friday and Susan Rice mentioned wildlife trafficking in the context of you know the US working with African corruption so it was kind of under that subheading as it was when President Obama made his speech in Addis obviously we have the the national strategy for combating wildlife trafficking the Global Antipoaching Act from the US Congress you know Gretchen especially in light of what you mentioned where you know 95% of the community the conservation community at least necessarily doesn't get it it how do you see these policy prescriptions fitting in or not and then Jackson if you have any thoughts I think there's a number of ways in which the US government ought to look at this problem differently first of all it's not a conservation problem it's an organized crime problem and therefore when the US Congress designates money for this issue it should go to organizations that fight crime and not organizations that agencies within the government that do conservation I'm not saying there isn't a big job for for conservation agencies also and conservation groups globally but there really needs to be more focus and more funding for the people who fight organized crime and and who fight money laundering and that I believe has been under resourced and an unfocused aspect of this problem I also think that we have to stop stove piping these issues between drugs human trafficking wildlife trafficking guns smuggling because the traffickers are all working together so when we come to say the Drug Enforcement Administration and bring a pat packet of evidence about a trafficker and they say well we can't work with you because we're a one-mission agency that does drugs and we say well we don't care we're bringing you information about a drug trafficker that makes my head explode every time that happens we need our agencies to start looking at crime and crime networks and not you never see the drug traffickers say I'm not letting that guy carry my heroin he's a terrorist right and yet we'll we have agencies in our government who say well we handle terrorism not narcotics not organized crime it's impossible to divide these networks any longer they are engaged in a multitude of activities and our crime fighting agencies have to be as flexible and adaptive and multifaceted as their enemies are or we will fail powerful point checks and you get the last word no of course I mean so I couldn't agree more I think the most recent policy prescriptions aren't incredibly appropriate invitation to invite stakeholders that may not have realized that they have a tangible stake in wildlife crime and looking at it as an issue of transnational organized crime however I think you know you inviting so many new or ostensibly new stakeholders to the table unfortunately may also invite a whole new slew of bureaucratic processes and a whole lot of paperwork so I think in terms of each organization specific mandate and each organization's capacity I think as long as those channels of communication are kept open only then will we really see some pretty rapid intangible results other than that unfortunately I feel like we may risk being buried buried under a lot of paperwork so thank you I'm sorry we didn't get to your questions maybe I'll can have a coffee afterwards but please join me in thanking Jackson and Gretchen for our panel well thanks very much to our panelists Gretchen and Jackson and to Sarah for her very successful moderating of that panel what a fascinating discussion the detail is incredible great to hear from Jackson how beneficial ownership can be used the way it's used once you know the owners of companies you can actually track what they're doing Gretchen's comment about how whether some of these traffickers are moving guns or wildlife or or other illicit commodities reminds me of a conversation I had with a US Army officer about 10 years ago at the Central Command who was tracking gun running in Afghanistan and when I asked them how they found out where they're running the guns he said oh it's where they're running the drugs I said so you're seeing both at the same time and he said yes and I said so you're you're collecting both at the same time he said no no drugs is DEA we don't do that so it's it goes right to what Gretchen was saying it's gonna be looked at a holistic in a holistic way I think before we're gonna have any major impact on it