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.. 15.: ?35nag-ii11ACKNOWLEDGEMENTS

CONTENTS

July 2017
This report would not have been possible without
the generous funding and support of Save the
Elephants and Wildlife Conservation Network’s
Elephant Crisis Fund, the Oak Foundation, Kindy
French, Stephen Stone, Vulcan Inc., Paul G. Allen
Family Foundation and The Rufford Foundation.
EIA also wishes to thank its numerous other
supporters whose long-term commitment to the
organisation’s mission and values helped make
this work possible.

3

FIRST ENCOUNTER IN 2014

6

THE MOZAMBIQUE MEETING IN 2016

9

THE 2016 PEMBA IVORY SHIPMENT

15

LINKED IVORY SEIZURES

16

SWITCHING SOURCES: NIGERIA

All currency conversions are approximations.
1 US Dollar = 6.83 Chinese RMB

18

LESSONS FROM THE SHUIDONG SYNDICATES

This report was produced by the Environmental
Investigation Agency (EIA).

19

MAP: ROUTE OF THE PEMBA IVORY SHIPMENT

21

RECOMMENDATIONS

© Environmental Investigation Agency 2017
All images are © EIA unless otherwise stated.

Report design: www.designsolutions.me.uk

LOCATIONS OF SHUIDONG TOWN AND MAOMING CITY IN
GUANGDONG PROVINCE, CHINA

Putian

Maoming City

Maoming City
Shuidong
62/63 Upper Street, London N1 0NY, UK
Tel: +44 (0) 20 7354 7960
email: ukinfo@eia-international.org

www.eia-international.org
EIA US
P.O.Box 53343
Washington DC 20009 USA
Tel: +1 202 483 6621
Fax: +202 986 8626
email: usinfo@eia-international.org

www.eia-global.org

COVER IMAGE:
Aerial photograph of Shuidong,
Guangdong province, China.

© Google Earth

ENVIRONMENTAL INVESTIGATION AGENCY (EIA)

Shuidong

 SUMMARY
Surprising many, and putting other countries to shame, China has taken significant
steps to close its legal domestic ivory market in the past year. This is a positive
move by a country with one of the biggest ivory markets and demonstrates
leadership and pragmatism. However, there remain serious questions on the lack
of enforcement in China, and abroad, against Chinese nationals deeply involved in
the illegal ivory trade, who continue to operate with complete impunity.
Following on from leads gathered in
Tanzania in 2014, the Environmental
Investigation Agency (EIA) began
investigating neighbouring Mozambique,
a country whose elephant population
has been devastated by poaching and
the illegal ivory trade.

Over the course of more than a year,
discussions with the traffickers gave an
unprecedented insight into the methods
used to source, ship and sell raw tusks,
and to manage profits. They provided
fascinating detail on the significance of
Shuidong in global illegal ivory flows.

What followed was beyond anything
EIA could have anticipated.

Since supplanting Chinese gangs from
Fujian as the main raw ivory traffickers
more than a decade ago, the Shuidong
syndicates have remained untouched
by any enforcement action in China or
abroad. Although some ivory shipments
have been intercepted, the only loss is
financial and the groups have developed
various mechanisms for limiting this risk.

The investigation in Mozambique
revealed a Chinese-led criminal
syndicate which for over two decades
has been trafficking ivory from Africa
to Shuidong, its hometown in southern
China. According to this syndicate,
it is just one of about 10 to 20 similar
groups originating from Shuidong.
Their criminal exploits reveal how
their small hometown has become,
and remains, the world’s largest hub
for ivory trafficking: the group claims
up to 80 per cent of tusks from
poached elephants in Africa pass
through Shuidong.

By being flexible and adaptable, the
Shuidong syndicate is relentless in its
pursuit of profit from wildlife crime.
With the profitability of tusks from East
Africa falling, the Shuidong smugglers
have moved into more profitable forest
elephant ivory and pangolin scales.
When enforcement improved in

Tanzania, they shifted to neighbouring
Mozambique. Their relentless criminal
activities continue to be a major factor
in the ongoing slaughter of elephants
and other wildlife across Africa.
Without enforcement action against
organised criminal networks, elephants
and other wildlife will continue to be
threatened by the illegal wildlife trade.
The Shuidong syndicates in China and
Africa need to be investigated and
prosecuted urgently. Continued
inaction against groups such as these,
undermines China’s announcement to
close its legal domestic ivory market
and will render it futile in the fight
against elephant poaching.
Specific policy and enforcement
recommendations are included at the
end of this report.
Actionable information from this
investigation has been shared with
the relevant enforcement authorities.

2

 20 minutes the car pulled up outside a
two-storey house in a remote location.
Waiting to greet the buyers was Wang,
the third member of the trafficking
group. The buyers were taken into the
house and shown into a side room.
A light was switched on to reveal large
elephant tusks laid out for inspection.

ABOVE:
Billboard seen at Bohe town
next to Shuidong, which
reads ‘Building a strong and
comprehensive anti-smuggling
frontline’.

THE SHUIDONG CONNECTION
It was past midnight on a night in
October 2016 when the prospective
ivory buyers arrived at the outskirts
of Shuidong, in China’s Guangdong
Province, to view a cache of tusks
recently arrived from Mozambique.
The journey had begun in the centre of
Shuidong, home to the criminal group
which had trafficked the tusks.
At an earlier lunch meeting, two
members of the group, Xie and Ou, had
met with the buyers to vet them one
final time. Satisfied they were genuine,
the sellers agreed to arrange a viewing
but it could not take place until the early
hours of the following day as the tusks
had to be moved to a secure location.
Late in the evening, Ou collected the
buyers and they began their journey
along narrow, winding roads. After

CHINA’S ROLE IN IVORY TRADE AND POLICY RESPONSES
The statements made by this criminal network on the volumes of
ivory it trades, and the deep-rooted connection of Shuidong to
the global ivory trade, help to confirm what many have known
for a long time – that China is the global centre of demand for
elephant ivory and the world’s main destination for illegal ivory.1
China recently took laudable steps to close its legal domestic ivory market.2
After announcing it would implement a ban and close its domestic ivory
market by the end of 2017, China has since followed through, closing 67
licensed ivory workshops and retailers in March 2017, with the remaining
105 to be closed before the end of the year.3 This has, quite rightly, been
labelled as a ‘game changer’; China’s licensing system was open to abuse
and illegal ivory was routinely being smuggled into its domestic markets.4
However, despite a historical involvement in sourcing ivory from Africa that
stretches to nearly 20 years – and allegedly accounting for up to 80 per
cent of the country’s ivory imports – there has not, to EIA’s knowledge,
been a single notable arrest in this region of China.

3

A discussion on price, payment terms
and advice on transporting the tusks
to the buyers’ warehouse followed.
The traffickers were looking for a quick
sale so the profits could be reinvested
in another consignment of ivory from
Africa. After promising to consult their
boss and get to them the following day,
the prospective buyers were driven back
into town by Ou.
The buyers immediately left Shuidong
and drove off, keen to leave the area as
soon as possible. They were undercover
investigators from EIA and had no
intention of buying the tusks – they
had just successfully infiltrated the
shadowy world of the Shuidong ivory
syndicates.

FIRST ENCOUNTER, 2014
EIA began investigating the role of the
Shuidong syndicates in the illegal ivory
trade after a chance encounter in
Tanzania in September 2014. At that
time, evidence was emerging of the
shocking scale of elephant poaching in
the African country; it lost 60 per cent of
its elephant population between 2009-14.5
Evidence from ivory seizures indicated
that Zanzibar in Tanzania had emerged
as a significant ivory trafficking hub,
ferrying tusks from elephants poached
in southern Tanzania to markets in
East Asia.6 In August 2011, a
consignment of 1.9 tonnes of ivory tusks
concealed in dried fish was intercepted
in Malindi Port, Zanzibar, bound for
Malaysia. Two years later, an even
bigger seizure of 2.9 tonnes of tusks,
hidden among seashells and bound for
the Philippines, occurred in the port.
In both cases, local freight agents were
arrested but there was scant information
on the identity of the leaders of the
smuggling syndicates.7
Sources in mainland Tanzania told EIA
investigators that the main ivory
smugglers operating in the country came
from a town called Shuidong in China’s
Guangdong Province – and that these
individuals were in the sea cucumber
trading business in Zanzibar.

 EIA travelled to Zanzibar and eventually
met with Shuidong native Wei Ronglu,
a sea cucumber trader who had been
based there since 2011. Wei was at first
evasive but later talked at length of the
methods used by Shuidong syndicates to
smuggle ivory.

FROM SEA CUCUMBERS TO
IVORY – SHUIDONG’S ROLE:
1990s ONWARDS
Wei explained that in the 1990s, the
trafficking of ivory from Africa was
controlled by criminal groups originating
from Putian, in China’s Fujian Province,
before being replaced by the Shuidong
syndicates. As a result of this shift,
Zanzibar, where the Shuidong sea
cucumber traders congregate, had
become the “biggest hub in Africa
for ivory trading”, shipping tusks out
from Tanzania, Kenya and Mozambique
under the cover of legal marine
product businesses.8
Located on the coast of Guangdong
Province, Shuidong’s emergence as
the world’s biggest hub for wholesale
ivory trading is rooted in its culture and
geography. Administratively, it falls
under Dianbai County, a district of
Maoming City which has a population
of almost eight million people.
The area is known as a trade centre
for a range of marine products
including fish maw, lobsters and squid,
with Shuidong specialising in sea
cucumber trade.

With their growing knowledge of doing
business in Africa, experience of supply
routes back to China, presence in
strategic coastal towns and their
business cover, the Shuidong traders in
East and West Africa were well-placed
to move into the illegal ivory trade.
They were ready to take advantage of
China’s demand for ivory, which grew
rapidly in the late 1990s.
Cultural factors have also played a role.
Unique to the Maoming area, people
from Shuidong speak a dialect which
originated from the Putian area of
neighbouring Fujian Province. As one
of the main ivory carving centres in
China,9 Putian is the chief market for
raw ivory tusks smuggled by the
Shuidong syndicates.

BELOW:
In places such as Tanzania, the
sea cucumber business acts as a
cover for the illegal ivory trade.
Sea cucumbers are a prized
delicacy in China.

Shuidong’s geographical location
is also advantageous to its role as
China’s main raw ivory trading
hub. To the east lies Hong Kong,
one of the world’s busiest ports
and an important transit route for
bulk ivory shipments. To the west
lies Guangxi Province, which
shares a porous border with
northern Vietnam where the port
of Hai Phong is another frequent
transit route for ivory. To the
north-east lies Fujian Province,
one of the biggest ivory processing
areas in China.10

Harvested for over a thousand years,
sea cucumbers are seabed-dwelling
marine animals found throughout the
world’s seas and oceans. They are
prized in China for their high protein
content and supposed health benefits.
Until recently,the bulk of sea
cucumbers consumed in China came
from regional waters. As a result of
China’s economic growth, there has
been a rapid increase in Chinese
demand for sea cucumbers sourced
globally, including from East Africa.
Dominated by Shuidong people, an
international network has sprung up to
supply this booming market. From the
1990s onwards, growing numbers from
Shuidong fanned out across Africa
searching for sea cucumbers and fish
maw, with key hubs including Mwanza
and Zanzibar in Tanzania, Mombasa in
Kenya and Lagos in Nigeria.
4

 Wei described a closed network,
with syndicate leaders in Shuidong
orchestrating shipments of tusks
arranged by people from their hometown
who were based in Zanzibar as sea
cucumber traders. The syndicate
members on the ground were extremely
cautious, protecting themselves by
building a network of Tanzanian
accomplices; they avoided contact
with the ivory and ensured only the
names of their local co-conspirators,
employed as freight agents, appeared
on shipping documents.

Apart from ivory, the
Shuidong group also trades
in a variety of endangered
and illicit wildlife products,
including pangolin scales,
rhinoceros horns and totoaba
maws. All images are from
this investigation

OTHER SPECIES TRADED BY THE GROUP
EIA: Do you often go to Africa?
XIE: Yes, I’ve been going … for many years.
EIA: Oh, you’ve been there a lot? What do you do there?
XIE: Before I did sea cucumbers … shark fins ... those things.
Now, it’s not possible to do that anymore.
EIA: If that can’t be done, what do you do then?
XIE: Now ... we just do this... I do ivory, pangolin scales.
At this level in an illegal wildlife trade chain, there are rarely specialists
who trade exclusively in, for example, ivory. Traders instead seek to
exploit legal loopholes, poorly regulated transport and logistic networks,
and weak enforcement to trade in multiple threatened species.
The Shuidong syndicate fits this pattern. As well as elephant ivory, the
group also trades in pangolins from Africa and Asia, totoaba fish maws from
Mexico, rhino horn from Africa and has previously traded in sea cucumbers
from Tanzania. It is unknown where the group was trading shark fins. It is
able to move rapidly from one group of species to another and the main
factor driving the decision to trade or not is, of course, profit.
During the course of this investigation, EIA has witnessed the group shifting
its operations from savannah elephant ivory to forest elephant ivory and
pangolin scales. Pangolin scales are becoming increasingly attractive as an
investment as they are cheaper to source and less risky to smuggle; the
profit margins are higher than for either type of ivory. These pangolin
scales are being traded to dealers and traditional Chinese medicine
producers in China, who then sell them on to pharmaceutical companies.
5

Wei revealed that it took up to three
years to build such local networks.
Local Tanzanians were tasked with
sourcing the poached tusks and
storing ivory safely at locations on
the mainland until a load of about
three tonnes had been collected.
The contraband would then be
transported to Zanzibar on small
vessels and stored at warehouses
for packing in a container, concealed
in legitimate and low-value goods
such as seashells, plastics or
agricultural products.
Shipment would also be handled by
the trusted Tanzanians, as would
payments of about $70 per kg of ivory
to customs officers and port officials to
ensure safe departure. Even with these
extensive safeguards in place, Wei said
the Shuidong smugglers would observe
the loading of the container onto the
designated vessel from a vantage point
overlooking the port. At any sign of
trouble, the Chinese would be prepared
to leave Tanzania immediately.
Such careful planning and execution
ensured that the vast majority of ivory
consignments left Zanzibar unimpeded.
Wei estimated that only one in every 20
shipments was intercepted and spoke of
a single Shuidong syndicate which had
successfully smuggled out 20 containers
of ivory in 2013 alone.
Wei even offered EIA’s investigators
the opportunity to invest in an ivory
consignment. He would be responsible
for the Zanzibar end of the shipment
and for arranging a meeting with his
“brothers” in Shuidong to discuss the
financing, estimating that a payment of
$1.3 million would be sufficient. He said:
“Over here, we will be responsible for
collecting the goods. Our friends in
Guangdong, our brothers, will be in
charge of receiving the goods and selling
them. When the time comes, the profit
will be transferred to you.”

 THE MOZAMBIQUE
MEETING, 2016
In April 2016, EIA investigators
travelled to Mozambique on a
fact-finding mission. As enforcement
against elephant poaching and ivory
smuggling in neighbouring Tanzania had
gradually improved, and with a series of
high profile cases and prosecutions of
Chinese nationals, it was rumoured the
traffickers were switching their
attention to Mozambique.
In the port town of Pemba, in northern
Mozambique, EIA encountered a
group of three Chinese nationals.
An important industry in the region
is the timber trade, which Chinese
companies dominate; the presence of
Chinese nationals in Pemba was
therefore unsurprising. What did stand
out, however, was their unique dialect –
they were from Shuidong.
During initial conversations, the three
stated their reason for being in Pemba
was to sell aluminium window frames

and to look into sourcing sea cucumbers
and lobsters. This seemed implausible,
given the group had flown all the
way from Guangzhou via Nairobi to
reach Pemba.
Over the course of five days, EIA
developed a rapport with the three
Shuidong people: all in their thirties,
they introduced themselves as Ou
Haiqiang, Xie Xingbang and Wang
Kangwen. They were also accompanied
by an unidentified Tanzanian national
who drove a black sedan car with a
Tanzanian number plate. Every day
the group would leave early with the
Tanzanian, returning to the hotel late
in the afternoon.
As time passed, they began talking
about wildlife trade, especially ivory,
but denied being directly involved in
the business, although Ou eventually
admitted to having done ivory deals in
the past while based in Tanzania.
After departing Mozambique, EIA
investigators maintained contact with
Ou and Xie, slowly winning their

BELOW:
The three ivory traffickers in a
hotel in Pemba, Mozambique.

6

 confidence until they met again in
Shuidong and then later in the Chinese
city of Shenzhen.
Over time, the traffickers explained their
history in the ivory trade. Ou first visited
Uganda and Tanzania in 2008 to trade
fish maws, with Xie arriving in Tanzania
around the same time to trade sea
cucumbers. Both speak passable
Swahili, testament to the time they
have spent in East Africa.

BELOW:
(From top to bottom)
Xie Xingbang, Ou Haiqiang,
and Wang Kangwen.

It emerged that Ou and Xie were second
generation ivory smugglers. Their
uncles had been part of the first wave of
Shuidong people to move to Africa in the
early 1990s. Xie’s uncle, Xie Yingjue,
went to Tanzania and Mozambique
around 1990 to collect sea cucumber;
he went on to become a major ivory
trafficker for the next two decades and
in 2008 invited his then-jobless nephew
to join him in Tanzania. Working with a
Tanzanian, Xie’s uncle became rich from
ivory and built one of the most luxurious
mansions in Shuidong, retiring about
2012 just as major ivory seizures started
increasing. By this time, Xie had learnt
the trade and taken over his uncle’s
business contacts, including the
expansion of his interests in Pemba.
Xie forged an alliance with the nephew
of the Tanzanian accomplice – this was
the unidentified Tanzanian accompanying
the three Shuidong traders in Pemba in
April 2016.

Ou also described his uncle, Ou
Guanchao, as an experienced ivory
smuggler, successfully running ivory
trafficking routes from several African
countries and becoming extremely
wealthy in the process. Married to a
Vietnamese woman, Ou’s uncle prefers
to send ivory shipments into China
via Vietnam. As a joint investor, Ou
collaborated with his uncle in a series
of ivory shipments from Tanzania
around 2012. The shipments were routed
via Vietnam and four containers were
successfully sent to Shuidong, providing
a profit of approximately $8 million for
Ou. His luck changed in 2013 when two
containers were seized in Hai Phong and
Zanzibar in quick succession. His uncle
insisted that Ou bear the entire loss of
about $5 million and the two never
cooperated again.
Ou had previously been arrested twice in
Tanzania but on both occasions paid his
way out of trouble. Moreover, he was
involved in another shipment of ivory
which was seized in Singapore in 2015
after being shipped from the Kenyan
port of Mombasa. The seizures and
arrests marked the end of Ou’s ivory
trading activities in Tanzania and
disrupted his preferred trafficking
route via Vietnam: by 2015, however,
he and his partner Xie were looking
for new opportunities and routes,
and switched operations to Pemba
in Mozambique.

SHUIDONG GROUP CASE STUDY: ORGANISED CRIME CHARACTERISTICS 1,2,3
Provision of high-quality lawyers and (attempted) corruption of judicial process
Financial investment in start-up
Sophistication of smuggling techniques and routes
Use of persons of high political or social status
Previous convictions for other types of crime
Use of mules or couriers
Huge profits
Multiple shipments
Corruption
Money laundering
Collaboration with other organised groups
Geographic scope and influence
Use of intelligence to defend against law enforcement and rival groups,
and to identify new targets
Diversification of activities
Cohesion (financial relationships, length of association and geographic origins)
Use of fake or front companies

P
P
P
P
P
P
P
P
P
P
P
P
P
P
P
Possibly

1. Composite based upon the characteristics from the following sources and excluding overlapping categories: CITES Secretariat. 2005. Presentation to
CITES Silk Road Enforcement Seminar at Urumqi, China.
2. United Nations (UN) Economic and Social Council. Illicit trafficking in protected species of wild flora and fauna and illicit access to genetic resources:
Report of the Secretary-General. Commission on Crime Prevention and Criminal Justice Twelfth session, Vienna, 13-22 May 2003. E/CN.15/2003/8.
https://www.unodc.org/documents/commissions/CCPCJ/CCPCJ_Sessions/CCPCJ_12/E-CN15-2003-08/E-CN15-2003-8_E.pdf
3. Royal Canadian Mounted Police. 2010. SLEIPNIR Version 2.0 Organized Crime Groups Capability Measurement Matrix. Ottawa.

7

 THE DECLINE OF ELEPHANTS IN MOZAMBIQUE AND TANZANIA
Mozambique and Tanzania have played a critical role in supplying ivory to criminal networks. Forensic
analysis of several large ivory seizures confirmed that the two countries were major sources of illegal
ivory.11 Over a five-year period (2009-14), Tanzania lost 60 per cent of its elephant population and
Mozambique 53 per cent.12 These were two of the worst recorded population declines of savannah
elephants in Africa based on surveys in 2014.

Tusks from elephants
poached in Mozambique,
2012

The cross-border Selous-Niassa ecosystem, spanning
south-eastern Tanzania and northern Mozambique, once
had a large elephant population.13 However, it experienced
a devastating decline and lost an estimated 75 per cent
of its elephants between 2004-14, primarily due to
poaching.14 Forensic analysis of seizures identified it as
an important source of illegal ivory.15 UNESCO declared
the Selous Game Reserve a “World Heritage Site in
Danger” because of the widespread poaching.16
Poaching levels in 2015 remained high in the SelousNiassa ecosystem – more than 70 per cent of the
elephants found dead were illegally killed.17 More
elephants are being killed each year than are being
born. These high poaching levels will cause the local
extinction of elephants if not halted and reversed.
The deadly ivory trade has reduced once-significant
savannah elephant populations, exceeding 100,000
elephants in the Selous in the 1970s, to fewer than
20,000. It can only be hoped this decline is stopped
before elephants disappear forever from these iconic
landscapes in eastern Africa.
8

 ABOVE:
Pemba port, Mozambique, 2012.

Ou told EIA:
“Frankly, it’s easier
to do this business in
Mozambique … it’s
easier to operate. In
Tanzania, don’t even
think about it.” Xie
later added: “We’re
able to move anything
through Pemba.
Everyone there has
been bought.”
9

THE PEMBA SHIPMENT: 2016

Each of the Shuidong group had a
defined role in the operation:

Detailed discussions provided an
unprecedented insight into an active
ivory smuggling ring and the methods
used to source, ship and sell raw tusks
and manage profits. Ou and Xie described
how they came to be involved in the
criminal enterprise and gave fascinating
detail on the methods used to traffic
ivory and the importance of their
hometown in global illegal ivory flows.

• Ou Haiqiang: investor, with a
50 per cent share in the consignment
and also responsible for arranging
buyers back in China;

After the initial encounter with the
three Shuidong ivory traffickers in
Pemba during April 2016, EIA
maintained regular contact and met
with them back in their hometown in
June 2016, the first in a series of
meetings. Back on their home turf,
Ou and Xie were more confident and
open. They revealed their real reason
for travelling to Pemba was to inspect
three tonnes of elephant tusks and
oversee the packing, loading and
payment procedures. It had been Ou’s
first visit to Pemba, while Xie had been
there once before while working for
his uncle. Ou said: “It was the first time
we had met you. I didn’t dare tell you
much or discuss these things. Now we
are back in China, I can tell you
whatever I want! Over there, I didn’t
want to say too much. I went over there
to move the goods out before returning
back here.”

• Wang Kangwen: representative for a
Hong Kong-based businessman
known only as “Nan-Ge”, or “elder
brother Nan”, who invested the other
50 per cent.

During the following months, EIA
gradually won the confidence of the
Shuidong traders until being invited to
inspect the Mozambique tusks in China
in October.

• Xie Xingbang: employed as a fixer by
Ou to coordinate collection of the
ivory because of his long-standing
association with the Tanzanian
national accompanying the group;

The decision to travel all the way to
Pemba from China to inspect the tusks
prior to despatch was informed by an
earlier shipment from the town in 2016,
also co-financed by Ou and Nan-Ge.
On that occasion, they contacted a
Mozambican supplier and placed an
order for 3.5 tonnes of tusks. The
supplier discouraged them from
conducting a physical inspection,
claiming it would be too risky for him to
have Chinese people visit his warehouse.
Full payment was transferred prior to
shipping, but when the load arrived it
weighed only 2.9 tonnes and 100kg
were of poor quality. As Ou had
introduced the Mozambican supplier,
he conceded the better-quality tusks to
Nan-Ge; Ou was left with poor quality
ivory and lost money on the deal.
The experience did not deter the group
from trying again. Improved enforcement

 in neighbouring Tanzania had cemented
their resolve to find new sources and
trafficking routes. While in Pemba, Ou
told EIA: “Frankly, it’s easier to do this
business in Mozambique … it’s easier to
operate. In Tanzania, don’t even think
about it.” Xie later added: “We’re able
to move anything through Pemba.
Everyone there has been bought.”

returning late in the afternoon. During
the inspection phase, they chose 2.3
tonnes from the assembled three tonnes,
discarding 700kg as low quality or too
small – the tusks were from very young
elephants. The chosen tusks were
then moved to a secure warehouse in
Pemba and packed for shipping in a
40-foot container.

For the group’s second shipment out of
Pemba, they opted to employ Xie’s
trusted Tanzanian associate to collect
the tusks and liaise with a different
Mozambican supplier. Contacts on the
ground confirmed to EIA that the
Tanzanian is a frequent visitor to the
area and is known to associate with a
group of local elephant poachers.

According to Xie, the choice of “filler” or
legitimate goods to conceal the ivory is
key and based on products that will not
arouse suspicion at the point of export
or import. The nature of the consignee’s
business is also an important factor as
this appears on the shipping documents.

An order for three tonnes of tusks was
placed, with an advance payment made
to the local suppliers in Mozambique
and Tanzania to fund the collection
process. The initial payment was half
of the cost of the consignment, a fee of
$300 per kg. This was referred to as
the “Bill of Lading” price. It covered
payment of around $80-100 per kg of
ivory to the local poachers, funds to
buy arms and ammunition, food for
poaching trips and bribes for police
and customs officers.
All local payments are made in US dollars,
with the group using Chinese black
market moneychangers based in Dar es
Salaam, Tanzania and Pemba. Money is
paid in Chinese renminbi into designated
accounts in China and transferred to the
local moneychangers who then provide
the cash for collection in dollars. While
deposit amounts vary depending on
relationships between traders, for this
three-tonne order of tusks the deposit
would have been $450,000, with the
balance paid once the Bill of Lading for
the shipment was received. Xie referred
to the role of the local accomplices as
a “dragon service”, encompassing
everything from collecting the ivory to
paying off customs officers.

For the Pemba shipment, the group
opted for grey plastic pellets, weighing
a total of 21 tonnes and worth about
$10,000. This was because the
co-investor from Hong Kong, Nan-Ge,
owns a plastics products factory based
in Shunde, Guangdong, which produces
items such as buckets made from
pellets. With a track record of importing
plastic pellets into Hong Kong, neither
the paperwork nor the destination of the
consignment was likely to raise any red
flags under customs risk assessment
procedures. The choice of filler is so
important that Xie had to source the
plastic pellets from a factory in Dar es
Salaam, since they could not be sourced
in northern Mozambique.

BELOW:
A copy of the PIL Bill of Lading
for the shipping container of
2.3 tonnes of ivory from Pemba
to Hong Kong. Key details of the
container, including the sender
are concealed.

By April 2016 the Tanzanian accomplice,
working with the Mozambican supplier,
had gathered the requested three tonnes
of ivory from elephants poached in
southern Tanzania and northern
Mozambique. The Shuidong group
boarded a flight from Guangzhou and
travelled to Pemba to oversee the final
stages of selection, packing and
shipping, arriving in town on April 6.
Every morning for two weeks, the group
left town with the Tanzanian driver,
10

 The routing of the container is another
vital factor in minimising the risk of
interception. Direct transport from
Africa to China is considered too great
a risk, so transit ports are used to
disguise the origins of the shipment.
As Xie explained: “The goods can’t come
directly from Africa. They must first go
to Singapore or elsewhere. There must
be a transit point. If they came directly
from Africa, they would definitely check
the container.”

BELOW:
Smugglers prefer to communicate
sensitive information using
WeChat due to its anonymity.
Here, one of the smugglers, Xie,
asks if the customs clearance
agent EIA uses is capable of
getting the plastic pellets that
they normally use as fillers.

Another tactic is to “switch” the Bill of
Lading for the consignment during the
journey. This method further hides the
origin of the container and conceals the
identity of the sender and recipient.
The role of complicit freight agents
involved in submitting documents for
customs clearance along the route is
also important in successfully moving
the container to its final destination.
Ivory smugglers who have set up
trustworthy routes with accomplices at
every stage are said to “own the road”.

For the shipment out of Pemba, the
Shuidong group planned to use the port
of Busan, in South Korea, as the main
transit point and where the Bill of
Lading would be switched. They
explained how the route was “owned”
by Nan-Ge, who had used it on five
previous occasions to smuggle
contraband wildlife. Shuidong traffickers
such as Ou often demand guarantee
deposits of about 70 per cent of the
wholesale market value for customs
clearance of containers; in the case of
the Busan agent and this container,
however, no guarantee was given. The
reason Ou agreed to this was because
Nan-Ge was a 50 per cent joint investor.
Another key factor was the involvement
of a Chinese freight forwarder operating
in South Korea who specialises in
arranging onward shipments of
containers holding illegal wildlife
products and even offers different rates
depending on the species, ranging from
$45 per kg for pangolin scales to $145
per kg for ivory. The export from Pemba
was to be arranged by another trusted
freight agent, the same Mozambican
who had worked with Xie’s Tanzanian
associate to collect the ivory.
By April 23, the tusks were packed in
the shipping container and Xie had
received the Bill of Lading from the
Mozambican agent. Such was the
confidence of the suppliers’ ability to
export the investment securely, all
agreed that should the shipment be
seized, the Mozambican and Tanzanian
suppliers would compensate the
Shuidong group for the full cost of
the container.
The remaining balance owing to the
local accomplices for the “dragon
service” was paid and the Shuidong
group flew back to China to await
delivery. On April 25 at Pemba port,
the container was loaded onto the
vessel Kota Hakim, owned by Pacific
International Lines (PIL) shipping
company. On the Bill of Lading the
contents of the 40-foot container, also
provided by PIL, were described as
“960 bags of plastics”. The port of
delivery was listed as Busan.
Yet despite the meticulous planning a
problem occurred along the route – not
as a result of enforcement action but
due to problems with the freight agents.
After passing through the ports of
Mombasa, in Kenya, and Singapore
unhindered, the container arrived at
Busan in late June. The intention was

11

 ENFORCEMENT GAPS
Ivory traffickers rely on the active cooperation or exploitable ignorance of people from a variety of
professions – a vital support network which includes corrupt rangers, customs officers, shipping
agents, money changers, lawyers and local fixers.
The paperwork from a seizure can support further investigation.
Following the interception of an ivory consignment in
Thailand in 2015, African and Asian enforcement networks
met and developed leads from the shipping documents.18
Investigations spanning six countries resulted in the
arrests of Government and shipping officials in Kinshasa,
Democratic Republic of the Congo.19
In 2014, the ‘fee’ to ensure non-inspection of cargo by
customs in Tanzania was said to be $70 per kg.20 Following
containerisation, shipping agents also play a central role –
either through active conspiracy or lack of due diligence
processes. Zanzibar’s quick cargo clearance and feeder
lines to Asia have enabled Shuidong smugglers to traffic
large quantities of ivory to China, while the names of many
freight agents from the island also appear regularly on
shipping paperwork in place of the true cargo owners.21,22
In the aftermath of a seizure, freight agents are often
early targets for enforcement enquiries, but with varying
outcomes. In Togo, a shipping agent was sentenced to two
years in prison and fined CFA 25 million ($42,000),23
whereas in Malaysia, despite its well-known role as a transit
country,24 there have been no convictions related to any
seizures of maritime ivory cargoes in recent years.25
After one of the Shuidong group’s shipments concealed in
tea was seized in Singapore, the identified freight forwarder

for the crooked freight agent to issue a
new Bill of Lading, which would break
the route, and move the container on to
Hong Kong. But the shipping agent in
Pemba had made a crucial mistake in
the original paperwork, listing Hong
Kong as the ultimate destination rather
than Busan.
This aroused the suspicions of the PIL
office in Busan because the route via
Busan between Singapore and Hong
Kong did not make sense; the company
refused to ship the container to Hong
Kong. This resulted in the container
being moved to a secure location in the
port and the contents reloaded into a
new container for delivery to Hong Kong
by another shipping line. During this
process, the freight agent employed by
Nan-Ge realised the consignment was in
fact ivory tusks and not pangolin scales
for which he had received a lower fee.
Nan-Ge had to fly out to placate the

was sanctioned $5,000 for failing to exercise due
diligence,26 which appears to be Singapore’s maximum
sanction for similar cases.27 The Singaporean authorities
later crushed the seized ivory;28 around the same time as
the Shuidong traders were coordinating their next ivory
collection in Nigeria.
Shipping lines are also open to abuse. In 2016, the
Shuidong group used the Singaporean shipping line Pacific
International Lines (PIL) to transport its Mozambican
shipment; ivory traffickers shipping from Mombasa in 2013
also used the same line.29
Criminals make use of financial services to pay for poaching
and ivory collection and for cargo logistics, sometimes in
instalments. State-owned and commercial banks may have
limits on international transfers as a preventative measure
against money laundering and some are in the process of
developing risk indicators for wildlife trafficking.
The Shuidong group therefore uses wire payments via a
Tanzania-based money changer to help finance poaching.
Payments for the successful delivery of a shipment of ivory
are made directly into a bank account in China in cash,
thereby side-stepping bank warning systems. Financial
investigation techniques, which identify money flows,
lifestyle and legal assets connected to such criminal
enterprises, are currently under-used methods.

agent and pay him the proper smuggling
fee due for ivory.
After the unexpected delay, the
repacked shipment finally reached
Hong Kong in mid-July; customs cleared
what appeared to be a routine shipment
of plastic pellets from South Korea.
The container was stored in a warehouse
owned by Nan-Ge until an opportune
moment arose to move it into the
mainland. By late September it had
finally arrived in Shuidong, having
been shipped from Hong Kong to
Shanghai. Ou picked it up himself
and drove it south.
All shipments of ivory tusks successfully
smuggled by the Shuidong syndicates
eventually reach their home base for
secure storage while buyers are contacted.
According to Xie and Ou, most of the
purchasers come from the main ivory
carving centres of Putian and Xianyou
12

 THE NEED FOR TARGETING LARGE-SCALE IVORY TRAFFICKING

Shuidong to view the tusks and pay the
agreed amount in cash. According to Ou,
the average sale price for good quality
tusks was about RMB5,000 ($750) per
kg, compared to RMB10,000 ($1,500)
at the height of illegal ivory seizures in
2012. For the Shuidong syndicates,
their role in smuggling ivory tusks
across international boundaries and into
China is a lucrative speciality, with a
consignment of three tonnes netting a
profit of RMB20 million ($3 million)
during the peak years of the trade.
The price agreed and payment made,
the Fujian buyers would load the tusks
into a fleet of SUVs for onward transport.
Xie estimated that buyers make a profit
of RMB500 ($75) per kg selling the
tusks onto carving factories.

ABOVE:
Much of the illegal ivory that
enters China makes its way to
Xianyou in Fujian province,
where it is carved into finished
products. The above photo was
taken in Baxia village in Xianyou
in August 2013.

in Fujian Province. Ou boasted of being
well known among the underground
network of illicit ivory traders in Fujian
and of having a long client list. These
traders are usually informed of incoming
ivory shipments in advance, with sales
normally completed within four days of
arrival. Generally, the Shuidong
smugglers sell only wholesale amounts
in tonnes and not smaller volumes.
Once alerted to the arrival of new
materials, the Fujian traders travel to

13

In October 2016, EIA’s investigators
were invited to Shuidong to view the
ivory tusks which had recently arrived
after the long journey from Pemba. Ou’s
motivation for breaking his usual habit
of dealing only with a closed group of
buyers from Fujian was his desire to
arrange a quick sale so he could
reinvest some of the profits in another
consignment of ivory. This practice of
continuous ‘recycling’ income from one
sale into another load of tusks ensures
a virtually continuous flow of goods
and indicates the scale of smuggling in
which the Shuidong traffickers are
involved. Xie also revealed that the
group’s usual buyers from Fujian

 already had considerable stocks in hand
and so were not interested in the Pemba
tusks at the asking price.
Upon arrival in Shuidong, EIA
investigators met with Ou and Xie for
lunch and one more round of vetting.
Ou and Xie initially appeared pensive at
the prospect of bringing outsiders into
their trusted circle but gradually relaxed
and, convinced a lucrative deal would
take place, agreed to an inspection.

The group entered the darkened house,
moved into a lit side room where the
tusks were stored and got down to
business. Ou explained he had moved
500kg of the best quality tusks from the
previous location and Wang confirmed
that none of the 2.3 tonnes shipment
had yet been sold. The tusks were laid
out on the concrete floor: there were
approximately 100 whole tusks, ranging
from 90-120cm long.

Initially planned for early evening, the
viewing was postponed until after
midnight due to a family bereavement
in the house where the tusks were
stored, necessitating removal to another
location. At about midnight, Ou finally
picked up the EIA investigators from
Shuidong, insisting for security reasons
they all travel in his vehicle rather than
follow behind in their own.

Ou wanted a price of RMB5,100 ($750)
per kg for the good quality tusks but
was willing to sell the entire 2.3 tonnes
from Pemba at a reduced cost of
RMB4,000 ($580) per kg: a total of
more than $1.3 million dollars. Wang
assured the prospective buyers that if
they bought the tusks it would be safe to
transport them out of the area to other
locations in southern China.

As the group travelled to the outskirts
of Shuidong, the town lights gave way
to pitch dark. All the passengers could
tell was that they were driving through
an area of forestland, along increasingly
narrow and winding roads. After a
20-minute journey, they arrived at
Baishitang. Exiting the car outside a
two-storey house, the investigators
were surprised to be greeted by Wang
Kangwen, who they had not seen since
their first encounter in Pemba in April.
It appeared Wang also had family
connections to the village since some of
his relatives were keeping watch outside.

Wang claimed he regularly moved ivory
between Shuidong and the city of
Shenzhen and had never experienced
any problems, explaining that he
routinely used a regular Toyota family
van and advising which roads were
preferable for the journey to Shenzhen.
He even offered to escort the ‘buyers’
for part of the journey, saying he was
98 per cent confident of success.
As Ou had earlier said, in 20 years of
ivory trading there had been no
incidents of ivory being seized by
authorities in the Shuidong area.

BELOW:
In October 2016, after months
of negotiation, EIA investigators
finally convinced Wang and Ou to
show them part of the 2.3 tonne
ivory shipment they had
arranged back in April 2016.

14

 IVORY SEIZURES LINKED TO THE SHUIDONG GROUP

1

2

3

1

2.4 TONNES OF TUSKS
seized in Hai Phong, Vietnam,
October 22, 2013, concealed with
seashells

Consignment believed to originate in Zanzibar, Tanzania. Transported via
Malaysia to Hai Phong.
Consignee: Cong Ty Co Phan Hoang Gia Exim. Container was due to be
re-exported to China via the Lang Son border crossing. Two other seizures of
ivory concealed by seashells occurred at Hai Phong Port around the same time.
No known arrests connected to this case.

2

2.9 TONNES OF IVORY
seized in Zanzibar, Tanzania,
November 13, 2013, concealed
with seashells

Believed to be linked to the Hai Phong seizure (above). Container due to be
loaded onto PIL vessel Kota Hormat and shipment bound for the Philippines.
Consignor: Island Sea Food Co Ltd, Mtoni, Zanzibar
Consignee: Trison Trading, Cebu, Philippines
Six individuals in Zanzibar linked to the attempted export arrested. Prosecution
on-going. Two Chinese suspects fled Tanzania.

3

3.7 TONNES OF IVORY
seized in Singapore in two
containers, May 19, 2015,
concealed with tea leaves and
shipped from Mombasa

The Shuidong group told EIA investigators that the container was going to be
inspected because of an earlier seizure of ivory tusks in Thailand which had
also departed from Mombasa and was concealed with tea leaves. “We had
people in Singapore, a customs clearance company … we were told that the
container had to be opened … that containers carrying tea leaves from Kenya
Mombasa … all had to be opened.”
Consignor: Almasi Chai Kenya Ltd, 92217-80100, Mombasa, Kenya
Original consignee: Keshav Traders, Dubai, UAE
Final consignee: FAF Flying Transportation Pte Ltd, Singapore
In Singapore, the freight forwarder was sanctioned $5,000 for failure to
exercise due diligence. In connection with the linked Thai case, at least nine
individuals were charged in one case in Mombasa under six laws and assets
frozen,30 with further arraignments reported;31 cases on-going.

15

 SWITCHING SOURCES
A few months later, Ou contacted EIA
again, offering a consignment of tusks
from Nigeria; they must have sold the
ivory smuggled from Pemba. At the time
of the viewing in October, Ou had
revealed his plans to switch sourcing
from East Africa to Nigeria, saying he
needed to transfer RMB2.5 million
($365,000) across to his contacts there
to begin collecting a new batch of tusks
from the region.
The main reason for the change in
operations was the diminishing
profitability of trafficking ivory from
East Africa (savannah elephants).
According to the Shuidong group,
“yellow materials” from West and
Central Africa (forest elephants) can be
sold for an average of RMB6,000 ($900)
in China, compared with RMB5,000
($750) for the best quality “white” or
savannah ivory.
According to the traders, four years
previously, “white” ivory could fetch
RMB10,000 ($1,500) per kg; while still
profitable, by early 2015 they were
looking at RMB7,000 ($1,000).

“YELLOW MATERIALS ... THE PRICE IS MUCH HIGHER”
The Shuidong syndicate made several mentions of “yellow”
ivory or materials from West and Central Africa, stating this
ivory could be sold for nearly $900 per kg in China. This is
$150 more than the price for “white” ivory from East and
southern Africa.
Traffickers made a clear distinction between the two types, describing
the different colour and shape of “yellow” ivory and its source in Africa.
This ivory is most probably from forest elephants, which are found only in
the tropical forests of West and Central Africa.
Nigeria and Cameroon were mentioned as two countries where forest
elephant ivory could be obtained. Both have experienced massive
declines in their elephant numbers32,33 so it seems likely that this ivory is
being sourced from forest elephant populations in the nearby countries
of the Central African Republic, Gabon and the Democratic Republic of
the Congo.
Forest elephants number far fewer than the better-known savannah
elephants of eastern and southern Africa.34 Also threatened by the loss
of tropical forest, any increase in the trade of forest elephant ivory will
have a significant impact on the survival of this species.35
The operations of this and connected criminal networks in West and
Central Africa are a direct threat to this species.

Although the costs of sourcing and
logistics on the ground were broadly
similar – the Bill of Lading price in
Nigeria was $340 per kg during June
2016 compared with $300 in
Mozambique – the group was unable to
force the supply price down in East
Africa, so Ou turned his sights towards
Nigeria. By early 2017, the Bill of
Lading costs in Nigeria had fallen to
$300 per kg.

To smuggle out of Nigeria, Ou had
forged a new partnership with two
Chinese from Fujian who were based in
Lagos. One of them had a main business
supplying rosewood timber out of Africa,
providing a useful cover for ivory
smuggling. Ou explained that as well as
owning a timber yard, that they had
access to a facility where ivory tusks
could be safely stored.

© Daniel Willcox 2017

Given increased enforcement effort and
the high-profile arrests and prosecutions
of Chinese nationals in their former
sourcing area of Tanzania, lax
enforcement and corruption in Nigeria
was another reason for the change.
Speaking of the events in Tanzania,
Ou said: “In East Africa, only in
Mozambique can these things still be
moved out; it’s not possible in any other
place. West Africa is easy.”

16

 © Getty Images

Pemba. Ou claimed Nan-Ge had lied to
him over the fee for the freight agent
in South Korea, cheating him out of
RMB1 million ($145,000). Ou and
Wang would collectively invest
50 per cent in the shipments out of
Nigeria, with the associate from Fujian
investing the other half. Xie was not
involved because his contacts and
suppliers are limited to East Africa;
however, he received a fee of
RMB450,000 ($65,000) for his role
in the Pemba shipment.

TOP:
Due to a price drop in savannah
elephant ivory in China, the
smugglers turned their attention
to forest elephant or “yellow”
ivory. Xie sent the photograph of
this yellow ivory that was being
collected by the Shuidong
traders in Nigeria to convince
EIA investigators to jointly invest
in their operation.

ABOVE:
Lagos port, Nigeria.

17

Ou claimed to have built good financial
relationships with customs officers in
Lagos port; once the ivory tusks were
ready to be shipped, corrupt customs
officers would come to weigh them,
charging a fee of $30 per kg to ensure
the container was not inspected.
As part of his Nigerian venture, Ou
also recruited Wang as a partner.
Ou was in dispute with the Hong Kong
businessman Nan-Ge over the problems
encountered in Busan during the
transport of the ivory consignment from

In addition to ivory tusks, Ou also
planned to expand his illicit wildlife
business to include pangolin scales, a
lucrative sideline in the world’s most
trafficked mammal.
Ou’s new Nigerian venture was soon in
full swing; by the middle of February
2017 he sent EIA pictures of tusks,
which had been consolidated in Lagos.
Shortly afterwards, Wang was
despatched to Nigeria to inspect the
ivory and, by the following month,
about three tonnes of ivory and
pangolin scales had been packed in a
consignment of peanuts ready for
despatch to Shuidong.

 HOW TO SMUGGLE IVORY TUSKS:
Lessons from the Shuidong syndicates
The Shuidong group’s success results from a blend of risk management and market adaptation.
Other Shuidong inhabitants have a history in ivory trade and, having inherited the business from older
relatives, the group relies on familial ties and trust.
Their methods, which help explain why there has never been any enforcement action, include:
“Commodity” sourcing

Spreading the risk

Ivory traffickers need to choose an area where elephants
are found and can be poached. It would therefore make
sense to focus on countries with elephant populations,
such as Botswana, home to the largest elephant population
in Africa.36 However, Botswana has experienced relatively
little elephant poaching and has not been targeted by the
group. This is due to a second key factor – the ease of
engaging in illicit business. Botswana has relatively good
governance and is one of the least corrupt countries in
Africa.37 Instead, the Shuidong traffickers prefer to source
from countries where the rule of law is weak. Despite
having a population of only 9,600 elephants,38 Mozambique
is attractive to the group as it is one of the most corrupt
countries in Africa.39

It is rare for a single Shuidong smuggler to shoulder the
entire risk of an ivory consignment. Instead, they seek
investors to mitigate any loss should the ivory be intercepted.
The proceeds of most shipments are split two or three
ways. While a seizure can lead to lost income, this is
generally only a temporary setback because the loss has
been shared. This investment model also allows for the
rapid recycling of funds, with some of the profit from a
successful shipment being quickly invested in another
consignment, continuing the cycle.

Supply chain management
Transporting supplies of illicit goods around the world
requires a safe route with trusted accomplices operating
along the way. The Shuidong group refers to this as
“owning the road”. If a route is broken as a result of
enforcement action, operations have to be disrupted as
new allegiances are forged. The route used by the group
for the Pemba shipment remains unbroken, with the
complicit freight agents at key stages along the chain
having a clean record of zero shipment interceptions.

Avoiding direct contact
The Shuidong group normally avoids direct contact with
the ivory, preferring to pay locals to do the dirty work of
collecting, collating and storing the tusks. One exception is
when the traffickers inspect the tusks prior to despatch,
but this is conducted under tightly controlled conditions.
In most of the cases of Chinese nationals being successfully
prosecuted for ivory trafficking in Africa, the culprits were
apprehended in physical possession of the tusks; three
Chinese nationals were arrested in Dar Es Salaam,
Tanzania, in 2013 in the act of packing tusks weighing
1.8 tonnes at a residential property.41 Two of them were
sentenced to 30 years in prison.

Specialisation
The Shuidong syndicates focus on a single part of the illicit
ivory supply chain – the smuggling of raw tusks from Africa
for the wholesale market in China. This has a number of
advantages. It is the most lucrative part of the chain; the
biggest single mark-up in the price of an ivory tusk occurs
when it is moved onto the Chinese mainland. Focusing on
wholesale trade to trusted buyers also ensures a low
profile, compared to those involved in operating carving
factories or retail outlets. One of the largest seizures of
tusks in China in recent years led to the prosecution of a
Fujian-based businessman who owned an ivory-carving
company and retail outlet registered with the Chinese
Government. He sought to diversify by directly sourcing
tusks from several African countries and was caught. His
lack of expertise in smuggling tusks, as well as a proactive
enforcement effort, led to a 15-year prison sentence.40

RIGHT:
A luxury mansion in Lipuzai village in Shuidong
town belonging to Xie Yingjue, a prolific ivory
trafficker, who was previously based in
Tanzania. He has since retired and handed over
his contacts to Xie Xingbang, his nephew.

18

 THE ROUTE FOR THE 2.3 TONNES OF IVORY TRAFFICKED
FROM PEMBA, MOZAMBIQUE TO SHUIDONG, CHINA IN 2016.

ROUTE:

1

From Pemba (Mozambique)
By sea to Busan (South Korea)
Ivory consolidated from across
eastern and southern Africa,
including Mozambique and Tanzania

COSTS AND PAYMENTS:
$200 per kg raw ivory
Increase to $300 per kg ivory + Bill of Lading
(total $900,000 for 3 tonnes)
$7,500-10,000 for container “fillers”
(plastic pellets)

1

19

 ROUTE:

2

By sea to Hong Kong

COSTS AND PAYMENTS:
Freight forwarder’s cut $450,000
Sliding costs for smuggling:
• To clear pangolin scales: $45 per kg,
• To clear ivory: $145 per kg
Bribes in Korea to move container: $1,500
Bill of lading switch $1,500-3,000

ROUTE:

4

Overland by car, south to Shuidong

LOCATION:

5

4

2

3

5

In house storage Shuidong, China

COSTS AND PAYMENTS:
Wholesale price: $720 per kg, $2.16 million
Mark-up price increase of 260%

ROUTE:

3

By sea to Shanghai

COSTS AND PAYMENTS:
Forwarding fees: $750

20

 RECOMMENDATIONS
THE GOVERNMENT OF CHINA:
• Deploy targeted multi-agency specialised investigations to
identify and disrupt networks engaged in the illegal ivory
trade in Shuidong, and connected groups and buyers in
Putian, Fujian province and beyond
• Employ a range of laws related to tax, anti-money
laundering, anti-corruption and organised crime to collect
evidence for asset seizures and criminal prosecution
• Coordinate intelligence-led operations targeting Chinese
nationals operating in and between source and transit
countries featured in this report
• Follow through on commitments made to close commercial
ivory trading and processing by the end of 2017. Publicise
it and prosecute individuals and companies found to be in
violation of the ban. Clarify and, if necessary, amend the
potential loophole, which may allow for the legal trade in
antiques or ‘cultural relics’
• Remove the existing legal quota system for pangolin
scales to restrict alternative revenue streams for criminal
syndicates and to support the CITES Appendix 1 listing

THE GOVERNMENTS OF ALL COUNTRIES
IMPLICATED IN THIS REPORT:
• Share intelligence and co-ordinate enforcement and legal
responses in a timely fashion, making use of existing
international programmes through the International
Consortium on Combatting Wildlife Crime (ICCWC) partners,
US Fish and Wildlife, the United Nations Convention on
Transnational Organised Crime (UNTOC) and the United
Nations Convention Against Corruption (UNCAC)
• Investigate and prosecute freight agents that are
facilitating trafficking

THE TRANSPORT SECTOR (INCLUDING
SHIPPING AGENCIES, LOGISTICS COMPANIES
AND AIR-FREIGHT):
• Review and, if necessary, update risk assessments and
profiling, taking into account intelligence relating to
concealment methods and smuggling routes

THE CITES PARTIES:
THE GOVERNMENTS OF MOZAMBIQUE,
NIGERIA AND TANZANIA:
• Investigate criminal activities detailed in this report and
exchange information with Chinese authorities
• Combat trafficking at exit ports: review current procedures;
strengthen capacity; improve detection methods and
employ anti-corruption measures

21

• Identify Mozambique and Nigeria as “primary concern
countries” under the NIAP (National Ivory Action Plan)
process, calling for time-bound implementation of
actions (including those mentioned above) to combat
ivory trafficking

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Savannah elephants in Niassa National
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22

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