
Governments, Trade Associations and NGO’s are meeting to talk trade and conservation with concerns around Elephant Ivory, Rhino Horn and the fate of the Mako Shark being high on the agenda at a CITES Wildlife Conference in Geneva. In all more than 50 proposals have been tabled for discussion, which include proposals submitted on not only Elephants, Rhino’s and Sharks but also on Pangolin’s, Big Cats and Giraffes.
As concern for the future of the wildlife on our planet increases, the international body tasked with regulating trade in endangered species is once again gathered for its 18th Conference of the Parties (COP) in Geneva being held between the 17-28th August, 2019. Originally slated for May 2019 in Sri Lanka, it was switched after the Easter terrorist attacks in March that killed more than 250. The last Conference (COP -17) was held in Johannesburg in 2017.
This Conference is being held with many concerned about the welfare of our Planet, with habitat reductions, human population growth, climate change, and a persistent Illegal wildlife trade, increasing pressures on ecosystems that endanger life that has roamed the planet for millenia.
The 18th CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora which came into force in 1975) Conference considers proposals affecting many species for places on the all important CITES Appendices. Species on Appendix 1 are considered sufficiently endangered to warrant international trading bans. Listing on Appendix 2 can permit some international trade though monitoring and controls are meant to halt the decline in species at risk of becoming endangered.

There is also an Appendix 3 where opportunities to trade are greater.
The Conference is attended by over two thousand representatives. (See the list from those Countries that have signed up to CITES and by Trade associations and NGO’s, that have a keen interest in understanding and lobbying decision makers to come to the right conclusions). Delegations are large, but perhaps the lure of the native wildlife around Lake Geneva in summertime had swelled the ranks this time. For example, the largest delegations registered by governments were from Angola (26), Nigeria (29), Malaysia (30), DR Congo (34), Indonesia (36), Japan (37), UK (44), US (48), Kenya (51), South Africa (53) and from China (54). Whilst the EU is sending 10 representatives, EU Countries together with the EU itself can count more than 200 representatives or over 10% of all those expected to be present. Whilst most Countries are present, India for example is sending a more modest 5 and Brazil only 1 person.
The UN and it’s Agencies such as the UN Food & Agriculture Organisation & the UN Environment Programme are also sending significant delegations (39), whilst the UNODC are much more modestly represented (4), as is the World Bank (2) and the WTO (2). Intergovernmental Agencies such as The International Union for Conservation of Nature (owner of the IUCN Red lists), which is a major source of truth to CITES and plays a crucial role in assessing the state of species around the world has one of the highest expected delegations (53). Other intergovernmental bodies include the World Customs Organisation (2) and Interpol (1).
Trade Associations are present though not in any great numbers and cover limited constituencies. Those expected to be present include the China Aquatic Products Processing & Marketing Alliance (10), the China Association of Traditional Chinese Medicine (2), the Private Rhino Owners Association (2), the Pet Industry Joint Advisory Council (2), the International Caviar Importers Association (1) & the Professional Hunters Association of South Africa (1).
Conservation Groups exceed more than 150 representing interests from every continent and covering all manner of species, with the largest delegations from WWF (34), the Wildlife Conservation Society (29) & TRAFFIC (24).

Despite a challenging environment for many species, and the prospect that in many cases the future looks bleak, it is surprising that of the more than 50 proposals submitted, only 16 are proposals to upgrade certain species, for example either from Appendix 2 to Appendix 1 or directly to Appendix 1 – and these are predominantly smaller mammals like particular species of rare otters and mice, under threat from habitat loss. The remaining proposals are looking for Appendix 1 delistings and or new Appendix 2 listings.
Of particular interest from the proposals submitted to Financial Crime News (FCN) are those that relate to 3 iconic animals, from the African continent; Giraffes, Rhino and Elephant.
A proposal submitted by the Central African Republic, Chad, Kenya, Mali, Niger & Senegal, to include Giraffe’s in Appendix 2 for the very first time relies on the 2016 IUCN Red List of Threatened species which rates Giraffe’s as “Vulnerable, ” reflecting declines in Giraffe populations between 36% and 40% over the last 30 years.

Giraffe numbers were estimated to be between approx 150,000-165,000 in the 1980’s, a population of 141,000 in the wild in the 1990’s and according to the IUCN the most recent estimate (from 2015), puts Giraffe populations at just below 100,000. Whilst habitat loss is one of the main reasons for the decline in numbers, Illegal trade also plays a part. Giraffes are also snared and illegally hunted for their meat and although meat is consumed locally, there is also cross border trade in wild Giraffe meat.
Despite the population declines FCN predicts this proposal is unlikely to pass. According to the CITES Sekretariat, in pre published materials, the numbers of Giraffes whilst in decline are still sufficiently large and dispersed to conclude “it’s wild population is not yet at a level at which its survival might be threatened by continued harvesting or other influence.”
Two further proposals of particular interest have also been submitted, with one from Namibia and one from Eswatini (formerly Swaziland) that relate to the Southern White Rhino, which is estimated at around only 19,000. The Northern white Rhino lost its last wild male Rhino in 2018, leaving only 2 females remaining, now under 24 hour armed guard in Kenya (with just 777 remain in captivity worldwide).

The proposal from Namibia requests moving Namibia’s Southern White Rhino population from Appendix 1 to Appendix 2, for the purpose of allowing international trade and trophy hunting. The proposal seeks to put Namibia’s Rhino’s on an equal footing with those in South Africa. Rhino’s were included in Appendix 1 in 1977, and the South African Rhino moved to Appendix 2 in 1995 (but limited to trade internationally of live animals to appropriate and acceptable destinations and hunting trophies). In 2005 all Rhino’s in Swaziland (now Eswatini) were transferred to Appendix 2 with the same restrictions. Namibia has the second largest Southern white Rhino population after South Africa, with approx 1,037 Rhino (although IUCN reports 975 Rhino, up from 822 in 2015).
FCN Predicts Namibia’s proposal is likely to pass. According to the Sekretariat, the numbers of Rhinos in Namibia “no longer meets the criteria for inclusion in Appendix 1.”
The second proposal on Southern White Rhino’s is from Eswatini, who propose an amendment to its Appendix 2 listing to permit it to sell from existing stocks, “330 Kg’s of Rhino Horn, to licensed retailers in the Far East and up to 20kgs a year.” The proceeds from the sale should “raise $9.9 million if sold at a wholesale price of $30,000 per kg,” and overall proceeds would be placed in a Conservation endowment fund that would generate $1.2 million a year and “can be sourced from sustainable none lethal harvesting of horn.” The monies would be used to fund the increasing security costs in Eswatini’s national parks to “protect the country’s rhino populations against the onslaught of transnational criminal poaching syndicates.”
Eswatini was home to 90 of these Rhino’s in 2015, which has since reduced to 66 due entirely to a sever drought affecting the habitat. Remarkably Eswatini reports only 3 successful illegal killings of Rhino in the last 25 years (compared to more than a 1,000 per year in South Africa, with 2 in 2011 and 1 in 2014.).
FCN predict Eswatini’s Proposal is not likely to pass. Notwithstanding Eswatini’s stellar record on Rhino conservation which speaks volumes, and it’s intent to raise money for increased security costs to protect its Rhino herd this is set against the danger that sanctioning legal sales simply generates further demand which further imperils all remaining Rhino’s. Still the discussion is likely to be interesting and one to watch.

Three more proposals concern African Elephants. These proposals are:
- to transfer Zambia’s elephants from Appendix 1 to Appendix 2;
- from Botswana, Namibia and Zimbabwe, that elephants from these 3 countries plus South Africa have certain restrictions in the Appendix 2 listing relaxed and in so doing expand elephant trade, and
- from Burkina Faso, Ivory Coast, Gabon, Kenya, Nigeria, Sudan, Syria and Togo to transfer the elephants of Botswana, Namibia, Zimbabwe & South Africa from Appendix 2 to Appendix 1 in response to the making of the prior proposal.
The first proposal from Zambia’s proposal is based on an elephant population of approx 27,000 and one that is considered stable and so Zambia proposes now to down list it’s population, “to allow for sustainable use of the species through trophy hunting,” and for the “commercial trade in hides and leather goods,” but also “trade in registered raw ivory.” FCN predict this is likely to be accepted if modified or clarified. According to the secretariat, Zambia’s elephant population “doesn’t seem to meet the biological criteria” for Appendix 1 but concerns around “how the proposed trade in raw Ivory” is to be managed has been raised.
The proposal from Botswana, Namibia and Zimbabwe, involves elephants from these 3 countries plus South Africa to relax restrictions in the Appendix 2 listing effectively expanding trade, similar to those proposed by Zambia (see above). The elephant populations in these 4 countries comprise around 250,000 or approx 61.6% of all remaining African elephants, and populations are stable and or increasing.
FCN prediction for both this and the Zambian proposal is that further clarification will be required. According to the CITES secretariat these countries elephant populations “continue not to meet the criteria for their inclusion in Appendix 1,” therefore expanding trade under Appendix 2 is likely, albeit concerns over safeguards regarding trade in raw Ivory are likely to be questioned.
The proposal from Burkino Faso, Ivory Coast, Gabon, Kenya, Nigeria, Sudan, Syria and Togo to transfer the elephants of Botswana, Namibia, Zimbabwe & South Africa from Appendix 2 to Appendix 1 appears to be a clear response to the prior proposal to remove current trade restrictions in these 4 Countries. FCN predicts this will be rejected. According to the CITES secretariat the proposal does “not seem to indicate that any of the four African elephant populations that are the subject of this proposal underwent marked declines.”
Conclusions
From a conservation perspective closing or restricting existing trade to provide time for populations of endangered animals to respond makes a lot of sense. Opening up markets once more to legal trade when populations recover generates revenue but it also sustains and or increases demand.
From a fighting financial crime perspective, closing or restricting existing legal markets, presents criminal opportunities where demand remains, and with supply diminished an even more lucrative market will develop. Markets that are predominantly damaging should not be legal or able to legally stimulate or satisfy demand.
The approach CITES takes is long-standing but looks at the trade in purely sustainability terms, instead of what conditions need to be in place to ensure sustainability is assured. CITES should instead consider incorporating restrictions beyond assessing current numbers and habitats for the animals, flora and fauna it regulates.
Our wildlife must be just that, wild – which means we have to set aside and protect our wild spaces, which includes protection from the real apex predator, mankind. Protecting our wild spaces from illegal poaching is possible, though not easy but protection from population growth, man made climate change both resulting in habitat loss is a future facing much of the planets biodiversity and still includes its most iconic species.
For CITES and it’s members to be proposing mostly delistings and removing species protections appears counter intuitive. That they will be discussed and be resolved on the basis of current numbers and trading opportunities, in a large hall in Geneva, which will largely will go unnoticed elsewhere, perhaps says more about the importance of short term trading opportunities and less about longer term sustainability and security goals.
That the trade in wildlife, be that mammals, fish or timber when combined is one of the worlds largest financial crimes, generating over a hundred billion dollars a year for criminal gangs, deserves consideration at the CITES Conference but it also deserves more than a handful of financial crime fighters attention at the conference currently underway by the shores of Lake Geneva.