A G R I C U LT U R E A N D E N V I R O N M E N TA L S E R V I C E S D I S C U S S I O N PA P E R 0 5 84396 ENFORCING ENVIRONMENTAL LAWS FOR STRONG ECONOMIES AND SAFE COMMUNITIES WORLD BANK REPORT NUMBER 84396-GLB FEBRUARY 2014 A G R I C U LT U R E A N D E N V I R O N M E N TA L S E R V I C E S D I S C U S S I O N PA P E R 0 5 ENFORCING ENVIRONMENTAL LAWS FOR STRONG ECONOMIES AND SAFE COMMUNITIES WORLD BANK REPORT NUMBER 84386-GLB FEBRUARY 2014 © 2014 International Bank for Reconstruction and Development / International Development Association or The World Bank 1818 H Street NW Washington DC 20433 Telephone: 202-473-1000 Internet: www.worldbank.org This work is a product of the staff of The World Bank with external contributions. The findings, interpretations, and conclusions expressed in this work do not necessarily reflect the views of The World Bank, its Board of Executive Directors, or the governments they represent. 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C ontents iii CONTENTS Abbreviations and Acronyms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii Chapter 1: The Evolution of a Roadmap . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Chapter 2: The Impacts of Environmental and Natural Resource Crime . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Chapter 3: A Taxonomy of Environmental and Natural Resource Crime . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Chapter 4: The Role of Law Enforcement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Chapter 5: The WBG Portfolio . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Chapter 6: The World Bank Group Support for ENRLE FY2013–15 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Mobilizing the Community of Practice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Results We Will Help Our Clients Achieve . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 BOX Box 5.1: Lessons Learned from the Design and Operational Aspects of ENRLE Investments . . . . . . . . . . . . . . . . . . . . . . 10 FIGURE Figure 3.1: Elephant Trade Information System’s Estimated Trends in Ivory Trade, 1996–2011 . . . . . . . . . . . . . . . . . . . . . 5 TABLE Table 6.1: Results We Will Help Our Clients Achieve . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 A G R I C U LT U R E A N D E N V I R O N M E N TA L S E R V I C E S D I S C U S S I O N PA P E R A bbreviations and A cronyms v ABBREVIATIONS AND ACRONYMS CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora COP Community of Practice DGF Development Grant Facility EITI Extractive Industries Transparency Initiative ENRLE Environmental and Natural Resources Law Enforcement FLEG Forest Law Enforcement and Governance GAC Governance and Anti-Corruption IBRD International Bank for Reconstruction and Development ICCWC International Consortium on Combating Wildlife Crime ICT Information and Communications Technology IDA International Development Association IUU Illegal, Unreported or Unregulated [Fishing] MDG Millennium Development Goals NRM Natural Resource Management PDR People’s Democratic Republic PEPs Politically Exposed Persons UNODC United Nations Office on Drugs and Crime VPU Vice-Presidential Unit WBG World Bank Group Ongoing consultations were undertaken in the development of this roadmap. A Community of Practice was established in 2012 to engage Bank staff across regional and network VPUs. This community—the Rangers—has been instrumental in providing input and feedback on this roadmap, culminating in a full consultation on the first draft during SDN Week in March 2013. Their contributions are gratefully acknowledged. The Roadmap was prepared under the guidance of the Environment Sector Board, with special thanks to Sari Soderstrom and Magda Lovei. Consultations in the context of the WBG’s role in the ICCWC partnership also helped inform the roadmap. Other people, representing a broad range of stakeholders, including civil society, academia, the private sector, and other development partners, were also consulted in the formulation of this roadmap. The Roadmap was prepared by a team comprising Valerie Hickey, Bill Magrath, Julian Lee, Klas Sander, and Marilyne Goncalves; with support from Elisabeth Mealey, Jim Cantrell, Sara Thompson, and Juliette Guantai. Note: All dollars are U.S. dollars unless otherwise indicated. A G R I C U LT U R E A N D E N V I R O N M E N TA L S E R V I C E S D I S C U S S I O N PA P E R EXECUTIVE SUMMARY v ii EXECUTIVE SUMMARY This roadmap for environmental and natural resources law enforcement (ENRLE) sets forth a course of action for the World Bank’s ENRLE Community of Practice for FY2013–15. It outlines for senior management a strategy to mobilize and strengthen the Bank’s engagement in the fight against environmental and natural resource crime, an issue that has significant detrimental effects on the economic, social, political, and environmental stability of our client countries. The roadmap also serves as a mobilizing tool for staff and management in regional departments to demonstrate the importance of ENRLE and to outline the menu of solutions that the Community of Practice (COP) can offer to strengthen our clients’ fight against environmental and natural resource crime. Recent spikes in poaching, in illegal logging, and in illegal, unreported, and unregulated (IUU) fishing have amplified the already urgent need for action. These crimes increase poverty, shrink prosperity, and magnify social and political tensions that under- mine healthy communities and strong economies. Investment returns in wise environmental and natural resource law enforcement can be high. Criminal activities that affect the environment and natural resources are on the increase and pose an increasingly seri- ous threat to development. Data and analyses reviewed by the World Bank’s Community of Practice on ENRLE begin to show the magnitude of illegal logging, poaching of wildlife, trade in endangered species, wildland arson, criminal toxic releases, and other environment and natural resource–related crimes. They also show the diversity of the criminal threat, ranging from small-scale, arti- sanal crime that arises from poverty and inequities to growing problems of organized transnational criminal networks and enterprises using corruption, money laundering, technology, and other sophisticated methods to exploit persistent weaknesses in resource man- agement and law enforcement. All World Bank client countries suffer from these crimes and are underserved by existing international law enforcement institutions and available mechanisms for support, capacity building, and operational cooperation. Vulnerability to environment crimes is often deepened by overarching problems of governance, corruption, and weaknesses in accountability at the national level. Environmental and natural resource crime is common, but in many countries it is rarely prosecuted. The very elements that make these crimes possible—that natural capital is undervalued, seldom properly guarded, and often has unclear or contested ownership—also compromise prosecution. This Roadmap FY2013–15 builds on recently scaled-up support for ENRLE1 that includes project commitments on the order of $50–60 million per year. Along with investments, the Bank supports advisory and analytic work and leadership in regional and interna- tional processes and dialogue. While the Bank is not a law enforcement agency, its established programs to support natural resource and environmental management and to safeguard global public goods, its commitment to strengthening good governance and to fighting 1 The coverage of ENRLE falls within investments in the natural resources sector and includes IDA/IBRD investments coded as agriculture, fishing, and forestry; environment; public-administration; and other investments that are directly related to governance and criminal justice. A G R I C U LT U R E A N D E N V I R O N M E N TA L S E R V I C E S D I S C U S S I O N PA P E R v i ii EXECUTIVE SUMMARY corruption, and its partnerships with key law enforcement agencies such as Interpol and Europol give it an opportunity and responsibility to do more. This report discusses how the World Bank Group (WBG) will mobilize to work better on ENRLE. Recognizing the evolving global context, a new and fully mobilized Community of Practice will put more emphasis on building a constituency within the WBG to work on the range of ENRLE issues, on building the capacity of WBG staff to provide investment and technical assistance on ENRLE, on strengthening analytical work to develop a pipeline of ENRLE investments, and on fostering demand among clients for Bank investment in ENRLE. E N F O R C I N G E N V I R O N M E N TA L L AW S F O R S T R O N G E C O N O M I E S A N D S A F E C O M M U N I T I E S C hapter 1 — T he E volution of a R oadmap 1 Chapter 1 THE EVOLUTION OF A ROADMAP The World Bank has historically tended to avoid direct the proceeds of crime, and tax evasion—affect governance involvement in criminal justice matters. Interestingly, and im- and development outcomes across the developing world portantly, this has led the Bank to support innovations in natural (World Bank 2011a). If they are to be effective, country-level efforts resource policy, addressing problems in a way that is not labeled to tackle these threats have to be backed by international coopera- law enforcement. The most important example of this is social and tion and collective action. The World Bank’s global governance and community forestry, which grew out of concern with problems of anti-corruption (GAC) agenda stresses and seeks to support this illicit grazing and uncontrollable theft of firewood across much of cooperation and mutual accountability. Given the scope of its oper- South Asia. Since the 1980s, World Bank support for a redefinition of ations and its relationships with a range of stakeholders and actors law enforcement problems as poverty reduction and development on the global stage, the Bank is well positioned to play a strategic challenges best addressed through local community participation and catalytic role in improving the governance of global initiatives, and tenure reform created a new paradigm for resource policy that whether it is protecting the global commons, safeguarding the has helped the lives of hundreds of millions of people. integrity of transnational flows of money, or guarding against illegal trade in natural resources (World Bank 2012). In the past several years the Bank began to reconsider its engagement with issues of corruption and criminal jus- A range of global threats can significantly impede efforts to tice. With the recognition of “the cancer of corruption” as a major improve governance and development gains at the country obstacle on development, and later with a broadened understand- level, including the illegal trade in natural resources. In 2008, ing of poverty as a vulnerability, including exposure to crime, the resource rents accounted for around 7 percent of global gross Bank has opened up to more-direct involvement in criminal justice domestic product. While more than 50 Bank clients are resource- work, and specifically to ENRLE. The Bank General Counsel’s various rich, many are also low-income, fragile, or in a post-conflict period. legal opinions—more specifically, the Legal Note on Bank Involvement Resource wealth provides an opportunity to stimulate economic in the Criminal Justice Sector (February 2012) and the staff guidance growth in these countries and advance sociopolitical progress and notes on Financing of Fisheries Enforcement Activities (2010) and achievement. Yet there are serious governance risks that contribute on Support for Criminal Justice Activities (2012) issued by the Legal to countries experiencing a paradox of plenty—a situation where Department—have clarified the Bank’s scope for engagement and abundant resource wealth is accompanied by poor governance opened the way for investment in fisheries law enforcement projects, and high levels of poverty. The Bank’s aim is to help ensure that analytics, and nonlending services in relation to anti-money launder- such natural resources are used correctly and to address issues of ing, stolen asset recovery, and other law enforcement support. exploitation. To date, this effort has included continued support for increased coverage and implementation of global governance The World Development Report 2011 demonstrated how glob- initiatives that address specific natural resource management (NRM) al threats—transnational organized criminal activity, corrup- issues, such as the Extractive Industries Transparency Initiative (EITI), tion, the illegal trade in natural resources, the laundering of the Forest Law Enforcement and Governance program (FLEG), and A G R I C U LT U R E A N D E N V I R O N M E N TA L S E R V I C E S D I S C U S S I O N PA P E R 2 C hapter 1 — T he E volution of a R oadmap Reducing Emissions from Deforestation and Forest Degradation. countries have paid scant attention to this escalating problem or It has also entailed efforts to strengthen corporate governance have been powerless to address the challenges in a sustainable of companies that are involved in natural resource extraction in manner. Many efforts to support countries have not established foreign countries (World Bank 2012). long-term solutions, which has created a cycle of mistrust and apathy by some stakeholders. Many types of activities support sustainable NRM regimes and good governance. ENRLE is an additional narrow Several elements combine to give the World Bank a unique specialization that addresses reducing criminal activities comparative advantage to help its clients address environ- that target and exploit natural capital, as well as helping mental and natural resource crime. First, the Bank has expertise to identify the criminals and criminal groups who are in- in anti-money laundering, customs enforcement, fraud and corrup- volved. Despite past efforts, World Bank client countries continue tion investigations, trade, justice sector reform, and environmental to suffer from environmental and natural resource crime and are law. Second, it is well versed in designing long-term financing and underserved by existing international and domestic law enforce- technical assistance, which is important given that law enforce- ment institutions and available mechanisms for support, capac- ment is often short-sighted and emphasizes seizures and captures ity building, and operational cooperation. Across the developing rather than underlying issues related to prevention and detection. world, criminal activities are an increasingly serious threat to Third, the Bank is well positioned to facilitate dialogue among stake- inclusive green growth and shared prosperity and to the conserva- holders and create inclusive networks for more effective ENRLE, tion of natural resources and the environment. Data and analyses as its participation in the International Consortium on Combating reviewed by the World Bank’s Community of Practice on ENRLE has Wildlife Crime (ICCWC) demonstrates. And finally, the Bank brings highlighted the magnitude of illegal logging, poaching of wildlife, to the table a poverty focus that seeks to ensure that ENRLE targets trade in endangered species, wildland arson, criminal toxic releas- organized crime rather than hurting the subsistence activities of es, and other environment and natural resource–related crimes. the poor. As a result of these factors, the Bank is already the largest Their work also identifies the diversity of the criminal threat, rang- development assistance provider on ENRLE. ing from small-scale, artisanal crime that arises from poverty and This roadmap outlines how the World Bank will mobilize inequities to growing problems of transnational criminal networks internally to provide support to our client countries as they and enterprises using corruption, money laundering, and other so- build their law enforcement capacity in support of sustain- phisticated methods to exploit persistent weaknesses in resource able NRM regimes. management and law enforcement. Many World Bank client E N F O R C I N G E N V I R O N M E N TA L L AW S F O R S T R O N G E C O N O M I E S A N D S A F E C O M M U N I T I E S C hapter 2 — T he I mpacts of E nvironmental and N atural R esource C rime 3 Chapter 2  THE IMPACTS OF ENVIRONMENTAL AND NATURAL RESOURCE CRIME Environmental and natural resource crimes are widespread Environmental and natural resource crime directly undercuts and severe, and they directly undermine sustainable natural development by undermining institutions and fueling cor- resource regimes and the strong economies that depend on ruption. Criminals take advantage of states’ weakness and inability them. As such, they mirror other crimes, for which the negative to govern and control their territory. As a result, they have a vested relationship with development has been conclusively established interest in preventing countries from developing and building (see, among others, World Bank 2011a, 2011b; Heinemann and effective state institutions (Haken 2011), which harms key areas Verner 2006; Ayres 1997). Crimes affecting natural resources and the for development, including the investment climate and public environment inflict damage on developing countries worth more service provision. Since these crimes rely on state powers “looking than $70 billion a year. In addition to their economic impacts, these the other way,” they inherently fuel corruption and elite capture: crimes undermine efforts to promote sustainable development and Where there is a lack of economic opportunity, people are easily lasting poverty reduction, further alienate and marginalize already enticed to engage in crime, and officials are easily bribed to facilitate disadvantaged communities, breed corruption and distrust in smuggling. Environmental and natural resource crime also provides civil authorities, and pollute the supply chains of legitimate natural liquidity for corruption that further drives poor decision making. This resource–based businesses. not only occurs at a micro-level, such as when a government official intercepts looters, but it extends to higher levels of government and Environmental and natural resource crime impedes progress financial systems that are abused for money laundering purposes. in a wide range of important areas of concern, including environment, poverty reduction, governance and the rule of Environmental and natural resource crime frequently deprives law, trade and customs, and investment climate. As the use of developing countries of scarce income. The Environmental natural resources constitutes the foundation of many poor people’s Justice Foundation estimates that Guinea loses $105 million worth of livelihoods, crime depresses incomes and well-being. Many poor fish to pirate fishing yearly, Sierra Leone loses $29 million, and Liberia, people are caught in a vicious cycle of being forced to unsustain- $12 million. In illegal trading, few monetary resources flow into ably exploit the very resources they depend on for their incomes, the source country. In one case, Indonesian loggers received $20 often times in contravention to the law. In many cases, however, per cubic meter of illegal timber, which Malaysian businesspeople external actors are responsible for illegal resource extraction. For subsequently sold for $200, leaving 90 percent of revenues outside example, illegal, unreported, and unregulated fishing off the coast the source country (Haken 2011). Lost income—whether private, in of West Africa by far-off nations consumes some 37 percent of the the form of lost wages or depressed prices in legal markets due to total catch, risking the fishery’s collapse and affecting the liveli- increased supply, or public, in the form of forgone taxes and royalties hoods, safety, and food security of local fishers and coastal commu- where legal markets exist—is something most developing countries nities (Valdmanis and Akam 2012), not to mention the loss to the can ill afford, as these funds are by definition unavailable for invest- national treasury. ment in productive development purposes. A G R I C U LT U R E A N D E N V I R O N M E N TA L S E R V I C E S D I S C U S S I O N PA P E R 4 C hapter 2 — T he I mpacts of E nvironmental and N atural R esource C rime Environmental and natural resource crime is often also linked Environmental and natural resource crime leads to envi- to insecurity, instability, and violent conflict. In Cambodia, ronmental degradation. In some cases, the very survival of a Liberia, Côte d’Ivoire, and the Democratic Republic of Congo, illegal species is at stake. Some of the world’s most iconic species and timber helped fund armed conflict, further benefiting timber traf- ecosystems—including rhinoceroses, tigers, elephants, tropical fickers who profited from the instability (Oksanen et al 2006). Sudan’s rain forests, and coral reefs—are threatened with extinction and Janjaweed militia slaughtered hundreds of elephants for ivory in destruction because of crime and related corruption. But the neighboring Chad to purchase arms for use in Darfur (Begley 2008). effects can also be more indirect. For example, deforestation, According to Interpol and the U.S. State Department, Somali war- especially when conducted illegally and in the absence of good lords and Al Qaeda–affiliated elements have sponsored elephant forest management practices, can contribute to soil erosion, and rhinoceros poaching to generate income (Wyler and Sheikh increased rainwater runoff, risk of flooding, reduced groundwater 2008), as has the Lord’s Resistance Army in Uganda (Gettleman recharge, and diminished local resilience against the effects of 2012). This blood ivory destabilizes near and far-off nations while climate change. undermining the development of local communities. Environmental and natural resource crime is rampant and Environmental and natural resource crime undermines the largely goes undetected and unpunished. Natural capital is sustainability of investments in the natural resources sec- often undervalued, unguarded, and suffers from an absence of clear tor and raises the cost of sustainable landscape or seascape ownership. Moreover, natural capital is rarely mapped or counted, management. The World Bank invested $1.18 billion on biodiver- thus making its disappearance difficult to confirm. Laws in many sity conservation between fiscal years 2001 and 2011, the majority countries, even when they do cover environmental crime, apply of which supported protected areas. These public investments are penalties that do not serve to deter the crime. Often treated as civil being liquidated by criminal elements, at the cost of sustainable crime, fines—even when applied—are rarely of an order to reverse a NRM regimes and public goods protection. Having to repeat the very favorable risk-reward balance that is currently and overwhelm- investment and rebuild the public sector and community capacity ingly on the side of the criminal. necessary to use it in the aftermath of crime is doubly expensive. E N F O R C I N G E N V I R O N M E N TA L L AW S F O R S T R O N G E C O N O M I E S A N D S A F E C O M M U N I T I E S C hapter 3 — A Taxonomy of E nvironmental and N atural R esource C rime 5 Chapter 3  A TAXONOMY OF ENVIRONMENTAL AND NATURAL RESOURCE CRIME Illegal logging. Illegal logging includes a wide range of activities FIGURE 3.1:  Elephant Trade Information System’s Estimated associated with the misuse of timber resources. In most countries, Trends in Ivory Trade, 1996–2011 (Transactions Index and Weights Index aggregated over ivory specific forms of illegal logging include timber theft from public or classes and countries with 90 percent credible private forests, evasion of timber taxes and royalties, and felling of intervals) protected trees or trees outside of designated areas. Smuggling of a stolen timber, falsification of documents related to timber harvest Relative number of 500 and transport, violation of forest practice regulations, and many 400 transactions other infractions both civil and criminal can constitute illegal log- 300 ging in some jurisdictions. Illegal logging is believed to cost devel- 200 100 oping countries on the order of $5 billion per year in lost timber 0 revenue alone, while the overall global trade is estimated to range 1996 1998 2000 2002 2004 2006 2008 2010 between $7 billion (Haken 2011) and $15–20 billion (Goncalves et al 2012; Seneca Creek Associates and Wood Resources International b 2004). Estimates are that suspicious material may constitute as 400 Relative weight much as 23–30 percent of the global supply of industrial hardwood 300 and that the availability of illegal material depresses global wood 200 products prices by 7–16 percent. 100 Wildlife poaching and trafficking. The global illicit wildlife trade has 0 been estimated at between $7.8 billion and $10 billion by one 1996 1998 2000 2002 2004 2006 2008 2010 source (Haken 2011) and at between $22 billion and $32 billion by Year others (Europol 2011). For the past 10 years there has been an expo- Source: Underwood et al 2013. nential growth in illicit trade in wildlife, driven mostly by increasing affluence in Asia, where there is an appetite for the rare and exotic. States also constitute important destinations (Europol 2011). For Figure 3.1 illustrates the best estimates currently available for the some species, poaching and illegal collection of live animals has increase over recent years in the level of illegal shipments of driven numbers so low that their very survival is at risk. Much of elephant ivory from African countries by volume and number of the most popular groups of species for trade in Southeast Asia have incidents. The most lucrative trade is in animal products that include been collected to the point where they are so scarce that it is no elephant ivory, tiger bones, Tibetan antelope, rhinoceros horns longer commercially viable to try to find them in the wild. These (which can fetch prices higher than that of gold [Guilford 2013]), include freshwater turtles, for example, and collection for trade in and exotic birds and reptiles. The European Union is considered these species has now shifted to Africa and the Americas. Poaching the primary market for illegal wildlife, but China and the United for protein provision—the bushmeat trade—is mostly a domestic A G R I C U LT U R E A N D E N V I R O N M E N TA L S E R V I C E S D I S C U S S I O N PA P E R 6 C hapter 3 — A Taxonomy of E nvironmental and N atural R esource C rime practice and may not be considered illegal in some countries, but Corruption. NRM authorities in many countries have wide discretion, its value and impact can be significant on ecosystems, conservation, operate with minimal supervision and oversight, and are exposed to and human health. Estimates of its value in West and Central Africa many temptations and inducements to endorse or overlook crimes range from $42 million to $205 million (Davies 2002). and infractions. Public resource taxation, pricing arrangements, an absence of transparency and discipline, weak technical planning, Illegal fishing. Illegal, unreported, or unregulated fishing is facilitated and other problems create space that private enterprises and politi- by the fact that once fish have been landed it is almost impossible cally protected interests can use to capture and exploit economic to determine their origin, making it easy to place illegally caught rent in corrupt payments. In some countries entire natural resource fish into regular markets. Estimated global economic losses from bureaucracies are built and operate on the basis of systems of IUU fishing range from $4.9 billion (Haken 2011) to $23.5 billion corrupt side payments at the expense of public revenues and en- per year (Agnew et al 2009). Sub-Saharan Africa alone is estimated vironmental sustainability. Many links in the chain from harvest to to lose more than $1 billion per year, and Southeast Asia some $3 consumer rely on government approvals and the issuing of licenses billion. As with wildlife and forest products, the largest importing and permits. This interface between government officials issuing markets for IUU fish are the European Union, Japan, and the United permits and those exploiting the resource generates major and States, with China and South Korea also believed to be significant frequent opportunity for corruption to flourish. destinations. Money laundering. As indicated, environmental and natural resource Toxic waste disposal. The increasing spread of modern industrial man- crime generates enormous sums of money. Those acting near the ufacturing processes has outpaced the ability of regulatory authori- acme of the criminal networks as well as the corrupt officials exercis- ties in many developing countries to keep pace with the generation ing control over concessions, licenses, and other arrangements use of hazardous byproducts and waste. Controls on waste disposal in a range of methods, often complex, to disguise the illegal origins some countries have generated concentrations of poorly regulated of their profits. Under commonly accepted international standards,2 recycling enterprises where workers and communities are exposed such efforts constitute money laundering and are themselves crimi- to high concentrations of hazardous substances. Indications reveal nal offenses in more than 150 countries. By extension, regulated that organized crime networks in source countries are involved on a financial institutions are obligated to monitor suspicious transac- massive scale in channeling waste to countries such as China, India, tions that could involve money laundering and are themselves Ghana, and Kenya. subject to penalties for failing to report or being party to illicit Arson. Illegal use of fire, primarily for land clearing, but also in asso- transactions. ciation with hunting, is one of the most widespread environmental Smuggling. Much of the criminal harvest of natural resources affect- and natural resource crimes. It has major consequences in both ing developing countries involves illegal international shipments. industrial and developing countries. In the latter, the illegal use of Some of this trade is controlled by specific international agreements fire by agro-industrial interests is associated with land grabs and (the Convention on International Trade in Endangered Species of encroachment. Wild Fauna and Flora [CITES]), the Basel Convention, the Montreal Protocol), while other movements are criminalized by national Direct criminal activities related to environmental and legislation of either or both countries of origin and destination. natural resource crime are often supplemented by cascad- Depending on the product, smuggling can involve concealment, ing crimes of a secondary nature but with no less an impact mislabeling, forged or falsified documentation, or other methods. on development. Especially with large-scale crime, diligent and Differences in legislation and practice between countries can be aggressive prosecutors can often establish culpability under many serious impediments to controlling smuggling. diverse statutes that reinforce, or can even replace, charges related to the underlying natural resource crime. Examples include false 2 See the recommendations of the Financial Action Task Force at www declarations, tax evasion, fraud, and conspiracy. .fatf-gafi.org. E N F O R C I N G E N V I R O N M E N TA L L AW S F O R S T R O N G E C O N O M I E S A N D S A F E C O M M U N I T I E S C hapter 4 — T he R ole of L aw E nforcement 7 Chapter 4 THE ROLE OF LAW ENFORCEMENT Law enforcement programs consist of measures to prevent, with only limited success. Moreover, in the few cases where it detect, and suppress crime. Criminologists define crime preven- has been used it has tended to target low-level criminals whose tion simply: it is the disruption of the mechanisms that cause crime. involvement in illegal activities is needs-based and often for sub- For most countries, combating environmental and natural resource sistence rather than trade. As such, it has created no real deterrent crime is not currently a priority and often remains overlooked and and has encouraged skeptics to further discount the relevance of poorly understood, despite the actual and potential scale and environmental law enforcement in general and criminal justice consequences. Environmental and natural resource policies and methods in particular. Large-scale illegal operations are carried out laws and their enforcement have not, or not always, kept up with by sophisticated criminal networks, and law enforcement actions the changing levels and patterns of trafficking in fauna and flora. need to be focused on the masterminds behind these networks Underdeveloped legal frameworks, weak law enforcement, and and the high-level corrupt officials who enable and protect them. poor prosecutorial and judicial practices, as well as a lack of under- Pursuing these important targets through the criminal justice sys- standing of the different factors that drive wildlife and forest offens- tem will require creativity and a clear focus on the criminal justice es, have resulted in valuable wildlife and plant resources becoming rules and procedures that prove most effective (Goncalves et al threatened by, among other things, illegal logging, illegal trade 2012). in timber products, and poaching and trafficking in animal parts, To be effective, law enforcement needs to look past low-level crimi- derivatives, and plant material. The high demand for timber, wildlife, nals and look at where the profits from environmental crime go. By animal parts, and plant material around the world has led to large- following the money trail, and using tools developed in more than scale illegal logging, harvesting, and poaching operations. Illegal 170 countries to go after “dirty money,” criminal justice can pursue trade in protected fauna and flora offers opportunities to make criminal organizations engaged in large-scale illegal operations significant profits because it supplies goods that are considerably and confiscate any ill-gotten gains. The criminal networks operate cheaper than legally sourced material. Illegal trade can also be an outside geopolitical boundaries and rapidly move their operations impediment to developing long-term legal industries. The gaps in when law enforcement in a particular national jurisdiction gets domestic and international control regimes, difficulties in identify- close to them. There is an urgent need to focus law enforce- ing illegal commodities and secondary products, and intricate traf- ment investigations across these networks in a coordinated way, ficking routes have resulted in the inability to effectively curtail the which requires rapid and trusted cooperation between countries. trade (UNODC 2012b). Unfortunately, such cooperation is far less likely for natural resource The criminal justice system has been used in the fight crime, as this is not a priority for most governments’ enforcement against environmental and natural resource crime, but agencies. A G R I C U LT U R E A N D E N V I R O N M E N TA L S E R V I C E S D I S C U S S I O N PA P E R 8 C hapter 5 — T he W B G P ortfolio Chapter 5 The WBG Portfolio The World Bank is now the largest provider of develop- the European Neighborhood and Partnership Instrument, a FLEG ment assistance for combating environmental and natural program that supports governments, civil society, and the private resource crime. A 2006 estimate found that the World Bank was sector in Armenia, Azerbaijan, Belarus, Georgia, Moldova, Russia, financing over $310 million in investments for forest law enforce- and Ukraine in the development of sound and sustainable forest ment and governance alone (World Bank 2008). A more recent management practices, including the prevention of illegal forestry review found that the level of funding had remained more or less activities. constant, with ongoing commitments at around $300 million sup- porting 39 projects covering forestry, fisheries, and wildlife law Nonetheless, a portfolio review revealed several weak- enforcement. Of this, $201 million has been devoted to crime pre- nesses, not least of which is an absence of broad and deep vention, with relatively little to suppression, and $95 million goes technical expertise at the World Bank to provide quality to crime detection efforts. Specifically, the Bank has financed such control on issues related to environmental law enforcement. diverse ENRLE work as the establishment of a forest police agency in This has resulted in operations that are less than fully satisfactory Lao People’s Democratic Republic; a series of projects across South and often disburse slowly. For example, the regional International Asia on wildlife law enforcement; a series of fisheries law enforce- Development Association (IDA) operations to support law enforce- ment projects in West Africa; park and protected areas ranger op- ment in South Asia are moving much more slowly than expected. erations and training and equipment, as well as log tracking and The portfolio review also highlighted the absence of transna- chain of custody systems in Liberia; and a forest crime detection and tional, regional, and global activities to facilitate developing case tracking system and independent forest crime monitoring in countries’ access to international cooperation in support of Cambodia and other countries. their domestic efforts to tackle environmental and natu- In addition to its investment operations, Bank analytic, due ral resource crime. The Bank cannot substitute for cooperation diligence, and partnership work addresses environmental between states, but it must enable states to cooperate more and natural resource crime. Dialogue with the Government of effectively—first by promoting inclusive networks that respond to Lao PDR during planning of the Nam Theun II Hydroelectric Power the needs and constraints of developing countries and, second, by Project, for example, secured more-effective control of illegal log- enabling cooperation between national authorities at an opera- ging and poaching of wildlife in the project area. The Bank’s pro- tional level, such as by providing information, facilitating contacts, gram of support to financial sector integrity is helping to bring or playing an honest broker role. The Bank can also play a valuable anti-money-laundering tools to bear in addressing ENRLE. The Bank role by helping bring together international organizations to tackle initiated the concept of forest law enforcement and governance issues of common concern and by supporting concerted action. with its sponsorship of the first East Asia Ministerial Meeting on the The Bank has begun to play this role collaborating with the CITES subject in 2001, followed by similar meetings in Africa, Europe, and Secretariat, the World Customs Organization, Interpol, and the North Asia. With funding from the European Union, the Bank set up United Nations Office on Drugs and Crime (UNODC) in ICCWC. E N F O R C I N G E N V I R O N M E N TA L L AW S F O R S T R O N G E C O N O M I E S A N D S A F E C O M M U N I T I E S C hapter 5 — T he W B G P ortfolio 9 Lessons from the last several years of implementation have of long-term planning. Combining both skill sets will be critical to been integrated into this roadmap (see Box 5.1). These lessons furthering the agenda in pursuit of countries’ domestic agendas. have relevance to broader themes across all regions. They are taken Similarly, civil society has an important role to play as crucial partner from a brief review of the WBG portfolio performance in ENRLE since to achieve ENRLE. 2000. Law enforcement in general—and ENRLE in particular—is The best ENRLE can only happen in the context of a suite of misunderstood. The objective for the ENRLE agenda is to strength- sustainable NRM investments. NRM operations across sectors en mutual accountability to protect national assets and domestic provide the singular vehicle to introduce ENRLE. Whether in forestry, revenues in low-income countries with weak institutions against fisheries, biodiversity, or land management, ENRLE is a narrow spe- global threats. This highlights the development imperative of the cialization important to facilitate the success of the broader NRM agenda, focusing on the protection of developing countries’ vulner- portfolio. Similarly, ENRLE in the absence of investments in achiev- able assets: their natural resources and the resources managed by ing sustainable NRM regimes cannot be successful. the public sector. Instead, too often ENRLE is seen as an enforce- ment-only approach that is blind to the need-greed dichotomy. As much as NRM operations provide the vehicle to introduce ENRLE, ENRLE needs to adopt practices and lessons from This misunderstanding often leads to an assumption of repu- existing specializations within the Bank, from anti-money tational risk associated with ENRLE investments. The strength- laundering to trade facilitation. ENRLE activities must tie in with ening of country institutions remains central to the larger develop- the Bank’s broader NRM and GAC agendas and should take advan- ment agenda, and ENRLE works to do this. In this sense, it carries no tage of expertise and experience in other specializations across the more risk than other institution building undertaken at the Bank. Bank. The organization has a cutting edge anti-money-laundering Moreover, the ENRLE agenda is about supporting developing coun- specialization in the Finance and Private Sector Development Vice- tries’ efforts to tackle environmental and natural resource crime Presidential Unit (VPU). The Bank also has a wealth of experience through the effective implementation of international standards in customs modernization, trade facilitation, and investigation of and by facilitating their access to operational-level cooperation, fraud and corruption in Bank-financed projects. Additionally, the in particular on law enforcement and criminal justice. Again, these Bank is a leader in environmental law and in supporting countries to activities do not uniquely carry reputational risk. develop comprehensive regulatory frameworks for environmental The Bank’s support to ENRLE has been warmly welcomed management. internationally and by client countries. The Bank’s role was There is a financing gap in ENRLE. The Bank’s current portfolio applauded by the Parties to CITES during the 16th Conference of of up to $300 million fails to tackle the quickly growing demands the Parties in Bangkok in March 2013. And the president of the for support against environmental and natural resource crime. African Development Bank sought out the World Bank’s assistance Nonetheless, this catalytic financing has unearthed the larger to address demands from their clients to deal with an increase in demands in client countries and has provided opportunities to elephant poaching in African elephant range states. show proof of concept. The global public good dimension of ENRLE is too often Partnerships will be key to the success of the ENRLE agenda. ignored. There are no effective systems in place to respond The Bank is not a law enforcement agency. However, as a devel- to what is an international problem. The World Bank is set up opment institution, it is forward-looking and an expert in project to effectively work on global public goods by promoting linkages design and long-term financing. Conversely, while law enforce- between global initiatives and the Bank’s work at the national level. ment institutions have the technical expertise from crime scenes to The Bank’s support, through the Development Grant Facility (DGF), court cases, they tend to be reactive and often suffer from a failure to ICCWC is a down payment on testing how to do this. A G R I C U LT U R E A N D E N V I R O N M E N TA L S E R V I C E S D I S C U S S I O N PA P E R 10 C hapter 5 — T he W B G P ortfolio BOX 5.1: Lessons Learned from the Design and Operational Aspects of ENRLE Investments Improve domestic, public sector cooperation. Domestic coopera- Consider all applicable offenses, not just regulatory environmental tion between agencies involved at different stages of the fight offenses. In addition to regulatory offenses, environment and against environmental and natural resource crime should be natural resource management officials, investigators, and pros- strengthened so as to coordinate action and maximize resources ecutors should consider the many different crimes that may have and expertise. Actors in the environmental and natural resource been committed. Identifying all offenses as early as possible in the sector should actively engage in the broader effort to increase the investigation will provide more options for prosecutors in bring- effectiveness of forest law enforcement through investigations, ing the case forward. prosecutions, and the confiscation of criminal proceeds. Follow the money. Criminals can be convicted of money launder- Enlist the private sector. When looking into the financial dimension ing related to many different predicate crimes. Furthermore, asset of environmental and natural resource crimes, financial institu- confiscation deprives criminals of the fruits of their crimes and tions and other entities obligated to report suspicious transac- makes it more costly for them to continue their operation. tions to financial intelligence units need to be fully mobilized. This Enforce anti-money laundering and due diligence requirements. can be done through implementing due diligence measures and Regulators should strictly enforce know-your-customer and by monitoring transactions made by politically exposed persons due diligence requirements—particularly those for enhanced (PEPs)1 and actors in the sector. due diligence in the case of transactions of PEPs and suspicious Engage civil society. Nongovernmental organizations need to be transactions within the environmental and natural resource engaged as powerful partners who can help governments, law sectors. enforcement, and the judiciary to combat environmental and Employ all available criminal tools to address these complex crimes. natural resource crime. In many countries, civil society has already Special investigative techniques like electronic surveillance, played an important role in detecting large-scale forest crimes, in undercover operations, and witness protection measures are increasing awareness of the extent and impact of illegal logging, critical tools. and in conducting studies on the forest law enforcement system. Improve international cooperation. Law enforcement, investigators, Develop an integrated criminal justice strategy. To be effective, the and prosecutors should increase their efforts to cooperate with strategy must target high-level corruption and the companies other jurisdictions. When necessary, they should make formal mu- that pay bribes. It must aim for successful investigations, pros- tual legal and administrative assistance requests as established ecutions, and the confiscation of the proceeds of crime. Policies in treaties or international conventions like the UN Convention should give priority to major illegal cases and should devote the against Corruption, or they may wish to make informal peer-to- necessary resources to ensure that competent practitioners with peer requests for information and assistance. the required tools and expertise can take on these cases. Reform and modernize export procedures in trade facilitation Include criminal justice as part of development assistance programs projects. Trade facilitation seeks to improve the quality of control and country assistance programming. Making criminal justice while endeavoring to reduce the burden on legitimate trad- a component of development assistance strategies will help ers. This can involve enhanced risk management, information countries receive the support they need to address the challeng- exchange with foreign customs agencies, the use of information es related to forest law enforcement. and communication technology (ICT), anti-corruption measures, Proactively target vulnerabilities and significant offenders. Instead awareness raising of trade requirements, compliance strategies, of using the criminal justice system to fine or imprison low-level and quality management of customs brokers. To date, Bank trade criminals for regulatory offenses, law enforcement, investigators, facilitation projects largely concentrate on import procedures, and prosecutors should target major crimes and serial offenders. but a broadening to export procedures could improve controls in producer countries of illegal natural resources. 1 PEPs are those entrusted with public functions, their relatives, and close  associates. Enhanced due diligence applies to PEPs in recognition that Source: Goncalves et al 2012. by virtue of their position there is an increased risk of money laundering. E N F O R C I N G E N V I R O N M E N TA L L AW S F O R S T R O N G E C O N O M I E S A N D S A F E C O M M U N I T I E S C hapter 6 — T he W orld B ank G roup S upport for E N R L E F Y 2013 – 1 5 11 Chapter 6  HE WORLD BANK GROUP SUPPORT FOR ENRLE T FY2013–15 MOBILIZING THE COMMUNITY OF PRACTICE of their time, plus a dedicated variable budget, to provide quality control and design ENRLE inputs across the NRM In response to the evolving and volatile context of the illegal, unre- portfolio. ported, and often unregulated trade in environmental services and ƒƒ Provide ongoing training and learning events for the broader natural resources, we have to adapt our approach to law enforce- Community of Practice. ment within the Bank to meet the needs of our clients. ƒƒ Develop an expert advisory panel from outside the Bank that can volunteer time to review, guide, and comment as Building a constituency of support for ENRLE within necessary. the World Bank Key Actions: Strengthening country dialogue, identifying projects, ƒƒ Develop and execute an annual workplan for knowledge- and improving ENRLE project quality sharing events. Key Actions: ƒƒ Develop communications products to mobilize understand- ƒƒ Increase the emphasis on monitoring and evaluation in ing of the ENRLE field. ENRLE operations to understand how to structure global ƒƒ Present on ENRLE at key WBG events, including during responses to sustain and scale up impact beyond individual Annual Meetings and sector weeks. country operations. ƒƒ Develop a mission statement that succinctly says why ENRLE ƒƒ Design protocols, with the Development Economics Unit, matters to the Bank and captures the intention of the COP. the Agriculture and Environment Sector, and the Legal Sector, to perform diagnostic work on the state of natural Building Bank technical capacity in ENRLE resource crime as part of project preparation for all invest- Key Actions: ment operations in the NRM sector. ƒƒ Identify areas of ENRLE expertise that need improvement, ƒƒ Convene quality enhancement workshops in collaboration such as intelligence-led policing, anti-money laundering, with task teams working on ongoing ENRLE operations, forensics capacity building, and development of guidance to including the South Asia Regional IDA Wildlife series (Nepal, strengthen application. Bangladesh, and Bhutan) and work in Madagascar con- ƒƒ Map the existing specialties—in anti-money laundering, cerned with management of stocks of rosewood and ebony. environmental law, customs modernization, fraud and cor- ƒƒ Explore the frontiers in methodologies (including in ICT, ruption investigation, trade facilitation, and so on—within the deployment of drones, DNA analysis, intelligence-led the Bank and mobilize these resources in support of the policing, and so on) and how they can be applied in client ENRLE agenda. countries. ƒƒ Use this gap analysis and mapping to develop and execute a ƒƒ Develop, in association with the Development Economics learning program in association with the WBG Community of Unit, a developmentally oriented research agenda on Practice in Criminal Justice. conservation criminology and explore Bank sponsorship of ƒƒ Establish a Global Expert Team consisting of representatives a workshop bringing together criminology researchers, law from across VPUs who will be involved at least 50 percent enforcement practitioners, and civil society organizations. A G R I C U LT U R E A N D E N V I R O N M E N TA L S E R V I C E S D I S C U S S I O N PA P E R 12 C hapter 6 — T he W orld B ank G roup S upport for E N R L E F Y 2013 – 15 Fostering demand from our clients to enhance investment ƒƒ Contribute a study on the global financing needs for prioritization of law enforcement improved ENRLE to the summit on wildlife law enforcement Key Actions: planned for early 2014 by the U.K. government. ƒƒ Dedicate a budget for staff time and travel as a pre-invest- ment facility to support task teams as they prepare projects RESULTS WE WILL HELP OUR CLIENTS ACHIEVE and foster demand for sustainable NRM regimes. ƒƒ Leverage existing specializations to guide sector dialogue We will continue to support our clients’ progress toward the and improve our future project pipeline, including tieing Millennium Development Goals (MDGs), but we will also monitor future actions in with broader Bank governance and anti- indicators being tracked as part of the IDA/IBRD corporate score- corruption work, especially focusing on NRM. card. The selected MDGs reflect the global targets of clients and ƒƒ Mainstream attention to ENRLE across sector and financial development partners, not what we would achieve alone with our strategies, such as the GEF-6 biodiversity strategy. FY2013–15 program, but they are important to monitor, following the direction of causality of contributions from project-level indica- Providing global leadership by linking conservation tors, to sector performance, to reductions in poverty and hunger criminology to global law enforcement responses (see table 6.1). Key Actions: ƒƒ Strengthen the WBG role in ICCWC, including, but not Going forward, the Community of Practice will focus on two limited to, providing continued financial support from DGF. tenets of ENRLE: addressing the causes of crime and building Specifically, in FY2014 the COP will: the capacity of law enforcement authorities. ƒƒ Work with ICCWC to develop a set of ENRLE Law Enforcement Indicators that will be, among other things, To address the underlying causes of structural crime, we will focus on: the starting point for a revision of the ICCWC Forest and Wildlife Crime Assessment Toolkit. ƒƒ Rural poverty reduction and empowerment of disenfranchised groups. We will do this by ensuring that projects address- ƒƒ Integrate DGF-financed country analytic work by UNODC ing land tenure issues harden transactions to bring them in Peru and Bangladesh into improvements in the design in line with the Voluntary Guidelines on the Responsible and implementation of Bank-financed operations. Governance of Tenure of Land, Fisheries, and Forest and by ƒƒ Starting with the Lao PDR Protected Areas and Wildlife ensuring that greater support to community-based resource Project operation, facilitate use by Bank task teams of sup- management approaches and resource tenure reform are port for pre-investment work by INTERPOL available from woven into operations. a grant from the European Commission. ƒƒ Through support to the Africa Region for the implementa- TABLE 6.1: Results We Will Help Our Clients Achieve tion of the Global Environment Facility’s Medium Size Grant TARGETS/INDICATORS project on Fighting against Wildlife Poaching and Illegal 1. High-level results our clients are striving to achieve (MDGs) Trade in Africa, contribute recommendations on strengthen- Ensure environmental sustainability Integrate the principles of sustainable development ing national, regional, and global architecture for wildlife into country policies and programs and reverse the loss criminal intelligence and further facilitate the application of of environmental resources Reduce biodiversity loss innovations in DNA forensic work to the understanding of ivory poaching and smuggling. 2. Sector-level results that contribute to reducing poverty and hunger Environmental services Reduce the rate of average annual deforestation and ƒƒ In collaboration with the Task Force against Money increase the proportion of fish stocks within safe Laundering in Central Africa (the regional Financial Action biological limits Task Force–style body for the Economic and Monetary 3. Examples of project-level results projected in FY2013–15 that contribute to improved sector performance (attributable to project implementation) Community of Central Africa, consisting of Cameroon, Forest and tree cover Hectares of forest and tree cover area under manage- Central African Republic, Chad, Republic of Congo, Equatorial ment plans Guinea, and Gabon), the COP staff from the Financial Market Land Population and number of land parcels with use or Integrity Group will lead a study to better understand illicit ownership rights recorded; land area where sustainable land practices have been adopted financial flows related to wildlife crime in the subregion. E N F O R C I N G E N V I R O N M E N TA L L AW S F O R S T R O N G E C O N O M I E S A N D S A F E C O M M U N I T I E S C hapter 6 — T he W orld B ank G roup S upport for E N R L E F Y 2013 – 1 5 13 ƒƒ Reduction of corruption in natural resource agencies. This will instruments to identify gaps in capacity and weakness in rel- require developing and promoting anti-corruption tech- evant legal and institutional frameworks. Simultaneously, we niques and ethics standards for environment and NRM agen- will identify and employ new technologies, including the use cies implementing Bank-supported projects, including, for of DNA inventories to track illegal trade in natural resource example, asset disclosure requirements. We will also work with goods (such as elephant ivory). clients to introduce EITI standards to additional NRM sectors. ƒƒ Building the capacity of national agencies for crime detec- ƒƒ Better documentation of the value of the natural capital that tion, by, among other things, introducing the use of natural is being lost and the rate of loss, which will require economic resource inventories and assessment. Security and transpar- valuation approaches. ency of natural resource stockpiles (such as ivory and rhino horn) will be reviewed and addressed to reduce corrupt To build the capacity of international and national authorities to practices. execute law enforcement actions, we will focus on: ƒƒ Recovering illicit assets gained through criminal activities. We will strive to introduce the use of environmental and natural ƒƒ Training trade and customs authorities, prosecutors and resource crime as a predicate offense to anti-money launder- judges, and financial regulators. Specifically, we will apply ing and accelerate the adoption of public revenue tracking. diagnostic tools under the ICCWC Toolkit and other relevant A G R I C U LT U R E A N D E N V I R O N M E N TA L S E R V I C E S D I S C U S S I O N PA P E R REFERENCES 15 REFERENCES Agnew, D. J., J. Pearce, G. Pramod, T. Peatman, R. Watson, J. R. Beddington, Seneca Creek Associates and Wood Resources International. 2004. and T. J. 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