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Money Laundering from Environmental Crime: Typologies and Trends in Countries in the Amazon Region

What can we learn from 230 environmental crimes committed in countries in the Amazon region over the past ten years? FACT’s latest report analyzes publicly available case data to better understand how these crimes are committed and how their associated profits are laundered. By understanding regional trends, typologies, and red flags, this report aims to inform policy discussions and law enforcement efforts in the Amazon region to curtail illegal deforestation, protect local communities, and strengthen the rule of law.

As a U.S. organization working on public policy, FACT also hopes that this report will inform U.S. efforts to address environmental crime and illicit finance. Through the 2024 Amazon Region Initiative Against Illicit Finance, the U.S. Treasury Department has committed to enhanced information sharing, new “follow the money” training programs, and joint investigations with countries in the Amazon region on issues pertaining to environmental crime. By taking stock of current needs and realities in the region, this report provides insights on the types of information sharing, technical assistance, and collaboration that are most needed to maximize the impact of the Amazon Region Initiative.

Click here to read the report in Spanish.

The 230 cases analyzed in the report leave important clues as to how environmental crimes are being committed and how the proceeds are laundered. We hope that law enforcement and policymakers can use this information to combat environmental crimes going forward.

Key takeaways and implications of these findings include:

  • Parallel Financial Investigations: Going forward, it is important to improve countries’ capacity to integrate financial investigations into their environmental crime investigation and enforcement actions. The U.S. government should support these efforts through capacity building and technical assistance to countries in the Amazon region, leveraging the existing framework of Treasury’s Amazon Region Initiative. Other regional and international stakeholders, including the Organization of American States and the United Nations Office on Drugs and Crime (UNODC), should continue capacity-building efforts related to illicit finance and environmental crime.
  • Information Exchange among Source, Transit, and Destination Countries: Timely, robust Information exchange between countries is essential. As noted in a recent report by the Egmont Group, “jurisdictions may need to recognise the illicit financial flows of wildlife crime and that these flows may cross into jurisdictions beyond source countries.” Among the 230 cases identified in this report, a relatively small percentage (25 percent of all cases, and 45 percent of “follow the money” cases) mentioned the involvement of other countries. Going forward, more and better international cooperation is needed in order to uncover transnational linkages and networks. The Amazon Region Initiative provides an ideal mechanism. If properly leveraged, the initiative can provide an opportunity for meaningful, timely information exchange pertaining to environmental crimes.
  • Abuse of Legal Persons: The results of this report suggest that shell and front companies play a pervasive role in environmental crimes. Going forward, countries in the region should redouble efforts surrounding beneficial ownership and corporate transparency in line with the Financial Action Task Force (FATF) standards. In the U.S., the Treasury should continue with robust, meaningful implementation of the bipartisan Corporate Transparency Act (CTA) to address issues with U.S. shell companies. Moreover, U.S. government agencies should establish protocols to share beneficial ownership information with trusted foreign partner governments, as is clearly permitted by U.S. regulations and the statute of the CTA.
  • Corruption as an Environmental Crime Issue: Since corruption has emerged as the single most prevalent convergent crime, efforts should be taken to address governance and anti corruption alongside environmental crime.53 As the United States chairs the United Nations Convention against Corruption (UNCAC) for the next year, it should prioritize efforts to address corruption linked to environmental crime and natural resources, as well as advocate for stronger global commitments to tackle environmental crime and corruption at the UNCAC’s 11th Conference of States Parties in 2025, and in other multilateral fora.

Many thanks to the following individuals for reviewing and otherwise contributing to this report:

  • John Dodsworth, World Wildlife Federation (WWF)
  • Corinna Gilfillan, UNCAC Coalition
  • Zorka Milin, FACT Coalition
  • Thomas Georges, FACT Coalition
  • Ian Gary, FACT Coalition
  • Erica Hanichak, FACT Coalition

Daniela Altamirano Crosby, former FACT Policy Fellow, contributed invaluable research assistance.

The recommendations and views expressed in this report are those of the FACT secretariat and do not necessarily reflect the views of our editors, coalition members, or funders.