Corruption – in both the public and private sectors – often acts as a “door-opener” for environmental crime. Corrupt public sector officials, particularly in commodity source countries, may enable illegal activity, and undermine the ability of law enforcement and the judiciary to effectively combat it. Similarly, corrupt private sector actors in the supply chain – from importers and exporters, extraction companies, refiners and smelters, manufacturers to traders, brokers and lawyers etc. may facilitate criminal activity by giving or receiving bribes.
Complex corporate structures – such as shell or front companies – enable actors to hide true beneficial ownership or links to criminal activity, avoid official oversight, or engage in tax evasion. This can present challenges for firms looking to distinguish between legitimate and illegal activities among their suppliers, business partners, or third parties, especially in industries that carry more environment-related risks. When used, front or shell companies often have ties to the import-export sector, to seem like they are issuing legitimate invoices and payments to suppliers, thereby covering up illegal trade practices.
Between 2022 and 2023, cocoa illegally grown inside Nigeria’s protected Omo Forest Reserve was routinely funnelled through licensed buying agents and sold to major international suppliers like Olam, Tulip, and Starlink, despite bans on agriculture in the conservation zone. The supply chain involved unregistered farms, licensed agents operating from illegal warehouses, and opaque intermediaries who lacked any formal traceability or deforestation checks. Cocoa was transported in unmarked vehicles to exporters' facilities, bypassing certification requirements, while traders used vague sourcing arrangements, minimal due diligence, and no verifiable land titles or geolocation data, enabling the laundering of deforestation-linked cocoa into global chocolate supply chains. This case highlights clear client profile red flags: use of front actors, absence of environmental compliance documentation, and purchasing agents who operated from high-risk, conservation-sensitive areas with minimal transparency or traceable oversight.
Criminals may look to take advantage of PEPs or their relatives or close associates (RCAs) in their family or network, leveraging such relationships for political favours or to avoid law enforcement.
Clients unable to provide evidence of compliance with local environmental requirements (e.g., permits, land titles, export licenses, etc).
Deforestation: Look for clients with forestry concessions or timber export licenses in high-risk regions like the Amazon, Congo Basin, or Southeast Asia, particularly where volumes exceed sustainable harvesting limits.
Illegal Mining: Focus on mining licenses in conflict zones or regions with weak governance. Absence of mineral extraction licenses is a key indicator of miners operating illegally on protected or Indigenous lands.
Wildlife Crime: Monitor clients with hunting licenses, wildlife export permits, or operations near protected areas and biodiversity hotspots.
Clients who possess land management or natural resource control rights, or those who have family members or close associates with such rights.
Clients listed as managers or directors of several companies linked to environmental extraction.
Individuals managing multiple resource companies may be linked to shell firms used to disguise illegal extraction operations, especially in remote regions.
Clients with a history of operating in conflict zones or areas with high rates of environmental crime.
In conflict zones (e.g., DRC, parts of Amazon basin), armed groups often profit from unregulated mining, raising risks for companies sourcing from these regions.
Clients involved in import/export, freight forwarding, customs clearance, logistics or construction.
Endangered wildlife commodities such as ivory, pangolin scales, and rosewood often travel long distances to destination markets, raising risks for freight-logistics firms, especially as shipping containers are under-inspected by authorities.
Companies active in commodity trading (as these can be used to conceal illicit commodities or products, such as timber, frozen foods, plastics and rubber, or agricultural products such as coffee).
Traders of perishable goods may use these supply chains to smuggle similar wildlife products – for example, traders may conceal endangered eels among legal specimens.
Clients lacking sector-specific experience.
Complex or illogical corporate structures, including an unnecessary number of shell companies.
Fraudulent corporate layering can mask attempts to evade tax on mining profits.
Individuals with an unrealistic number of directorships (this might indicate interconnected companies that are attempting to present themselves as unrelated).
Shared names, addresses or directors across companies which may indicate mass registrations.
A trafficking ring smuggling rhino horn and pangolin scales from South Africa and Namibia to markets in Laos and Vietnam used complex layers of shell trading firms, often with the same directors across multiple entities and registered in offshore or unrelated jurisdictions, to disguise beneficial ownership.
Seemingly circular relationships or ownerships between companies, which can be indicative of attempts to obscure beneficial ownership, launder money or transact fraudulently.
Obscured ownership can disguise illegal breeding or trading facilities posing as legitimate zoos or exporters.
General trading companies set up as foreign entities and registered at residential addresses.
Shell companies often registered far from actual logging operations may be used to legitimise timber or agricultural commodity transactions.
Trade entities with no visible industrial/commercial footprint, e.g. registered and operating from a residential address without any industrial or commercial premises.
In Peru, a network of shell exporters (registered at residential addresses, with no visible operations and minimal online presence) bought gold illegally mined in Amazonian reserves, issuing falsified legality permits and invoices to cover its origin. The operation layered proceeds by moving payments through multiple front companies across Latin America before repatriating funds via round-tripping, which were then reinvested in real estate and luxury vehicles.
Entities utilising copy names, almost identical to a very well-known trading entity, perhaps to pretend that it is part of a larger well-established group which it has no connection to.
Long periods of dormancy, especially if followed by a spike in revenue (criminals may strategically age companies to maintain a low profile before using it for nefarious means).
Where revenue seems at odds with the number of employees.
Outliers relating to company or client information, for example, a beneficial owner that is improbably young or old.
Minimal or inconsistent online presence (e.g. no website or digital presence, lack of specific information on webpage, or use of non-business email addresses like hotmail or gmail for business purposes).
Intermediary companies that are operating out of rural or high-risk regions for environmental crimes.
Offshore companies tied to mining claims in high-risk jurisdictions should be scrutinised for potentially laundering proceeds from unlicensed operations.
Entities based in frontier agricultural zones (e.g., forest edges in Brazil, Indonesia) may be engaged in speculative land grabs or illegal forest clearance.
For further information on key geographical risks,
see geographical indicators page and risk assessment.
Discrepancies between residency or nationality of company directors or beneficial owners and jurisdiction of registration, especially where one of those countries is high-risk for money laundering or for environmental crime risk.
Intermediary companies registered in offshore jurisdictions, particularly those identified as having a higher prevalence of shell companies or lacking transparency in beneficial ownership.
Companies registered offshore but operating in tropical forest regions (e.g., the Amazon, Congo Basin, Southeast Asia) may be obscuring illegal land acquisition or agricultural expansion.
Involvement of foreign PEPs in corporate or ownership structures, particularly when front companies are used to hide them. Pay particular attention to PEPs from countries with significant natural resources (forestry officials, mining ministers, wildlife protection authorities) who may abuse their positions to grant illegal concessions or permits.
As outlined by the FATF, a company in one country may use offshore financial centres to obscure a connection with a subsidiary that has a PEP as a director, while using connections to this PEP to illegally obtain a mine concession.
Clients who are overly secretive or evasive about details such as their identity, source of wealth or funds, nature of their business, the end-use of a product or about the co-signor/co-signee, residential address, beneficial owners of accounts, or reasons for choosing a particular payment method. hide them. Pay particular attention to PEPs from countries with significant natural resources (forestry officials, mining ministers, wildlife protection authorities) who may abuse their positions to grant illegal concessions or permits.
Clients unwilling to identify end-users or receivers of animal shipments may be engaged in laundering trafficked species under false paperwork.
The address provided by a client is unknown, seems incorrect, or is a correspondence rather than a physical address (e.g. a PO Box or mass registration address).
Multiple bank accounts held by a customer individually or along with closely related family members. These accounts may be held at one or more financial institutions.
Large deposits made into personal accounts of unemployed individuals.
Large, unexplained personal deposits in gold- or mineral-rich areas may indicate cash payments from unregulated mining activities.
Deposits that exceed declared income.
Account activity inconsistent with the declared nature of business.
Multiple customers or accounts sharing the same address or phone number without justifiable grounds, or where these are frequently changed without justifiable grounds.
Exporters whose volume/value exceeds what is available in the region.
Exporters reporting unusually high outputs of soy, palm oil, or beef may be laundering products from illegally deforested areas.
The Environmental Crimes Financial Toolkit is developed by WWF and Themis, with support from the Climate Solutions Partnership (CSP). The CSP is a philanthropic collaboration between HSBC, WRI and WWF, with a global network of local partners, aiming at scaling up innovative nature-based solutions, and supporting the transition of the energy sector to renewables in Asia, by combining our resources, knowledge, and insight.
Clients who are overly secretive or evasive about details such as their identity, source of wealth or funds, nature of their business, the end-use of a product or about the co-signor/co-signee, residential address, beneficial owners of accounts, or reasons for choosing a particular payment method.
The address provided by a client is unknown, seems incorrect, or is a correspondence rather than a physical address (e.g. a PO Box or mass registration address).
A client identified as a manager or director of several companies linked to environmental extraction or with a history of sourcing from conflict zones or areas with high rates of land conversion or violence.
Clients who possess land management or natural resource control rights in their home country, or those who have family members or close associates with such rights.
Intermediary companies that are operating out of a rural area, particularly one in a higher risk jurisdiction or region for land conversion.
Intermediary companies that are registered in an offshore jurisdiction, particularly in one identified as having a higher prevalence of shell companies or lacking transparency in beneficial ownership.
Businesses involved in commodity trading (as these can be used to conceal illicit commodities or products, such as timber, frozen foods, plastics and rubber, or agricultural products such as coffee).
General trading companies set up as foreign entities and registered at residential addresses.
Multiple bank accounts held by a customer individually or along with closely related family members. These accounts may be held at one or more financial institutions. Such accounts may be used to facilitate the placement and layering of illicit funds.
Involvement of a client’s legitimate business in import/export, freight forwarding, customs clearance, logistics or constructions.
Any reluctance to offer information about the business at hand, the end-use of a product or about the consignor/consignee, as this could potentially be due to a shell company being set up to mask the actual ownership.
Large deposits made into personal accounts of unemployed individuals.
Deposits made into accounts which are significantly above declared income.
Account activity which does not seem in line with the declared nature of business.
Multiple customers or accounts sharing the same address or phone number without justifiable grounds, or where these are frequently changed without justifiable grounds.
A complex and illogical corporate structure, including an unnecessary number of shell companies within its corporate structure.
Individual clients holding an unrealistic number of directorships (this might indicate interconnected companies that are attempting to present themselves as unrelated).
Corporate formation patterns where companies share names, addresses or directors or where there are indications of mass registration, which could indicate an attempt to obscure ownership.
Jurisdictional irregularities, like where identified residency or nationality of company directors or beneficial owners are different to a company’s country of registration, where one of those countries is high-risk for money laundering or for land conversion-related financial crime risk.
Anomalies in financial activity which might indicate shell company behaviour: for example, where revenue seems at odds with the number of employees.
Outliers relating to company or client information; for example, a beneficial owner that is improbably young or old.
Company online presence that seems inconsistent with business activity or size (e.g. no website or digital presence, lack of specific information on webpage, or use of non-business email addresses like hotmail or gmail for business purposes).
Seemingly circular relationships or ownerships between companies, which can be indicative of attempts to obscure beneficial ownership, launder money or transact fraudulently.
Long periods of dormancy, especially if followed by a spike in revenue (criminals may strategically age companies in order to maintain a low profile before using it for nefarious means).
A trade entity registered and operating from a residential address without any industrial or commercial premises.
An entity which utilises a copy name, almost identical to a very well-known trading entity, perhaps to pretend that it is part of a larger well-established group which it has no connection to.
Clients with a lack of experience/background in a commodities sector.
Organisations in the metals sector lacking an adequate organisational structure.
Clients that are unable to provide evidence of compliance with local environmental requirements (e.g. proof of permit for environmental activity, export, land purchase/lease agreements, etc.)
Clients whose stated business is to export products of land conversion but where the volume/value is in excess of what is available in the region.
Customers with mining licenses operating in or around active conflict zones.
Individuals identified as managers or directors of several companies linked to environmental extraction.
High-Risk Location Patterns
Large cash withdrawals from institutions in remote areas near illegal mining or conservation zones
Significant cash payments from high-risk jurisdictions for illegal mining/wildlife trade
Transfers between free trade zones or countries with weak beneficial ownership transparency
Cross-Border Movements
Deposits from foreign companies followed by immediate transfers to other jurisdictions
Escrow-type transactions with same beneficial owner for cross-border shipments
Multiple MVTS transfers in regions known for environmental crime
In October 2024, Interpol dismantled two criminal networks across Paraguay–Brazil–Argentina. These syndicates logged and trafficked timber using forged permits, and laundered proceeds by cycling them through fake companies in the Tri-Border. They then parked illicit funds in real estate and offshore holdings.
