Since corruption often facilitates environmental crimes such as deforestation and land conversion, illegal mining, and the illegal wildlife trade, corruption-related red flags can also be a good indicator of environmental crime related risk in certain high-risk jurisdictions. This page provides an overview of some key corruption red flags; it is intended to be an indicative rather than exhaustive list.

Corruption red flags

Suspicious financial transactions

  • Large, frequent or unexplained cash or wire deposits payments, transfers, or withdrawals involving:

    • Government or senior officials or other politically exposed persons (PEPs), especially from environment, agriculture, forestry, mining or other natural resources, or land management ministries.

    • Customs or border control officials, law enforcement, police, border guards, or highway checkpoint personnel.

    • Rapid movement of funds through multiple accounts, currencies, or institutions

  • Transactions inconsistent with a client’s usual business activity, commercial purpose, or known profile.

  • Offshore business activities by public officials responsible for environment or land/tenure rights, without disclosure.

Unusual official behaviour or wealth

  • Customs or other government officials showing sudden, unexplained wealth (e.g. luxury vehicles, expensive homes) inconsistent with their salary.

  • Evidence of association (e.g. pictures in the media or links via associated companies or company ownership) with officials, those subject to adverse media, or those operating in natural resource/high risk commodity sectors.

Irregular or incomplete documentation

  • Dubious trade or shipment documentation (e.g. invoices, shipping forms), suggesting forgery or manipulation.

  • Customer’s inability to provide valid documentation for financial transactions (e.g. invoices, originator/beneficiary details).

  • Evidence of double invoicing or inconsistent documentation.

Environmental crime type
High corruption risk industries
Deforestation and land conversion
Agribusiness (e.g. cattle, soy, palm oil, rubber)
May be linked to land grabbing, illegal land clearing, and manipulation of land titles.

Timber and Logging
Can involve bribery for logging permits, falsified transport documents, and collusion with forest officials.

Land Administration & Cadastre Authorities
May be subject to corruption in land titling, reclassification of protected areas, or unauthorised land concessions.

Infrastructure and Construction (e.g. roads, dams)
Projects may be used to open access to forests, often with manipulated environmental assessments.

Customs & Border Control
Corrupt officials may facilitate smuggling of commodities linked to deforestation.

Transport & Logistics Companies
Can be used to smuggle commodities linked to deforestation, often involving collusion with customs or police.
Illegal mining
Environmental and Agricultural Ministries
Officials may approve illegal land clearances or overlook violations in exchange for bribes.

MiningLicensing & Permitting Agencies
Often a high risk of corruption in granting or extending exploration/extraction rights.

Customs  & Border Control
Corrupt officials may facilitate smuggling of illegally mined commodities.

Transport & Logistics Companies
Can be used to smuggle illegally mined commodities, often involving collusionwith customs or police.

Military  & Security Forces
Can be bribed to protect illegal operations or turn a blind eye. 

Precious  metals and gemstone refining or jewellery
Often used to  launder illegally mined commodities.
Illegal wildlife trade
Wildlife Traders & Pet Shops
May be involved in enabling or covering up the illegal wildlife trade.

Tourism & Trophy Hunting Operators
In some cases, linked to laundering or trafficking under the guise of legal hunting or ecotourism.

Customs & Border Control
Corrupt officials may facilitate smuggling of illegally species.

Transport & Logistics Companies
Used to smuggle illegal species, often involving collusion with customs or police.
Geographic/ jurisdictional indicators
Sectoral indicators
Financial transactions & services indicators
Client profile indicators
Transportation & trade-based money laundering indicators
Corruption indicators
Human rights indicators
Reporting regulatory requirements & best practices for FIs

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.

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