Xavier Aubert: Strengthening Cross-Border Wildlife Crime Detection

This World Wildlife Day, ACAMS Today sat down with Xavier Aubert, CAMS. Aubert is an anti-money laundering/know your customer (AML/KYC) professional with international experience across Chile, Canada and Luxembourg. He served as consultant and is now working as director and head of the Compliance division at NOVA Partners, a consulting firm based in Luxembourg.

Recognized for his in‑depth knowledge of AML and KYC regulatory requirements—particularly within the Luxembourg financial sector—he has built a career focused on strengthening compliance frameworks and supporting financial institutions (FIs) in complying with evolving regulatory expectations. Aubert received his Certified Anti-Money Laundering Specialist (CAMS) designation in 2021. 

Aubert is looking to raise awareness among anti-financial crime professionals on complex AML/KYC problems and dissecting them into easy-to-understand formats. He has published several articles on various topics such as the challenges of central bank digital currencies, the effects of cannabis legalization in Canada and the European legislation against illegal wildlife trade. This theme is of particular interest to Aubert, which is why he also made a video explaining the money laundering techniques in the illegal wildlife trade. He wishes to continue to involve himself with nongovernmental organizations (NGOs) and FIs to stop this scourge. Aubert has been an active associate and writer for the International Studies and Research Center of the prestigious Pontifical Catholic University of Chile, for which he explained European economic, political and social issues. 

Aubert is the former communications director for the ACAMS Montreal Chapter board. 

In an effort to contribute to the sharing of knowledge, Aubert became involved with an NGO in Colombia in order to teach underprivileged children.

ACAMS Today (AT): From your perspective, what are the most critical red flags FIs should monitor to detect transactions linked to wildlife crime?

Xavier Aubert (XA): FIs should focus on transactional behavior that is inconsistent with a client’s declared business activity. One key red flag is a mismatch between a company’s stated sector and its financial flows. For example, a small seafood exporter or agricultural trader receiving large transfers from jurisdictions associated with ivory or pangolin trafficking may indicate that wildlife products are being concealed within legitimate trade.

Another important indicator is structured cross-border payments, where multiple transfers just below reporting thresholds are sent to the same counterparties in known wildlife trafficking hubs such as Vietnam, Thailand or parts of Southern China. These payment patterns may indicate attempts to fragment financial flows to avoid detection and reporting obligations, particularly when they involve high-risk jurisdictions linked to wildlife trafficking networks.

Trade-based money laundering (TBML) is also frequently used. Compliance teams should closely examine invoice inconsistencies, abnormal pricing, or vague product descriptions, such as shipments declared as “plastic scrap” or “frozen fish” but associated with payments significantly above market value. These discrepancies can indicate attempts to disguise illegal wildlife products within legitimate supply chains and international trade transactions.

Finally, sectors adjacent to wildlife trade such as exotic pet dealers, taxidermy services, traditional medicine suppliers, wildlife breeding facilities or specialized animal exporters should be monitored for unusual cash activity, rapid growth in international transactions or payments routed through intermediaries in multiple jurisdictions. Combining transaction monitoring with customs data, NGO intelligence and trade information can significantly improve detection capabilities and help institutions identify suspicious financial flows linked to wildlife trafficking.

AT: Based on your research, what emerging money laundering techniques tied to wildlife crime should compliance teams be preparing for?

XA: Wildlife trafficking networks are increasingly adopting more sophisticated financial strategies and adapting to evolving financial systems. One notable development is the use of online marketplaces and e-commerce platforms to facilitate the sale of wildlife products. Traffickers may advertise items such as “legal antiques,” “collectibles” or “traditional medicine ingredients,” while payments are processed through legitimate payment providers, digital wallets or fintech platforms. These mechanisms create an additional layer of legitimacy that complicates detection for FIs and regulators.

Another significant trend is the convergence between wildlife crime and other forms of organized crime, including illegal logging, illegal fishing and narcotics trafficking. Criminal groups often rely on the same logistics networks, transportation routes, corruption channels and financial intermediaries. By mixing proceeds from different criminal activities, they can obscure the origin of funds and make financial investigations more complex.

There is also a gradual increase in the use of cryptocurrencies, particularly in peer-to-peer marketplaces where exotic animals or rare wildlife products are traded. Although the overall volume remains relatively limited compared to traditional financial channels such as cash and bank transfers, crypto-assets introduce additional challenges related to anonymity, cross-border transactions and decentralized platforms.

In addition, traffickers frequently rely on front companies operating in logistics, seafood trading, timber exports or agricultural businesses. These companies provide a legitimate commercial façade while facilitating both the transportation of illicit wildlife products and the laundering of related financial proceeds through seemingly legitimate trade transactions.

AT: How can compliance teams strengthen cross-border collaboration to better identify and disrupt illicit financial flows connected to wildlife trafficking?

XA: Because wildlife trafficking operates across multiple jurisdictions, effective detection requires robust international cooperation and systematic information-sharing between institutions and authorities. One practical approach is strengthening public-private partnerships between FIs and financial intelligence units (FIUs). Collaborative initiatives allow banks to exchange typologies, operational intelligence and real-life case studies related to wildlife trafficking networks. These frameworks help FIs to better understand emerging risks and develop more effective detection tools.

Collaboration should also extend beyond the financial sector. Compliance teams can benefit from closer engagement with customs authorities, environmental enforcement agencies, wildlife protection bodies and specialized NGOs that monitor trafficking routes and seizure data. These organizations often possess valuable intelligence on emerging smuggling techniques, geographic hot spots and criminal networks involved in wildlife trafficking.

Another key mechanism is cross-border sharing of suspicious activity reports between FIUs. Wildlife trafficking networks frequently operate through intermediary jurisdictions to fragment financial flows and reduce the risk of detection. Effective international information exchange allows authorities to reconstruct the full financial network and identify key actors involved in trafficking operations.

Finally, institutions should develop regional risk frameworks that identify high-risk corridors (such as Central Africa to East Asia or Latin America to North America) where wildlife trafficking and related financial flows are frequently concentrated. Understanding these geographic patterns allows compliance teams to refine monitoring systems and strengthen risk-based controls.

AT: Considering the broad impact of illegal wildlife trade on biodiversity and financial integrity, what steps do you believe organizations should take to integrate environmental crime risk assessments into their existing AML frameworks?

XA: Organizations should begin by formally recognizing environmental crime as a material financial-crime risk within their AML risk assessments. Despite the scale of the illegal wildlife trade (estimated to generate billions of dollars annually), it is still insufficiently integrated into many compliance frameworks. As a result, FIs may underestimate the exposure of certain sectors or clients to wildlife trafficking risks.

Second, institutions should develop sector-specific risk indicators for industries that may intersect with wildlife trade. Businesses such as exotic pet traders, taxidermy services, wildlife tourism operators, traditional medicine suppliers, wildlife breeding farms or animal product exporters may require enhanced due diligence. This should include verification of supply chains, licensing documentation and beneficial ownership structures to ensure that companies are not being used as fronts for illegal activities.

Training and awareness are also essential as compliance professionals should understand how wildlife trafficking networks operate financially, including typologies such as shell companies, TBML schemes, complex international payment chains and the use of intermediaries in multiple jurisdictions.

Last but not least, environmental crime risks should be embedded within broader environmental social and governance strategies. This includes board-level oversight, integration into enterprise risk management frameworks and collaboration with regulators, international organizations, conservation NGOs and law enforcement agencies to improve intelligence-sharing and strengthen the overall response to environmental crime.

Interviewed by: Karla Monterrosa-Yancey, CAMS, ACAMS, [email protected]

Ben Bahner, CAMS, ACAMS, [email protected]