Recent high-profile arrests by US and Chinese law-enforcement agencies have dismantled major wildlife-trafficking networks that operated across the continent.

In June 2019, Moazu Kromah (of Liberian nationality) and three associates were indicted by the court of the Southern District of New York (SDNY) on charges of wildlife trafficking, money laundering and heroin distribution.1 The indictment documents a conspiracy to traffic 190 kilograms of rhino horn and at least 10 tonnes of elephant ivory, and intent to distribute more than 10 kilograms of heroin.2

In January 2019, the China Customs Anti-Smuggling Bureau (ASB) apprehended and repatriated Ou Haiqiang from Nigeria on an INTERPOL red notice.3 Ou was the last of the three major ivory traffickers leading the Shuidong syndicate4 to be arrested and brought back to China for prosecution.5

Both these cases led to the dismantling of major wildlife trafficking networks. Both involved long-term investigations into transnational crime syndicates led by investigators from jurisdictions outside the continent, who had been given the mandate and resources to investigate transnational organized wildlife crime relatively recently.

The Kromah cartel

The Kromah cartel, or Guinea cartel, was one of the major organized wildlife crime networks operating in Africa.6 Based out of Uganda, their operations stretched from West Africa, through Central Africa, to East Africa – shipping ivory in containers from Mombasa, Kenya, and Pemba, northern Mozambique, and rhino horn by air from Entebbe, Uganda, and Nairobi, Kenya.7 At one time, the network reached as far south as the Mozambican capital, Maputo.8 The indictment reads that Kromah’s wildlife trafficking activities dated back to at least December 2012.9 This is significant because the date tallies with a landmark seizure by Malaysian customs officers on 11 December 2012,10 which contained four tonnes of ivory from East Africa and two tonnes from West Africa.11 At the time, this was the second largest ivory seizure ever, and the only large seizure to contain ivory of mixed origins – suggesting a criminal network that extended across Africa.

Overview of the Kromah network: major trafficking routes, key hubs and countries of activity

Figure 1 Overview of the Kromah network: major trafficking routes, key hubs and countries of activity

SOURCE: Members of African criminal enterprise charged with large-scale trafficking of rhinoceros horns and elephant ivory and heroin distribution, Department of Justice, U.S. Attorney’s Office, Southern District of New York, 13 June 2019,, along with author’s own research.

Kromah was first arrested in February 2017 in a compound in Kampala, Uganda, where 437 pieces of ivory weighing 1.3 tonnes were also found.12 The Uganda Wildlife Authority (UWA), who made the arrest, and the Natural Resources Conservation Network, a Ugandan NGO that supports the UWA with investigations and prosecutions, described Kromah as being at ‘the centre of a vast ring of organized criminals … connected to at least four other major criminal syndicates … supplying the biggest wildlife criminal syndicates worldwide.’13 The case never progressed through the Ugandan courts, which is perhaps not surprising, given that an internal INTERPOL document referring to Kromah was found in the house where he was arrested.14

The size and importance of the Kromah cartel, and its members’ impunity, attracted the attention of the United States Fish and Wildlife Service (USFWS) Office of Law Enforcement in early 2017. Crucially, new legislation had just come into force. The 2016 END Wildlife Trafficking Act15 and the February 2017 Presidential Executive Order on Transnational Criminal Organisations and Trafficking16 expanded the USFWS’s mandate to investigate international wildlife traffickers. They drew on expertise from the US Drug Enforcement Administration (DEA), which has longstanding experience tackling transnational criminal networks17 and had recently dismantled the Akasha network in Kenya, which had been involved in narcotics and ivory trafficking (see Risk Bulletin issue 1 for more on the Akasha network).18 The two-year USFWS-led investigation involved national law-enforcement authorities and partners in at least five African countries, and was supported by the DEA and SDNY.

The investigation worked with so-called vetted units,19 which have been established to investigate organized crime and for which personnel undergo formal vetting procedures, such as interviews, polygraph tests and background checks.20 The investigation also worked with other ‘trusted partners’, which may not have under­gone formal vetting but which are known to operate effectively and typically without the influence of corruption, as well as experienced confidential sources. The case was built until it included a US nexus21 – which allows the senior figures to be prosecuted by the SDNY, who specialize in complex cases involving corruption and transnational organized crime.

The Shuidong syndicate

Like the Kromah cartel, the Shuidong syndicate, named for the town in southern China, was a major ivory trafficking network. This network had been smuggling ivory from Tanzania to China for more than 20 years22 and claimed that Shuidong was the destination for 80% of all poached ivory illegally trafficked to China from Africa.23 The Environmental Investigation Agency’s (EIA) two-year undercover investigation revealed the syndicate’s trafficking and money-laundering methods. It emerged that traders from Shuidong originally involved in shipping sea cucumbers from Zanzibar had diversified into illicit trade in ivory and other wildlife products.24 When enforcement tightened up in Tanzania in 2015/16, they shifted operations to Pemba and, latterly, Nigeria in 2017. The syndicate relied on corruption and money laundering, and concealed their ivory shipments among legitimate products. They chose routes using several transit ports to avoid detection. Accomplices, including corrupt government officials and complicit freight agents, were placed at strategic points along the trade chain, which enabled the syndicate to ‘own the route’.25

Before they published their report, the EIA provided confidential information to China Customs.26 The ASB then led a raid of Shuidong, involving some 500 enforcement officers. One of the three key syndicate figures, Wang Kangwen, was arrested, convicted and sentenced to 15 years’ imprisonment.27 The two other key figures were found to be in Africa. Under instructions from President Xi Jinping to focus on the illegal wildlife trade (IWT) and ivory trafficking in particular,28 the ASB launched an international investigation, gathering information on the suspects and engaging with law-enforcement authorities in Tanzania, Mozambique and Nigeria. The second key trafficker, Xie Xingbang, was tracked down in Tanzania and voluntarily returned to China to face trial. He was convicted and sentenced to six years’ imprisonment. Finally, on 5 January 2019, in a coordinated operation, Ou Haiqiang was arrested by law enforcement in Nigeria and repatriated to China. So far, 11 suspects have been convicted in China.29

Overview of the Shuidong network: major trafficking routes, key hubs and countries of activity

Figure 2 Overview of the Shuidong network: major trafficking routes, key hubs and countries of activity

SOURCE: The Shuidong connection: Exposing the global hub of the illegal ivory trade, Environmental Investigation Agency, 4 July 2017,

Different motivations

Despite the similarities between these two investigations – both of which were led by competent national law-enforcement authorities from well-resourced countries that were given the mandate and means to operate transnationally – the motivations of the US and China are nevertheless markedly different. It is worth understanding their mandates, and how they might affect the prospects for more investigations of this kind.

The US authorities engage in long-term investigations that dismantle transnational criminal networks on the premise that these networks are either involved in shipping illicit products that will end up in the US, are associating with terrorist networks, or, more broadly, disrupt global governance and rule of law, which leads to a more insecure world and thus negatively impacts US security.

These broad motivations mean that US law enforcement will often support investigations that don’t involve US citizens or where the US connection takes time to become apparent. The focus on global governance also means that they broadcast their actions widely.

Chinese law-enforcement authorities seek to prevent accusations of neocolonial intervention and emphasize the national sovereignty of law-enforcement action.30 However, they have become more involved in tackling transnational organized crime that involves Chinese citizens for two main reasons – firstly, because President Xi has articulated his interest in positioning China as a global leader on ecological governance,31 which includes making wildlife crime a priority law enforcement issue.32 Secondly, these investigations protect China’s international image, especially in priority countries for China’s Belt and Road initiative.33 Therefore, Chinese law-enforcement activities outside China focus only on Chinese citizens, with a view to bringing them back to China for prosecution. And the Chinese authorities, unlike their American counterparts, do not broadcast their interventions internationally, as China views law-enforcement action as the sole purview of the sovereign state where it occurred.

Promising as these investigations are, the risk of relying on external countries to drive them is that domestic priorities are not addressed if they don’t fall within the scope of these mandates. Transnational wildlife trafficking networks that do not involve Chinese nationals, affect Chinese citizens, or where no US nexus can be found or developed, would not fall under the purview of either country. For example. Vietnamese networks, which play a major role in trafficking all kinds of wildlife products, including ivory and rhino horn from southern Africa to Vietnam, might not fall within these US or Chinese mandates, and therefore may go uninvestigated.34

The role of African states in transnational IWT investigations

The fact that these investigations were driven by non-­African countries demonstrates that the countries directly affected by poaching activities of transnational syndicates are not able to build prosecutions themselves. Across the Eastern and Southern African region, corruption sours prospects for effective local enforcement of wildlife trafficking laws. In many countries, syndicates are protected by political figures, sometimes at very high levels, who use their influence to ensure that investigations do not proceed or that prosecutions fail.

What’s more, in resource-strapped countries investigation agencies often do not take on these complex cases because they lack the resources to fund lengthy investigations that require transnational liaison and payments to confidential informants or sources. Where caseloads are overwhelming, and success is measured by the number of cases closed, investigators are incentivized to focus on easier cases.

However, the Chinese and American investigative teams both worked in close cooperation with national authorities and their partners – often relying on them for local investigations, expertise and operational capacity. These collaborations mitigated the potential for corruption to influence the investigations by working with vetted units and trusted individuals within national authorities. They also kept different parts of the investigations separate to limit the damage of information leaking out, and sometimes exerting higher-level political pressure to ensure that the arrest and expulsions of key individuals happened. Given greater independence, access to resources and an incentive to investigate transnational syndicates, local investigative authorities were able to perform to high standards.

These cases demonstrate what local authorities are capable of when given the required support. Tackling transnational organized crime in this region will require changes. These cases show that it can be done, hand-in-hand with local authorities.


  1. Members of African criminal enterprise charged with large-scale trafficking of rhinoceros horns and elephant ivory and heroin distribution, 13 June 2019,

  2. See

  3. EIA (UK), China customs disrupts major wildlife trafficking syndicate, World Customs Organisation News Vol. 88,

  4. The Shuidong connection: Exposing the global hub of the illegal ivory trade, 4 July 2017,

  5. Shreya Dasgupta, China busts major ivory trafficking gang following EIA investigation, Mongabay, 15 January 2019,

  6. Chris Morris, Moazu Kromah and the case of the West African ivory cartel, International Policy Digest, 24 August 2019,

  7. Interview with United States Government investigator, November 2019, email correspondence. 

  8. Interview with Ugandan investigator, April 2017, email correspondence. 

  9. See United States v Moazu Kromah and others. United States Southern District of New York. 18 CRIM 338. Sealed indictment,

  10. TRAFFIC, Massive African ivory seizure in Malaysia, 11 December 2012,

  11. Wasser et al, Genetic assignment of large seizures of elephant ivory reveals Africa’s major poaching hotspots, Science, 3 July 2015,

  12. Rodney Muhumuza, Uganda seizes ton of ivory, arrests 2 West African suspects, AP News, 18 February 2017,

  13. Chris Morris, Moazu Kromah and the case of the West African ivory cartel, International Policy Digest, 24 August 2019,

  14. Interview with Ugandan investigator, May 2018. 

  15. See Eliminate, Neutralize, and Disrupt Wildlife Trafficking Act of 2016, Public Law No: 114-231 (10/07/2016), 114th Congress of the Government of the United States,

  16. See Presidential Executive Order on Enforcing Federal Law with Respect to Transnational Criminal Organizations and Preventing International Trafficking, February 2017, Government of the United States,

  17. Tucker Reals, How Prince William helped U.S. agents bust a major wildlife and drug smuggling network, CBS News, 14 June 2019,

  18. Tristan McConnell, ‘They’re like the mafia’: the super gangs behind Africa’s poaching crisis, The Guardian, 19 August 2017,

  19. See, for example, DEA: Kenyan drug traffickers arrive in US to face charges, Drug Enforcement Administration of the United States, 31 January 2017,

  20. The US Drug Enforcement Agency uses formal vetted units all around the world. For more information, see 

  21. Rachel Nuwer, Arrest of key ivory and rhino horn trafficker signals a game change – Conservationists, law enforcement team up to infiltrate wildlife crime syndicate, Sierra, 25 June 2019,

  22. The Shuidong connection: Exposing the global hub of the illegal ivory trade, 4 July 2017,

  23. Ibid. 

  24. EIA (UK), China customs disrupts major wildlife trafficking syndicate, World Customs Organisation News Vol. 88,

  25. Ibid. 

  26. Personal communication with Mary Rice of the EIA, July 2017. 

  27. EIA (UK), China customs disrupts major wildlife trafficking syndicate, World Customs Organisation News Vol. 88,

  28. See: Feature: China continues strengthening ivory ban, 23 January 2019, Xinhua,

  29. Busted! China customs dismantles major ivory trafficking syndicate, 11 January 2019,

  30. Interview with Chinese illegal wildlife trade and law-enforcement expert, November 2019. 

  31. Heidi Wang-Kaeding, What does Xi Jinping’s new phrase ‘ecological civilization’ mean?, The Diplomat, 6 March 2018,

  32. China spearheads campaign to end illegal wildlife trade, 6 May 2019,

  33. See Daniel Russel, How to clean up the Belt and Road, Bloomberg, 11 June 2019,

  34. See, for example, Environmental Investigation Agency, ‘Exposing the Hydra’: The growing role of Vietnamese syndicates in ivory trafficking, 2018,