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The long road to prosecuting Moazu Kromah and his wildlife-trafficking network.

Liberian national Moazu Kromah – known as ‘Kampala Man’ – led one of the most active wildlife-trafficking syndicates on the African continent before his arrest in the Ugandan capital in February 2017.1

Just over five years later, over 11 000 kilometres away from the city in which he based his operation and from which his alias derives, Kromah quietly entered into a plea bargain with the Southern District of New York, which is known for tackling high-profile organized crime and corruption cases. Kromah pled guilty to three wildlife-trafficking offences for which he was indicted before being expelled to the US in 2019.2 His two co-accused made their own plea bargains in the following weeks.

Yet prosecuting members of Kromah’s network and the individuals who facilitated his shipments of ivory and other wildlife products is, collectively, a far larger task. Out of the 15 major ivory-trafficking cases known to be linked to Kromah’s network which have been prosecuted in the Kenyan courts since 2010, only one case has so far secured a conviction. These cases account for over 30 tonnes of seized ivory. Many of these prosecutions have been ongoing for several years.

The progress of law enforcement and prosecuting authorities in dismantling Kromah’s network provides a window into the challenges that prosecutors face in handling complex wildlife-trafficking cases. It also highlights the role that NGOs can play in supporting prosecutions and building both prosecution and law enforcement capacity.

The Kromah prosecution

Kromah was first arrested in Kampala in February 2017. Some 437 pieces of ivory weighing 1.3 tonnes were also seized.3 The operation was a collaboration between the Ugandan Wildlife Authority (UWA) and members of a Ugandan investigative NGO, the Natural Resource Conservation Network (NRCN),4 who had been carrying out a long-term investigation into Kromah’s network.5

The UWA and NRCN 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.’6

However, the case did not progress through the Ugandan courts, perhaps unsurprisingly: Kromah offered officials present a large cash bribe to make his case disappear and INTERPOL documents relating to his case were found at his house, suggesting he was used to corrupting criminal-justice systems.7 US authorities initiated another investigation: in 2018, a US confidential informant set up a deal where Kromah and his associates delivered three rhino horns to the US. With a case within the jurisdiction of US authorities’ secured, Kromah was again arrested in June 2019 and extradited to the US.8

Kromah was charged with three counts relating to wildlife trafficking and a fourth money laundering charge. He was charged alongside co-accused Mansur Mohamed Surur, a Kenyan citizen resident in Mombasa, and Amara Cherif, a Guinean national based in Conakry.9 A fourth co-accused, Abdi Hussein Ahmed, remains at large. Surur and Ahmed were also charged with narcotics trafficking, for conspiring to sell 10 kilograms of heroin to a buyer in New York, who was actually an undercover agent.10

At the time, the arrests of Kromah, Surur and Cherif were seen as a major coup for the prosecution of international wildlife trafficking. The collaboration between a coalition of Ugandan government and law enforcement officials, US agencies, and NGOs, was described as ‘unprecedented’ and ‘unparalleled’ in expert commentary.11 International NGO Save the Rhino expressed hope that ‘the case of Moazu Kromah gives a new example of such positive international collaboration.’12

The eventual plea bargain has been met with far less international fanfare.13 Some weeks after Kromah, Cherif pled guilty to the same three counts.14 This came after an application by Cherif to be tried separately from the other defendants was dismissed.15 This plea bargain came about despite Cherif’s seemingly turbulent relationship with his defence lawyer, whom at one point he accused of attempting to ‘pressure’ him into a plea agreement that he had not had the opportunity to read or understand.16 Surur also entered into a plea agreement on 1 June, pleading guilty to one count of conspiracy to commit wildlife trafficking and the narcotics trafficking charge.17 All three are yet to be sentenced.

In May, the US Department of State issued new rewards of up to US$1 million for information leading to the arrest of two Kenyan nationals linked to the Kromah case: Abdi Hussein Ahmed, co-accused in Kromah’s original indictment, and Badru Abdul Aziz Saleh, who was identified during the wildlife-trafficking investigation of Kromah’s associates and is now wanted on heroin-trafficking charges.18 Saleh was arrested just days after the reward was offered.19

Kromah’s criminal network

Kromah’s criminal network was vast,20 shipping ivory in containers from Mombasa, Kenya and Pemba (in northern Mozambique) and rhino horn by air from Entebbe, Uganda, and Nairobi, Kenya.21 The US indictment of Kromah argues that between 2012 and 2019, his network was responsible for trafficking at least 190 kilograms of rhino horn and at least 10 tonnes of elephant ivory, sourcing these products in Uganda, the DRC, Guinea, Senegal, Kenya, Tanzania and Mozambique.22 However, the true volumes of ivory trafficked by his network are thought to be far higher.

Wildlife trafficker Moazu Kromah and his sons upon their arrest in Kampala in 2017 (left); ivory seized from Kromah’s compound in Kampala (right). Wildlife trafficker Moazu Kromah and his sons upon their arrest in Kampala in 2017 (left); ivory seized from Kromah’s compound in Kampala (right).

Wildlife trafficker Moazu Kromah and his sons upon their arrest in Kampala in 2017 (left); ivory seized from Kromah’s compound in Kampala (right).

Photos: EAGLE network, www.eagle-enforcement.org

Kromah was operating during a period in which East Africa was experiencing an ivory poaching crisis. In 2013, the standing committee for the Convention on International Trade in Endangered Species of Wild Fauna and Flora singled out Kenya, Tanzania and Uganda as being among what became known as the ‘gang of eight’: the eight countries most heavily implicated in the illegal ivory trade.23

Analyses of seized evidence from police operations have argued that, at the time that Kromah was active, the transnational ivory trade was tightly controlled by a very small number of large-scale criminal networks. DNA analysis of ivory seizures, which found tusks from the same individual elephants in separate seizures that were transported through the same ports, concluded that individual traffickers were exporting dozens of large-scale shipments and that the high levels of interconnectivity suggested that as few as three major networks were controlling the bulk of the trade, based in Kenya, Uganda and Togo, respectively.24 Seizures containing matched tusks often had the same modus operandi as ivory trafficking.

Subsequent analysis of seizures between 2002 and 2019, which extended the DNA testing to include close genetic matches between tusks (showing closely related individual elephants in each seizure, indicating the tusks had been poached in the same incidents) suggested that these networks were even more closely connected than initially thought, to the extent that the authors argued that one major organized-crime network may have dominated the trade across Kenya and Uganda.25 All 12 seizures in the study, which had been containerized in Kampala and transited through Mombasa, contained tusks that were genetically linked.

Social-network analysis of phone records taken from a Uganda-based wildlife-trafficking network (which could not be named in the study because of the possibility of prejudicing ongoing court cases) also found significant cooperation of traffickers across East and West Africa. Trafficking groups were found to be operating closely as ‘allies of sorts’ across the region to supply South East Asian buyers.26

Kenya’s prosecution of cases linked to Kromah

Prosecutions of Kromah’s network and the individuals who facilitated shipments of ivory and other wildlife products for him are ongoing in several countries. In Kenya alone, we reviewed the progress of 15 major ivory-trafficking cases suspected to be linked to this network that have been in prosecution since 2010. While Kromah’s operation spanned across East and West Africa, Kenya was a key conduit for ivory shipments, particularly from the port of Mombasa.

Case number Seizure location Seizure date Volume of ivory seized (kg) Description Link to Kromah
1 Haiphong, Vietnam April
2011		 2 194 The ivory was seized in two containers packed with dried seaweed.27 An unnamed Kenyan facilitator was charged in a Mombasa court. However, the charges were later dropped due to lack of evidence relating to the seizure, as Vietnamese authorities did not appear in court to testify.28 Alleged involvement of Frederick Mungule, a clearing agent at Mombasa port linked to Kromah via other cases.29
2 Nairobi August
2011		 2 160 The ivory, along with five rhino horns, was packed in wooden boxes, destined for Malaysia as air freight from Nairobi.30 Kenneth Kamau Maina, whose ID was used to deliver the ivory to the airport, was acquitted on the defence that his ID had been stolen.31 He was subsequently arrested in relation to case 11 in this list. Maina, charged in this case, appeared as co-accused with a Guinean national, N’faly Doukoure, known to be linked to Kromah.32
3 Bangkok March
2011		 2 033 Thai officials seized a container of frozen mackerel with the ivory hidden inside. The container is believed to have originated in Kampala, Uganda, and transited Mombasa. Two Kenyan clearing agents, Fredrick Sababu Mungule (convicted in another case) and one other were reportedly found to be the facilitators of the shipment. They were never prosecuted.33 Vehicles and drivers involved in delivering this shipment to the port were also involved in Mombasa-related ivory shipments in March–April 2015 for which there are also charges ongoing in Mombasa (see case 13).34
4 Mombasa December
2011		 1 647 Some 465 pieces of elephant tusks, described as ‘soapstone handicrafts’, were packed in 60 well-secured cartons and eight wooden crates destined for export to Cambodia.35 No one was ever charged. This seizure contained a DNA match to another shipment from Kampala, which transited Mombasa, typical characteristics of exports by Kromah’s network.
5 Mombasa December
2011		 1 500 The Kenya Revenue Authority (KRA) scanned a container of apparent waste plastic and found the tusks inside. It was destined for Dubai. On 16 February 2012, clearing agent Sammy Ndiririgi Maina was arrested and charged with attempting to export the ivory.36 He was acquitted almost seven years later. KRA head of verification James Njagi was implicated in evidence as the facilitator of this shipment and another (see case 10).37
6 Hong Kong January
2013		 1 323 The container was shipped from Mombasa via Malaysia. Covered by architectural stone plates, the ivory tusks were packed in 40 sacks inside five wooden crates. Clearing agent Fredrick Mungule, KRA official James Kassiwa and Kenya Ports Authority employee Gideon Nyangau were charged. The case was merged with case 7 below and Kassiwa and Mungule were convicted in March 2022. The same logistics companies, drivers and vehicles were used to deliver seized ivory in other cases linked to Kromah not included in these selected example cases.38
7 Mombasa January
2013		 3 828 Several days after the Hong Kong seizure was made, this shipment was seized in a container in Mombasa, covered in the same flat stones. The cases were merged and Mungule and Kassiwa convicted.39 As above.
8 Singapore January
2013		 1 833 This ivory was shipped using the same method as cases 6 and 7 and the same three people were charged, with the addition of another KRA employee, Nelson Ayoo. The court ruled in February 2022 that the prosecution had not proved a prima facie case and the accused were acquitted.40 As above.
9 Mombasa May 2013 1 478 Dubai customs officers located the ivory in a container, declared as wooden furniture, during a routine X-ray scan.41 The ivory originated in Kampala and was transported to Mombasa for export to Malaysia. No arrests were made or charges filed. Two tusks were genetic matches to tusks in the shipment in case 7. Two further matches were made to the shipment in case 11.
10 Singapore March 2014 1 004 Hidden in a cargo of coffee beans, this shipment was seized in Singapore, having originated in Kampala and transited Mombasa port. Charges were filed in April 2017 against six defendants, with assistance from the Freeland Foundation and the Lusaka Agreement Task Force. The case is ongoing: the prosecutions case concluded in April 2022.42 KRA head of verification James Njagi was implicated in testimony as being the facilitator of this shipment and another (see case 5). The same logistics companies, drivers and vehicles were used to deliver the ivory as seen in other cases linked to Kromah.
11 Nairobi April 2014 784 The ivory was seized from a vehicle in Nairobi. Kenyan national Kenneth Maina (see case 2) and Guinean N’faly Doukoure were arrested. Doukoure was deported mid-trial for unknown reasons.43 The progression of the case against Maina is unknown. Doukoure is known to have been linked to several associates of Kromah.
12 Mombasa June 2014 2 152 Police made the seizure at the premises of Fuji Motors, Mombasa. Feisal Mohammed Ali was initially convicted, while several co-accused were acquitted, but the conviction was overruled on appeal. The appeal judge cited irregularities with the presentation of evidence.44 Feisal Mohammed Ali was known to have contacts to Kromah and the Akasha drug-trafficking network.45
13 Bangkok port April 2015 3 127 The ivory was found in a shipment of tea leaves destined for Laos. The clearing agent was Siginon Freight Services Limited, owned by a son of former Kenyan president Daniel Arap Moi, and the exporter was Potential Quality Supplies, run by brothers Nicholas and Samuel Jefwa (see case 14).46 Nine people – including three members of the same family, the Sheikhs – have been charged and the case is now in its seventh year. There were phone numbers in seized cell phones linked to Moazu Kromah, and the Kenyan Office of Director of Public Prosecutions stated that it had received intelligence from the US justice system linking the Sheikhs to the Kromah cartel and that the US believed that the cartel was behind the ivory shipment to Thailand.47
14 Singapore May 2015 4 600 Singaporean authorities seized a container declared as tea leaves but found to contain 1 783 pieces of ivory, five rhino horns and 23 lion’s teeth weighing approximately 4 600 kilograms in total.48 There were no charges brought in Kenya, but Xie Xingbang, member of the notorious Shuidong cartel, was charged and convicted as the buyer for this seizure in China.49 Brothers Samuel and Nicholas Jefwa were sought in connection with the contraband.50 The same clearing agent and exporter as in case 13.
15 Mombasa December 2016 1 097 The ivory was hidden in hollow wooden logs sealed with wax and declared as ceramics bound for Cambodia via Singapore. Some was identified as leaked from a Burundi government stockpile. Ephantus Gitonga Mbare was charged in December 2016 and acquitted in 2019.51 This shipment contained ivory from a Burundi state stockpile. Ivory from this stockpile had also been identified in several other seizures thought to be linked to Kromah, including from the 2017 raid on Kromah’s address in which he was arrested.52

Figure 1 Key wildlife-trafficking cases linked to Kromah in prosecution in Kenya since 2010.

Photo: Andrew Kasuku/AFP via Getty Images

Feisal Mohamed Ali in August 2018 during the appeal of his 20-year sentence for ivory-trafficking offences. The appeal was successful.

Feisal Mohamed Ali in August 2018 during the appeal of his 20-year sentence for ivory-trafficking offences. The appeal was successful.

Photo: Andrew Kasuku/AFP via Getty Images

Many more linked cases, some including smaller seizures of ivory and other wildlife products, are known to be in progress, in Kenya and in other East African countries. These 15 were selected to demonstrate the large-scale logistical capacities of the Kromah network and the typical modes of trafficking used. All 15 relate to a seizure of over (or, in one case, close to) one tonne of ivory.

Collectively, all of these prosecutions have so far resulted in the conviction of only two people: Fredrick Sababu Mungule, a clearing agent, and James Ngala Kassiwa, a Kenya Revenue Authority (KRA) officer. Mungule and Kassiwa were convicted in March 2022 in relation to two seizures, one of over three tonnes of ivory seized in Mombasa in 2013, the other of over a tonne seized in Hong Kong, shipped from Mombasa several days before.53 They received two-year sentences and it is understood that they will not appeal.54 The fact that these convictions came at the same time as Kromah’s guilty pleas in New York suggests that Mungule and Kassiwa may have chosen not to appeal for fear that evidence provided in the plea bargain could result in much longer sentences in an appeal procedure.

Mungule and Kassiwa’s convictions are currently the only successful major prosecution of international wildlife-trafficking in Kenya. The 2016 conviction of Feisal Mohamed Ali, a transporter and facilitator suspected to be linked to Kromah,55 was overturned on appeal. The appeal ruling cited several trial irregularities, such as the prosecution providing no witness testimony linking the truck that Feisal supposedly was driving to the seized ivory, and no testimony or forensic evidence linking Feisal to the ivory.56 Yet the seizure for which Feisal was originally convicted demonstrates clearly how interlinked major ivory seizures have been: DNA analysis of this seizure found genetic matches with 24 others.57

Many of these cases have seen considerable delays and adjournments. The conviction of Mungule and Kassiwa took nine years: a third accused died in the interim. Their conviction came just months after the same pair were acquitted in relation to another 2013 ivory seizure.58 In another case, which has now entered its seventh year,59 the court sat 29 times before the first witness testified, over two years after the first arrests.60 These adjournments arise for a variety of reasons, including issues with evidence disclosure, absent witnesses and frequent changes of prosecutors assigned to cases.

Similar courtroom delays are seen in other jurisdictions. A seizure of over three tonnes of ivory and over 400 kilograms of pangolin scales in Kampala in January 2019, linked to Kromah, has likewise faced numerous obstacles in the Ugandan courts.61 As hearings were repeatedly postponed, the prosecution process dissolved, in part due to the COVID-19 pandemic but also because interpreters and court officials were unavailable. The accused, released on bail, absconded, and prosecutors were compelled to adjourn the case indefinitely pending their re-arrest.62

In none of the 15 cases reviewed was the ultimate owner of the seized ivory ever established. The prosecutions, such as those of Feisal, Mungule and Kassiwa, have primarily targeted facilitators with more minor roles, such as clearing agents and transporters. In one case, a shipping agent named Ephantus Gitonga Mbare was prosecuted in relation to a tonne of ivory seized in Mombasa in 2016.63 ‘It is astounding that the only person charged in relation to the seizure was a lowly shipping agent,’ reported Wildlife Direct, an NGO that runs a court-monitoring programme recording the prosecutions of wildlife cases in Kenya.64 Mbare’s peripheral role in the case was what secured his acquittal, as it could not be proven that he knew that the shipment contained wildlife products. The trial magistrate noted that the prosecution had failed to identify other people involved in the case.65 In three of the cases reviewed for this analysis, no one has been charged.

There are several links between the accused in different cases. Mungule, one of the two people convicted, was linked to two other previous ivory shipments. James Njagi, former KRA head of verification at Mombasa Port, was implicated in two separate prosecutions. Njagi was charged in relation to a 2014 seizure made in Mombasa. A witness testified that Njagi’s ID was used when releasing the container holding the ivory for shipment. 66 Similarly, in relation to a 2011 seizure in Mombasa, Njagi’s name was identified on a verification form for the shipment found to contain ivory.67 Njagi argued that the document was a forgery.68

In several cases, the same vehicles and drivers, clearing agents and methods of smuggling crop up repeatedly.69 In two cases, the clearing agent used was Siginon Freight Services Limited, a company owned by the son of former Kenyan president Daniel Arap Moi.70

In the view of Wildlife Direct, the number of links between the accused in different major ivory cases prosecuted in Kenya suggests the existence of ‘a cartel controlling major shipments of ivory out of Kenya’. Their report concluded that based on the rate of convictions in major ivory cases, ‘this cartel, if it exists, remains beyond the reach of the law.’71

Systemic challenges in the prosecution of complex wildlife-trafficking cases

Kromah’s conviction in New York is just one part of the longer-term, often far less publicized work of untangling the networks of his associates and facilitators. For some commentators, the delays experienced in prosecuting these cases are an unavoidable consequence of prosecution authorities – some of them institutions still in their infancy – being restricted in terms of personnel, resources and capacity.72 Shamini Jayanathan, an advisor on environmental crime prosecutions at the UN Office on Drugs and Crime, argued that ‘failures in prosecution disclosure, lack of organization of witnesses, exhibits and lack of coordination with investigators are inevitable in the context of such limited prosecution resources.’73

There is also the potential influence of corruption in delaying – and, in some cases, derailing – court processes, as is suspected to have been the case in the initial Ugandan prosecution of Kromah.74

In this context, NGOs often play a role in assisting and monitoring prosecutions, including in the prosecution of Kromah and his associates. Court-monitoring programmes – in which trained observers record the outcomes of wildlife-crime cases, identify potential issues in court proceedings and help build prosecutorial capacity – have had a demonstrable impact in some East and southern African countries.75

Such programmes can follow two different approaches. First, some NGOs have taken on a role of monitoring the progress of wildlife-crime cases in courtrooms, publicizing the outcomes of these prosecutions and attempting to prevent corruption or weak prosecutions through public pressure. The work of Wildlife Direct’s ‘Eyes in the Courtroom’ project and the sharing of public information about ivory prosecutions through SEEJ-Africa (Saving Elephants through Education and Justice) both follow this first model.76 Second, other NGOs have taken on more of a capacity-building role, working closely with prosecuting authorities to identify where prosecutions are weakest and to tackle these shortcomings.

Outside of the courtroom, other NGOs are providing support to investigations and have been instrumental in gathering evidence on wildlife-trafficking networks.77 This has been influential, for example, in the role of the Natural Resource Conservation Network in investi-
gating Kromah before his 2017 arrest, as well as in the investigations of other major wildlife traffickers, such as Yang Feng Lan (the ‘Ivory Queen’) in Tanzania and Lin Yunhua, a major trafficker in Malawi.78

As prosecutions of Kromah’s associates continue to face stumbling blocks, NGOs and governments can consider how these partnerships may help overcome the challenges that lead to many prosecutions being delayed or ultimately unsuccessful.

Notes

  1. The investigation of Kromah’s network and the role of US investigators was covered in a previous issue of this Bulletin; see GI-TOC, Observatory of Illicit Economies in Eastern and Southern Africa Risk Bulletin, Issue 3, https://globalinitiative.net/analysis/esaobs-risk-bulletin-3. ↩

  2. Case 1:19-cr-00338-GHW Document 137 Filed 04/28/22, US SDNY vs. Moazu Kromah, Consent Preliminary Order of Forfeiture as to Specific Property, 30 March 2022. Available via the US PACER system. ↩

  3. Rodney Muhumuza, Uganda seizes ton of ivory, arrests 2 West African suspects, AP News, 18 February 2017, https://apnews.com/ebd7c6990d52412f85c2fe29dc36c7f0/uganda-seizes-ton-ivory-arrests-2-west-african-suspects. ↩

  4. Saving Elephants through Education and Justice (SEEJ-Africa), 1.3 tonnes of ivory seized from West African (Kromah) syndicate, 17 February 2017, https://www.seej-africa.org/linked-ivory-seizures/43-feb-2017-kampala-1-3-tonnes-of-ivory-from-west-african-syndicate. ↩

  5. The NRCN conducted this investigation as part of the EAGLE Network (Eco Activists for Governance and Law Enforcement), a coalition of NGOs working on investigating wildlife crime. See EAGLE Network, 1.3 ton of ivory seized in a crackdown on a West African criminal syndicate, 19 February 2017, https://www.eagle-enforcement.org/news/-A280. ↩

  6. Chris Morris, Moazu Kromah and the case of the West African ivory cartel, International Policy Digest, 24 August 2019, https://intpolicydigest.org/2019/08/24/moazu-kromah-and-the-case-of-the-west-african-ivory-cartel. ↩

  7. GI-TOC, Observatory of Illicit Economies in Eastern and Southern Africa Risk Bulletin, Issue 3, https://globalinitiative.net/analysis/esaobs-risk-bulletin-3. ↩

  8. Department of Justice, US Attorney’s Office, SDNY, Press release: Members Of African Criminal Enterprise Charged With Large-Scale Trafficking Of Rhinoceros Horns And Elephant Ivory And Heroin Distribution, 13 June 2019, https://www.justice.gov/usao-sdny/pr/members-african-criminal-enterprise-charged-large-scale-trafficking-rhinoceros-horns. ↩

  9. Case 1:19-cr-00338-GHW Document 3 Filed 05/07/19, US SDNY vs. Moazu Kromah, Amara Cherif, Mansur Mohamed Surur, Abdi Hussein Ahmed, 7 May 2019, https://storage.courtlistener.com/recap/gov.uscourts.nysd.515127/gov.uscourts.nysd.515127.3.0.pdf. ↩

  10. Case 1:19-cr-00338-GHW Document 125 Filed 02/28/22 US SDNY vs. Amara Cherif, Memorandum of Law of the United States of America in Opposition to Defendant Amara Cherif. Available via the US PACER system. ↩

  11. Chris Morris, Moazu Kromah and the Case of the West African Ivory Cartel, International Policy Digest, 24 August 2019, https://intpolicydigest.org/moazu-kromah-and-the-case-of-the-west-african-ivory-cartel; SEEJ-Africa, The ‘Enterprise’, the Burundi stockpile, and other ivory behind the Extradition, 2 September 2021, https://www.seej-africa.org/commentary/the-enterprise-the-burundi-stockpile-and-other-ivory-behind-the-extradition. ↩

  12. Emma Pereira, More international collaboration is needed to take down poaching syndicates, 28 June 2019, https://www.savetherhino.org/africa/international-collaboration-to-take-down-poaching-syndicates. ↩

  13. The only news coverage that the GI-TOC has seen so far covering Kromah’s plea is in a publication detailing the proceedings of the SDNY courthouse; see Matthew Russell Lee, In SDNY Rhino Horn Case Moazu Kromah Pleads Guilty After Telling of Liberia & Guinea, Inner City Press, 31 March 2022, http://www.innercitypress.com/sdny6rhinohornunsealed033122.html. After Surur’s guilty plea there was some coverage in the Kenyan press; see, for example: Capital FM, Kenyan Pleads Guilty to Conspiracy to Traffic Rhino Horn, Ivory in Manhattan, 2 June 2022, https://allafrica.com/stories/202206020219.html ↩

  14. Case 1:19-cr-00338-GHW Document 137, 27 April 2022. Available via the US PACER system. ↩

  15. Case 1:19-cr-00338-GHW Document 132, 14 April 2022. Available via the US PACER system. ↩

  16. Case 1:19-cr-00338-GHW Document 138, 12 April 2022. Available via the US PACER system. ↩

  17. Case 1:19-cr-00338-GHW Document 145, 1 June 2022, Available via the US PACER system, US SDNY vs. Mansur Mohamed Surur, Consent preliminary order of forfeiture as to specific property/money judgement. ↩

  18. US Department of State, Abdi Hussein Ahmed, Transnational Organized Crime Rewards Program, Bureau Of International Narcotics And Law Enforcement Affairs, 26 May 2022, https://www.state.gov/abdi-hussein-ahmed; US Department of State, Badru Abdul Aziz Saleh, Transnational Organized Crime Rewards Program, Bureau Of International Narcotics And Law Enforcement Affairs, May 26, 2022, https://www.state.gov/badru-abdul-aziz-saleh. ↩

  19. Mohammed Yusuf, Kenyan Fugitive Wanted for Wildlife, Drug Trafficking Arrested, VoA, 31 May 2022, https://www.voanews.com/a/kenyan-fugitive-wanted-for-wildlife-drug-trafficking-arrested/6597302.html ↩

  20. Chris Morris, Moazu Kromah and the case of the West African ivory cartel, International Policy Digest, 24 August 2019, https://intpolicydigest.org/2019/08/24/moazu-kromah-and-the-case-of-the-west-african-ivory-cartel. ↩

  21. GI-TOC, Observatory of Illicit Economies in Eastern and Southern Africa Risk Bulletin, Issue 3, https://globalinitiative.net/analysis/esaobs-risk-bulletin-3. ↩

  22. Case 1:19-cr-00338-GHW Document 3 Filed 05/07/19, US SDNY vs. Moazu Kromah, Amara Cherif, Mansur Mohamed Surur, Abdi Hussein Ahmed, 7 May 2019, https://storage.courtlistener.com/recap/gov.uscourts.nysd.515127/gov.uscourts.nysd.515127.3.0.pdf. ↩

  23. Matt McGrath, ‘Gang of eight’ on ivory probation, BBC News, 14 March 2013, https://www.bbc.com/news/science-environment-21788664. ↩

  24. Samuel K Wasser, et al., Combating transnational organized crime by linking multiple large ivory seizures to the same dealer, Science Advances, 4, 9, 2018. ↩

  25. Samuel K Wasser, et al., Elephant genotypes reveal the size and connectivity of transnational ivory traffickers, Nature Human Behaviour, 6, 2022, pp 371–382. ↩

  26. Jacopo Costa, Working Paper 35: Social network analysis applied to illegal wildlife trade between East Africa and Southeast Asia, Basel Institute on Governance, March 2021, https://baselgovernance.org/publications/SNA_IWT. Note that Costa’s paper does not state that the network is Uganda-based. This detail is given in Samuel K Wasser, et al., Elephant genotypes reveal the size and connectivity of transnational ivory traffickers, Nature Human Behaviour, 6, 2022, pp 371–382. ↩

  27. TRAFFIC, Major ivory seizures in Viet Nam, 27 May, 2010, https://www.traffic.org/news/major-ivory-seizures-in-viet-nam. Information on Fredrick Mungule derived from notes in an un-published document of ivory seizures prepared by Chris Morris, independent wildlife investigator and former member of Wildlife Direct’s ‘Eyes in the Courtroom’ project. ↩

  28. Personal communication from SEEJ-Africa, May 2022. ↩

  29. Information on Fredrick Mungule derived from notes in an unpublished document of ivory seizures prepared by Chris Mor-ris, independent wildlife investigator and former member of Wildlife Direct’s ‘Eyes in the Courtroom’ project. ↩

  30. Cosmas Butunyi, Two held as KWS seizes ivory cargo at Nairobi airport, 23 August, 2010, https://nation.africa/kenya/news/Two-held-as-KWS-seizes-ivory-cargo-at-Nairobi-airport-/1056-995518-71rjyk/index.html. ↩

  31. SEEJ-Africa, 2160 kg Ivory Seizure Jomo Kenyatta International Airport, 21 August 2010, https://www.seej-africa.org/linked-ivory-seizures/17-august-2010-jomo-kenyatta-ia-nairobi-2160-kg-ivory-seized-amongst-air-freight. ↩

  32. SEEJ-Africa, Kibera The Water Tanker Seizure, 17 April 2014, https://www.seej-africa.org/linked-ivory-seizures/110-cf-1673-2014-kibera-the-water-tanker-seizure. ↩

  33. SEEJ-Africa, Bangkok, Thailand – 2033 kg of Ivory From Mombasa Found in Container (Mungule 1), 30 March 2011, https://www.seej-africa.org/linked-ivory-seizures/117-march-2011-bangkok-thailand-2033-kg-of-ivory-from-mombasa-found-in-container. ↩

  34. Ibid. ↩

  35. Gitonga Marete and Bozo Jenje, Sh150m ivory haul seized at Kenyan port, Nation, 3 December, 2011. http://www.nation.co.ke/news/Sh150m-ivory-haul-seized-at-Kenyan-port-/-/1056/1283540/-/r56c3x/-/index.html. ↩

  36. SEEJ-Africa, On The Brink of Acquitting Another Ivory Trafficker, 15 April 2019, https://www.seej-africa.org/wildlife-court-cases/concluded/on-the-brink-of-acquitting-another-ivory-trafficker. ↩

  37. Ibid. ↩

  38. Notes in an unpublished document of ivory seizures prepared by Chris Morris, independant wildlife investigator and for-mer member of Wildlife Direct’s ‘Eyes in the Courtroom’ project. See also AP, Illegal ivory worth $1.4m seized in Hong Kong, The Guardian, 4 January 2013, https://www.theguardian.com/environment/2013/jan/04/illegal-ivory-seized-hong-kong. ↩

  39. SEEJ-Africa, Mombasa: Republic versus Fredrick Sababu and James Kassiwa, 14 January 2013, https://www.seej-africa.org/wildlife-court-cases/cf-417-2013-mombasa-republic-versus-fredrick-sababu-and-james-kassiwa. ↩

  40. Chris Morris, After Nine Years, a Kenyan Court Hands Down Guilty Verdict in Ivory Case, International Policy Digest, 14 April 2022, https://intpolicydigest.org/after-nine-years-a-kenyan-court-hands-down-guilty-verdict-in-ivory-case. ↩

  41. Caline Malek, Hundreds of pieces of raw elephant ivory seized in Dubai, The National, https://www.thenational.ae/uae/hundreds-of-pieces-of-raw-elephant-ivory-seized-in-dubai-1.255274. ↩

  42. SEEJ-Africa, Charges Laid in 2013 One Tonne Singapore Ivory Seizure, 25 March 2014, https://www.seej-africa.org/linked-ivory-seizures/a-2014-ivory-case-at-shanzu-court-41817. ↩

  43. SEEJ-Africa, Guinean national, N’faly Doukoure, and Kenyan Kenneth Kamau Maina found with 131 pieces of ivory hid-den in a water tanker, 17 April, 2014, https://www.seej-africa.org/linked-ivory-seizures/110-cf-1673-2014-kibera-the-water-tanker-seizure. ↩

  44. Chris Morris, The appeal acquittal of Feisal Mohamed Ali: A victory for rule of law, a process corrupted, or both?, Monga-bay, 17 August 2018, https://news.mongabay.com/2018/08/the-appeal-acquittal-of-feisal-mohamed-ali-a-victory-for-rule-of-law-a-process-corrupted-or-both-commentary. ↩

  45. Information from Feisal’s phone records obtained through police investigations reported in Kenya Law, Criminal Appeal 87 of 2016, 22 July, 2016, and an interview with Gretchen Peters in 2018, who at the time was conducting research on organized crime for the US Government; Chris Morris, The appeal acquittal of Feisal Mohamed Ali: A victory for rule of law, a process corrupt-ed, or both?, Mongabay, 17 August 2018, https://news.mongabay.com/2018/08/the-appeal-acquittal-of-feisal-mohamed-ali-a-victory-for-rule-of-law-a-process-corrupted-or-both-commentary. ↩

  46. SEEJ-Africa, Fugitive Mombasa Brothers Now Linked to West African Ivory Cartel, 1 June 2021, https://www.seej-africa.org/kenya/fugitive-mombasa-brothers-now-linked-to-west-african-ivory-cartel. ↩

  47. Joackim Bwana, Mombasa man and sons linked to Liberian smuggling suspect, The Standard, 23 June 2015, https://www.standardmedia.co.ke/coast/article/2001413728/mombasa-man-and-sons-linked-to-liberian-smuggling-suspect; Brian Ocharo, DPP on the spot over stalled Sh576m ivory case in Mombasa, Nation, 27 August 2019, https://www.nation.co.ke/counties/mombasa/DPP-accused-of-delaying-Sh576m-ivory-case/1954178-5250362-cnpikk/index.html. ↩

  48. SEEJ-Africa, No charges laid despite identical logistics for Thailand 3.8 tonne seizure three weeks previous, 16 May 2015, https://www.seej-africa.org/linked-ivory-seizures/38-may-16-2015-4-6-tonnes-of-ivory-from-mombasa-seized-in-a-shipment-of-tea-the-sheikhs-2. ↩

  49. EIA, Busted: China Customs dismantles major ivory trafficking syndicate, 11 January 2019, https://eia-international.org/press-releases/busted-china-customs-dismantles-major-ivory-trafficking-syndicate-2. ↩

  50. Daily Nation, Police hunt for Tanzanian, Kenyan brothers linked to Sh570 million ivory haul, Save the Elephants, 25 May 2015, https://www.savetheelephants.org/about-elephants-2-3-2/elephant-news-post/?detail=police-hunt-for-tanzanian-kenyan-brothers-linked-to-sh570-million-ivory-haul. ↩

  51. Jim Karani, Another trafficker walks free, Wildlife Direct, 26 April 2019, https://wildlifedirect.org/another-trafficker-walks-free. ↩

  52. SEEJ-Africa, Mombasa Ivory in Hollowed Out Timber, 20 December 2016, https://www.seej-africa.org/linked-ivory-seizures/cf-2511-2016-mombasa. ↩

  53. Cases 6 and 7 in our analysis. A third accused, former Kenya Ports Authority employee Gideon Nyangau, died before the proceedings concluded. ↩

  54. Personal communication from Chris Morris, independent wildlife investigator and former member of Wildlife Direct’s ‘Eyes in the Courtroom’ project. ↩

  55. This is according to information from Feisal’s phone records obtained through police investigations reported in Kenya Law, Criminal Appeal 87 of 2016, 22 July 2016, and an interview with Gretchen Peters conducted in 2018. At the time, Peters was conducting research on organized crime for the US Government. ↩

  56. Details of the case can be found in Feisal’s appeal court record; see Kenya Law, Criminal Appeal 87 of 2016, 22 July 2016, http://kenyalaw.org/caselaw/cases/view/158158. ↩

  57. Samuel K Wasser, et al., Elephant genotypes reveal the size and connectivity of transnational ivory traffickers, Nature Human Behaviour, 6, 2022, pp 371–382. ↩

  58. Case 8 in our analysis. ↩

  59. Case 13 in our analysis. Brian Ocharo, DPP on the spot over stalled Sh576m ivory case in Mombasa, Nation, 27 August 2019, https://www.nation.co.ke/counties/mombasa/DPP-accused-of-delaying-Sh576m-ivory-case/1954178-5250362-cnpikk/index.html. ↩

  60. Personal communication from Chris Morris, independent wildlife investigator and former member of Wildlife Direct’s ‘Eyes in the Courtroom’ project. Morris has continued to monitor this case. ↩

  61. This seizure is suspected to be linked to Kromah for several reasons: first, the shipment contained a tusk with a direct genetic link to a tusk seized at Kromah’s compound during his arrest in 2017, second, the method of concealment, in hollowed-out logs sealed with wax, was the same as in several other cases that also contained tusks genetically linked to the ivory seized at Kromah’s compound; and third, the shipment contained ivory stolen from a stockpile in Burundi, as had been found at Kromah’s compound and in several other linked seizures. See SEEJ-Africa, 3.3 tonnes of ivory destined for Vietnam, 24 January 2019, https://www.seej-africa.org/linked-ivory-seizures/48-january-2019-kampala-3-3-tonnes-of-ivory-destined-for-vietnam. ↩

  62. Environmental Investigation Agency (EIA), Three years on from Uganda’s 2019 ivory and pangolin scale seizure, there’s still no sight of justice, 26 January 2022, https://eia-international.org/news/three-years-on-from-ugandas-2019-ivory-and-pangolin-scale-seizure-theres-still-no-sight-of-justice. ↩

  63. Case 15 in our analysis. ↩

  64. Wildlife Direct, Crimes against wildlife and the environment: Kenya’s legal response to wildlife, forestry and fisheries crime, Court monitoring report 2018–2019, https://wildlifedirect.org/wp-content/uploads/2021/03/WildlifeDirect-4th-Eyes-in-the-CourtroomReport-2018-2019-1.pdf. ↩

  65. Ibid. ↩

  66. SEEJ-Africa, Charges Laid in 2013 One Tonne Singapore Ivory Seizure, 25 March 2014, https://www.seej-africa.org/linked-ivory-seizures/a-2014-ivory-case-at-shanzu-court-41817. ↩

  67. SEEJ-Africa, On The Brink of Acquitting Another Ivory Trafficker, 15 April 2019, https://www.seej-africa.org/wildlife-court-cases/concluded/on-the-brink-of-acquitting-another-ivory-trafficker. ↩

  68. SEEJ-Africa, Charges Laid in 2013 One Tonne Singapore Ivory Seizure, 25 March 2014, https://www.seej-africa.org/linked-ivory-seizures/a-2014-ivory-case-at-shanzu-court-41817. ↩

  69. For example, in cases 1 and 13 in our analysis, and cases 6 and 7. ↩

  70. SEEJ-Africa, 4.6 tonnes of Ivory From Mombasa Seized in a Shipment of Tea (The Sheikh’s #2), 16 May 2015, https://www.seej-africa.org/linked-ivory-seizures/38-may-16-2015-4-6-tonnes-of-ivory-from-mombasa-seized-in-a-shipment-of-tea-the-sheikhs-2. ↩

  71. Wildlife Direct, Crimes against wildlife and the environment: Kenya’s legal response to wildlife, forestry and fisheries crime, Court monitoring report 2018–2019, https://wildlifedirect.org/wp-content/uploads/2021/03/WildlifeDirect-4th-Eyes-in-the-Courtroom-Report-2018-2019-1.pdf. ↩

  72. Shamini Jayanathan, Africa’s hot and dusty courtrooms – a frontline in the global fight against illegal wildlife trade, EIA, 16 May 2022, https://eia-international.org/blog/africas-hot-and-dusty-courtrooms-a-frontline-in-the-global-fight-against-illegal-wildlife-trade. ↩

  73. Ibid. ↩

  74. See discussion in a previous iteration of this Bulletin: GI-TOC, Observatory of Illicit Economies in East and Southern Africa Risk Bulletin, Issue 3, https://globalinitiative.net/analysis/esaobs-risk-bulletin-3. ↩

  75. See discussion relating to the impact of a court-monitoring project in Malawi in Victoria May, et al., A Review of Wildlife Crime Court Cases in Malawi 2010–2017: A technical report produced on behalf of the Department of National Parks & Wildlife of Malawi, Lilongwe Wildlife Trust, Citizens for Justice, November 2017, https://www.lilongwewildlife.org/wp-content/uploads/Malawi.Wildlife.Justice.Report.2017.pdf. For a discussion of how conviction rates in Kenya have improved in recent years, see also Wildlife Direct, Crimes against wildlife and the environment: Kenya’s legal response to wildlife, forestry and fisheries crime, Court monitoring report 2018–2019, https://wildlifedirect.org/wp-content/uploads/2021/03/WildlifeDirect-4th-Eyes-in-the-Courtroom-Report-2018-2019-1.pdf. ↩

  76. Available at https://wildlifedirect.org/eyes-in-the-courtroom and https://www.seej-africa.org. ↩

  77. EAGLE Network, 1.3 ton of ivory seized in a crackdown on a West African criminal syndicate, 19 February 2017, https://www.eagle-enforcement.org/news/-A280. ↩

  78. For discussion of both the Yang Feng Lan and Lin Yunhua cases, see GI-TOC, Observatory of Illicit Economies in East and Southern Africa Risk Bulletin, Issues 4, https://globalinitiative.net/analysis/esaobs-risk-bulletin-4, and Issue 16, https://globalinitiative.net/wp-content/uploads/2021/03/GITOC-Eastern-and-Southern-Africa-Risk-Bulletin-16.pdf. ↩