See link for charting of network.
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A major crackdown on pangolin, elephant ivory, and rosewood smugglers in Thailand is demonstrating the critical role financial intelligence can play in taking down wildlife crime networks.
On April 19, Thai police arrested Kampanart Chaiyamart (a.k.a Sia Tang or Sia Thang[1]), a Thai-Vietnamese national at the center of a major wildlife trafficking ring. Kampanart’s sister, Daorueng Chaiyamart, is the owner of the Star Tiger Zoo in the Chaiyaphum province in northeastern Thailand. Daorueng was arrested in 2010 for involvement in trafficking tigers from Malaysia and Thailand into Vietnam via Laos, though she was never formally prosecuted.[2] Thai authorities now allege that Kampanart used his sister’s connection to Star Tiger Zoo to smuggle elephant ivory from the north of Thailand into China, and live pangolins to southern Thailand.
Kampanart’s network was also involved in smuggling of protected Thai rosewood to China on a massive scale. It was as Kampanart was on his way to purchase rosewood from a trader named “Mr. Tavorn” in the Khao Yai Forest north of Bangkok that police apprehended him. Police found Kampanart when they stopped his vehicle at a police checkpoint and noticed that he appeared to be part of a convoy of cars that included a vehicle with no license plates. In another of the cars, it turns out, were two of Kampanart’s associates, Somachai Valjupo and Chartchai Prabchanasuek, both of whom had been hired to keep lookout during the rosewood purchase.[3]
Upon being taken to the police station in Chok Chai for questioning, Kampanart provided police with information about the scale and nature of his network’s operations, which police believe has been involved in wildlife smuggling since 2000.[4] Though he’s currently out on bail, Kampanart’s network is the subject of a major investigation by the Anti-Money Laundering Office (AMLO), Thailand’s financial intelligence unit, which is responsible for detecting and preventing illicit financial activity. AMLO’s work has helped to reveal the complex web of businesses, associates, and multi-jurisdictional money transfers Kampanart relied upon to conceal the nature of his ring’s activities. Press reports from Thailand indicate that the Kampanart network relied upon typologies of financial crime activity frequently associated with wildlife trafficking. These included:
· Multi-country accounts and payments: According to AMLO, Kampanart relied upon a vast network of associates throughout Southeast Asia to handle transactions. Kampanart’s networks utilized as many as 28 separate accounts and exploited his connections in Thailand, Vietnam, Laos, and Malaysia to move money. Payments related to rosewood shipments originated in Laos and were sent via Kampanart’s associates in southern Thailand to accounts in Malaysia.[5]
· Bribery: The journalist Bryan Christy has noted that “where there is long-term high-volume international wildlife trafficking there is certain to be one or more government officers who are either complicit in the smuggling or so complacent as to be reasonably considered an accomplice.”[6] Wildlife traffickers frequently pay bribes to secure the favors and protection of corrupt officials, and Kampanart’s network was no exception. After two members of Kampanart’s network, including an individual named Jakkarin Larpchai, were arrested on January 27, 2014, in Khon Buri, Thailand, for rosewood smuggling, four other members of Kampanart’s network, acting at Kampanart’s request, attempted to bribe police to the tune of 1.5 million Thai baht (approximately USD $45,000) to secure the release of Larpchai and the other detained individual.[7] While in that instance police refused took take the bribe and arrested those who attempted the payment, police are investigating Kampanart’s links to the brother of a politician in Thailand’s north.[8]
· Cash: According to the Bangkok Post, at the time of his arrest, Kampanart had 4.7 million Thai baht (approx. USD $150,000) in his possession that he intended to use for purchasing rosewood.[9] Stashes of cash were found at Star Tiger Zoo when Thai police searched the zoo. The network appears to have relied heavily upon cash transactions.
· Multiple business interests: In addition to Star Tiger Zoo, the Kampanart network appears to have had other ostensibly legitimate business interests that it used as fronts for its illicit dealings. Kampanart and his wife, Ketsirin Lertkhampom, owned a car dealership that they may have used to launder their funds. [10]
AMLO believes Kampanart’s network laundered as much as 1.18 billion Thai baht (approximately USD $35 million) between 2011 and 2014 using his web of accounts, connections, and business interests.
In addition to revealing the methods Kampanart’s network used to launder its illicit gains, AMLO has seized assets worth over 1 billion Thai baht (approximately USD $30 million)[11] belonging to Kampanart and his associates. These include:
· Homes – AMLO seized properties belonging to Kampanart’s sister Daorueng; his wife; and his associate Wanida Wongsai, who was arrested along with Kampanart on April 19.
· Jewelry – Police found 14 luxury women’s watches at Kampanart’s wife’s home.
· Cars – 29 cars were seized from the car dealership Kampanart and his wife jointly own.
· Cash – Police seized 6 million Thai baht (approximately USD $185,000) in cash from members of the network.
· Land – Members of Kampanart’s ring owned as many as 24 plots of land between them.
In addition to the investigation into the Kampanart network, the Thai press revealed this summer that AMLO is investigating another major rosewood smuggling operation based in Thailand’s north, this one headed by an individual named Pakin Siriwarom.
As with the Kampanart network, Pakin’s ring involved a network of individuals operating across Thailand’s borders with Laos and relied upon a web of business interests, including car dealerships, designed to give its activities a legitimate face.
Pakin’s car dealership leased cars to its members for use in smuggling rosewood to Laos, where the ring stored rosewood before selling it. By leasing the cars to members of the network, Pakin’s car dealership could reclaim the vehicles if they were seized by the police, claiming the dealership was not involved in the smuggling. When the rosewood was sold in Laos, AMLO discovered, money mules would deposit cash into the accounts of nominees – that is, accounts held by an individual on behalf of someone else. Nominee accounts are useful to money launderers because they make it easy to conceal the identity of the person on whose behalf an account is actually used and on whose behalf the nominee is acting.
After depositing cash into the nominee accounts in Laos, other individuals would withdraw the funds from ATMs and convert the funds to US dollars. The dollars were then taken into Thailand, declared as proceeds of gambling or legitimate export activity, and were in turn laundered through a vast network of tour companies, car dealerships, and other businesses. According to The Nation, relatives of individuals involved with the gang were employed at banks used for depositing funds.[12]
AMLO’s seizures and its vast investigation into the Kampanart and Pakin networks demonstrate the importance of complementing the investigations of wildlife, forestry, and law enforcement officials with robust financial intelligence in the effort to expose wildlife traffickers. AMLO’s investigations into the Kampanart and Pakin networks may prove critical as Thai authorities pursue charges. Other countries would do well to follow Thailand’s examples and ensure that their financial intelligence units have sufficient resources to detect financial flows related to wildlife trafficking, as well as the legislative frameworks necessary to permit timely and meaningful asset seizures.
[1] “AMLO seizes Bt27 million from illicit rosewood trader,” The Nation, June 14, 2014. http://www.nationmultimedia.
[2] “Officials seize over $40 million from wildlife smuggling ring,” Thai Royal Embassy. http://www.thaiembdc.org/dcdp/
[3] “Rooting out the rosewood robbers,” Chaiyot Yongcharoenchai, Bangkok Post, May 11, 2014. http://www.bangkokpost.com/
[4] “AMLO follows the money trail to bring down Siamese rosewood smuggling cartel,” Piyanut Tumnukasetchai, The Nation, July 21, 2014. http://www.nationmultimedia.
[5] “AMLO seizes Bt27 million from illicit rosewood trader,” The Nation; “B1bn seized from wildlife, timber gang,” King-oua Laohong, Bangkok Post, May 6, 2014.http://www.bangkokpost.com/
[6] “The Serpent King,” Bryan Christy, Foreign Policy, 29 December 2010.
[7] “Rooting out the rosewood robbers,” Chaiyot Yongcharoenchai, Bangkok Post.
[8] “AMLO follows the money trail to bring down Siamese rosewood smuggling cartel,” Piyanut Tumnukasetchai, The Nation.
[9] “AMLO reveals huge seizures,” Piyanut Tumnukasetchai, The Nation, May 7, 2014. http://www.nationmultimedia.
[10] “Rooting out the rosewood robbers,” Chaiyot Yongcharoenchai, Bangkok Post.
[11] “AMLO reveals huge seizures,” Piyanut Tumnukasetchai, The Nation.
[12] “AMLO follows the money trail to bring down Siamese rosewood smuggling cartel,” Piyanut Tumnukasetchai, The Nation.