By Ezaruku Draku Franklin

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated Malaysian national Teo Boon Ching, the Teo Boon Ching Wildlife Trafficking Transnational Criminal Organization (TCO), and the Malaysian company Sunrise Greenland Sdn. Bhd. for the cruel trafficking of endangered and threatened wildlife and the products of brutal poaching.

“OFAC is designating the Teo Boon Ching Wildlife Trafficking TCO pursuant to Executive Order (E.O.) 13581, as amended, for being a foreign person that constitutes a significant transnational criminal organization. Teo Boon Ching is being designated pursuant to E.O. 13581, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, the Teo Boon Ching Wildlife Trafficking TCO. Teo Boon Ching’s Malaysia-based company Sunrise Greenland Sdn. Bhd. is being designated pursuant to E.O. 13581, as amended, for being owned or controlled by, directly or indirectly, Teo Boon Ching,” the statement from the treasury department states.

The U.S. Department of the Treasury is a member of the Presidential Task Force on Wildlife Trafficking, established by E.O. 13648, which coordinates a U.S. government-wide approach to combat wildlife trafficking. To implement its strategy to combat wildlife trafficking, Treasury uses numerous preventive, diagnostic, and pressure tools, including the application of economic sanctions, when appropriate.

The Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. In a statement said Teo Boon Ching specializes in the transportation of rhino horn, ivory, and pangolins from Africa, generally utilizing routes through Malaysia and Laos and onward to consumers in Vietnam and China.

Nelson said the action is the result of a collaboration between the U.S. Department of the Treasury, the U.S. Fish and Wildlife Service, U.S. Department of State, and the U.S Department of Justice and that the United States appreciates the assistance of the Royal Thai Government in this case.

 “Wildlife trafficking groups are cruel and inhumane, and they also perpetuate corruption and illicit finance. The United States considers wildlife trafficking to be not only a critical conservation concern, but also a threat to global security,” he said.

Despite the fact that the international trade in rhino horn has been highly regulated and largely banned for decades, horns and items carved from those horns remain highly valued commodities in certain countries.

As a result of widespread poaching between 1970 and 1992, an estimated 96 percent of black rhinos, one of two types of African rhino species, were lost to poaching. Today, there are only approximately 5,000 black rhinos remaining in the wild. International agreements, such as the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), exist to ensure the trade in wild animals does not threaten their survival.

Black rhinos, African elephants found in certain African countries, and some species of pangolins are currently listed by CITES as threatened with extinction, its most severe category. Trade in such species is only permitted in exceptional circumstances.

The treasury department statement says today, wildlife poaching is often coordinated by organized criminal syndicates and that specialized transporters, such as Teo Boon Ching, smuggle the resulting wildlife parts, such as rhino horn and ivory, out of Africa and onward to other countries, primarily in Asia.

It says during his two-decade long involvement in the illegal wildlife trade, Teo Boon Ching claims to have transported multiple metric tons of rhino horn, ivory, and pangolins. Some of the rhino horn shipments Teo Boon Ching transported were derived from the critically endangered black rhino.

Teo Boon Ching

Although Teo Boon Ching has been publicly linked to the illicit wildlife trade for years, he has evaded justice and continued to operate his illicit transportation enterprise. On June 29, 2022, Teo Boon Ching was arrested in Thailand based on a request from the United States and in accordance with the bilateral extradition treaty between the United States and Thailand. Today, an indictment was unsealed in the U.S. District Court for the Southern District of New York charging  Teo Boon Ching with conspiracy to engage in wildlife trafficking and money laundering.

According to Environmental Investigations Agency, Teo has been involved in the business for more than two decades, providing concealment and packing services to a number of criminal networks involved in the smuggling of elephant ivory, rhino horns and pangolin scales into Asia via Malaysian ports.

In EIA’s 2018 report “Exposing the Hydra,” investigators documented his role as a specialist transporter assisting Vietnamese and Chinese syndicates in trafficking wildlife between Africa and Asia.

As of 2017, Teo claims to have provided clearance services for approximately 80 containers, with only one seizure since he started operations.

He also claims to have played a significant logistics role in the recovery of two shipments of pangolin scales linked to the seizure of 7.2 tonnes of elephant ivory, which occurred in Hong Kong in July 2017.

Based on investigations, Teo is believed to have strong connections to Customs officials at Johor Port, who enable his customers to enter the Customs Clearance Warehouse to verify goods once the wildlife shipments have arrived in Malaysia. Once cleared, the consignment is moved to Teo’s own warehouse for repacking into multiple standard air cargo packages for onward transportation.

Teo has also established strong connections with individuals involved in the acquisition and distribution of illicit wildlife commodities in Malaysia, Vietnam, China and Laos.

EIA Executive Director Mary Rice said given Teo Boon Ching’s lengthy operations in illegal wildlife trade and previous enforcement failures, this is a great opportunity to bring him and his associates to justice.

“For more than two decades, Chinese and Vietnamese organised crime networks have exploited Malaysia and other South-East Asian countries as transit hubs for illegally importing wildlife commodities from Africa into Asia. The relationship with specialist transporters such as Teo Boon Ching is key to successful clearance in these countries,” Rice said.

“EIA urges the US and law enforcement authorities in all relevant countries to work together to strengthen international cooperation on this case to conduct a thorough investigation of the offences which could lead to a successful prosecution and conviction of Teo and his associates implicated in wildlife trafficking,” she added.

Sanctions implications

The statement from the treasury department says following the designation, all property and interests in property of the designated persons that are in the United States or in the possession or control of U.S. persons will be blocked and reported to OFAC.

“In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. OFAC’s regulations generally prohibit all transactions by U.S. persons or persons within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons. U.S. persons may face civil or criminal penalties for violations of E.O. 13581, as amended, or the Transnational Criminal Organizations Sanctions Regulations, 31 C.F.R. Part 590,” the statement says.

It adds that: “the power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior.”