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NGO Flags Rise in Illegal Wildlife Trade Guised as ‘Zoo Transfers’, Including to India

The organisation noted in internal alerts that the CITES permits India gave for the imports of wild primates from Congo may have been invalid.
A chimpanzee rests in its enclosure. Photo: Harry Dona/Pexels/
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Bengaluru: There are rising instances of wildlife being smuggled illegally under the guise of transfers between zoos and rehabilitation and rescue centres across the world, an international organisation that works to prevent the illegal trade of endangered species worldwide has said in internal alerts sent to its task force, The Wire has learnt.

In one alert, the NGO listed the modus operandi of how this illegal smuggling works, and in another, highlighted “multiple red flags” in a consignment of endangered primates including chimpanzees from the Democratic Republic of the Congo to a “private facility” in India.

The alert does not say which private facility this is.

It also said that the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) permits that India gave for the imports of these wild primates were amended multiple times, suggestive of the permits being re-used – and thus invalid.

The Wire wrote to the international NGO, as well as India’s Union environment ministry and the Wildlife Crime Control Bureau (WCCB), the only nodal agencies that can give CITES permits for zoos and rehabilitation centres for international transfers into India.

While an official from the NGO said that they cannot comment on their internal documents, the environment ministry and WCCB have not yet responded. This story will be updated when they do.

This development comes shortly after a March 13 report by German daily Süddeutsche Zeitung – based on data from two trade databases – said that the demand for “rescued” animals by the Greens Zoological Rescue and Rehabilitation Centre aka Vantara at Jamnagar, Gujarat may have fuelled illegal wildlife trade, with animals possibly being sourced from their wild habitats through zoos and exporters from across the world.

Vantara has termed the allegations “baseless”.

The illegal wildlife trade

Illegal wildlife trade involves any activity that includes “obtaining, capturing, poaching, smuggling, importing, exporting, processing, possessing, collecting and consumption of wild flora, fauna and funga, aquatic or terrestrial, dead or alive, including derivatives, parts and products thereof, which are regulated or protected by national and/or international laws”, according to a recent study.

It was to tackle this that in 1975 the CITES came into force. The international treaty regulates the transfer of wildlife or its products and derivatives between countries (it permits transfer of live animals between zoos under certain conditions for instance) and its guidelines aim to ensure that illegal trafficking does not occur.

The way it tries to do this is through permits. No one can transfer or trade specific endangered and the wanted species – listed under Appendix I of CITES – without an import or export permit.

These permits require both purpose and source codes. Purpose codes refer to the purpose of the transaction. For instance, a purpose code ‘T’ refers to a commercial transaction, while ‘Z’ refers to a zoo transfer. Source codes, meanwhile, indicate the origin of the specimen. A source code ‘C’ refers to animals bred in captivity and in accordance with the treaty’s provisions, while source code ‘W’ refers to specimens taken from the wild.

But despite 185 countries being party to CITES as of 2025, illegal wildlife trade remains one of the most lucrative illegal industries in the world. Between 1997 and 2016 alone, this trade was worth $2.9-4.4 trillion, a study found.

And over the years, kingpins have come up with novel ways to smuggle or traffic wildlife across borders. A 2017 study, for instance, points to the “laundering” of animals caught from the wild as ‘captive-bred’ as “an emerging trend in wildlife crime and the illegal pet trade”.

Laundering, in the lexicon of illegal wildlife trade, essentially means hiding the illegal origin of animals to enable them to be traded legally.

Zoos can also be part of the system. A researcher found in 2021 that 16 zoos across the world (including in Austria, Germany and Japan) had obtained individuals of the earless monitor lizard – an extremely rare and threatened species of reptile, found only in some parts of Borneo and legally protected under national laws – despite there being no evidence of the legal export of the species from Malaysia, Indonesia or Brunei Darussalam where the animals occur in the wild, or any proof of the legal import of the species into the European Union.

Modus operandi, red flags

The trend – increasing instances of wildlife being trafficked under the guise of zoo transfers – is increasing, according to an international organisation that works to prevent illegal wildlife trade.

Through a source who cannot be named because they shared internal information, The Wire has learnt that the organisation recently issued two alerts to its internal task forces aimed at helping its members identify consignments of potentially illegally trafficked wildlife.

In these task force alerts, the organisation listed how live wild animals are being smuggled via zoos and rescue and rehabilitation centres worldwide, and highlighted “multiple red flags” in multiple consignments of endangered primates, including chimpanzees from the Democratic Republic of the Congo to India.

According to one alert, the modus operandi of operating the illegal trade through zoos and rescue centres involves illegal wildlife traffickers first registering with their governments as “zoos, conservation centres, captive breeding centres or rescue centres”.

Then, they enter into official agreements – such as memorandums of understanding – with other similar centres. Some of these wildlife traffickers even orchestrate wildlife seizures and rescues in the source and transit countries, the alert said.

In many cases, CITES permits are “forged or fraudulently procured” through bribes and other corrupt means, it added.

It also red-flagged “high risk corporates” such as private zoos, conservation and captive breeding centres, and rescue and rehabilitation centers, especially facilities in countries including the Congo, Germany, Guyana, the United Arab Emirates and India.

It did not, however, name the specific facilities.

The second alert said that at least eight consignments of mountain gorillas, chimpanzees and bonobos from the Democratic Republic of the Congo to India since March 2024 may have contained “laundered and smuggled” individuals “hidden” amongst legally-traded ones.

It noted that the boxes that the animals were shipped in were not in compliance with International Air Transport Association guidelines, which renders their CITES permits invalid.

Moreover, it said that the CITES permits for the transfers may have been falsified and could “contain discrepancies that render them invalid”.

For instance, it noted that the CITES permits provided by India for the import of the primates were possibly amended several times, which essentially means that the permits were “re-used” multiple times. This, once again, renders them invalid, the NGO noted.

The Wire wrote to all agencies in India that are authorised to grant CITES permits for imports of animals from other countries: the Ministry of Environment, Forests and Climate Change; and the four branches of the WCCB under the ministry. More than a week later, there has been no response. This story will be updated if any response is received.

According to the alert, a consignment of nine chimpanzees – which is a species listed in Appendix I of CITES – and other species including 135 individuals of thick-tailed galagos and 15 Hamlyn’s monkeys were transferred to India from Congo with the ‘C’ code in the CITES permits (which shows that they are captive-bred).

However, the alert says that there are no known captive breeding or commercial breeding facilities in the Congo for any of these species. The alert quotes “confidential sources” as saying that these animals were poached from the wild. It also adds that the chimpanzees went to a “private facility” in India and not a zoo, but does not specify which one.

The information in these alerts – such as the possibility of CITES permits that India gave for imports being potentially re-used several times – is independent of that provided in the news report on March 13 by German daily Süddeutsche Zeitung that looked at the origin of animals coming to Vantara, which is a zoo, rehabilitation and rescue center in Jamnagar.

The report had said that Vantara had received 1,770 animals from the Democratic Republic of the Congo, and around 11,700 animals from the United Arab Emirates including 41 chimpanzees and 100 Hamlyn’s monkeys.

The alerts do not refer to this specific media report or Vantara at all.

When The Wire wrote to the international organisation asking for more details about these alerts, including transfers and the names of the specific facilities in question, an official from the organisation said that they cannot comment on internal documents circulated within members of the organisation or its partners.

The official pointed to the disclaimer in the alerts, which states that while the organisation has “high confidence” in the analysis and findings represented in the alerts, there is “no warranty” on the “accuracy or reliability” of the information.

However, The Wire was also able to verify – through another independent source who also didn’t want to come on the record – that the international organisation did circulate the alerts.

Loopholes to launder

Reusing the same CITES certificates multiple times for different animals is one of the ways that commercial traders “launder” wildlife, writes Daan van Uhm, currently associate professor of criminology who specialises in green criminology at Utrecht University in the Netherlands, in a book chapter titled “Wildlife and laundering: Interaction between the under and upper world”.

“Theoretically, certificates should be sent back to the CITES authority when the animal dies but in practice this hardly happens. This allows commercial traders to transfer newly obtained illegal animals using those certificates. Another method is to re-use the same certificate for different shipments of animals and animal products,” van Uhm writes.

He also adds that people involved in illegal wildlife trafficking and laundering include owners or employees of legitimate companies, such as animal traders, wildlife park owners or wildlife breeders “who conceal their illegal practices”. 

“Findings show that these green-collar perpetrators are experts regarding the rules and regulations and know how to use loopholes to dodge law enforcement,” he writes.

The fact that CITES permits animals to be transferred between zoos worldwide and that CITES permits can be obtained fraudulently is indeed a loophole that traders and collectors use to illegally transfer wildlife, a conservationist who works on illegal wildlife trade told The Wire.

There has also been a sudden uptick in the number of zoos “that have sprung up overnight”, the source, who did not want to be named, said.

The source also added that there have been several reports of multiple consignments of exotic animals – species not native to India – bound for India from across the world.

“What is the background to these zoos? Why are they giving away their animals? Where did the animals come from? Why did CITES give permits? Are they zoos or breeding centres, what do they aspire to be? There are lots of questions to be asked. CITES needs to do lots of inquiries,” the conservationist remarked.

Moreover, what does it mean for India if exotic species are arriving in the country? Are they going to be traded in India, and are people going to breed them? Will they turn invasive? The issue of alien invasives is a huge concern, the conservationist added.

Diseases, including zoonoses too, will follow, they added.

For instance, Taiwan is now culling green iguanas by the hundreds, the source added. The reptiles – bought as pets and released into the wild after their owners could not care for them – have now turned invasive on the island.

Similarly, the pet trade has led to red-eared sliders (a species of turtle kept as pets) far outnumbering native turtle species in Japan. So much so that the country has been planning to not only ban pet owners from releasing them in the wild, but also banning the import of the turtles as well.

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