A TICKING TIME BOMB TH E GLOBAL TR ADE IN DON KE Y SKINS: THE DONKEY SKIN TR ADE AS A TROJAN HORSE FOR WILDLIFE TR AFFICKING

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A TICKING TIME BOMB TH E GLOBAL TR ADE IN DON KE Y SKINS: THE DONKEY SKIN TR ADE AS A TROJAN HORSE FOR WILDLIFE TR AFFICKING
REPORT 1

T H E G LO B A L T R A D E
I N D O N K E Y S K I N S:
A TICKING TIME BOMB

T H E D O N K E Y S K I N T R A D E A S A T R OJA N
H O R S E FO R W I L D L I F E T R A F F I C K I N G
 WAR N I N G

T H I S R E P O R T C O N TA I N S G R A P H I C I M A G E S W H I C H S O M E R E A D E R S M AY F I N D D I S T R E S S I N G
A TICKING TIME BOMB TH E GLOBAL TR ADE IN DON KE Y SKINS: THE DONKEY SKIN TR ADE AS A TROJAN HORSE FOR WILDLIFE TR AFFICKING
Cover image: Donkeys awaiting slaughter, Kenya.

                                                                                    CONTENTS

                                                                                          4    Foreword: united for wildlife
                                                                                          6    Introduction
                                                                                          8    The global trade in donkey skins
                                                                                          10   The donkey skin trade: a trojan horse
                                                                                               for wildlife trafficking
                                                                                          12   Donkey skin seizure reports
                                                                                          14   Online trading: donkey skins and
                                                                                               wildlife products sold together
                                                                                          20   Global traders map
                                                                                          23   Case study: Kenya
                                                                                          26   Global shipping: donkey skins and
                                                                                               wildlife products shipped together
                                                                                          32   Case studies: notable seizures
                                                                                          34   Focus on Colombia
    Donkey in slaughterhouse holding pen, Tanzania.                                       36   Focus on South Africa
                                                                                          42   Implications for online trading platforms
AC K N OW L E D G E M E N T S                                                                  and the global shipping industry
                                                                                          44   Conclusion
The Donkey Sanctuary offers sincere thanks to its network of friends, partners
and colleagues around the world who contributed information and advice during             46   Recommendations
the preparation of this report, including the Wildlife Conservation Research
Unit (WildCRU) and Saïd Business School at the University of Oxford, United for           48   References
Wildlife, Oxpeckers Investigative Environmental Journalism, Focused Conservation,
Advocates for Animals, Wildlife Justice Commission and Monitor Conservation
Research Society.

We are very grateful to The Robert H.N. Ho Family Foundation Global for
generously supporting this work.

Many others have contributed but cannot be named to protect their identities.

Simon Pope, Emily Reeves and Janneke Merkx, The Donkey Sanctuary.
All images are © The Donkey Sanctuary unless otherwise stated.
Copyright ©2022 The Donkey Sanctuary.

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A TICKING TIME BOMB TH E GLOBAL TR ADE IN DON KE Y SKINS: THE DONKEY SKIN TR ADE AS A TROJAN HORSE FOR WILDLIFE TR AFFICKING
FO R E WO R D :
U N I T E D FO R W I L D L I F E

The illegal wildlife trade is a serious transnational
organised crime. It is also a significant financial
crime. Worldwide, for every wildlife product
trafficked illegally, money changes hands –
from online marketplaces to cross-border wire
transfers. At United for Wildlife, our mission is to
bring together relevant and leading players from
the public, private and not-for-profit sectors to
combat this heinous crime and save protected
species from extinction.                                                                                                        AFRICOM CTF is using the analysis provided
                                                                                                                                by The Donkey Sanctuary confluent with law
                                                                                                                                enforcement information on illegal wildlife trade
This report by The Donkey Sanctuary shines a light on an
                                                                                                                                networks throughout the area of responsibility
overlooked aspect of the illegal wildlife trade. It reveals how the
                                                                                                                                (AOR) in an effort to map and identity individuals,
trade channel has been co-opted by wildlife traffickers as a vehicle
                                                                                                                                networks, and other witting malign actors
for their illegal activities. It shows how so-called business-to-
                                                                                                                                while also providing case support to assist with
business online sites and even social media are acting as platforms
                                                                                                                                potential US Government law enforcement
on which illegal wildlife items are being openly sold alongside
                                                                                                                                finishes. The Donkey Sanctuary has provided
donkey skins.
                                                                                                                                significant support and their efforts have
                                                                                                                                quickly become a vital piece for our strategic
United for Wildlife and The Donkey Sanctuary have much
                                                                                                                                understanding of illicit networks. Specifically,
common ground in the fight against wildlife crime,. By working
                                                                                                                                analysis by The Donkey Sanctuary has advanced
together, they have highlighted the hidden associations with
                                                                                                                                the defence enterprise’s knowledge on the illegal
criminality that now stain the donkey skin trade.
                                                                                                                                aspects of the trade (and other illicit activities)
                                                                                                                                that occur via business-to-business marketplaces
Through collaboration like this, informed by innovative research
                                                                                                                                while identifying global retailers and online
and evidence gathering, we hope to raise awareness and ultimately
                                                                                                                                trading platforms, in addition to addressing
eradicate the unsustainable, dangerous and illegal trade in donkeys
                                                                                                                                concerns associated with the shipping industry
and wildlife.
                                                                                                                                in countries that have introduced bans on the
                                                                                                                                export of donkey skins. This is of particular
                                                                                                                                interest as donkey skins are often being traded
                                                                                                                                and shipped with other illegal wildlife items.

                  DAVID FEIN
                  CHAIR OF THE UNITED FOR WILDLIFE
                  FINANCIAL TASKFORCE

                                                                       Stack of wet salted donkey skins.

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INTRODUCTION

The Donkey Sanctuary’s Under the Skin               Far more can, and needs to, be done to stop
reports,1,2 lifted the lid on the vast reach        the international trade in donkey skins, and
and impact of the global donkey skin trade,         to penalise those that operate outside of the
demonstrating the harm done, not just to the        law. But while the trade remains legal in some
donkeys themselves but also to the millions of      countries and illegal in others, there will always
people who depend on them for a livelihood. This    be traders that exploit inherent enforcement
opportunistic and extractive trade has operated     challenges, to the detriment of donkeys.
under the radar of enforcement bodies for many      This report does more than expose the extent
years, causing immense suffering, depleting         to which national laws are ignored - it uncovers
national donkey populations and depriving local     a convergence of criminality, revealing the role
communities of a precious resource. Despite         that the international trade in donkey skins
the immeasurable impact on donkey welfare           plays in facilitating wildlife trafficking and its
and donkey-dependent communities, donkey            connections to drug trafficking, e-commerce
skin traders and the ejiao producers who drive      fraud and other illicit activity. Selling illegal
the global trade in donkey skins operate largely    wildlife products alongside donkey skins enables
without consequence.                                traders to use a legally complex trade to mask an
                                                    entirely illegal one – using the donkey skin trade
                                                    as a Trojan horse.
         Selling illegal wildlife
         products alongside donkey                  At a time when the world continues to suffer the
                                                    impacts of Covid-19, and when governments are
skins enables traders to use a                      increasingly recognising the links between animal
legally complex trade to mask an                    health and welfare and the health of people          Pile of donkey carcasses and carrion birds.
                                                    and the environment, a concept known as ‘One
entirely illegal one                                Welfare,’ the donkey skin trade operates largely
                                                    unabated. Some of the world’s most dangerous
In an effort to protect their national donkey       diseases in humans are linked to animals - for
populations and the communities that rely           example, MERS, SARS and now Covid-19 -
on them, many countries have subsequently           making the vast scale of the global trade in
prohibited the export of donkey skins,              donkeys and donkey products, alongside wildlife
either directly, or through delicencing of          and wildlife products, a ticking time bomb.
slaughterhouse facilities. The trade continues,
despite this, often in open defiance of national    Action is urgently needed to recognise and address
laws and without adherence to international         the risks and halt the trade. In this, the ejiao
and national biosecurity protocols designed to      industry, global shipping industry, online trading
prevent the spread of disease. Traders are highly   platforms, law enforcement agencies and national
opportunistic and, when it becomes difficult to     governments all have a critical role to play.
source donkeys in one country, they simply move
to another where donkeys are more plentiful and     This is no ordinary trade and the action needed
may be less protected by law.                       to tackle it cannot be ordinary either.

                                                                                                         Slaughterhouse notice regarding                              Skins drying at slaughterhouse with waste
                                                                                                         stolen donkeys, Kenya.                                       pile in background.

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T H E G LO B A L T R A D E I N
DONKEY SKINS

                                                                                                             Donkeys support the livelihoods of 500 million
    Penned donkeys awaiting slaughter.                                                                       people worldwide.

                                                                                                                                                                      donkey once did.
The trade in donkey skins, which centres on              Many donkeys experience extreme suffering
Africa, the Americas and Asia but extends well           at the hands of traders. They are often            Variations in figures reported by the ejiao               The wide scale movement and unhygienic, often
beyond, sees millions of donkeys slaughtered             transported long distances, by truck or on foot,   industry, and the largely unregulated and often           illegal, slaughter of donkeys of unknown health
annually. Their skins are exported to China for          without adequate food, water and rest. They        illegal nature of the trade, make it impossible to        carries inherent biosecurity risks, the consequences
use as a raw material in the production of ejiao,        are then held, often for days on end, again        obtain precise figures for the number of donkeys          of which could be globally significant.
a Chinese remedy believed by some to have                without adequate food or water, before being       required to produce current levels of ejiao,3
medicinal properties.                                    slaughtered in brutal and unhygienic conditions.   however estimates suggest it could be as high as          The risks associated with the trade demand urgent
                                                         Others are stolen from their owners during         4.8 million donkeys.4                                     action. This urgency escalates as links between
                                                                           the night and are ruthlessly                                                               the global trade in donkey skins and the trade in
                                                                           slaughtered before their skins   The trade has had catastrophic results for many           wildlife, drugs and other illegal items are exposed.
                                                                           are removed and the carcasses    communities and families that rely on donkeys
                                                                           left to rot.                     for their livelihoods. When a donkey is stolen, it
                                                                                                            is often the women and children who are forced
                                                                                                            to do the work, such as carrying water, that the

     S L A U G H T E R E D FO R T H E S K I N T R A D E A N N U A L LY

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THE DONKE Y SKIN TR ADE:
A T R OJA N H O R S E FO R
WILDLIFE TR AFFICKING

The multi-billion-dollar global wildlife trade                  What has been less recognized,
is one of the most lucrative businesses in the
world.5 The trade in wildlife and wildlife parts
                                                                studied or understood is the
for use as souvenirs, pets, medicine or clothing        role that the trade in donkey skins has
not only has serious implications for global
conservation efforts6 but also hinders social and
                                                        played in facilitating this arena of highly
economic development.                                   organized international crime.
The trade represents a threat to national and
global security7 and it undermines the efforts
of national governments and intergovernmental           Evidence shows that the legally complex trade in
bodies to achieve sustainable development               donkey skins may be acting as a vehicle for the
goals.8 The direct cost of zoonotic diseases            wildlife trade as well as other illegal items including
between 2000 and 2010 is estimated to                   hardwoods and Class A drugs.
exceed USD20 billion and the indirect costs
are estimated to exceed USD200 billion.9                The practice of trading in multiple illegal
Approximately 70% of emerging infectious                products is known as ‘parallel trafficking’19
diseases are of zoonotic origin10 and these             and is common in the illicit trade in wildlife
zoonotic diseases are increasingly being linked to      where traders use existing routes and anti-
the trade in wildlife and wildlife parts.11             detection methods to evade enforcement. As
                                                        just one example among many in the global
Wildlife trafficking is orchestrated by increasingly    trade in donkey skins, an investigation by the
sophisticated transnational organised crime             Organised Crime and Corruption Reporting
syndicates.12 These groups frequently use the           Project (OCCRP)20 found that “…poly-traffickers
dark web to carry out their illicit activities,13       from Zimbabwe and Botswana (are) operating                 Seized ivory. Photo courtesy of Wildlife Justice Commission.
they take advantage of rapid and secure online          contraband pipelines alongside their donkey
communications,14 and they benefit from increased       smuggling businesses that traffic ivory, pangolin
ease of communication and movement of goods in          scales, contraband cigarettes and marijuana               quarantine regulations. However, these facilities               national laws and regulations, or if it should
the era of global free trade.15                         across jurisdictions.”                                    are frequently located in countries where                       be refused and/or referred to an appropriate
                                                                                                                  an export prohibition on skins exists, either                   enforcement or regulatory authority for further
The routes used to smuggle wildlife and wildlife        Using a legal trade as a smokescreen for illegal          directly (Nigeria, Benin, Ghana) or because                     investigation.” TRAFFIC 2021.
products around the globe are also often used           activity is not new. Illegal wildlife traders often       countries have withdrawn licences from donkey
to smuggle weapons, drugs, and people,16                offer a diverse range of products and doing so            slaughterhouses (Kenya, Tanzania). Other                        Donkey skins are both a smuggling vehicle, and a
and wildlife crime often occurs in conjunction          enables them to ship illegal products disguised           countries known to be exporting donkey skins                    smuggled item itself - disguised in consignments,
with other offences such as passport fraud,             as, or concealed within, legally traded ones.21           (South Africa, Egypt, Botswana, Mexico) have                    alongside other illegal items, from countries
corruption,17 money laundering and murder.18            In many cases however, the trade in donkey                no slaughter/export facilities registered with                  where donkey slaughter and donkey skin exports
                                                        skins is itself illegal, since a growing number of        Chinese customs.                                                are prohibited. China not only recognises that
What has been less recognized, studied or               countries have banned the export of donkey                                                                                smuggling of donkey skins takes place but that
understood is the role that the trade in donkey         skins in an attempt to safeguard national                 Awareness about the role of the donkey skin                     it is set to increase – a 2021 market analysis
skins has played in facilitating this arena of highly   donkey populations and the communities who                trade as a vehicle for illegal trade is growing. A              paper by the Donkey Branch of the China
organized international crime.                          depend on them. Despite this, donkeys are                 2021 TRAFFIC report23 gave donkey skins a red                   Animal Husbandry Association24 concluded that
                                                        slaughtered, and their skins exported in direct           flag designation alongside illegally traded wildlife            due to market conditions “...some enterprises
Research commissioned by The Donkey Sanctuary           defiance of national prohibitions,22 and recipient        items such as elephant ivory and rhino horn.                    that do not abide by the law will increase their
and undertaken by the Wildlife Conservation             government administrations are complicit in                                                                               willingness to smuggle and participate.”
Research Unit (WildCRU) at the University of            this undermining of national efforts to protect           “Red flags are indicators that can be applied to
Oxford from 2019 to 2021 demonstrates that              donkey populations. Chinese customs authorities           shipping transactions to help identify possible                 The legality of the trade in donkey skins is often
donkey skins are both being offered for sale,           oblige in-source-country donkey slaughter                 attempts to circumvent controls. Further                        ambiguous and this is exploited by traders for
and being shipped, with wildlife products, most         and export facilities to register with them for           enquiries will then assist in identifying whether               their benefit.
commonly pangolin scales, ivory and seahorses.          the purposes of biosecurity, veterinary and               a transaction is legitimate and compliant with

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DONKE Y SKIN SEIZURE REPORTS                                            2017 – 2022
                                                                        R EPOR TED I NC I DENTS                                 83
                                                                        COUNTR I ES                                             27
                                                                         TOTAL NUMBER OF
                                                                                                          75, 4 70
                                                                         TR AFFI C K ED DONK E Y SK I N S

CO-SEIZURES

         Elephant ivory

         Pangolin scales

         Hardwoods

         Tiger skins

         Shark fins        Abalone
                                       DONKEY SKIN SEIZURE INCIDENTS

         Seahorses         Zebra

         Fish maw          Dog skins
                                       0                                                                                      10,000+

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ONLINE TR ADING: DONKE Y                                                                                       B2B platforms are a growing segment of
                                                                                                               e-commerce, and thus are likely to represent
                                                                                                                                                                               B2B platforms are a growing
SKINS AND WILDLIFE                                                                                             an expanding threat to those working to
                                                                                                                                                                               segment of e-commerce, and
P R O D U C T S S O L D TO G E T H E R                                                                         combat illegal wildlife trade and the illegal           thus are likely to represent an
                                                                                                               trade in donkey skins. The freedom and reach
                                                                                                               provided by these platforms, and the so-called
                                                                                                                                                                       expanding threat to those working to
                                                                                                               democratization of shipping and commerce                combat illegal wildlife trade.
                                                                                                               globally, presents unscrupulous criminals with a
                                                                                                               multitude of opportunities to reduce risks and
                                                                                                               driveup profits.
BUSINESS-TO-BUSINESS
PLATFORMS
Business-to-business (B2B) e-commerce                   B2B e-commerce websites through which                  The table below shows the wildlife items being
platforms serve wholesalers and retailers               donkey skins are traded. A total of 382 individual
worldwide by facilitating the promotion and sale        vendors, registered across 55 countries, were
                                                                                                               offered for sale by traders alongside donkey skins:
of products globally. Some offer a subscription-        found to be selling donkey skins and 20% of
based model, charging fees to buyers and sellers        those traders were also selling a total of 30           www.tradekey.com                                       www.tradeford.com
for varying levels of service, while others take        wildlife products from at least 11 species,
a commission from vendors for sales made or             including pangolins, cheetahs, elephants,
charge a fee for listing products. Considering          tigers and rhinoceros that are all listed under         Leopard skins, lion skins, live cheetah cubs,          Pangolin scales, hardwoods (inc ebony).
the sheer numbers of products sold on these             the Convention on International Trade in                pangolin scales, abalone, seahorse, sea
marketplaces, it is no surprise that some are           Endangered Species (CITES).                             cucumber, shark fin, fish maw.
illegal, and this includes wildlife products and
illegally sourced donkey skins.                         CITES exists to prevent the over-exploitation           www.ec21.com                                           www.globalsuppliersonline.com
                                                        of wild animals and plants, and to ensure that
In 2017, The Donkey Sanctuary discovered                the international trade in those species doesn’t        Pangolin skin / scales, rhino horn, elephant           Pangolin scales, elephant ivory, fish maw,
online B2B traders offering donkey skins                threaten their survival.26 The international trade      tusk, dog fur, crocodile skins, african tiger skins,   parrots, reptiles, live birds, rhino horn, capuchin
alongside wildlife products such as pangolin            in the 11 species being sold alongside donkey           tiger fur (sic), leopard pelt, saltwater crocodile     monkey, tiger teeth / skin, live cubs, black
scales and seahorses. Instances of these co-            skins is either illegal or tightly regulated. There     skins, zebra hides, hardwoods.                         scorpions, fish maw.
sales were logged and monitored, and appeared           appeared to be a predominant association with
to increase in number over                                                       marine-derived species         www.alibaba.com                                        www.eworldtrade.com
the subsequent 12 months,                                                        including abalone, sea
along with a diversification of                   Thisresearch                   cucumber and fish maw          Sea cucumber, hardwood charcoal, conch,                Lion teeth, tiger teeth.
both the wildlife items offered                                                  (dried fish swim bladders).
and the range of countries
                                                  established clear                                             abalone, seahorse.
from which they were being             evidence of a link between               The Donkey Sanctuary
sold. Large numbers of                                                          continued to monitor and        www.ecplaza.net                                        www.engormix.com
traders registered on the
                                       wildlife trafficking and the             investigate 12 B2B sites
B2B platforms during 2017              legally complex global trade             following the completion of     Pangolin scales, sea cucumber, hardwood                Ivory tusks, walrus tusk/skull/penis, dried
and 2018, with the biggest                                                      the WildCRU research in         charcoal, walrus tusks, narwhal tusks, bear bile       northern fur seal penis.
proportion from South Africa,
                                       in donkey skins.                         early 2021 and into 2022.       & fats, musk pods.
Kenya and Cameroon, claiming                                                    All the sites hosted traders
to be able to source far more donkey skins in            offering large volumes of donkey skins for             www.exportersindia.com                                 www.ecrobot.com
total than the national donkey populations of the        sale. Traders were found to be offering wildlife
countries in which they were operating.                  products alongside donkey skins on all of the          Macaw eggs, elephant tusks, golden eagle eggs,         Seahorse, sea cucumber, tiger & lion teeth,
                                                         sites. On one B2B site, 14 traders were found to       python (live and eggs) 100 different species           rhino horns, tiger/leopard skin, elephant tusks.
The Donkey Sanctuary supported a study by                be offering a range of items including elephant        of parrot and eggs, seahorses, pangolin scales,
Oxford University’s WildCRU and Saïd Business            ivory, tiger hides and rhino horns alongside           rhino horn/powder, african lion skulls, shark
School (2019/20) into the co-sale phenomenon             donkey skins, and on another, 13 different             fins/tails, fish maw, hardwoods, live tortoise.
in order to establish its size and its role in the       traders offered items including pangolin scales,
illegal wildlife trade. These findings will be           capuchin monkeys and hardwoods alongside
published in Conservation Science and Practice           donkey skins. Shark fins and seahorses of
in May 2022.25                                           unspecified species, as well as sea cucumbers          www.global-trade-center.com                            www.go4worldbusiness.com
                                                         and abalone were found being offered for sale
This research established clear evidence of              with uncertainty around their conservation             Removed pages of traders offering wildlife             Pangolin, kosso wood, fish maw.
a link between wildlife trafficking and the              status. Other traders offered wildlife products        products after notification from TDS.
legally complex global trade in donkey skins.            unassociated with donkey skins.
WildCRU researchers identified seven large

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Figure 2: Ghana-based trader
                                                                                                                                          openly admits selling illegal wildlife
                                                                                                                                          products.

B2B sites all contain search functions enabling     being sold illegally, the donkey skins they are
potential buyers to find items offered for sale.    being sold alongside are also illegal. The slaughter
Traders offering donkey skins were identified by    of donkeys and the export of their skins has
using the search terms ‘donkey skin/s’ or ‘donkey   been prohibited from numerous, mainly African,
hide/s’ and, once traders’ pages were identified    countries owing to concerns about unsustainable
and logged, this was cross-checked against          offtake, rising donkey thefts and the subsequent
searches for wildlife items.                        risks to donkey-dependent communities.

The Donkey Sanctuary has separately identified      Large numbers of B2B donkey skin traders claim
over 70 B2B traders advertising donkey skins        to operate from countries where the export
alongside wildlife items. The most common           of donkey skins is currently prohibited or not
wildlife species/products being offered alongside   permitted, including Kenya, Burkina Faso and
donkey skins were found to be pangolin scales,      Nigeria where, in 2020, the Federal Ministry of
elephant ivory, rhino horn, lion/tiger teeth/       Agriculture and Rural Development took the
skins and a range of marine items including         drastic step of designating the domesticated           Figure 3: Uganda-based
                                                                                                           trader confirms availability   Figure 4: Some traders opt for email or
fish maw, sea cucumber and seahorses. The           donkey as an “…endangered species due to high          of pangolin scales.            WhatsApp communication for wildlife trading.
Donkey Sanctuary research also discovered           haulage of the animal from north to the south-
an increasingly diverse range of other illicit      eastern part of the country for consumption and
commodities being offered for sale including        export.”27 Other traders are based in countries
drugs such as cocaine, nembutal, MDMA/ecstasy       that do not have the requisite ‘registered
and xanax, fake passports, currency and even        facilities’ required by Chinese customs for
human body parts. The largest number of co-sale     veterinary and quarantine purposes, including
traders (18) claimed to be based in Cameroon        Egypt, South Africa, Botswana and Mexico.
offering donkey skins alongside everything          Across the 12 B2B sites, where it was possible
from elephant tusks to human bones. eight           to identify the location of the traders, large
were based in Kenya and five in Nigeria. In some    numbers claimed to be based in Kenya (157),
instances, not only are the wildlife products       Nigeria (117), Thailand (67) and Cameroon (59).

ONLINE TRADING OF ILLEGAL GOODS
                                                                                                                                                                  The Donkey Sanctuary
                                                                                                                                                                  research also discovered
                                                                                                                                                        an increasingly diverse range of
                                                                                                                                                        other illicit commodities being
                                                                                                                                                        offered for sale including drugs
                                                                                                                                                        such as cocaine, nembutal,
                                                                                                                                                        MDMA/ecstasy and xanax, fake
                                                                                                                                                        passports, currency and even
                                                                                                                                                        human body parts.

                                                                                                                                               Figure 5: online trader provides
                                                                                                                                               list of illegal items that can
                                                                                                                                               be shipped to Hong Kong or
                                                                                                                                               mainland China.

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SOCIAL MEDIA SITES                                        Facebook                                            YouTube                                              Twitter
The sale of illicit products on online platforms          A Nigeria-based trader lists over 200 photos of     YouTube hosts multiple donkey skin traders from      Twitter42 hosts donkey skin traders from Nigeria.
is not limited to illegal wildlife trade on B2B           items for sale including donkey skins, hardwoods    a range of countries, including:                     In addition, a 2018 post on Twitter from a company
marketplaces. Social media platforms act as               and pangolin scales.32 There are several                                                                 based in Abu Dhabi advertises donkey skins
facilitators of illegal trade by providing traders        images of dead and dying donkeys in appalling       ƒ A trader in Senegal who promotes sales of          alongside lion and tiger teeth,43 as does another
with anonymity and secure communication                   conditions. Footage of hides being prepared in        donkey skins and dried seahorses.39 Senegal        from a company in Romania.44 The same trader
channels28 and by developing algorithms that              filthy facilities are also included.33                has a ban on the export of donkey skins. Many      offers macaws and grey parrots for sale.45,46
inadvertently but effectively connect buyers with                                                               seahorse species are protected.
illegal traders.29 In many instances, tech firms          ƒ Three other Nigeria-based traders,34,35,36
operate with impunity and this provides them                also offer donkey skins on their Facebook
                                                                                                                                                                   Instagram
                                                                                                              ƒ An Italian-based trader which openly
little incentive to actively combat illicit activity.30     pages, despite an explicit export prohibition       advertises donkey skins from Ghana, has            Instagram hosts traders from Kenya47 and
It is little surprise then that donkey skin traders         on donkey skins in Nigeria. Images illustrating     footage of 2,800 skins in its warehouse in         Nigeria48, which have slaughter/export
are exploiting social media sites to offer skins for        the pages show donkeys being slaughtered in         Tepa, Ghana currently on YouTube.40 Ghana          prohibitions in place, and Cameroon,49 which has
sale alongside illegal wildlife items.                      appalling conditions. Hardwoods and fish maw        has issued a prohibition on the slaughter of       no facilities licenced by China for the purposes of
                                                            are also offered for sale.                          donkeys for their skins.                           veterinary and quarantine regulations.
The Donkey Sanctuary used variations on the
Google search terms ‘donkey skins’ ‘donkey                ƒ A Kenyan-based company, posted on its             ƒ A donkey skin trader based in Nigeria.41
hides for sale’ to identify social media platforms          Facebook page in January 202137 that it had
hosting donkey skin sales. This initial research            “2000 pieces of donkey skin/hides available
identified multiple traders, often from countries           for sale now in Kitale, Kenya. Price $40 per
with a ban on donkey skin export in place and, in           skin. We can ship you anywhere in the world.
many instances, alongside wildlife products.                Email                         .com for more
Despite an explicit export ban on donkey skins in           info.” Another trader also based in Kenya,
Nigeria and a no-slaughter policy by the Kenyan             offers camel and alligator skins alongside
Government, traders are using social media to               donkey skins. Kenya has not licenced donkey
offer skins for sale from both countries.                   slaughterhouses since early 2020.

                                                          ƒ A trader based in Thailand38 offers donkey
                                                            skins alongside a number of wildlife products
         The biggest social media                           including Ling Yang Jiao (Saiga Antelope
         platforms, Facebook, Instagram                     horn), Tezhi Sanbian Jiu or Three-Penis
                                                            Liquor (Cantonese dog, seal and deer penis)
and WeChat have become ground zero                          and Lu Bian (slices of Sika deer testes).
for wildlife crime syndicates to connect
with buyers, market their illegal goods,
and move money.
           – Alliance to Counter Online Crime31

                                                                                                              Donkey skins being offered
                                                                                                              alongside pangolin scales
                                                                                                              and hardwoods on Facebook.

18   REPORT 1                                                                                                                                 TH E G LOBAL TR AD E I N DON KE Y S KI N S A T I CKI N G T I M E BOM B   19
G LO B A L T R A D E R S M A P

     UK
     Ben Wilson’s Cleaning Lab

                                                                                                                                            Poland
     Chad                                                                                                                                   Browar Lomsa
     Afri Hides                                                                                                                             Tradehouse.Kft

     USA
     ACBS Fragrance
     & Cosmetic Ltd
                                                                                                                                            India
                                                                                                                                            Jimdam Trading Ltd

     Senegal
     Territorial Adverts UK
                                                                                                                                            Thailand
                                                                                                                                            Nittaya Trade Co. Ltd

     Burkina Faso
     Burkinabe Native Dealer
     Ltd
     Italian Fashion

     Nigeria                          Cameroon
     Stephen’s World of Donkey Skin   Ewellecoof int. Ltd
     Swala Simeon                     Abattoir SA
     Nwoaha Isaiah                    Methoda Resourses
     Donkey SKIN dealers in Nigeria   West Coast Livestock and Fisheries Co Ltd
                                                                                  South Africa        Tanzania                              Kenya
     MacGyver Services                Zoto Atangana
                                                                                  Animal Skins        Daisy Agric Consultancy               Vrall Exotics Ltd
     Skills and Taz Ventures          Bandecoal Limited                                               Limited
                                                                                                                                            Great Lakes Foods
                                      Agrogold                                                        Tranax Investment Limited

20     REPORT 1                                                                                  TH E G LOBAL TR AD E I N DON KE Y S KI N S A T I CKI N G T I M E BOM B   21
DETECTION AVOIDANCE
Online platforms often lack policies to protect       Some online traders may be attempting to
                                                                                                                 C A S E S T U DY: K E N YA
against the sale of protected wildlife species,       obfuscate or evade listing rules by using
let alone legally ambiguous donkey skins, and         aggregated or deliberately misspelt descriptions           A Kenya-based company with connections to
the sheer scale of electronic activity makes          such as the listing soliciting “...donkey hidesea          a range of other global businesses, websites
enforcement of policies, where they do exist,         hourseabalonefish bladder” on Tradekey53 (see              and social media pages, which variously
particularly challenging.50 This is evidenced         Figure 7) or selling “pangolinsss scales” on               advertise products such as donkey skins,
by the blatant disregard for national and             ECPlaza (see Figure 8).54                                  gold, diamonds, snake and toad venom,
international law shown by some sellers. The                                                                     narcotics (ketamine, crystal meth) and wildlife
trade is continually evolving, and traders move                                                                  products including hardwoods, shark fins,
from one platform to another and use other                                                                       seahorses, and sea cucumbers. Claims made
avoidance tactics to escape detection.51                                                                         on the company website suggest that it acts
                                                                                                                 as an intermediary, connecting buyers in
In several instances, traders advertising on online                                                              Thailand, Germany, China and the USA with
platforms openly acknowledge the illegality                                                                      exporters and wholesale suppliers in Kenya,
of their sale and provide potential buyers with                                                                  Cameroon and South Africa with companies
information on the steps that will be taken to                                                                   and consumers.
obfuscate the shipment of other illegal products.
A US-based trader advertising illegal pangolin                                                                   Many products offered by the company are
scales on the EC21 trade platform assures                                                                        either trafficked or used to obscure other
potential buyers that they will “…package them                                                                   trafficked wildlife. The company also sells
in corrugated cardboard boxes and make them                                                                      cashew nuts, sisal fibers, coffee, timber and
look like electronic appliances to deter customs                                                                 cloth, commodities often used to obfuscate
                                                                                                                                                                              Donkey skin is prohibited in
attention,”52 (see Figure 6). On being approached                                                                illegal shipments of wildlife from Africa to Asia.           Kenya as of now and we ship
by investigators from The Donkey Sanctuary, the
same trader offered a range of wildlife items for
                                                      Figure 6: A trader outlines detection avoidance tactics.
                                                                                                                 The company offers donkeys skins for export
                                                                                                                                                                      under total discretion alongside
sale alongside donkey skins (see Figure 6) with                                                                  from Kenya, even though it acknowledges this         heavy bribery to the port authorities.
shipping to Hong Kong or China.                                                                                  is illegal. In response to an email in January
                                                                                                                 2021 from investigators from The Donkey
                                                                                                                                                                      Chinese residents are completely
                                                                                                                 Sanctuary, the company said:                         banned dealing with donkey skin in
                                                                                                                                                                      Kenya. We have 2,000 skins available
                                                                                                                                                                      now and priced at $40 per skin. If
                                                                                                                                                                      you are interested, we can start
                                                                              Figure 7: Product names are                                                             shipping smaller quantities to avoid
                                                                              frequently misspelt, perhaps
                                                                              as a detection avoidance tactic.                                                        too much questioning. We can start
                                                                                                                                                                      with 500 skins.
                                                                                                                                                                                                            – Mr Tony

                                                                              Figure 8: Product misspelling
                                                                              is a regular occurrence.

22   REPORT 1                                                                                                                                    TH E G LOBAL TR AD E I N DON KE Y S KI N S A T I CKI N G T I M E BOM B   23
E-COMMERCE INDUSTRY
                                                                                                                         ATTEMPTS TO TACKLE
                                                                                                                         ILLEGAL TRADE

                                                                                                                         E-commerce platforms face an enormous task            While the facilitating role that social-media
                                                                                                                         in detecting and combatting illegal activity          platforms play in wildlife trafficking has attracted
                                                                                                                         on their sites. While some traders are openly         more attention, and many have joined the Global
                                                                                                                         trading illegal goods,55 others take measures to      Coalition to End Wildlife trafficking online,57
                                                                                                                         avoid detection. The online trading environment       their efforts to stem the tide of wildlife sales
                                                                                                                         is also dynamic and, particularly when involved       are often similarly disappointing. Most platforms
                                                                                                                         in illegal activity, can involve complex webs         that committed to the coalition’s target of
                                                                                                                         spanning multiple countries. Traders use highly       reducing wildlife trafficking by 80% have failed
                                                                                                                         anonymized payment methods, such as Western           in their efforts.58 In February 2022, The Donkey
                                                                                                                         Union or MoneyGram, which makes tracking the          Sanctuary wrote to all the B2B sites found to be
                                                                                                                         details of payments made for illegal products         offering donkey skins for sale alongside wildlife
                                                                                                                         time-consuming and likely cost prohibitive.           items, asking for both products to be removed
                                                                                                                                                                               from sale. Global Trade Center deleted the
Key figures from the Coalition to End Wildlife Trafficking Online’s 2021 progress report. IFAW, WWF and wildlife trade
monitor TRAFFIC launched the coalition in 2018. Since then, it has blocked or removed more than 11.6 million posts and   An examination of the terms and conditions            trader’s sites we had drawn to their attention
ads. Image courtesy of the Coalition to End Wildlife Trafficking Online.                                                 on the B2B sites showed that only six (EC21,          saying they valued “...environmental protection
                                                                                                                         eWorldTrade, Tradeford, Global Suppliers              and animal protection...”. No positive response
                                                                                                                         online, Alibaba, Go4worldbusiness) included a         has been forthcoming from others we contacted.
                                                                                                                         list of prohibited items. Four (Tradekey, Ecplaza,
                                                                                                                         Exporters India and Ecrobot) merely state that        It remains unclear what percentage of the
                                                                                                                         unlawful items should not be sold on their            traders advertising on social media sites
                                                                                                                         platform and one (Global Trade Center) did not        are either bona fide donkey skin traders or
                                                                                                                         have terms and conditions listed at all. Of the       wildlife criminals, as opposed to perpetrators
                                                                                                                         six platforms with a prohibited item list, five       of schemes such as advanced fee fraud.
                                                                                                                         (EC21, eWorldTrade, Alibaba, Go4worldbusiness,        The overt advertisement of illegal products,
                                                                                                                         Tradeford) specifically mention protected             and the length of time the listings remain live,
                                                                                                                         animal parts.                                         however demonstrates that current detection
                                                                                                                                                                               measures are insufficient to dissuade traders.
                                                                                                                         As with most online platforms, traders appear         More must be done to ensure that the cost
                                                                                                                         to take advantage of the lack of oversight by         of this illegal activity outweighs its benefits
                                                                                                                         B2B marketplaces and freely include pictures          to such an extent that online traders are
                                                                                                                         and detailed descriptions of goods, amounts           deterred. The Donkey Sanctuary is unaware
                                                                                                                         available, minimum order amounts, prices,             of any enforcement activity having been
                                                                                                                         delivery areas, shipping options, and details on      undertaken in this online context.
                                                                                                                         the quality of goods. This raises some pressing
                                                                                                                         questions about how much effort the owners
                                                                                                                         of B2B marketplaces are putting into the                       Online trading platforms have a
                                                                                                                         policing and removing of illegal content. The
                                                                                                                         e-commerce industry has failed to effectively
                                                                                                                                                                                        greater role to play in detecting
                                                                                                                         self-regulate, despite pledges to do so, and the      and addressing illegal activity occurring
                                                                                                                         B2B segment of the e-commerce world has
                                                                                                                         been almost entirely overlooked as a potential
                                                                                                                                                                               on their sites. Until they do, the donkey
                                                                                                                         enabler of criminality.56                             skin trade will continue to act as a
                                                                                                                                                                               Trojan horse for the sale and shipping
                                                                                                                                                                               of wildlife products.

Confiscated wildlife products at JFK airport. Source: Wiki.

24   REPORT 1                                                                                                                                             TH E G LOBAL TR AD E I N DON KE Y S KI N S A T I CKI N G T I M E BOM B   25
G LO B A L S H I P P I N G :                                                                                 Importing     Source country     Number of          Total $ Value/$ av.       Equine/bovine/any      Mode of

DONKEY SKINS AND WILDLIFE                                                                                    country                          consignments       consignment value         description            transport

P R O D U C T S S H I P P E D TO G E T H E R                                                                 China         Peru               121                $26m (av. $214,876        Equine

                                                                                                                           Mexico             115                $15m (av. $130,434)       Equine/Donkey

                                                                                                                           Uruguay            73                 $2.7 (av. $36,986)        Equine

                                                                                                                           Panama             8                  $96,000                   Not given

                                                                                                                           Brazil             13                 Not Given                 Salted Asinine Skins
The links between the global donkey skin                       Customs seizure reports and
trade and wildlife trafficking extend beyond                                                                               Venezuela          4                  $48,000                   Not given
products being offered for sale alongside each
                                                               records, as well as news
                                                                                                                           Colombia           3                  $76,000                   Not given
other. Seizure records maintained by customs           reports, obtained by WildCRU show
authorities show that donkey skins are shipped                                                                             South Africa       9                  $353,000                  Not given
alongside products from a wide range of wild
                                                       evidence of donkey skins being shipped
                                                                                                                           Egypt              3                  $1.4m ($466,666)          Not given
animals, including those that are CITES listed.        with elephant tusks, pangolin scales,
Customs seizure reports and records, as well                                                                               Mauritania         1                  $254,000                  Not given
as news reports, obtained by WildCRU show
                                                       abalone, sea cucumber, shark fins, tiger
                                                                                                                           Nigeria            2                  $557,000                  Not given              By air
evidence of donkey skins being shipped with            skins and fish maw.
elephant tusks, pangolin scales, abalone, sea                                                                              Tanzania           1                  $161,000                  Not given
cucumber, shark fins, tiger skins and fish maw.                                                                            Kyrgyzstan         31                 $7.3 million ($235,483)   Not given              By road
Many of these items are CITES Appendix 1 listed
meaning that commercial trade is either entirely       Analysis of the Panjiva shipping database                           Mongolia           3                  $68,000                   Not given              By road
illegal or at least tightly controlled.                identified 1,600 consignments of 41020, valued
                                                       at USD$95 million, destined for China, Hong
Traders exporting donkey skins can simply              Kong, Thailand, South Korea and Vietnam               Hong Kong     Brazil             34                 Not Given                 Salted Asinine skins
designate their cargo under one of the                 between February 2017 and February 2022.                            Colombia           17                 $837,000                  Not given
internationally recognised Harmonised System           249 of these shipments originated in countries
or HS codes, which is the standardized numerical       or regions that are not known to export donkey
method of classifying traded products. Customs         skins, so these are likely to be bovine in origin.    Vietnam       Nigeria            1                  Not Given                 Dried Donkey Skins
authorities globally use the HS system to identify     Consignments within Asia accounted for 77 in
products when assessing duties and taxes,              total, with 31 from Kyrgyzstan which is a known                     Brazil             35                 Not Given                 Asinine Skins
and for gathering statistics, but shippers are         donkey skin source country and 24 from India                        Colombia           15                 $815,000                  Not given
under no obligation to provide any more                where it is suspected that the trade has been
detailed description of the consignment.               operating for some time.                                            Peru               1                  $416,000                  Equine
A single HS code, 410120, covers all equine                                                                                Mexico             10                 $955,000                  Mainly equine, some
and bovine-derived skins, and this vagueness           500 consignments of 410120 from known                                                                                               bovine
is routinely exploited by exporters who provide        donkey-skin source countries were examined.
either ambiguous descriptions, or no description
                                                                                                            Table 2: Donkey skin exports / imports
at all (See Table 2). For example, analysis of         While the lack of specificity of the 410120 code     (data from Panjiva shipping database).
410120 exports from South Africa, which has            makes it impossible to know precisely what was
a national slaughter quota of 12,000 donkeys           in each of the consignments, the majority were
for export of skins to China, found only nine          either listed as donkey or equine skins or were      Only 17 consignments of 410120, valued at                        A similar analysis of the Tradeatlas and Volza
consignment records, none with descriptions            shipped by known donkey skin exporters and           $USD2.7 million in total, were recorded from                     shipping databases found 97 consignments
and all from 2017. This practice is regularly          received by known donkey skin importers. This        Africa to China. Details of shippers are not listed,             of 410120 destined for China between
seen in wildlife trafficking where, according          analysis has revealed that donkey skins may          and quantities of product are not recorded.                      January 2015 and February 2022, in addition
to TRAFFIC, “Descriptions of commodities               be being sourced and shipped from a much                                                                              to 184 for Hong Kong and 50 to Vietnam.
are vague or misleading. Examples of vague             more diverse range of countries than we had          Based on what is documented about the scale                      Source countries such as US and Canada
descriptions for wildlife shipments include ‘shell’,   previously realised. There is also no explicable     of the trade in Africa60 these consignments can                  were discounted as they do not supply donkey
‘horn’, and ‘rosewood’ (there are many species of      reason for the huge variation in average values      only represent a fraction, less than 1%, of the                  skins. Searches were undertaken for donkey
rosewood, some of which can be traded legally, and     for the consignments going to China and those        actual numbers of skins exported from Africa                     hides/skins in the descriptions (where given)
others prohibited from international trade).”59        to Vietnam and Hong Kong.                            over the five-year period.                                       and for HS code variations and miscodes.

26   REPORT 1                                                                                                                                        TH E G LOBAL TR AD E I N DON KE Y S KI N S A T I CKI N G T I M E BOM B   27
This analysis has revealed that                                                                                Importing        Source            Number of consignments        Equine/bovine/any              Notes
        donkey skins may be sourced                                                                                    country          country           / HS Code                     description

and shipped from a much more                                                                                           Hong Kong        Mexico            43 coded to 410120            Not given

diverse range of countries than                                                                                                                           34 coded to 410007 (Code      Salted donkey hides
we had previously realised.                                                                                                                               not identified)

                                                                                                                                                          4 coded to 410007 (Code       Salted Donkey Hides
                                                                                                                                                          not identified)

                                                                                                                                        Brazil            17 coded to 410120            Not given

                                                                                                                                        Colombia          33 coded to 410120            Not given
Table 3 & 4: Donkey Skin Exports / Imports
(from TradeAtlas and Volza databases)                                                                                                   Chile             17 coded to 410120            Not given

                                                                                                                                        Cyprus            16 (2 coded to 410120, 8      Donkey Skins                   Exporter is Ortiz Lan
 Importing       Source           Number of consignments      Equine/bovine/Any           Notes                                                           to 430219 (HS code for                                       based in Colombia so this
 country         country          / HS Code                   description                                                                                 Furskins), 4 to 180200                                       seems to be miscode.
                                                                                                                                                          (Cocoa shells and husks),
 China           Mexico           65 coded to 410120          Mainly Equine
                                                                                                                                                          2 to 292143 (HS code for
                                  +4 coded to 410007          Wet Salted donkey skin                                                                      Toluidines)
                                  (Code not identified)
                                                                                                                                        Peru              6 coded to 410007 (Code       Salted Donkey Hides
                                  +4 coded to 410009          Donkey Skin Wet Salted      HS Tariff 400120 given in                                       not identified)
                                  (Code not identified)                                   description-
                                                                                                                                        Uganda            1 coded to 410120             Not given
                                                                                          HS 400121 is a code for
                                                                                          Natural Rubber in Sheets                      Ghana             4 coded to 410150 (Equine     Dry Donkey Skin
                                                                                                                                                          skins exceeding 16kg)
                                  +4 coded to 410009 (Code
                                  not identified)                                                                                       Kenya             2 uncoded                     Not given                      From Star Brilliant donkey
                                                                                                                                                                                                                       slaughterhouse
                                  +14 coded to 41012002       Salted Donkey Hides
                                                                                                                                                          1 coded to 410692             Not given                      From Goldox donkey
                                  +2 coded to 41012002        Salted Donkey Hides
                                                                                                                                                          (Tanned or crust hides and                                   slaughterhouse
                 Brazil           10 coded to 410120          Equine                                                                                      skins of animals other than
                                                                                                                                                          equine or bovine)
                 Peru             4 coded to 410007 (Code     Salted Donkey Hides
                                  not identified)                                                                                       Tanzania          1 coded to 410120             Not given

                 Kenya            8 coded to 410120           Not given                   From Star Brilliant                           South Africa      1 coded to 410120
                                                                                          slaughterhouse
                                                                                                                                        China             2 coded to 960000 -           15 Pallets Raw Donkey Skins
                 Nigeria          7 coded to 410006 (Code     Donkey Skin                                                                                 (Closest code is HS           (x2)
                                  not identified)             Dried Salted Donkey Skins                                                                   960110 which is worked
                                  7 coded to 410006 (Code                                                                                                 Ivory)
                                  not identified)
                                                                                                                                                          2 coded to 960000             Donkey Hides
                 Ethiopia         1 coded 05051000 (HS        Salted Donkey Skin          NB from Volza database
                                                                                                                       Vietnam          Togo              5 coded to 410000             Donkey Skin                    +2 (Volza) 2020
                                  code for Raw feathers for
                                  stuffing)                                                                                             Nigeria           4 coded to 320014 (HS         Dried Salted Donkey Hides      +2 (Volza)
                                                                                                                                                          code for Tanning and dying
                 Tanzania         2 uncoded                   Salted dried donkey skins   From Fang Hua donkey
                                                                                                                                                          extracts)
                                                                                          slaughterhouse
                                                                                                                                        Kenya             1 uncoded                     Dry Donkey Skin
                 Egypt            1 coded to 410120           Not given
                                                                                                                                        Mexico            10 coded to 410007 (Code      Salted Donkey Hides
                 South Africa     1 uncoded                   Not given
                                                                                                                                                          not identified)
                 Vietnam          8 uncoded                   Equine
                                                                                                                                        Peru              20 coded to 410007 (Code      Salted Donkey Hides
                 Malaysia         1 uncoded                   Dried Salted Donkey Skins                                                                   not identified)

                                  9 uncoded                   Dried Salted Donkey Hides                                                 Turkey            10 coded to 410002 (Code      Wet salted donkey hides
                                                                                                                                                          not identified)
                                  3 uncoded                   Dry Salted Donkey Hides

                                                                                                                      Note: Data shows results from searches undertaken for donkey skins and HS codes used to identify equine skins.

28   REPORT 1                                                                                                                                                 TH E G LOBAL TR AD E I N DON KE Y S KI N S A T I CKI N G T I M E BOM B           29
It appears that some specific source countries    consignments shipped by sea. The seizures
predominantly ship to countries that are not      discovered co-shipments of ivory, dried African
the ultimate destination. A high percentage of    grey parrot carcasses, agarwood, shark fin,
donkey skin exports from Brazil and Colombia,     worked coral, rhino horn, crocodile skin and
for example, are shipped to Hong Kong. The        unidentified animal bones. An unspecified
reason for this is unclear and will be examined   number of donkey skins are listed as having
further.                                          been found in consignments of pangolin scales.
                                                  Nigerian-based companies on a range of B2B
Another anomaly being investigated is the         sites currently offer donkeys skins in association
diverse number of HS codes that are used for      with a range of wildlife items including pangolin
donkey skin shipments, some of which bear no      scales, elephant ivory and hardwoods. A 2021
relation to the consignment description.          crime index report on Nigeria produced by the
                                                  Global Initiative Against Transnational Organised
A December 2021 paper in Biological               Crime62 states that “Nigeria has become a major
Conservation61 examined 80 Nigeria-linked         transit hub for wildlife trafficking, particularly for
seizures of pangolin scales between January       Central African ivory and pangolin scales as well as
2010 and September 2021, finding that 65% of      for donkey hides destined for Vietnam and China,
the total mass of seized pangolin scales were     the primary markets for wildlife products.”              Donkey skins seized by Hong Kong Customs. Source: Hong Kong Customs.

                                                                                                           ƒ In May 2018, Nigerian customs authorities                in which 16 tons of donkey skins had been
                                                                                                             intercepted a Chinese national attempting                hidden.67 Analysis of the Tradeatlas shipping
                                                                                                             to smuggle 23 bags of pangolin scales,                   database however found that not one of the
                                                                                                             eight bags of elephant tusks and 99 bags of              38 consignments of salt arriving in Hong
                                                                                                             ‘unprocessed’ donkey skins out of the country.           Kong during March and April 2020 originated
                                                                                                             The suspect had been attempting to board a               from Egypt; this raises serious questions
                                                                                                             Qatar Airlines flight to China.63 In September           about the reliability of the information
                                                                                                             2021, two 40-foot containers of donkey                   provided in the documentation accompanying
                                                                                                             skins (12,500 in total) were seized by Nigerian          the shipments. The case was reportedly
                                                                                                             customs, along with five 20-foot containers              handed to the Agriculture, Fisheries and
                                                                                                             of logs and a 20-foot container of charcoal.64           Conservation Department. In an email from
                                                                                                                                                                      January 2022, customs authorities indicated
                                                                                                           ƒ In March 2022, Nigeria Customs Service65                 that the case was “…currently under court
                                                                                                             seized donkey skins valued at £4,400. The                proceedings...”
                                                                                                             skins were being stored in a warehouse in
                                                                                                             Lagos, alongside cannabis valued at £24,000.          ƒ In 2017, customs officials in Hai Phong,
                                                                                                                                                                     Vietnam, discovered a ton of seahorses
                                                                                                           ƒ On 11 April 2020, the South China Morning               disguised in a consignment of donkey skins
                                                                                                             Post66 reported on the interception at the              originating from Peru. It was estimated
                                                                                                             Kwai Chung Customhouse Cargo Examination                that the consignment comprised 300,000
                                                                                                             Compound in Hong Kong of a consignment of               seahorses, although the particular species
                                                                                                             table salt from Egypt. The shipping container           could not be identified.68
                                                                                                             was found to contain smuggled items
                                                                                                             including 17 tons of donkey skins, 520kg of
                                                                                                             sea cucumbers and 2kg of fish maws. This
                                                                                                             followed on from a seizure on 9 April of a
                                                                                                             container of table salt, again from Egypt,
 Live Pangolin. Source: Wiki.

30   REPORT 1                                                                                                                                TH E G LOBAL TR AD E I N DON KE Y S KI N S A T I CKI N G T I M E BOM B   31
C A S E S T U D I E S: N OTA B L E S E I Z U R E S

                                           25,0 0 0                                                                       11 ,0 0 0
                                           DONKEY                                                                         DONKEY
                                           SKINS                                                                          SKINS, 7
                                                                                                                          TIGER SKINS

     23 B AG S O F                                              16 TO N N E S
      PA N G O L I N                                           OF DONKEY
       SCALES, 8                                               S K I N , 1 TO N
         B AG S O F                                                OF DRIED
      ELEPHANT                                                           SHARK
       T U S K S , 99                                          F I N S , 520 KG
         B AG S O F                                                    OF SEA
         DONKEY                                               CUCUMBERS,
             SKINS                                            2 KG O F F I S H
                                                                          M AW

                                           70 D O N K E Y S                                                               30 0,0 0 0
                                           W E R E FO U N D                                                               I N D I V I D UA L
                                           TO O W E A K                                                                   SEAHORSES
                                           TO S TA N D                                                                    WERE
                                                                                                                          FA L S I F I E D A S
                                                                                                                          A SHIPMENT
                                                                                                                          OF DONKE YS

32   REPORT 1                                                                     TH E G LOBAL TR AD E I N DON KE Y S KI N S A T I CKI N G T I M E BOM B   33
FO C U S O N CO LO M B I A

A 2021 InSight Crime investigation into donkey        InSight Crime spoke with a state forensics          In 2016, Colombian news outlet La FM
trafficking in Colombia69 revealed widespread         investigator, who had been commissioned             reported72 that 760 donkey skins had been                  STOP PRESS
purchasing, theft and slaughter of donkeys, and       by Colombia’s Attorney General, to investigate      seized by police in Cordoba’s animal protection
exposed the impact of this on people who use          the illegal donkey trade. He revealed that          unit. Police Colonel Engelbert Grijalba indicated
                                                                                                                                                                      At the time of writing, ongoing
donkeys on their farms and for the transport          prosecutors suspected local representatives         that donkey skin “…is also used by drug
                                                                                                                                                                      investigations commissioned by The Donkey
of goods, food and people. The investigation          of the Regional Autonomous Corporation              traffickers, with the intention of ‘camouflaging’
                                                                                                                                                                      Sanctuary are uncovering evidenced links
found substantial evidence of loopholes and           (Corporaciones Autónomas Regionales) as having      coca shipments in the inspections of anti-
                                                                                                                                                                      between the donkey skin trade in South
non-compliance with existing Colombian laws           overstated production numbers at a licenced         narcotics dogs.” A news report from February
                                                                                                                                                                      America and the smuggling of jaguar teeth
by companies involved in the trade. This was          crocodile-breeding farm in the Antioquia            201773 detailed the activities of a gang named
                                                                                                                                                                      to Hong Kong and Vietnam. Investigations
seemingly an issue that the authorities have          department, which was legally exporting             the ‘Pela Burros’ (Donkey Peelers) operating on
                                                                                                                                                                      in Africa have found donkey skin traders
been aware of for some years. In a 2016               crocodile and alligator skins. These extra          the Colombian-Venezuelan border and stealing
                                                                                                                                                                      operating in countries with a ban on the
interview with, the El Heraldo newspaper70            animals on paper gave the exporters space           donkeys for their skins. Local speculation was
                                                                                                                                                                      slaughter of donkeys and the export of their
with Luis Humberto Martínez, National Director        in the cargo hold to send additional items.         that donkey skins were used to “...camouflage
                                                                                                                                                                      skins, and who are involved in the trading
of the Colombian Agricultural Institute, ICA                                                              cocaine that is shipped to Asian countries.”
                                                                                                                                                                      of a range of prohibited wildlife items from
said that:                                            Attached to the breeding farm was a ‘clandestine’
                                                                                                                                                                      endangered species. This information has
                                                      donkey slaughterhouse and tannery, all run and
                                                                                                                                                                      been shared with the relevant international
     "This activity (donkey skin export to China      operated by the same couple who the authorities
                                                                                                                                                                      enforcement authorities who are acting on
     and Hong Kong) is carried out without            claimed were trafficking donkey skins. According
                                                                                                                                                                      the intelligence.
     a health certificate for exports, that is,       to InSight Crime:
     without the certification of specific health
     requirements, since exporters present a             “The tannery, breeding zoo and
     declaration indicating that the countries of        slaughterhouse were complementary
     destination do not require the Animal Health        businesses. Stolen donkeys were run through
     Certificate. With this, they automatically          the slaughterhouse for their skin, which
     exonerate the ICA from responsibility for           was processed with a brine, then stored in
     possible returns. At the exit point only the        cold rooms. Later, they were transferred
     physical verification of the merchandise            to refrigerated trucks, before being sent
     is carried out and the respective health            abroad alongside the products from the
     inspection certificate is issued on site. As a      tannery. Their destination, the Attorney
     result… it is impossible to be certain of the       General’s Office believes, was China. The
     origin of the skins.”                               donkey carcasses were sent to the zoo,
                                                         where the owners would feed them to the
As an example of the high levels of ambiguity            alligators and crocodiles they were breeding,
that plague the trade in donkey skins, Martinez          one former employee told InSight Crime.”
indicated that China does not specify import
requirements when, in fact, China has clear
and specific rules regarding veterinary and                    There is a market for space in
quarantine certification on donkey skin imports,
and only allows imports from source-country
                                                               the cargo hold. In addition to
production facilities it has licenced for that        sending the treated donkey skins,
purpose. No listings of any such facilities in
Colombia are recorded on China’s customs
                                                      exporters can send skins and furs of
database. When questioned by InSight Crime,           other animals that have been captured
the Colombian authorities admitted that none
of the donkey skin export companies “...complied
                                                      and killed illegally. Prosecutors also
completely...” with export regulations, saying        suspect that money launderers and
that many consignments of exported skins “…
did not have a certificate to prove they had been
                                                      drug traffickers can buy this space.
cleaned and sanitized for export.”71
                                                                                       – InSight Crime

                                                                                                           Freezer room at a donkey slaughterhouse.

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FO C U S O N S O U T H A F R I C A

One of the key alerts to the link between the
donkey skin trade and the wildlife trade was an
insightful 2017 National Geographic feature by
                                                                                                    January 2017 – Bapsfontein
South African journalist Kimon de Greef.74                                                          South African company, Anatic Trading Pty Ltd,
                                                                                                    founded in September 2015,77 was investigated
This revealed a close link between the individuals                                                  by South African Police Service on 16 January
involved in South Africa’s illegal abalone trade                                                    2017. Acting on a tip-off, Captain Ockert Jaco
and the donkey skin trade. It also uncovered                                                        Van Der Walt of the Cullinan Stock Theft Unit
a plethora of other problems with the trade                                                         discovered 2,921 donkey skins in a storage unit
from abject cruelty to contravention of local                                                       in Bapsfontein near Johannesburg, which were
laws and environmental pollution and the active                                                     about to be imminently shipped from Durban.
involvement of Chinese Triad cartels. It sparked a
flurry of enforcement activity by the authorities                                                   Captain Van der Valt was “...handed seemingly
and some high-profile seizures in a short space                                                     false invoices to account for the possession
of time.                                                                                            of the donkey hides...”78 and subsequently “...
                                                                                                    obtained further shipping invoices of previous
                                                                                                    shipments of donkey hides by Anatic Trading.”
June 2016 - Bloemfontein                                                                            These invoices showed that Anatic Trading
Following a tip-off by the Highveld Horse Care                                                      shipped a total of 12,776 donkey skins to Hong
Unit,75 a raid by the authorities on a property                                                     Kong between July 2016 and December 2016, a
outside Bloemfontein in June 2016 found 82                                                          figure that far exceeded the entire annual quota
dead and dying donkeys, corralled for days                                                          for South Africa. The shipping instructions for
without food or water and awaiting slaughter                                                        the seized hides were linked by the police back to
for their skins. One of the South African SPCA                                                      Anatic Trading.
inspectors, Reinet Meyer said it was the worst
case she had seen in 27 years of service.                                                           The National Prosecuting Authority issued a
                                                                                                    press statement on 10 May 2017 stating:
     “The donkeys had begun eating cardboard
     and bark from desperation,” Meyer says.                                                            “The invoices received only account for the
     “Many had deformed hoofs and were                                                                  purchase of 133 donkeys. This leaves the
     infected with herpes. Several mothers had                                                          origin of 2788 donkey hides unexplained. It
     aborted their pregnancies from stress. We                                                          is the State’s case that the only reasonable
     found at least 19 foetuses, but counting was                                                       inference that can be drawn from the lack
     difficult—they were small and had started                                                          of documentation is that the remaining
     decomposing.”76                                                                                    2,788 donkey hides, if not all, were illegally
                                                                                                        acquired or stolen, which is a contravention
In an outbuilding at the property, Meyer                                                                of the Stock Theft Act.
discovered a gas burner and giant pots for
processing abalone, a prized shellfish in Asia,                                                         "Captain Van der Walt obtained statements
which is smuggled out of South Africa in huge                                                           from two of the three registered equine
quantities. De Greef concluded: “Cases like the                                                         abattoirs. Both Middelvlei and Vaalbank
Bloemfontein raid help connect the dots. Dried                                                          Abattoirs deny that the hides seized
abalone, a status food that can sell for more than                                                      originate from their abattoirs. What is
$90 per pound in China, forms the nucleus of                                                            disturbing is that both Middelvlei and
a criminal economy worth millions each year in                                                          Vaalbank Abattoirs were approached by
South Africa, with documented links to money                                                            Chinese nationals after the search and
laundering and the drug trade. Police confiscated                                                       seizure for false invoices. None of the 2,921
fewer than two dozen dried abalone from the                                                             donkeys were therefore legally slaughtered
Bloemfontein property, a tiny haul, given that                                                          which is an offence in terms of section 7 of
illicit exports from the country exceed 2,000                                                           the Meat Safety Act.”
tons annually, equivalent to some 500,000
shellfish. But the find added credence to
                                                     Donkey skins seized during Bapsfontein raid.
suspicions that donkey skins have been shifting      Image courtesy of Highveld Horse Care Unit.
onto the black market.”

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