Cecil The Lion
Surprising as it may seem, the Cecil The Lion incident is a money laundering issue.
First some background facts.
According to the Zimbabwe Parks and Wildlife Authority, on July 1, 2015, Cecil The Lion was killed by Dr. Walter Palmer, a US citizen who lives in Minnesota, and a Zimbabwe national, Theo Bronkhorst.
Dr. Palmer is a dentist. Mr. Bronkhorst is a professional hunter who works with a company called Bushman Safaris and is affiliated with a place called Antoinette Farm, beside Zimbabwe’s Hwange National Park. The owner of Antoinette Farm is a person surprisingly named Mr. Honest Trymore Ndlovu.
Cecil The Lion was a “protected animal” under Zimbabwe law.
In early 2015, Honest Ndlovu was authorized to provide hunting services at his Farm for certain animals for 2015. He was not authorized to provide hunting services of lions but he did anyway, to Dr. Palmer.
Mr. Honest Ndlovu and Mr. Bronkhorst have both been charged in Zimbabwe, as has Dr. Palmer.
Zimbabwe Hunting Laws
Pursuant to Zimbabwe’s Parks and Wildlife Act, it is an offense to hunt a protected animal that is not a threat without permission, punishable on conviction to a term of imprisonment of 20 years. It is also an offense for a professional hunter to allow a person to hunt a protected animal or any animal outside of authorized zones. And further, it is an offense to transport or ship, animal parts (a trophy) of an illegally hunted animal, an offense which has legal ramifications for airlines.
Before the Cecil The Lion incident, Emirates Airlines took a leadership role by eliminating the carrying of trophy lion parts on its airlines pursuant to the UN Convention on International Trade in Endangered Species of Wild Fauna and Flora.
Left Cecil The Lion to Bleed for 40 Hours
According to Zimbabwe officials, Mr. Palmer paid $70,000 to his guides to hunt a lion.
On the day of July 1, 2015, they allegedly placed animal meat on a vehicle and drove around at night to lure a lion out of the National Park. Cecil took the bait and he was shot, but not killed, with a cross bow by Dr. Palmer. The team decided to let him bleed out for 40 hours until they ultimately shot him dead when he was weak and dying. Dr. Palmer then cut off Cecil’s head and skinned him, for trophies. Cecil The Lion was collared and GSPed. Dr. Palmer allegedly subsequently made arrangements with an airline to have the lion’s body parts shipped to the US.
On July 7, 2015, the Zimbabwe authorities learned Cecil had been killed from an informant.
The Zimbabwe authorities say that, in additional to conducing an illegal hunt, Dr. Palmer illegally financed the illegal operation.
There are about 30,000 lions left in the world. Zimbabwe has about 1,000 of them left. Over a ten year period, Zimbabwe allowed 800 lions to be hunted legally. Many more are apparently hunted illegally. Most of the hunters are American. In 2013, 49 lion parts (trophies) were legally shipped to the US by hunters from Zimbabwe by willing international airlines. Zimbabwe issues permits for 100 lion killings annually.
Now for the money laundering part.
The illegal killing of big game, as a Cecil The Lion, is a type of wildlife crime of which there are several components but materially, the three key ones are the illegal killing, the unpermitted export and import of dead animal parts (the trophies) and the trade thereof, which is the business aspect of the activity. Wildlife crimes can be purely commercial enterprises or conducted by an individual.
The US government confiscates large volumes of animal parts from wildlife crimes when their citizens return from hunting trips, or attempt to import parts. This photo is of seizures of trophy cats either illegally killed or illegally imported into the US.
The US enforces its domestic Endangered Species Act and the UN Convention on International Trade in Endangered Species of Wild Fauna and Flora. Both protect endangered and protected animals of concern globally.
Persons such as Dr. Palmer, who make arrangements to travel overseas to kill big game, must pay their safari guides – in this case Mr. Bronkhorst and Mr. Ndlovu, tens of thousands of dollars for the hunt by wires into their banks in Zimbabwe.
Because the killing of Cecil The Lion appears to be illegal in the criminal sense in Zimbabwe, and a predicate offense, dealing with the proceeds of that crime is money laundering under the Zimbabwe Serious Offences (Confiscation of Profits) Act, 2001. What this means is that Mr. Bronkhorst and Mr. Ndlovu are both holding proceeds of crime in their bank accounts, i.e., the money Dr. Palmer sent them to commit the crime.
Pursuant to that the Serious Offences (Confiscation of Profits) Act, 2001, a person need not be convicted of a predicate offense in order to establish that the property involved is proceeds of crime. Where there is no evidence to show that a person participated in the predicate offence but that he benefited from it, he can be prosecuted for money laundering. This applies to all three of the people who hunted Cecil The Lion.
One would suspect that the reason the Zimbabwe government mentioned the financial aspect of the transaction, is because the extraction of Mr. Palmer would be expedited and simplified if there are allegations of money laundering on the table. Most countries have made a money laundering charge an extraditable offense in and of itself.
Dr. Palmer is not a particularly sympathetic player in the story, especially when it emerged that he has killed several other big game animals, such as this leopard. The Zimbabwe Government has said they are seeking his extradition, and in the meantime, Dr. Palmer quit practicing dentistry and has gone into hiding.
What Should the Average Person Do?
Airlines – Vote with Your Wallet
If you personally care about the issue of the killing of protected species or big game animals for sport, one constructive thing people can do is vote with their wallets by not using airlines that ship big game trophies into countries like Canada and the US, particularly where those airlines do not verify the kills were legal and permitted.
Take a look again at that picture, above, of the voluminous number of stuffed big cat heads seized by the US government in just one of their offices –> each of those decapitated animal trophies was shipped for profit to the US by airline companies and was an illegal importation (unpermitted at the shipping or receiving end), hence they were seized. The same happens in Canada. Ethical business practices matter a great deal to consumers.
Big game hunters want lion heads and such, hanging in their homes for show. Depriving them of the ability to ship animal parts internationally when they break the law, helps to curb the practice of illegal hunting of endangered cats like Cecil The Lion.
Scams & Donations
Many scams will crop up all over the world to raise money, purportedly for Cecil The Lion – one should exercise financial crime common sense when donating to such causes. Because of the financial crime issues, and corruption problems in Zimbabwe, sending money to agencies associated with Zimbabwe, or the Government of Zimbabwe, is not recommended, even if they purport to work for wildlife preservation.
It is preferable to make donations to an organization in the US or Canada, for example, where they enforce financial crimes, including for charities, and their customs agents stop trophies entering the country illegally.
One should also exercise caution with crowdfunding sites raising money for Cecil The Lion that just cropped up – some sites do not have financial crime rules or policies in place and some campaigns are raising money for Zimbabwe, which is to be avoided due to the financial crime concerns.