Combating Wildlife Trafficking: Opportunities Exist to Improve the Use of Financial Rewards
Fast Facts
Wildlife trafficking is a multibillion-dollar, global criminal activity that imperils thousands of species. To help combat it, the U.S. Fish and Wildlife Service and the National Oceanic and Atmospheric Administration can offer rewards in certain circumstances for information on wildlife trafficking activities.
We found that these agencies have not prioritized offering rewards, and they have paid few of them—27 rewards in 11 fiscal years, totaling about $205,000.
We made seven recommendations to these agencies, including telling the public about the possibility of rewards and reviewing how effectively the agencies are using rewards.
Recovered: A trafficked Asian leaf turtle with taped legs
A photo of a turtle with its legs taped to its body.
Highlights
What GAO Found
Multiple laws—such as the Endangered Species Act and Lacey Act—authorize the Departments of the Interior's U.S. Fish and Wildlife Service (FWS) and Commerce's National Oceanic and Atmospheric Administration (NOAA) to pay rewards for information on wildlife trafficking. FWS and NOAA reported paying few rewards from fiscal years 2007 through 2017. Specifically, the agencies collectively reported paying 27 rewards, totaling $205,500. Agency officials said that the information was complete to the best of their knowledge but could not sufficiently assure that this information represented all of their reward payments.
Turtle Taped for Transport (Left) and Other Illegally Trafficked Turtles (Right) Recovered Based on Information from a Source Who Then Received a Reward from the U.S. Fish and Wildlife Service
FWS and NOAA have reward policies that outline the general process for preparing reward proposals, but FWS's policy does not specify factors for its agents to consider when developing proposed reward amounts. Some FWS agents GAO interviewed said that in developing proposals, they did not know whether their proposed reward amounts were enough, too little, or too much. By augmenting its policy to specify factors for agents to consider, FWS can better ensure that its agents have the necessary quality information to prepare proposed reward amounts, consistent with federal internal control standards.
FWS and NOAA communicate little information to the public on rewards. For example, most agency websites did not indicate that providing information on wildlife trafficking could qualify for a reward. This is inconsistent with federal standards that call for management to communicate quality information so that external parties can help achieve agency objectives. FWS and NOAA officials said they have not communicated general reward information because of workload concerns, but they said it may be reasonable to provide more information in some instances. By developing plans to communicate more reward information to the public, the agencies can improve their chances of obtaining information on wildlife trafficking that they otherwise might not receive.
FWS and NOAA have not reviewed the effectiveness of their use of rewards. The agencies have not done so because using rewards has generally not been a priority. FWS and NOAA officials agreed that such a review would be worthwhile but provided no plans for doing so. By reviewing the effectiveness of their use of rewards, FWS and NOAA can identify opportunities to improve the usefulness of rewards as a tool for combating wildlife trafficking.
Why GAO Did This Study
Wildlife trafficking—the poaching and illegal trade of plants, fish, and wildlife—is a multibillion-dollar, global criminal activity that imperils thousands of species. FWS and NOAA enforce laws prohibiting wildlife trafficking that authorize the agencies to pay financial rewards for information about such illegal activities.
GAO was asked to review FWS's and NOAA's use of financial rewards to combat wildlife trafficking. This report examines (1) laws that authorize FWS and NOAA to pay rewards for information on wildlife trafficking and the extent to which the agencies paid such rewards from fiscal years 2007 through 2017, (2) the agencies' reward policies, (3) information available to the public on rewards, and (4) the extent to which the agencies reviewed the effectiveness of their use of rewards.
GAO reviewed laws, examined FWS and NOAA policies and public communications on rewards, analyzed agency reward data for fiscal years 2007 through 2017 and assessed their reliability, interviewed FWS and NOAA officials, and compared agency policies and public communications on rewards to federal internal control standards.
Recommendations
GAO is making seven recommendations, including that FWS and NOAA track reward information, FWS augment its reward policy to specify factors for agents to consider when developing proposed reward amounts, FWS and NOAA develop plans to communicate more reward information to the public, and FWS and NOAA review the effectiveness of their reward use. Both agencies concurred with these recommendations.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status Sort descending |
|---|---|---|
| United States Fish and Wildlife Service | The Assistant Director of the FWS Office of Law Enforcement should augment FWS's financial reward policy to specify factors law enforcement agents are to consider when developing proposed reward amounts. (Recommendation 3) |
Closed – Implemented
The Department of the Interior concurred with this recommendation. As of April 2019, the FWS Office of Law Enforcement took steps to address this recommendation. Specifically, the office updated its financial reward policy to specify factors law enforcement agents are to consider when developing proposed reward amounts. For example, the office's reward policy now instructs field agents to consider the probability that the investigation would have been successfully concluded without the information provided, as well as the relationship between the success of prosecution and the information provided. The FWS Office of Law Enforcement said it posted this updated policy on its internal website to guide field agents. By taking these steps, we consider this recommendation to be closed.
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| United States Fish and Wildlife Service | The Assistant Director of the FWS Office of Law Enforcement should determine the types of additional information to communicate to the public on financial rewards and then develop and implement a plan for communicating that information. (Recommendation 4) |
Closed – Implemented
The Department of the Interior concurred with this recommendation. As of July 2020, the FWS Office of Law Enforcement had taken steps to address this recommendation. Specifically, the office developed pamphlets, business cards, and posters that officials plan to use to inform the public of ways to report violations and that financial rewards may be available if information provided leads to an arrest, a criminal conviction, civil penalty assessment, or forfeiture of seized property. In addition, headquarters and regional websites were updated with this information. Furthermore, the office reminded special agents and wildlife inspectors during their 2019 annual training that financial rewards can be a useful law enforcement tool. By taking these steps, we consider this recommendation to be closed.
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| National Oceanic and Atmospheric Administration | The Director of the NOAA Office of Law Enforcement should determine the types of additional information to communicate to the public on financial rewards and then develop and implement a plan for communicating that information. (Recommendation 5) |
Closed – Implemented
As of November 2018, the NOAA Office of Law Enforcement reported that it had taken steps to address this recommendation. Specifically, the office developed an informational pamphlet, provided it electronically to field officers and special agents for further distribution, and posted reward information on its public website. The pamphlet and website state that financial rewards are available, identify reward eligibility criteria, provide instructions on ways to report federal marine resource violations, and list what information to include when reporting these violations. By taking these steps, we believe the agency has addressed this recommendation and consider it closed.
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| United States Fish and Wildlife Service | The Assistant Director of the FWS Office of Law Enforcement should review the effectiveness of the agency's use of financial rewards and implement any changes that the agency determines would improve the usefulness of financial rewards as a law enforcement tool. (Recommendation 6) |
Closed – Implemented
The Department of the Interior concurred with this recommendation. As of July 2020, the FWS Office of Law Enforcement had taken steps to address this recommendation. Specifically, the office assessed the financial rewards paid, system used to track rewards, reward policy, reward information publicly available, and training information provided to special agents and inspectors. Based on its review, the office implemented changes to improve the usefulness of rewards. These changes included developing a new component within its investigation monitoring system that allows officials to electronically process financial rewards, updating its financial reward policy, posting reward information on its websites, developing outreach materials to publicize reward availability, and providing training to remind agents and inspectors that financial rewards are a useful law enforcement tool for combating wildlife trafficking. By taking these steps, we consider this recommendation to be closed.
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| National Oceanic and Atmospheric Administration | The Director of the NOAA Office of Law Enforcement should review the effectiveness of the agency's use of financial rewards and implement any changes that the agency determines would improve the usefulness of financial rewards as a law enforcement tool. (Recommendation 7) |
Closed – Implemented
The Department of Commerce concurred with this recommendation. As of September 2018, the NOAA Office of Law Enforcement reported that it had taken steps to address this recommendation. Specifically, the office reviewed its use of financial rewards by identifying the amount of complaints received, some of which involved wildlife trafficking, and instances NOAA offered rewards. Based on its review, the office updated its financial reward policy and posted reward information on its website to advertise reward availability. The information includes instructions on how to report federal marine resource violations and what information to include when doing so. NOAA officials indicated that they may also consider using rewards more frequently than in the past as a result of its review. By taking thee steps, we consider this recommendation to be closed.
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| United States Fish and Wildlife Service | The Assistant Director of the FWS Office of Law Enforcement should track financial reward information so that it is clearly documented and readily available for examination. (Recommendation 1) |
Closed – Implemented
The Department of the Interior concurred with this recommendation. As of July 2020, the FWS Office of Law Enforcement had taken steps to address this recommendation. Specifically, the office developed a new component within its investigation monitoring system that allows officials to electronically process financial reward requests and payments as well as readily retrieve reward information, such as the amount requested, the request's status, and the case number. In addition, the office updated its financial reward policy to include instructions for processing reward payments using this new component within the office's investigation monitoring system. By taking these steps, we consider this recommendation to be closed.
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| National Oceanic and Atmospheric Administration | The Director of the NOAA Office of Law Enforcement should track financial reward information so that it is clearly documented and readily available for examination. (Recommendation 2) |
Closed – Implemented
The Department of Commerce concurred with this recommendation. As of May 2018, the NOAA Office of Law Enforcement had taken steps that addressed this recommendation. Specifically, the office updated its financial reward policy to include a new procedure for tracking reward payments in NOAA's financial system. In particular, the procedure directs law enforcement agents to use a unique identifier when making reward payments. The procedure also requires NOAA Office of Law Enforcement divisions to provide additional information on each reward to headquarters, including the case number that the reward was associated with in the office's law enforcement database. NOAA reports that it can now better ensure that it has complete information on the rewards it has paid to help manage the agency's use of rewards as a law enforcement tool. By taking these steps, we consider this recommendation to be closed.
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