Green crime is no longer sitting on the edges of regulatory concern. It has moved firmly into the centre of the financial crime agenda. What was once framed as an environmental or conservation issue is now widely recognised by regulators, enforcement bodies, and FATF as a highly organised, profit-driven illicit economy generating hundreds of billions in criminal proceeds annually.

Current global estimates place environmental crime broadly in the range of $110–$281 billion per year, with illegal wildlife trade alone valued at approximately $7–$23 billion annually, depending on methodology and coverage. Some broader enforcement assessments suggest that environmental crime as a whole may represent one of the largest illicit economies globally, ranking alongside drugs and counterfeiting in scale. FATF has been explicit in its recent work: environmental crime is a “low risk, high reward” financial crime category, driven by weak sanctions, fragmented enforcement, and limited financial investigation into underlying flows. More importantly, FATF and partner agencies are now consistently emphasising the need to follow the money rather than the commodity, signalling a clear shift from environmental enforcement to financial crime detection.

The shift is not definitional, it is structural. Environmental harm is now the output of a wider financial system that enables, disguises, and monetises illegal activity across borders. Critically, large-scale environmental crime rarely operates without corruption. Fraudulent permits, compromised customs processes, politically connected intermediaries, licensing abuse, and weak regulatory oversight frequently enable the extraction, movement, and export of illegal commodities across borders. In many jurisdictions, corruption is not adjacent to environmental crime, it is embedded within its operating model. This further reinforces why regulators increasingly view environmental offences as predicate financial crimes tied to bribery, organised crime, and illicit financial flows rather than isolated conservation issues.

In other words: green crime is no longer just about what is taken from nature. It is about how the proceeds are generated, moved, and integrated into the global financial system.

From environmental harm to financial infrastructure

Wildlife trafficking, illegal logging, illegal mining, pollution-related offences, and resource exploitation are increasingly embedded in organised crime networks that operate like commercial enterprises.

Illegal mining in particular has become a major financial crime concern due to its links with corruption, organised crime, sanctions evasion, and commodity laundering. Once minerals such as gold enter legitimate refining and export chains, tracing origin becomes significantly more difficult, allowing illicit and licit supply to merge within formal markets

Recent enforcement actions led by INTERPOL and customs coalitions highlight the scale and sophistication of these networks. Large-scale operations have involved 134+ countries, tens of thousands of seizures, and thousands of suspects, reinforcing the reality that wildlife trafficking is not isolated crime — it is part of globalised organised criminal infrastructure intersecting with drugs, fraud, and corruption.

These networks are not informal or opportunistic. They are:

• structured across jurisdictions

• supported by corporate entities and intermediaries

• reliant on trade routes and legitimate supply chains

• and ultimately dependent on the financial system to scale

This is why regulators increasingly frame environmental crime as a predicate financial crime risk, not a standalone category.

The implication for financial institutions is direct: if the crime is financially enabled, then detection must sit within AML frameworks — not adjacent to them.

The real challenge: the financial system is the enabler.

The proceeds of green crime rarely appear “dirty” at first glance. Instead, they are systematically integrated through familiar financial crime methodologies.

What makes this typology particularly complex is that it often sits inside legitimate commercial activity. Environmental exploitation is frequently disguised as lawful trade —timber, agriculture, logistics, import/export — making detection a question of behavioural consistency rather than obvious illicit indicators.

Common financial crime patterns include:

• Trade-based laundering structures: Illegal wildlife products and natural resources are moved through import/export chains, with invoices, documentation, and counterparties engineered to appear legitimate. This is a core risk area highlighted in FATF analysis of environmental crime financial flows, where trade-based laundering is repeatedly identified as a primary concealment mechanism.

• Corporate layering and front entities: Shell companies and trading intermediaries are used to obscure ownership and origin. In many cases, legitimate and illicit revenues are co-mingled within the same structures, particularly in resource-heavy sectors such as forestry and agriculture.

• Professional facilitators and intermediaries: In more sophisticated networks, professional enablers may also play a role in structuring and legitimising financial activity. Corporate service providers, freight forwarders, customs brokers, trade intermediaries, and other facilitators can be used, knowingly or unknowingly, to obscure beneficial ownership, legitimise trade documentation, and create additional layers of separation between criminal actors and underlying environmental offences. This increasingly places environmental crime within the same professional facilitation ecosystem commonly associated with sanctions evasion, corruption, and complex money laundering structures.

• Asset conversion and wealth integration: Proceeds are frequently converted into real estate, vehicles, and luxury goods, embedding illicit value into stable asset classes that are harder to trace and easier to justify.

• Digital and informal channels: While still emerging, encrypted platforms and informal online marketplaces are increasingly used to facilitate cross-border trade and settlement.

The result is a typology that is not visibly “environmental” from a transaction perspective — it is financial crime disguised as commerce.

Why this is becoming a financial crime priority now?

Three shifts are driving urgency:

First, scale.

Environmental crime generates an estimated hundreds of billions of dollars annually, with illegal wildlife trade alone contributing up to $23 billion per year, and other sectors such as forestry and mining adding tens of billions more. FATF and enforcement bodies consistently emphasise that these figures are likely conservative due to under-detection and limited financial investigation.

Second, convergence.

These networks are increasingly interconnected with other illicit economies — narcotics, fraud, corruption, cybercrime, and human exploitation — creating shared financial infrastructure across crime types. Recent INTERPOL-led operations have explicitly

highlighted the intersection between wildlife trafficking and broader organised crime networks.

Third, regulatory alignment.

FATF has formally embedded environmental crime into its AML risk framework, urging jurisdictions to assess exposure and improve financial investigative capability. The EU has also strengthened its environmental crime directive, explicitly elevating environmental offences within criminal law frameworks and reinforcing their status as predicate offences. Despite this, enforcement remains fragmented. The gap is not recognition — it is consistent detection across financial systems not designed to identify environmental predicate crimes.

What this means for financial institutions

For financial institutions, the challenge is not identifying “wildlife crime transactions”. It is recognising that environmental crime risk is embedded in otherwise legitimate financial activity.

This creates three practical blind spots:

• traditional AML models are not tuned to environmental typologies

• trade-based indicators are often under-weighted in monitoring systems

• and sector-specific behaviours (agriculture, logistics, commodities) are rarely mapped to financial crime risk in a structured way

As a result, exposure is often indirect, dispersed, and difficult to isolate without enhanced contextual intelligence.

What organisations need to do now

Addressing green crime risk does not require reinventing AML frameworks — but it does require extending them in a more deliberate way.

1. Move from geographic risk to supply chain risk

Risk assessment frameworks need to evolve beyond country-level exposure and begin mapping commodity and supply chain typologies. Wildlife, timber, agriculture, and logistics networks should be treated as financial crime-relevant sectors in their own right. Higher-risk exposure may include sectors such as mining, timber, seafood, waste management, agricultural exports, and commodity trading businesses operating across high-risk corridors or biodiversity-sensitive regions.

2. Embed environmental crime into CDD logic

Customer due diligence must reflect not just who the customer is, but what economic role they play in global trade flows. Import/export businesses, resource-based industries, and intermediaries should be assessed through a green crime lens where relevant.

Enhanced due diligence should also consider:

• ownership opacity

• politically exposed persons

• unusual licensing structures

• dependence on intermediaries

• and inconsistencies between declared operations and trade activity.

3. Strengthen behavioural transaction monitoring

Detection needs to shift from static rules to behavioural consistency:

• does transaction activity align with declared business model?

• are trade flows consistent with sector norms?

• are counterparties and corridors indicative of higher-risk supply chains?

Environmental crime rarely appears as a single alert, it emerges through pattern inconsistency over time.

Potential indicators may include:

• trade flows inconsistent with stated business activity

• abnormal pricing or invoice patterns

• repeated use of high-risk transshipment jurisdictions

• fragmented payments across multiple counterparties

• rapid growth in export volumes without clear commercial rationale

• unusual relationships between logistics providers, exporters, and offshore entities

• or activity involving sectors known to carry elevated environmental crime exposure.

4. Expand Intelligence and Data Integration

Effective detection increasingly depends on integrating external intelligence sources beyond traditional AML datasets. This may include customs data, shipping and vessel intelligence, adverse media, permit verification, NGO reporting, geospatial risk indicators, and supply chain analytics. Environmental crime often cannot be identified through transactional monitoring alone. Detection typically requires combining financial behaviour with trade, logistics, and ownership intelligence to identify hidden exposure.

5. Strengthen intelligence sharing

FATF and enforcement bodies repeatedly highlight a persistent weakness: limited sharing of environmental crime intelligence between public authorities and financial institutions. Without better integration of enforcement data and typologies into AML systems, institutions will continue to operate with partial visibility.

Green crime is now financial crime in disguise

Those that take this seriously will stop treating wildlife crime as an environmental compliance issue and start treating it as a live financial crime exposure embedded within their own financial ecosystem. This is not a distant conservation problem — it is a multi-billion-dollar illicit economy, increasingly recognised by FATF and global regulators as part of the core AML risk landscape. It moves through legitimate trade and corporate structures, relies on financial infrastructure to scale, and is deeply interconnected with other forms of organised crime.

For organisations, the implication is direct: wildlife crime is not something occurring outside the financial system — it is something that is processed through it. Those that fail to recognise this early risk not only missing suspicious activity, but falling behind a regulatory direction of travel that is already underway.

Where Finomni can help

Most organisations are not struggling with awareness of green crime, they are struggling with operationalisation. Finomni helps translate this evolving risk landscape into something executable within existing AML and financial crime frameworks. Our work typically includes:

• embedding environmental crime typologies into risk assessments and monitoring systems

• redesigning KYC and CDD frameworks to reflect trade and supply chain exposure

• enhancing transaction monitoring rules and behavioural models with environmental indicators

• supporting investigations by linking financial flows to predicate environmental offences

• aligning governance frameworks with evolving FATF and regulatory expectations

If you would like to discuss how green crime, illegal mining and the illegal wildlife trade may impact your financial crime programme or organisation, or how to operationalise these risks within existing frameworks, please get in touch.