By Kelsey Hamilton and Robert Kim
November 15, 2022
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has imposed sanctions against a network involved in wildlife trafficking. The Malaysia-based Teo Boon Ching trafficking group relied on an international network of companies to import the illicit wildlife products from Africa and transport them throughout Asia.
On October 7, OFAC used its authority to sanction transnational criminal organizations (TCOs) to designate the wildlife trafficking group, along with its leader and a company that he controlled. Teo Boon Ching and his companies transported rhinoceros horns and other wildlife products from Africa using routes through Malaysia and Laos, ultimately shipping them to consumers in Vietnam and China, according to OFAC. The designation accompanied Teo’s arrest in Thailand and extradition to the U.S. to face criminal charges of wildlife trafficking and money laundering.
Teo provided detailed instructions to shippers in Africa to buy rather than rent shipping containers and to pack other goods alongside the illicit wildlife products, according to a report by the Environmental Investigation Agency (EIA), a U.K.-based nonprofit. After containers cleared customs in Pasir Gudong, a port city in the Malaysian state of Johor located at the southern tip of the Malay Peninsula near the Malaysia-Singapore border, Teo moved them to his warehouse for repacking and onward transportation to their buyers.
Sunrise Greenland Sdn. Bhd., is a timber trading company majority owned by Teo, according to Malaysian corporate records. Sunrise Greenland shares an office suite with Metaldeck Corporation in a small building in Johor’s capital city Johor Bahru. The co-owners of Metaldeck manage other logistics companies that provide cross-border truck transportation from Singapore to China through Malaysia, Thailand, Laos, and Vietnam. While the routes and locations that these businesses serve follow Teo’s wildlife trafficking patterns, there is no evidence that Teo used them to facilitate the shipment of his products.
The use of a common address by Sunrise Greenland and Metaldeck demonstrates one of the key indicators mentioned by Treasury’s Financial Crimes Enforcement Network (FinCEN) to file suspicious activity reports (SARs) in its first notice on environmental crimes in 2021. FinCEN requested that SAR filers provide any available details about how illicit products were solicited, acquired, stored, transported, financed, and paid for, such as names, identifiers, and contact information, including Internet Protocol (IP) and email addresses and phone numbers.