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Is organized crime still a thing? The answer is yes, but it might not look like the mobster movies you’re familiar with—although Tony Soprano’s waste management business might provide a clue. In recent decades, crime rings have been growing in areas we might not expect, such as environmental crimes—areas in which criminal activities are low-profile and unsexy but also have a low entry threshold.
Environmental crimes such as unlawful waste disposal and illegal logging rarely make the headlines or get targeted by law enforcement. As a result, these crimes, committed at scale, have become profitable for enterprises without scruples. Environmental crime is reaping hundreds of billions of dollars annually, and it’s inflicting a growing toll on the natural world and its resilience. Illegal logging devastates forests and the people who rely on them, and that’s just one of the best-known examples. Illegal and unreported fishing [ [link removed] ] is a global threat to ocean ecosystems and our sustainable food supply. Meanwhile, international Mafia-style sand mining [ [link removed] ] for construction cement is outstripping geological systems and making cities vulnerable to flooding and rising sea levels.
The Mechanics of Environmental Organized Crime
A June 2023 report [ [link removed] ] by the John Jay School of Criminal Justice and the nonprofit Earth League International explains how these environmental crime syndicates operate. This report, the Environmental Crime Convergence Study, surveys the field and probes two major crime networks, labeled M2 and M3, that profit from environmental crime. From undercover work on transnational networks in Latin America trading in endangered species, the study’s authors found patterns of collaboration and competition. They showed that such networks are not simple family businesses but multilayered multinational organizations, with regional and transnational hubs that strengthen their operations.
The M2 and M3 criminal networks employ strategies for diversification and growth similar to those used by legitimate businesses. Their environmental plunder overlaps with other operations in narcotics trafficking, human trafficking and money laundering, just as legitimate organizations might expand from product manufacturing to transport. And that overlap leads to insights for law enforcement.
The study’s approach to analyzing these entities exposes, in the words of the authors, “multiple gaps in the enforcement chain,” ranging from how intelligence is gathered to how environmental laws get applied in court. For much of the study’s undercover work, the Jay College authors credit Earth League International’s intel gathering and analysis. The study reflects ELI’s experience painstakingly gaining the trust of network players in order to decode larger patterns.
Mark Ungar, one of the study’s authors, is a professor of criminal justice at John Jay College of Criminal Justice, but before that he spent 25 years engaged with the nuts and bolts of police reform, working with the U.S. government and United Nations agencies, assisting in structural reform of police in over half a dozen countries. Part of what makes the study so impressive is that its authors have spent decades in the day-to-day challenges of prosecuting organized crime.
“We wanted to revisit and re-understand convergence in terms of how does it actually function on the ground,” Ungar told me. “We wanted to provide a very new paradigm, a very new understanding, that's not based on any kind of assumptions or secondary sources.”
The authors show how these networks work in their complex specifics, highlighting intersections often left out of criminology studies. One hallmark of environmental crime, Ungar says, is an infrastructure network for moving and storing. That network can be as direct as trucking companies and transport-adjacent officials that get banned items “from point A to point B to point C” along routes that connect rainforests in Latin America to international markets in Asia, or sand from riverbeds to urban construction sites. Those transport syndicates can look completely legit, but unraveling their complex connections can help law enforcement officials get the information they need to investigate and prosecute environmental crimes.
Collusion and Convergence
Organized crime isn’t just a job for full-time criminals: It needs the cooperation of government officials. None of the large-scale crimes reviewed in the Environmental Crime Convergence Study, says Ungar, “could have happened without the collusion of local officials, as well as the ineffectiveness and lack of resources of prosecutors and other judicial officials.” The study shows the patterns through which this corruption happens, he says, based on “our own work, using our own connections, using their own words and the direct firsthand understandings of how these groups operate.” The involvement of government officials is not always the result of deliberate corruption, however; officials may unknowingly aid environmental criminals at various points of their criminal enterprise.
The authors distill four types of convergence, based on how criminal networks combine different types of activity. Type 1 involves illicit trafficking of multiple species of plants and animals. Type 2 involves a wider spectrum of environmental crimes; for example, trafficking wildlife along with illegal logging. Type 3, “serious crime convergence,” involves networks that combine environmental crimes with other serious crimes, such as money laundering and drug trafficking. Type 4 is “transnational network convergence,” involving complex networks across borders.
This fourth category also involves seamless financial connections with legitimate business networks. “For example,” Ungar says, “a lot of the money laundering through corporate shell companies based in the United States” is a kind of Type 4 convergence. Republic Gold, a gold-processing company based in Florida, turned out to have connections with illegal mining in Peru, according to Ungar. These financial links mark one way that organized crime blends in with legitimate business activity, which makes prosecutions difficult.
It can be hard to make environmental crime charges stick, so Ungar and his co-authors recommend that prosecutors look hard at Type 3 actors and prioritize the more notorious offenses. For example, where a network commits human trafficking and narcotics trafficking along with environmental offenses, prosecutors should focus on making the human trafficking case, where conviction brings stiffer penalties.
In Mexico in late 2021, that’s what happened. ELI’s undercover work yielded high-profile arrests, and Mexico’s national prosecutors charged a half dozen people with poaching and smuggling methamphetamines and cash, among other felonies⁠. After the arrests, ELI Director Andrea Crosta’s phone rang, and a prosecutor in Mexico City thanked his organization for sharing the leads that cemented the charges. In that instance, a case that started from wildlife trafficking had grown to snare major money-laundering and human-trafficking offenders, says Crosta—“with their hands in the jam, as we say in Italian.”
One of the offenders arrested that November had been trafficking between Tijuana and Mexicali for over a decade. Identified in court papers as “El Chino David,” he owned a restaurant in Baja and had business partners in Los Angeles and San Francisco. Like many kingpins, he maintained legitimate businesses—restaurants, travel agencies—that lent cover to his shadier kingdom.
Healthy Animals
That connection from the business underworld to the legitimate business community relies on the systems of fees and permits that support business everywhere. Even animal health inspectors get used. Ungar gives an example from Colombia, where land grabs and illegal cattle ranching are stealing from protected conservation areas, but the government agency that deals with cattle ranches doesn’t have the capacity or focus to sort out and identify illegal operations. Rather, the agency’s focus is animal health.
“They vaccinate the cows,” Ungar explains. “Their number one priority is that this cow—the meat—doesn’t get contaminated. … They don’t care enough where the cow actually comes from.” So fraud happens as the agency approves the animal for processing and it moves on to the supermarket. By that point, he says, “it’s been legalized. … And so you have this sort of seamless integration of the illegal with the legal through these weak points in the enforcement system.”
In another case in the Amazon basin, planes would come in bringing drugs for transit near Colombia's border with Brazil, along with timber and trafficked wildlife species. Customs would inspect the trucks, but the inspection stations lacked the personnel needed to do meaningful diligence. A truck would therefore get marked as carrying timber, with no indication of other contraband on board.
These intersections of bureaucracy, Ungar says, form a “huge Achilles heel of the enforcement system.” Often, bureaucracy is the weakest link. Permits can be doctored; officials can be bribed. In one case, a single official in a lumber permitting agency was responsible for 60% of faked logging permits. Even after that official was exposed, he was not fired.
Fragmentation and poor coordination at various levels of government—often, databases that don’t communicate with each other—are additional weak points. A sequence of fraud on land titles, through which parcels get resold legally, can “add up to almost legal ownership” or legal status. The collusion can come almost by accident.
In terms of how networks like M2 and M3 affect a national economy, that of course varies with the scale of the criminal operation. Vanda Felbab-Brown, a Brookings Institution expert on international organized crime, has observed that the specifics of the sector shape whether it affects hundreds of people (smuggling operations) or millions (labor-intensive enterprises like poppy growing, which employs large swaths of farm families). Similarly, illicit sectors can also have vastly different environmental impacts: Trafficking in endangered species or illegal timber can destabilize entire ecosystems and, if a nation is already wracked by internal conflict, fuel unrest even more, which typically makes it less able to manage the negative effects on the environment, notes Felbab-Brown.
From Baja With Seafood
The network known as M2 has, for more than a dozen years, been one of the most active dealers of an endangered small porpoise’s swim bladder (known as maw, a delicacy in some Asian cuisines), having recently expanded its client base from the U.S. and China to high-end markets worldwide. The banned swim bladders go by air shipments directly from Mexico to China, with the network contracting with a major international courier for packaging that avoids routine official inspections.
M2 also transports its illegal products using a range of individual travelers as mules, often going through Hong Kong, South Korea, Japan, Taiwan and the U.S. M2’s members consist mostly of Chinese nationals who own homes and businesses in China and Mexico, and also business operations in the U.S. They travel often, and the network is deep into other serious crimes.
To identify the key players, an undercover operation assembled a group of informants and other sources, many of them involved in the fish maw trade. ELI’s undercover operatives found that M2 smuggles products from warehouses in Mexico, where it processes illegally harvested seafood, into the U.S. for sale and onward transit. M2 has transactional links with other crime rings in Mexico and China, including the Fujian Mafia, and its reach extends to money laundering, illegal drugs, human trafficking, and fake permits and visas.
M2 also helps overseas clients with money laundering, registering local companies in Mexico. For this, they use wire transfers to M2’s Chinese accounts, and then return the money to the client in a different currency (usually U.S. dollars or pesos) for re-investment. M2 plows the profits into real estate purchases for use as fronts. One M2 member owns a currency exchange business as a front for illegal transfers.
Franchising
The M3 network, based in central Mexico, has comparable operations. Its human trafficking operation smuggles Chinese immigrant workers into the U.S. with a success rate of 95% [ [link removed] ], thanks to its integrated network. Their operatives obtain fake travel documents (charging immigrants fees of more than $20,000 per person) and then subcontract with drug cartels to move those immigrants from Mexico to the U.S. on foot or in the trunks of cars. The cartels add to their slice by getting the immigrants to ferry drugs across the border.
Such diversification can make it hard for prosecutors to prioritize which offenses to pursue. As a result, often only the low-hanging fruit get arrested—essentially, lower-ranking members of M3 and comparable organizations—and judges then don’t allow those cases to go forward because the accused are so far below the decision-making level.
Ungar likens the modular structure of M3 and its ilk to corporate franchising. “We have to understand them as franchises and as very sophisticated, nimble networks,” he says, where labor is very temporary and ad hoc. Unlike the lifelong “made men” of Mafia movies, people get recruited as specialists in fields such as language or customs, work on a contract basis and then leave.
This franchise model is a source of strength and flexibility for a modern crime network. Again, the model often revolves around transport, allowing a network to integrate its disparate strands much as Amazon.com might do, combining in the same truck illegal timber, say, with narcotics. “It’s sort of a Noah’s Ark of criminality,” says Ungar.
The final piece spurring growth for the big-box criminal networks is the boom in informal and mobile financial networks. With the ubiquity of mobile banking, blockchain and cryptocurrency, tracing money has gotten harder for authorities.
Working for two years on one case, Earth League International assembled intelligence, building out crime maps and connecting the dots. After untold hours of analyzing intelligence information and assessing the capacities of the prosecutors poised to handle the case, ELI’s undercover team turned over reams of evidence to law enforcement—and held its breath.
The evidence pointed to high-level members of a network with connections and property in California and New York, as well as links to the notorious Sinaloa Cartel, which is based in Mexico and has “massive influence now in the Amazon region,” according to Ungar. Sinaloa is diversifying too, leveraging its cocaine base into illegal logging, mining and ranching. By investing further in environmental crime, the cartel has expanded and become more difficult to dismantle. Yet Ungar and his co-authors hope their Environmental Crime Convergence Study helps provide a map for prosecutors to gear up for the growing challenge.
The crime rings studied in this report and the problems it highlights are an immediate threat to wildlife conservation and environmental protection efforts, as ELI’s undercover work has shown. They operate globally across borders and take advantage of many gaps that enable them to thrive. “If we can, from a policy point of view, address those gaps,” says Ungar, “we can really turn the tide on this.”

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