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Environmental crime is one of the fastest-growing sectors of organized crime, generating hundreds of billions [ [link removed] ] in illicit profits every year. I have previously described [ [link removed] ] how environmental crime and organized crime have increasingly converged. A June 2023 report [ [link removed] ] by the John Jay School of Criminal Justice and Earth League International (ELI), a nonprofit dedicated to investigating wildlife criminals, revealed how large-scale environmental crime is now no longer the domain of small-time gangs but of multilayered, multinational networks with regional and transnational hubs run like franchises across the globe.
Soon after the 2023 report came out, two law enforcement operations targeting environmental crime culminated in arrests and prosecutions, highlighting both the inner workings of these syndicates and the uphill battle law enforcement faces in getting convictions against them. The government can make headway, however, by supporting agency-wide efforts to prosecute these crimes with a proven strategy. Also, by tying the negative environmental consequences of these crimes with the corresponding economic ones, law enforcement may be able to achieve more successful prosecutions.
Agencies Taking Action
The Fish and Wildlife Service (FWS), the government agency charged with managing and protecting the nation’s fish and wildlife resources, took the lead in the 2023 investigations but received critical support from several other agencies, including the newly created Homeland Security Investigations (HSI), part of the Department of Homeland Security (DHS). This agency, led by Elliott Harbin, investigates crimes that cross borders and threaten national security, including the smuggling and trafficking of everything from people to art, pharmaceuticals, intellectual property and classified technology—as well as contraband fish and marine wildlife. In my interview with Harbin, he said their unit takes a particular interest in the convergence of organized crime with environmental crimes.
In May 2023, FWS arrested two individuals with cross-border ties to crime in Mexico and the U.S. The first was Zifeng “Gabriel” Wu, who paid co-conspirators to smuggle illegally harvested totoaba swim bladders—a product so valuable it’s known as “cocaine of the sea [ [link removed] ]”—and other marine life concealed among tools in trucks. A search of Wu’s home yielded more than $600,000 in cash and illegal wildlife worth hundreds of thousands. About a week later, Chin Wang, one of the most notorious wildlife traffickers of the past two decades, was arrested, with HSI in a supporting role. Wang also was charged with importing totoaba swim bladders. Besides a home in a posh San Diego suburb, Wang maintained an apartment on Manhattan’s Park Avenue with her ill-gotten wealth, records revealed.
Three months later, in August, another operation led to the arrests of Zunyu Zhao and Xionwei Xiao, charged with conspiracy and the illegal importation of sea cucumbers, an endangered and protected marine species, in a criminal operation dating back to 2017. Prosecutors had already obtained a sealed indictment from a grand jury in San Diego and were moving toward sentencing in the fall of 2023 when Zhao and Xiao both decided to collaborate with prosecutors.
For two years prior to the arrests, undercover investigators from Earth League International helped with the operations, especially those involving Wu and Wang, infiltrating the criminal organizations to gather evidence. Their work was risky. Fearing retaliation from the cartels, ELI’s board urged Andrea Crosta, the organization’s founder and executive director, and his staff to take a lower profile for a while. Nonetheless, Crosta witnessed the San Diego arrests firsthand from a nearby location, in a desire to see the operation through and justice served.
Elliott Harbin’s HSI brought added manpower to monitor the ELI undercover operation and all the arrests to ensure their safety and success. When I spoke with Harbin, he emphasized the collaboration that had taken place among federal agencies. He said, “Whether it’s Fish and Wildlife or the EPA [Environmental Protection Agency] on pesticide cases,” he said, “it’s as though we’re all part of the same agency, the way that we worked in San Diego.” 
According to Mark Ungar, one of the authors of the Jay College report, the way in which HSI was set up and organized allowed it to respond to some of the ongoing challenges of prosecuting environmental cases. Environmental crimes are often seen as low priority, unlikely to make headlines, making it difficult for them to compete with other crimes for the attention of prosecutors. Gathering information on environmental crime becomes a challenge when crime databases don’t speak to one another across different agencies or national borders. Data gathering on environmental crime is far behind data gathering on narcotrafficking, says Ungar: “They’ve got a long road ahead.” Ungar notes that having a list of known environmental criminals, similar to the State Department’s Engel list (formally known as the Section 353 Corrupt and Undemocratic Actors Report [ [link removed] ], which tracks individuals whose crimes threaten democratic institutions), would be very helpful.
Individual Efforts
Real change often rests on the individuals in key roles, and how long they can act in those roles to make a difference. Harbin acknowledged the many challenges of prosecuting these cases but praised the work of the San Diego U.S. Attorney’s office and of Assistant U.S. Attorney Melanie Pierson. Pierson, who had been a lead prosecutor in the Zhao and Xiao arrests, is “probably one of the best in the nation when it comes to wildlife prosecutions,” according to Harbin. Pierson, he said, would never turn down a criminal prosecution if there were some way she could make the case. “There’s no bigger champion of the planet than Melanie Pierson.”
Earlier, Pierson had worked with Harbin to create a task force to address the growing environmental threat of illegal pesticides brought into the country by drug cartels. As documented in a series of investigative articles [ [link removed] ] in the Times of San Diego, the poisonous pesticides—aimed at killing rodents in the cartels’ huge cannabis operations on sites deep within national parks in the Southwest—had a ruinous impact, killing a wide swath of wildlife. Rep. Doug LaMalfa, a Republican from Oroville, California, complained that across the West, “cartels are illegally growing marijuana in the most environmentally devastating ways, at a scale that should concern any group or governor that claims to be pro-environment.”
In the 15 years before the task force began operations, Harbin recalled, there wasn’t a single criminal prosecution involving illegal pesticides. After Pierson became lead prosecutor in 2019, the number of prosecutions jumped to at least 22, with over a hundred cases total (many were downgraded to civil charges, but they nevertheless resulted in substantial jail time). Harbin praised Pierson’s ability to make the cases stick, but more importantly her efforts to make the system more robust: training her peers to take on similar cases and training many federal agents in FWS, National Oceanic and Atmosphere Administration, DHS and EPA. “They are much, much better for having worked under her direction,” Harbin said.
The modular way in which the large crime networks are organized and operate can also complicate the process of connecting the dots and getting convictions. By outsourcing or franchising part of its operations to local outfits, the international network can resist prosecutors’ efforts to connect the players for a jury. Transport businesses, often adaptable and fast-growing, are core to this franchise model. Ungar warns that this trend of environmental crime convergence is growing in scale and isn’t limited to just a few big networks or isolated black markets. “They will continue to operate until we fully understand and address the convergence itself,” he said.
Environment and Economics
In the summer of 2023, acting Commissioner for U.S. Customs and Border Protection Troy Miller noted the link between economic and environmental perils. Cross-border trade depends upon closely interconnected infrastructure and global supply chains, and it “will not withstand climate and environmental impacts” of large-scale crimes, such as illegal logging and wildlife trafficking, and their implications for the global climate. He warned, “If we fail to prepare, the consequences could be devastating.” At the same time, Miller noted the progress in wildlife trafficking operations and the seizure in Arizona, with the FWS, of over 240 pounds of protected totoaba swim bladders worth an estimated $2.7 million, the second-largest such seizure in the United States. “These bladders should have never been harvested,” Miller said, “which is why we will continue to ramp up our enforcement efforts with our partners.”
I asked Harbin if he sees the paradigm shift in law enforcement described by Ungar and the Environmental Crime Convergence report: a decision to (1) focus on this intersection of environmental crime and organized crime, and (2) find the most likely path for successful prosecutions. He thought for a moment.
“That paradigm shift is what we presented to Congress and what pretty much sold them on HSI needing to be a player,” he said. “We enforce just about every one of those converging crimes committed by transnational organized criminal organizations, whether it’s wildlife or timber or fishing.”
A few other countries have established special units like HSI to tackle the organized crime/environmental crime convergence. Colombia, for example, has created a national prosecutor’s office on the environment and set up special offices in environmental crime hotspots. Challenges remain, however, including a lack of personnel and difficulties coordinating with local officials, says Ungar. “You have these prosecutors coming into new areas where they aren’t necessarily trusted by people already working in the area. So there are a lot of growing pains.”
Sometimes the convergence between organized crime and environmental crime has a clear geographic focus. Hawaii, for instance, has attracted interest as a Pacific hub where illegal fishing occurs alongside waste dumping by international fishing boats. Journalist Ian Urbina documented [ [link removed] ] the human trafficking and forced labor common in international fishing fleets. Ungar says that Hawaii has become a center not just for environmental criminals but also for Asian-based cyber criminals.
Says Ungar, “We have to address all these very specific points of convergence, tracking the enforcement chain and identifying where the gaps are.” These gaps may include how evidence gets collected and tested, how operations gain the trust of ordinary citizens, how prosecutors get training and how judges get prepared for environmental law cases. Ungar says, “If we can address those gaps, each of which is manageable, we can really turn the tide.”
The convergence of vast international criminal networks and environmental crimes isn’t going away. Researchers at Brookings have identified more than 100 criminal networks [ [link removed] ] linked to China that are engaged in illegal operations within many economies, often acting with the Chinese government’s help and protection. In return, the networks serve as the government’s extralegal agents, monitoring the Chinese diaspora. Harbin explained how the recent U.S. Drug Enforcement Administration’s National Drug Threat Assessment confirmed the basis of the environmental crime partnership between Mexico and China: “The drug cartels in Mexico are basically providing illegal wildlife products to Chinese organized crime in exchange for precursors for fentanyl and methamphetamine,” he said. To what extent will China’s support for Russia advance these crime networks?
As these threats continue to grow, the question of society’s response remains. Recent successful prosecutions offer examples of the coordination needed across agencies, national governments and nonstate actors. The Jay School’s report on environmental crime convergence offers a blueprint for a more effective prosecutorial strategy. Now we need the political will to make the response a priority.

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