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Coalition against online wildlife trafficking shares little evidence of success (analysis)

  • Officials from the Coalition to End Wildlife Trafficking Online say progress is being made, but the evidence is minimal, a new analysis shows.
  • The Coalition’s three NGO partners – TRAFFIC, IFAW and WWF – divide up primary “point of contact” duties with big online platforms like eBay where wildlife and illegal animal products can be found for sale.
  • Critics call the Coalition “a black box” from which little light emerges, allowing member companies like Facebook to say they’re part of the solution by pointing to their Coalition membership.
  • This post is an independent analysis by the author and does not necessarily reflect the views of Mongabay.

Finding endangered plants and animals for sale online remains easy. “Rampant” according to Mark Hofberg of the International Federation for Animal Welfare (IFAW).

The strong word is significant since it comes from an official of one of three major nonprofit groups that have tried a new strategy to combat online sales: constructive engagement with Facebook and 46 other social media and e-commerce platforms.

Officials from the Coalition to End Wildlife Trafficking Online say progress is being made, but the evidence is minimal.

Critics call the Coalition “a black box” from which little light emerges, allowing the member companies to greenwash by pointing to their Coalition membership cards.

Figures shared publicly via the Coalition to End Wildlife Trafficking Online’s 2021 progress report.

“The coalition is premised on the idea that self-regulation will work,” said Simone Haysom, a senior analyst with the Global Initiative against Transnational Organized Crime (GITOC).

Activists outside the Coalition pursue more confrontational approaches and strongly criticize the platforms for inaction. Facebook is “directly fueling the global extinction crisis,” said Gretchen Peters, Executive Director of the Alliance to Counter Crime Online (ACCO). Her group and others are filing lawsuits and backing legislation to regulate the platforms.

One widely agreed prescription for holding the platforms accountable is more transparency. The Coalition provides only a handful of figures about what its members are doing collectively about online IWT.

When the Coalition began in 2018, it announced a major goal – to cut online illegal wildlife trafficking (IWT) by 80% by the end of 2020. But this metric was quietly dropped.

It was “a bold target,” said Crawford Allan, senior director for TRAFFIC, a Coalition member. But measurement, he said, proved to be nearly impossible and too expensive.

It was “a ridiculous target,” said Haysom. “They never had a baseline, so how can you measure it?” she said.

A social media post offering a baby slow loris for sale. Image courtesy of Anonymous.

After dropping the 80% goal, the Coalition started developing “updated targets and indicators to monitor success internally,” Allen said. We are recording whether they are hitting those goals and how much time they have left,” he said. These “action plans” are customized for each corporate member.

The plans are not disclosed.

“I am not sure the Coalition would be keen to say who are the good guys and who are the bad guys,” said Lionel Hachemin, a wildlife crime researcher with IFAW. “We don’t want too much negativity,” he said, noting that membership is voluntary. On the other hand, he said, “We are not afraid to say to this platform, you are doing a bad job.”

The process of quiet engagement occurs at regular meetings, held as often as quarterly, between NGO and company representatives. The three NGOs – TRAFFIC, IFAW and the World Wildlife Federation (WWF) – divide up primary “point of contact” duties. For example, IFAW works with eBay.

The interactions are “not like a confrontation at all,” said Mark Hofberg, a Campaigns Officer with IFAW’s Washington D.C. office, who said, “I think it’s definitely helping.”

At the meetings, Coalition NGO officials said they help the companies understand what’s illegal, advise them on working with law enforcement and discuss warnings for consumers. TRAFFIC’s Allen said, “There has been a significant amount of progress made and there is most certainly disruption happening across online platforms.”

“We know we are going in the right direction,” said the IFAW’s Hachemin. “I don’t want to say that the coalition is perfect, but we are having an impact. We just don’t know the extent of the impact.”

The Coalition’s quantitative transparency about its efforts is contained in a two-page progress report issued in October of 2021, and is of questionable value in assessing the Coalition’s impact.

See related: Where trafficked pangolins originate is a puzzle, hobbling efforts to save them

Pangolins like this Philippine species are one of the most trafficked animals in the world. Image by Gregg Yan/ACB via Wikimedia Commons (CC BY-SA 4.0).

The highlighted number tallies how many online listings were “removed or blocked” – 3,335,381 during the Coalition’s first two years, and 8,296,438 in the third year. The increase, however, largely reflects the growth in corporate members from 18 to 47.

More detail, such as monthly data from each company, is not provided, although it is available, according to Coalition officials. More detailed information might be useful, said several Coalition NGO officials, but another said such disclosure is limited by “capacity constraints.”

More useful than the numbers of postings removed or blocked would be information about the process used in getting there, known as content moderation, according to analysts of social media companies. “Sometimes you need to know how things are being done, not just statistics,” said Heidi Tworek, a senior fellow at the Centre for International Governance Innovation.

On this score, the closest the Coalition comes is by sharing a figure for the number of enforcement staff trained to detect illegal content. It says 470 persons were trained in the first two years, 1,906 in the third.

The Coalition does not provide any more detail, and commenters said that more important would be figures on how many moderators, trained or not, track IWT online and how much time they spend monitoring it.

Facebook “always says they have 35,000 moderators,” Peters observed. “I have never had any information on how many are focused on wildlife and environmental issues.”

Neither does the Coalition. “We don’t have detailed information on staffing,” said Giavanna Grein, a senior official with TRAFFIC and WWF.

The Coalition also reports on how many IWT postings were flagged by volunteer “cyber spotters” trained by the Coalition through its OWLET program. This figure grew from 4,500 in the first two years to 7,500 in the third year.

View all of Mongabay’s coverage of the illegal trade in wildlife here.

Assorted traditional medicine products and items from endangered species, including tigers, Asian moon bears, rhinos, Tibetan antelopes and elephant ivory. Image courtesy of IFAW.

A more significant figure, on which the Coalition does not report, would show the number of overall tips received and how the platforms handle them. Such a comparison is one of the basic disclosures proposed in the EU legislation.

An ambitious Coalition goal, included in the progress report, calls for enhancing automated detection filters through the development of image repositories and robust training sets to advance block filters and reduce dependence on manual review from conservation partners.”

The progress report provides no information on how these artificial intelligence (AI) efforts are going.

The Coalition NGOs contribute to the development of AI systems by maintaining “a key search words database” with over “2,500+” terms in multiple languages. The nonpublic list is “shared regularly with companies to enhance automation,” according to the 2021 report.

“We push them” on machine learning, said IFAW’s Hachem. And Grein said, “For algorithms, we know that each company has their own in place, but due to the proprietary nature of AI, we don’t work specifically on these or have detailed information on how they work.”

More transparency about algorithmic systems, including through external audits, is recommended in The Santa Clara Principles, a set of guidelines for social media companies developed by NGOs. Peters said, “We’d like to see under the hood.”

The Coalition reports on its member companies’ efforts to boost public awareness of IWT, specifically how many users were “reached through external communications to help reduce participation in illegal activities and encourage reporting of suspicious content.”

According to the 2021 report, the 47 Coalition members had more than 1 billion “social media engagements through user messaging.” The report does not break this down or elaborate on these messages. Coalition officials said the messages include pop-ups that appear when suspicious postings are reached. “We are pushing them to use pop-ups…” according to IFAW’s Hachem.

Peters likes pop-ups, too, saying they have been shown to be effective. But she said that besides being warned, persons searching for certain terms should have their accounts flagged and the search results blocked.

More government regulation is anathema to the companies in the Coalition, but there are hints that its NGO members are growing more supportive of government action.

The most notable move has been IFAW’s lobbying for the Digital Security Act in the European Union. The legislation “is a good step in the right direction,” IFAW said in a statement, “as it introduces new transparency requirements for companies.”

TRAFFIC and WWF, however, were “not able to work on this topic at the moment due to a lack of human and financial resources,” according to a spokeswoman, “but we fully support IFAW’s actions as we share the same position.”

The rhinoceros hornbill’s distinctive, ivory-like bill ‘casque’ is a highly sought illegal trade item. Image courtesy of Mark Louis Benedict via Flickr.

Peters praised the EU bill, but said it did not go far enough. Peters and ACCO members support bills in the United States to limit the legal immunity provided to online companies. The online liability bills have yet to be approved by congressional committees.

IFAW is sympathetic to the U.S. liability legislation, a spokesman said, but added that the conversation “extends significantly beyond the remit and expertise of a conservation and animal welfare organization like ours.”

The value of government controls may be evident in China, where trafficking moved away from e-commerce platforms, although sellers likely have shifted to messaging apps, according to a November 2021 report by the Wildlife Justice Commission. “We cannot say whether illegal wildlife trade has gone up or down because the Wildlife Justice Commission does not have any baseline to compare against,” a Commission spokesperson said.

In general there’s ample evidence of online IWT, according to snapshots taken by academic researchers and investigative journalists.

Anyone who says the trend is going down “would be lying,” said an expert who works for one of the NGOs in the Coalition, but who asked not to be named.

TRAFFIC said in a 2019 report that “the true scale of the current online trade may be considerably larger than observed.” And IFAW in a 2021 report said online IWT “remains a significant challenge.”

In the face of this persistent trafficking problem, the Coalition’s generalities raise questions about whether it is seriously pursuing transparency as part of the solution.

The author is editor of, where a longer version of this article appears.

Editor’s note 4/1/22: The passage about Wildlife Justice Commission’s report was adjusted to indicate that there is still much ambiguity due to the general lack of data.

See related coverage of the Coalition here at Mongabay:

In wildlife traffickers, the internet finds a cancel target everyone agrees on


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