The confiscation of illegally-traded or

CITES WorldOfficial Newsletter of the Parties

Convention on International Tradein Endangered Species of Wild Fauna and Flora (CITES)

Issue Number 16 – December 2005

ISSN 1564-9164

From the Editor – Everyone’s problem

Resolutions Conf. 9.9, 9.10 (Rev. CoP13) and10.7 explained

Experiences from Belgium, Indonesia, Switzerland,the United Kingdom and the United States

Perspectives from NGOs

WAZA Guidelines

Handling confiscated specimens

New checklist; updated training presentations

Everyone’s problem

What is the most difficult problem facing those whoimplement CITES? If the questions posed by par-ticipants in capacity-building workshops are indeeda ‘window on the soul of CITES’, then the problemof confiscations is by far the most difficult problem.I have yet to take part in a workshop where this ques-tion does not come up, and it usually does so quiteearly in the discussions.

The confiscation of illegally-traded or -possessedspecimens of CITES-listed species is usually hailedas a success for conservation and law enforcement.Confiscation of specimens traded in violation of theConvention is one of the most basic measures requiredof Parties by the text of the Convention, leading tothe eventual return of specimens to the State ofexport, to a rescue centre, or to any other suitableplace the Management Authority may select. Beyondan announcement in the media about a successfulconfiscation, attention seldom remains and thespecimens disappear from public attention. But thesespecimens certainly do not disappear, and theypresent a particularly difficult challenge for allParties: what to do with confiscated specimens?

Confiscated parts and derivatives can be stored fairlyeasily, even beyond their usefulness in any courtproceedings that may require them as evidence, aslong as secured storage space is available. For somecountries, seized items made from CITES-listedspecies can amount to significant quantities.

But the more pressing problem concerns theconfiscation of live specimens. Smuggled livespecimens are often transported in very harshconditions and seized animals may be injured or inpoor health, and plants may be dehydrated anddamaged. The challenge in such cases is not only tocope with handling and holding the specimens, butkeeping them alive and bringing them back to health.

It may also happen that, for a number of reasons,live specimens prepared and shipped with allnecessary care are confiscated, and the quantitiesinvolved and the species concerned may also poseserious problems. What can be done quickly,humanely, and in accordance with nationallegislation, policy and available personnel? Beyondthe initial confiscation is the matter of disposal.Should specimens be returned to countries of exportand if so, who pays the costs? Should confiscatedspecimens be destroyed, sold or permanently placedin zoos or botanical gardens?

This edition of CITES World focuses on confiscationof specimens of CITES-listed species, starting withthe obligations imposed by CITES and anexplanation of the approach adopted by the Partieson how to deal with confiscated specimens and theirdisposal. In this edition Belgium, Indonesia,Switzerland, the United Kingdom and the UnitedStates share their experiences with confiscations andthe disposal of specimens. The World Associationof Zoos and Aquariums (WAZA) shares itsguidelines on the acceptance of seized or confiscatedanimals. The TRAFFIC Network offers thoughts onthe issue of ivory and rhino horn stockpiles, and theRoyal Society for the Prevention of Cruelty toAnimals of the United Kingdom offers itsperspectives as an operator of rescue centres dealingwith exotic animals.

While we cannot offer any easy solutions to dealingwith confiscated specimens, we can at least try tofocus some attention on a very important aspect ofCITES law enforcement and implementation that,while too often hidden from view, is everyone’sproblem.

Stephen Nash

World – Official Newsletter of the Parties Issue 16

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Explaining ResolutionConf. 9.9 - Confiscation ofspecimens exported orre-exported in violation of theConvention

The Convention requires Parties to take appropriatemeasures to provide for the confiscation or return tothe State of export of specimens exported or re-exported in violation of the Convention. However,returning confiscated specimens to the country ofexport or re-export may result in the specimens re-entering trade at a later time unless measures aretaken to prevent this from happening. Parties arealso aware that when specimens are exported or re-exported in violation of the Convention, often theonly enforcement action taken against the exporteris the confiscation of these specimens by theimporting Party, and the Management Authority ofthe country of export or re-export may not be awareof the confiscation (and therefore would notinvestigate these violations in their country). Toprovide guidance on these matters, the Conferenceof the Parties adopted Resolution Conf. 9.9 onConfiscation of specimens exported or re-exportedin violation of the Convention.

In this Resolution Parties recommend that whenspecimens are exported or re-exported in violationof the Convention, importing Parties shouldconsider that the seizure and confiscation of suchspecimens are generally preferable to the definitiverefusal of the import of the specimens. ImportingParties should also notify as soon as possible theManagement Authority of the State of export or re-export that a violation has occurred, and notify themof any enforcement actions taken concerning thespecimens. Finally, when the import of specimensis refused by the importing country, it isrecommended that the exporting or re-exportingParty take the measures necessary to ensure that thespecimens do not re-enter illegal trade, includingmonitoring their return to the country and providingfor their confiscation.

The Secretariat

U.S. procedures for handlingCITES ‘contraband’

When the U.S. Government seizes animals, plants,or products imported in violation of CITES,enforcement officers have a number of options fordealing with the contraband. Live animals and plantsare sometimes returned to the country of export. Buta number of other alternatives exist for ‘placing’ wildanimal, parts and derivatives thereof and wild plants.

Wild animals

When U.S. Fish and Wildlife Service (Service)inspectors seize live animals, they often turn to localad hoc networks of qualified institutions, such asaccredited zoos, aquaria and nature centres, that canprovide temporary or long-term care. The Serviceuses written transfer documents to loan or donatewildlife officially to such groups for scientificresearch, educational use or public display.

To retain custody of seized animals, organizationsmust comply with U.S. regulations governingwildlife loans and donations and with any specificconditions in the transfer document. All recipientsmust show that they can provide adequate care andsecurity. They cannot sell the animals and they maybe required to account for them periodically. Theymust also give Service officers access to theirpremises for inspection purposes.

Service Wildlife Inspector Ed Marshall (front right)enlisted counterparts from U.S. Customs and Border

Protection to help remove this Appendix-II queen conchseizure from a vessel in Brownsville, Texas. Confis-

cated shells and other wildlife products typically go to aService repository that makes them available for use in

education, scientific research and public display.

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.S. Fish and W

ildlife Service


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In addition, those holding seized wild animal as aloan cannot transfer custody without prior Servicepermission. Even donees typically cannot retransferwithout Service permission for a specified period oftime.

Parts and derivatives

Many seizures for CITES violations involve wildanimal parts and derivatives. Once officially aban-doned or forfeited to the U.S. Government, these itemsare shipped to the Service’s National Wildlife PropertyRepository outside of Denver, Colorado. Items storedthere include products imported into the United Statesin violation of CITES and U.S. wildlife trade laws andregulations – products that range from sea turtle shells,rhino horns and leopard skins to ivory carvings, tigerbone medicinals and reptilian leather goods. TheRepository’s one million-plus item inventory alsocontains parts and products confiscated during Serviceinvestigations of domestic wildlife crimes involvingpoaching and profiteering in U.S. species.

Some of this inventory is used to support conservationeducation. The Service has a formal partnership withseveral non-profit groups and the National Oceanicand Atmospheric Administration (another U.S.government agency that also enforces wildlife laws)called ‘Suitcase for Survival’ that provides wildlifeitems to zoos, nature centres, school, refuges andsimilar groups for ‘hands-on’ conservation education.Products are also loaned to museums for use indisplays spotlighting threats to wildlife. Some itemsgo to universities and research centres to supportscientific studies as well as anthropological and othertypes of academic research.

In addition, the Service has the authority to destroyitems or sell confiscated wildlife property that is notin itself barred from commerce (e.g. CITESAppendix-II specimens). A 1999 auction of wildlife

products, for example, netted over USD 435,000 foruse in paying rewards to people who help the Servicesolve wildlife crimes.

Plants

In 1978, the Service established the Plant RescueCenter (PRC) programme to care for confiscatedCITES-listed plants. At first, the Service assignedthese plants to the U.S. National Botanical Gardenand other affiliated agencies. These centres, how-ever, soon reached their full capacity for caring forconfiscated plants, and the Service was obliged toenlist additional centres. To qualify as a PRC, a facilitymust be a public botanical garden, arboretum,zoological park, or research institution, and must bea government or a privately-funded non-profit entity.Currently, there are 74 institutions in 25 U.S. States,the District of Columbia and Puerto Rico thatcooperate as volunteer PRCs.

When U.S. agricultural inspectors confiscate a CITESplant shipment, they alert the Service and providedetails about the plants contained in the shipment.The Service identifies a PRC that has the capabilityto care for the species involved and is interested inaccepting the shipment. Once a home is located,inspectors ship the plants, typically at U.S.government expense.

The Service then notifies appropriate officials in thecountry of export/re-export and inquires about theirinterest in the return of the shipment. Confiscatedplant shipments are available for return providedthat these officials notify the Service within 30 daysand arrange to cover return shipping costs. Becauseof this notification process, the PRC must main-tain the plant ship-ment as a unit for30 days. After30 days, if the coun-try of export/re-export has notclaimed the ship-ment it becomespart of the PRC’scollection. ThePRC may then dis-play, propagate, oruse the plants forother purposes con-sistent with CITES.

During 2004, theUnited States Go-vernment confis-

Sea turtle shells and boots are among the seized wildlifeproducts that the Service provides to educators for use in

teaching about threats to wildlife

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ildlife Service

Confiscated CITES plants areplaced in public institutions to

contribute to conservation,research and education

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Explaining ResolutionConf. 9.10 (Rev. CoP13) -Disposal of illegally traded,confiscated and accumulatedspecimens

Parties have long recognized the challenge ofdisposing of confiscated specimens and over the yearshave adopted no less than seven resolutions providingor including guidance on this subject. The Conferenceof the Parties chose to consolidate the advice foundin these resolutions into Resolution Conf. 9.10 onDisposal of illegally traded, confiscated andaccumulated specimens. This Resolution was thenamended at its 10th (Harare, 1997) and 13th meetings(Bangkok, 2004).

The Convention requires Parties to return anyconfiscated living specimen to the State of export, af-ter consultation with and at the expense of that State,or to place it in a rescue centre or other appropriateplace of their choosing. Of course, Parties are alsofree to refuse to accept a shipment of CITES speci-mens, meaning the specimens have to be sent back tothe exporter or re-exporter (Resolution Conf. 9.9 of-fers advice on such cases). Some Parties allow the sa-le of confiscated specimens, though others are concer-ned about the message this may transmit to the public.

With regard to the export or re-export of illegallytraded specimens, the Parties recommend that no re-export of specimens be authorized for which there isevidence that the specimens were imported inviolation of the Convention, except if the specimensare re-exported for investigatory or judicial purposes,or are being returned to the State of export or re-

export or to a designated rescue centre or otherappropriate place. A further exception may occur inthe case of the legal sale of confiscated specimens bya Management Authority if it is satisfied that thiswould not be detrimental to the survival of thespecies. In all of these instances the permits andcertificates must clearly indicate that the specimensare confiscated specimens.

With regard to the disposal of illegally traded,confiscated and accumulated dead specimens ofAppendix-I species, Parties are recommended totransfer specimens only for bona fide scientific,educational, enforcement or identification purposes,and Parties should save in storage or destroy anyexcess specimens whose transfer for these purposesis not practicable.

With regard to the disposal of illegally traded,confiscated and accumulated specimens of Appen-dix-II and Appendix-III species, as a general ruleconfiscated dead specimens, including parts andderivatives, of such species should be disposed of inthe best manner possible to benefit enforcement andadministration of the Convention, and that stepsshould be taken to ensure that the person responsiblefor the offence does not receive financial or othergain from the disposal.

Parties are also recommended to make provision intheir legislation to require the guilty importer and/or the carrier to meet the costs of confiscation, custodyand storage or destruction of the specimens, includingreturning specimens to the country of origin or re-export (as appropriate), where the Scientific Authorityof the confiscating State deems it in the interest of thespecimens to do so, and if the country of origin or re-export so wishes. Where such legislation does notexist and the country of origin or re-export wishesthe live specimens to be returned, financial assistanceshould be sought to facilitate the return.

With regard to the disposal of seized or confiscatedplants, priority should be given to the care of seizedor confiscated wild-collected specimens ofAppendix-I species and of Appendix-II species thatmay be at risk.

Finally, Parties are recommended to publicizeinformation on seizures and confiscations whenappropriate as a deterrent to illegal trade, and informthe public about their procedures for dealing withseized and confiscated specimens and about rescuecentres.

The Secretariat

cated 269 plant shipments traded in violation ofCITES, which contained a total of 6,422 plants(5,261 orchids, 600 cacti, 202 agaves, 141 cycads,63 euphorbias and 155 plants of other taxa). Of these269 shipments, 263 were assigned to PRCs. Theplants in the remaining six shipments perished beforeassignment to PRCs or were destroyed at the port.

Ms Sandra Cleva, U.S. Fish and Wildlife Service,Office of Law EnforcementMs Monica Powell, U.S. Fish and Wildlife Service,Division of Management Authority – Branch of Operations


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Confiscated specimens -Switzerland

Article VIII of the Convention requires that CITESParties take appropriate measures to enforce theprovisions of the Convention, including measures toprovide for the confiscation or return to the State ofexport of specimens traded in violation thereof. Withregard to living specimens, the ManagementAuthority has to, after consultation with the State ofexport, return the specimens to that State at theexpense of that State, or to a rescue centre or suchother place as the Management Authority deemsappropriate and consistent with the purposes of theConvention. A rescue centre as referred to in ArticleVIII means an institution designated by aManagement Authority to look after the welfare ofliving specimens, particularly those that have beenconfiscated. Switzerland does not only place in suchrescue centres live confiscated specimens but alsocertain types of confiscated goods.

Thus according to Article 18 of the Swiss EndangeredSpecies Ordinance, seized (i.e. not yet confiscated)specimens are to be brought to a place destined bythe Swiss Management Authority at the costs and therisk of the importer.

In the case of live animal specimens this place is aquarantine station in a zoo in the eastern part ofSwitzerland under contract with the SwissManagement Authority. Goods derived from animalsare kept at a safe place at the border.

Seized live plants as well as plant parts and derivativesof commercial shipments are usually placed at thedomicile of the importer and banned from sale, underpenalty of a fine or imprisonment in case of violation,until the case is closed, i.e. the seizure lifted or theshipment confiscated or delivered. Non-commerciallive plant shipments are usually placed at the nationalCITES rescue centre at the Botanical Garden of theUniversity of Bern, under a contract with the SwissManagement Authority.

If the importer is not able to present valid documentswithin one month (or within 10 days for livespecimens in transit), the Management Authorityconfiscates the specimens. An extension of this timeis possible in well-founded cases.

Confiscated specimens of animals and plants have tobe returned to the State of export at the expense ofthat State or will be stored at a safe place or at another

place as the Management Authority deemsappropriate and consistent with the purposes of theConvention.

In the case of confiscated live animals, we indeedalways look at the possibility of returning them tothe State of export. But in the few cases where weconsidered this reasonable (in view particularly ofResolution Conf. 10.7), the States of export have beenmostly unwilling to cover the expenses of the returntransport. Thus we have sent back confiscated livespecimens only in very exceptional cases, in par-ticular when the carrier (who brought these specimensinto Switzerland) offered to bring them back again.

Consequently, in most cases, confiscated live animalsare registered and placed with appropriate institutionsin Switzerland or in other parts of the world. Weconsider as appropriate institutions – in that order –scientifically administered zoos (that preferably havea breeding programme for the species in question orhave already bred the species or a related one), privateor public zoos, breeder associations and – very rarely– private individuals. The animals are not donatedbut given as a permanent loan and there is a contractsigned between the Management Authority and theinstitution, which defines clearly rights and duties.The institution must agree to pay all the costs forhousing, feeding and care and is able to transfer theloaned specimen only with the consent of theManagement Authority. The ownership of theconfiscated specimen remains with the ManagementAuthority, but any offspring is owned by theinstitution. If a loaned confiscated live specimen diesthen the Management Authority has to be informedand the report from the veterinarian sent to it, and itwill note the death in its files.

Confiscated goods derived from animals are registeredin data file and are then stored, as we always say, foreternity, in a safe store room in the subterraneanvaults of the Federal Veterinary Office. We destroyspecimens that are really in bad shape or areperishable. Confiscated goods are never sold, as wedo not want those illegal goods to enter into tradeagain, however we may loan them to individuals andinstitutions for research or instruction purposes. Forexample, we have loaned confiscated specimens toschools for their natural history collections, to theCustoms for exhibition and instruction purposes, tomuseums for exhibits and also to the CITESSecretariat for training courses. The pressure todestroy part of this collection and gain storing spaceis increasing. We are therefore trying to find a museumwhich would be willing to house these (or most ofthese) items in a permanent exhibit.


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Confiscated live plants are placed, as far as possible,in botanical gardens and public parks under a contractas a permanent loan. Conditions are the same as foranimals. If no destination can be found, specimensare destroyed. So far, no candidates for repatriationhave ever been identified, as confiscated shipmentsusually consist of artificially-propagated specimensor of wild-collected specimens of very commonspecies or in a very bad shape. Confiscated parts andderivatives of plants are treated the same way as goodsderived from animals.

Federal Veterinary Office

Funding conservation fromthe sale of confiscatedspecimens: the Belgianexperience

In January 1986, Customs officers of the port ofAntwerp discovered and seized a consignment of9.6 tonnes of raw African elephant ivory originatingfrom the United Republic of Tanzania, disguised asbeeswax. Following legal proceedings, the tribunalconfiscated the ivory and, in conformity with CITESprovisions at that time, the ivory was sold at auctionby the Customs Administration. This sale earnedthe equivalent of EUR 1.25 million. In 1993 anagreement was reached between the Governmentsof Belgium and the United Republic of Tanzania touse the funds for elephant conservation in the lattercountry. The ‘Beeswax Fund’ was administered bythe CITES Secretariat, to be used for field projectsdeveloped with the Tanzanian authorities andimplemented by the World Wide Fund for Nature(WWF). The projects were submitted for approvalby the Belgian authorities and administered asexternally-funded projects by the Secretariat.

Since the funds were made available, USD 460,641was spent on strengthening anti-poaching activitiesin key protected areas and ecosystems, USD 40,000on supporting the Pasiansi Wildlife TrainingInstitute, USD 33,929 on supporting anti-poachingactivities in the Tarangire National Park andUSD 99,000 for TRAFFIC and wildlife trademonitoring in the United Republic of Tanzania.Current projects funded by the Beeswax Fundinclude a USD 356,643 project on the conservation

Explaining ResolutionConf. 10.7 - Disposal ofconfiscated live specimens ofspecies included in theAppendices

At the ninth meeting of the Conference of the Parties(Fort Lauderdale, 1994) a third Resolution relatingto confiscated specimens was adopted, afterResolutions Conf. 9.9 and Conf. 9.10 (see elsewherein this issue). However, Resolution Conf. 9.11 wasrepealed at the 10th meeting of the CoP (Harare, 1997)and replaced with Resolution Conf. 10.7 on Disposalof confiscated live specimens of species included inthe Appendices. While the Resolution is quite short,its Annexes are the most detailed to be found in any

and management of the Selous Game Reserve, and aUSD 95,625 project on the conservation andmanagement of the Mkomazi Game Reserve.

In 1989 Belgian Customs officers seized 1,623 wholeskins and 3,967 flanks of spectacled caiman at theport of Antwerp, originating from Argentina and intransit towards Italy. In 1998, after a long legal caseand the prosecution of the exporter in Argentina, theBelgian Customs Administration organized anotherauction, and raised EUR 29,747.20. The BelgianCITES Management Authority proposed, inaccordance with Resolution Conf. 9.10 (Rev. CoP13)and with the agreement of the Finance Ministry, todelegate the administration of the funds to the CITESSecretariat with the purpose of supporting CITESprojects in Argentina.

Conservation projects require funding and it is clearthat many more valid projects exist than there areavailable funds to support them. In these instances,the proceeds of the sale of CITES specimensconfiscated by the importing country were used tosupport conservation activities in the country fromwhere the specimens originated. This approach is aninnovative example of international collaborationand of the use of confiscated specimens forconservation purposes.

Management Authority of Belgium


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of the Conference of the Parties’ Resolutions. Unlikethe earlier Resolutions that are concerned mainlywith the procedural aspects of the confiscation anddisposal of specimens in violation of the Convention,and the disposal of parts and derivatives, thisResolution attempts to help guide Authoritiesthrough the difficult decision-making process ofdealing with live specimens.

The Resolution notes that shipments ofAppendix-II or -III live specimens often include large quantities of specimens for which no adequatehousing can be made available, and that in generalthere are no detailed data about country of originand site of capture for these specimens. Even if thecountry of origin, and the location where thespecimens were obtained are known, the Resolutionrecognizes the risks of releasing confiscatedspecimens into the wild, such as the introduction ofpathogens and parasites, genetic pollution andnegative effects on the local fauna and flora, and thatrelease to the wild may not always be in the bestinterest of the conservation of a species, especiallyone not in danger of extinction.

Before making a decision on the disposal ofconfiscated live specimens of species included in theAppendices, Parties therefore recommend that aManagement Authority consult with and obtain theadvice of its own Scientific Authority and, ifpossible, of that of the State of export of theconfiscated specimens, and other relevant expertssuch as the IUCN/SSC Specialist Groups. TheScientific Authorities should consider the CITESguidelines for the disposal of confiscated live animalsand plants found in Annexes 1 and 2 of theResolution. In the case of disposal of confiscatedlive specimens of species that are either in AppendixI or involve commercial quantities of Appendix-IIor -III species, the Secretariat should be informedabout any decision taken. The Resolution alsorecommends that in cases where shipments arrivewithout documents and are refused by the importer,the shipment should be confiscated and thespecimens disposed of in accordance with the CITESguidelines.

The Secretariat

Re-homing of seizedspecimens in the UnitedKingdom

The majority of confiscations of CITES-listedspecimens in the United Kingdom are made atHeathrow Airport, London. Her Majesty’s Revenueand Customs (HMRC) are the lead agency ininspecting and confiscating any CITES specimens thatare not covered by the correct import or exportdocumentation. HMRC have a dedicated team of eightofficers at Heathrow who deal with all aspects ofCITES enforcement. The team undertake all theconfiscations of live specimens and unlike manyother countries are also responsible for re-homingthem. In 2004 - 2005 the CITES team re-homed some7,065 live animals, reptiles, birds and corals and4,191 live plants.

Although the team is made up of eight officers, oneofficer is responsible for coordinating all the re-homing of confiscated specimens. The role ofdedicated re-homing officer has worked so well thatthe officer concerned now coordinates the re-homingof all live specimens confiscated at the UnitedKingdom’s ports and airports. Two crucial aspectsof the re-homing officers’ role are those of liaisonand accurate record keeping. A full tracking systemmust be in place for each specimen from confiscationto re-homing.

We are fortunate in having expert animal handlersand a secure facility in which to conduct theexamination of shipments containing CITES-listedspecimens available to us at Heathrow. Once the exa-mination has been completed it may be necessary toconfiscate some or all of the shipment. Arrangementsare made by the detecting officer to remove thespecimens and house them temporarily, if practically

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possible, at Heathrow. This can include reptiles,tortoises or small numbers of birds. Any quarantinerestrictions will also apply to seized birds ormammals. The seizure information is passed to there-homing officer who will then oversee thepermanent re-homing of the seized specimens.Temporary housing of confiscated mammals is notpossible on site and the re-homing officer willendeavour to move these specimens as soon aspossible to a larger quarantine facility. The Customslegislation also allows for animals to be movedimmediately to a larger quarantine facility or newinstitution if this is required.

HMRC have a good working relationship with ourtwo scientific authorities, the Joint NatureConservation Committee (JNCC), for fauna, and theRoyal Botanic Gardens, Kew, for flora. There areover 28,000 plant species covered by CITES andsome of these species are very delicate and requirespecialist handling and immediate care. We havedifferent guidelines in place for species listed onAppendix I and those listed on Appendix II or III.Should we need to confiscate any live animals or birdslisted on Annex A of the European Commission(which includes all CITES Appendix-I species), there-homing officers will first call the JNCC and passonto them the details of species and quantity ofspecimens for their consideration. The JNCC willthen provide the re-homing officer with the necessaryinformation and contact details of the most suitablelocation for the specimens. This location may not bein the United Kingdom or even the European Union.If the confiscated specimen is to be re-homed outsidethe European Union, the re-homing officer will liaisewith the UK CITES Management Authority, theGlobal Wildlife Division of the Department for Foodand Rural Affairs (DEFRA). Arrangements will bemade to issue the required CITES re-export permitsfor the confiscated specimen. If the confiscatedspecimens are plants, things are a lot simpler as theshipment will already be at the Royal Botanic Garden,

Kew for the inspection. In addition any phytosanitarychecks will also need to be undertaken if the correctphytosanitary certificates do not accompany theplants.

If the confiscated specimens are listed on Appen-dix II or III, things are dealt with in a slightly differentmanner. The JNCC will only be contacted if thespecimens are unusual or rare in trade. Since theinception of the CITES team in 1992, the various re-homing officers have built up a considerable libraryof institutions or recognized societies that may beavailable to house the confiscated specimens. It isdepartmental policy not to re-home specimens tomembers of the public unless they are members of arecognized society. If a quantity of specimens is re-homed with a society, a detailed list of the recipientsis provided to the re-homing officer by the societyconcerned. This has proved a workable solution towhat can be a logistical problem if you are dealingwith a large number of confiscated specimens fromthe same species, e.g. 700 Testudo horsfieldii or497 Testudo graeca. The recipients of the confiscatedspecimens are required to sign a letter of receipt forthe specimens; they are also given a letter fromHMRC listing the species, the number, any permanentmarkings and stating that the specimens have beenconfiscated by HMRC. It must be stressed that thisletter does not give the recipient the authorization tosell the specimens. They still have to obtainpermission from HMRC if they want to move thespecimens to new owners.

At Heathrow, in addition to the live-animal BorderInspection Post, we have a live-fish Border InspectionPost. This facility has a properly equipped exa-mination area separate from the storage areas. Wereceive large consignments of live fish but theseconsignments can also include seahorses and livecorals. While the seahorses are readily identifiable,the live corals pose much more of a problem beingdifficult to identify and very sensitive to theirenvironment. Consequently they have to be dealtwithout delay and we have put in place a system with

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one of the recognized institutions whereby, afterinforming the relevant institution of any confiscatedlive coral and seahorses, the specimens are collectedfrom the airport, their identification is double-checked and they are temporarily re-homed. Thisinstitution will then re-home the specimens but onlywith prior consent from our re-homing officer.

Fortunately most of the non-EU commercial liveanimal and plant shipments enter the UnitedKingdom via Heathrow, Gatwick or Manchesterairports and provisions are in place to deal withthose. The problems arise when passengers arrive atthe regional airports with a small number of tortoisesor parcels are found at the Coventry Internationalparcels Hub (C.I.H.) that are suspected to containlive animals. Procedures have now been im-plemented at C.I.H. to process these parcels in linewith current health and safety guidelines. A qualifiedexpert is now available to examine these suspectparcels in a controlled environment and providetemporary housing while arrangements are put inplace to transfer the specimens to Heathrow. This isnot always possible at the regional airports. In somecases airlines may transport the specimens toHeathrow, if this is not possible other arrangementsneed to be made in order to house the specimenslocally. These last two scenarios further emphasizethe need for forward planning and liaison with othercompetent bodies.

The re-homing of seized specimens provides thedepartment with very positive publicity, many ofthe zoos and wildlife parks will have an informationpanel explaining that such and such specimen hasbeen confiscated by HMRC and providinginformation about CITES. The role of re-homingofficer on our team is certainly a challenging one butonce you have a robust re-homing system, transparenttracking system and the assistance of your colleaguesin times of need, it can also be a rewarding one.

HMRC Team

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The Indonesian experiencewith the disposal of illegallytraded, confiscated andaccumulated specimens

Indonesia is known as a major wildlife producer andexporter. It is situated in between two majorcontinents (Asia and Australia) and between twooceans (the Indian Ocean and the Pacific) and consistsof more than 17,000 islands with more than60,000 km of coastline. With the intensification andstrengthening of CITES law enforcement inIndonesia, interception of smuggling has improvedand illegally-traded specimens have been confiscatedin Indonesia, usually during attempts to export them.Confiscations also occur in the countries of des-tination or transit, and specimens may be returned toIndonesia. For live specimens, especially ofnationally-protected and Appendix-I species, the firstconsideration is given to the possibility of returningthe specimens to the wild. For this purpose theGovernment has established several live-animal post-confiscation rescue and orang-utan rehabilitationcentres.

Legal basis

Act No. 5 of 1990 concerning Conservation of LivingResources and their Ecosystems along with associatedgovernment regulation No. 7 of 1999 concerningPreservation of Animals and Plants Species, governmentregulation No. 8 of 1999 concerning Utilization ofWild Animals and Plants Species, and the decree of theMinister of Forestry number 447/2003 concerningAdministrative directives provide the legal basis forundertaking the confiscation and disposal ofspecimens, and establishment and management ofpost-confiscation rescue centres and the orang-utanrehabilitation centres. Specimens seized as evidencein the country of destination or transit are regardedas belonging to the State. The cost of returning thespecimens is borne by the exporter or the importer,in accordance with regulations in the country ofdestination.

Establishment of rescue andrehabilitation centres

In order to fulfil the provisions of Article VIII of theConvention and to reduce the risks of stress, injuryand death of confiscated live animals, the


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Government has developed and established eightpost-confiscation rescue centres as transit places andtemporary care centres forconfiscated live animals.The centres are located in Jakarta, Bogor, Sukabumi,Yogyakarta, Malang, Denpasar, Ambon andManado. The centres are developed and run in acollaborative partnership between the Governmentand non-government organizations (NGOs). Allconfiscated live specimens are directly sent to therescue centre for quarantine purposes and furthertreatment. The decision on the final disposal of theconfiscated specimens is taken jointly by theprovincial office of the Management Authority andthe rescue centre.

The daily management of each centre is run by anNGO with full coordination and control by theprovincial office of the Management Authority. TheManagement Authority has full control of theconfiscated animals, while the running of the centreis the responsibility of the NGO in charge. A databaseon the confiscated animals in the rescue centres isbeing developed. For example, the table above liststhe holdings of four rescue centres.

The orang-utan (Pongo pygmaeus, Appendix I) isfrequently encountered in illegal trade. Severe forestfires have degraded forest habitats important to thisspecies, adults are illegally killed and orphans areillegally traded as pets. The precise annual figure ofspecimens entering trade remains unknown, and it isbelieved these are mainly smuggled by sea on loggingand fishing vessels. Last year the Thai Governmentconfiscated more than 100 animals at a zoo that weresuspected to be of illegal origin, and recently Cam-bodian authorities seized more than 30 orang-utans.

The Government operates several rehabilitationcentres for the orang-utan. These are in TanjungPuting National Park, Wanariset, Samboja Lestari,Pangkalan Bun, Nyaru Menteng, Sibolangit andBukit Tiga Puluh. The rehabilitation centres aim toadapt confiscated and repatriated orang utans (as wellas other animals) to semi-wild conditions with theultimate goal of full reintroduction in the wild.

The Government is developing guidelines andstandard operating procedures for the managementof rescue centres and for post-rescue treatment ofthe animals held in the centres including the orang-utan rehabilitation centres. These procedures willcover the roles and authority given to the centresregarding specimen care, maintenance of thefacilities; administration and reporting; and the finaldisposal of the specimens. The increasing numberof specimens taken on by centres places a strain onthe limited financial and human resources available.

Concerns with the application ofResolution Conf. 9.10 (Rev. CoP13)

Resolution Conf. 9.10 (Rev. CoP13) stipulates thatconfiscated specimens of Appendix-II and -IIIspecies may be subsequently sold by the ManagementAuthority. From the Indonesian point of view, thisprovides a loophole that facilitates the laundering ofconfiscated specimens, especially parts andderivatives. Indonesia is aware of one instance whereconfiscated reptile skins illegally shipped fromIndonesia were seized and confiscated on arrival inanother country and then auctioned by theManagement Authority of that country withoutinforming the Indonesian authorities. Being keptinformed of this case would have influencedsubsequent Indonesian non-detriment findings fortrade in the species concerned, and the revenue fromthe sale could have been invested in conservation inIndonesia.

Samedi and Faustina Ida HardjantiCITES Management Authority of Indonesia

Photo: P

eter Dollinger

Rescue centre Number of animals held (to December 2004)

Tasikoki (Manado) reptiles: 205; mammals: 69; birds: 457

Cinangka (Sukabumi) reptiles: 370; mammals: 149; birds: 269

Petungsewu (Malang) reptiles: 1; primates: 32; other mammals: 7; birds: 105

Yogyakarta reptiles: 590; mammals: 63; birds: 163


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The increasing problem offinding good homes forunwanted exotics

Over the past few years exotic animals have becomeincreasingly popular as household pets. Exoticanimals, usually defined as non domesticated andnon endemic, include both CITES and non-CITESspecies and have become increasingly available inpet shops and through specialists’ outlets. Whilstexact figures are difficult to obtain, estimates indicatethat over 114,000 reptiles and amphibians areimported into the United Kingdom each year for saleto the public. People in the United Kingdom nowhave as many terrapins and snakes as horses orponies, and the number is rising. Keeping an exoticsuch as a snake or lizard has assumed iconic fashionstatus.

However this rise has also seen an increase in animalswith physical or psychological problems. Manyowners or prospective owners do not understand howto care for their exotics as species-specificinformation is often not easily accessible. Thewelfare problems or abandonment of these specieshave risen and more worryingly have added to anincreasing problem of finding good new homes forthese animals.

The Royal Society for the Prevention of Cruelty toAnimals (RSPCA) has been working to improveanimal care in the United Kingdom for over 180years. Its 330-strong inspectorate investigates over100,000 cases of animal cruelty and abuse annually.In recent years inspectors have been called out togrowing numbers of rescues and collections of non-domesticated animals such as birds, snakes, terrapinscaimans and primates. The stray iguana is starting toreplace the stray dog as a problem animal.

The RSPCA has carried out a number of studies onthe scale of the problem. The number of exotics thatare coming into the care of the RSPCA is increasing.Between 1999 and 2000 alone there was a 200%increase in the numbers of exotics being collectedby inspectors. This increase is supported by a surveyof owners of exotics which found that many ownershad concerns on the level of information they weregiven and on their pets’ poor appetite and breedingsuccess. Also many veterinarians feel that they donot have the expertise to treat exotics and had seriousconcerns on the neglect of exotics by uninformed

pet owners. In a 2003 RSPCA survey of British vets,less than half treated exotics and, amongst those thatdid not, only a third referred the case to another vet.

The problem in the United Kingdom appears to befairly broad across the country and common to bothrural and urban areas. The RSPCA, as the leadinganimal rescue organization in the United Kingdom,has had to respond to this growing number ofunwanted exotic animals that come into our care. Itis becoming increasingly difficult to keep up withthe increase in numbers.

There are three options available to an inspectoronce he has collected any exotic. The first is to takeit to specialized keepers. The RSPCA has a list ofapproved keepers that will take on an animal, provideit with the proper care and veterinary help andcrucially only ‘re-home’ it to a prospective ownerthat has the necessary skills, knowledge andequipment. This is the most common outlet, takingover 54 % of all exotics that were re-homed in 2004.However as the numbers of unwanted exoticscontinues to increase so the numbers of placesavailable in these homes decreases. The secondoption is to re-home the animal through a RSPCAhome but the same limitations apply. It is importantthat the animals do not go back into commercial tra-de but the number of people that can provide theright accommodation is limited. The final option,euthanasia, is used as a last resort for a healthyanimal, but may become more common asopportunities to use the other two options decrease.

CITES Parties also face a similar conundrum withthe disposal of confiscated live CITES animals. Ifthere are no re-homing possibilities, and this wouldprobably be limited to zoos, euthanasia becomes theonly remaining option. The dilemna is that eutha-nasia is a realistic option but is a difficult concept toexplain to the general public. Ironically the initialproblem lies with the same constituency. There aresome moves towards rectifying this in the UnitedKingdom. A new law is being discussed by Parlia-ment that would mandate any owner to provide aduty of care to any pet. However, this is probably along-term solution and until unwanted exotics arereduced in the short-term, new innovative ways ofdealing with this problem will have to be considered.

The Royal Society for the Prevention of Cruelty to Animals


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Guidelines of the WorldAssociation of Zoos andAquariums (WAZA) on theacceptance of seized orconfiscated animals

Live wild animals are seized and confiscated by local,regional and national authorities for a variety ofreasons. After seizure, the authorities must ensurethat the animals are temporarily placed at a facilitywhere they are housed, fed and cared for accordingto animal welfare requirements. By the subsequentact of confiscation, the authorities become theowners of the animals and have to dispose of them ina responsible, timely and efficient manner, takinginto account practical, legal, animal welfare andconservation aspects.

The authorities are assumed to take into account thefollowing guidelines when disposing of confiscatedanimals:

a. The CITES Guidelines for the Disposal ofconfiscated live specimens of species included inthe Appendices [Resolution Conf. 10.7, adoptedat the 10th meeting of the Conference of theParties (Harare 1997)]; and

b. The IUCN guidelines for the placement ofconfiscated animals [approved at the51st Meeting of the IUCN Council(Gland, 2000)].

Both guidelines refer to zoos and aquariums assuitable recipients of confiscated animals. Theyrecognize, however, that zoos and aquariums gene-rally cannot accommodate large numbers of animalsthat become available through confiscations and that,in particular for species with lower conservationvalue, the authorities may also have to explore otheroptions, such as rescue centres, life-time carefacilities, specialist societies, humane societies,commercial captive breeders or research institutions.

Further guidance is provided to the authorities by

c. The IUCN guidelines for re-introductions[approved at the 41st meeting of the IUCNCouncil ( Gland 1995)]; and

d. The IUCN guidelines for the prevention ofbiodiversity loss caused by alien invasive species[approved at the 51st meeting of the IUCNCouncil (Gland 2000)].

Acceptance of seized animals

Whenever possible, zoos and aquariums shouldsupport the efforts of their authorities by acceptingto temporarily house, feed and care for seized animalstemporarily. Institutions accepting such animals mayrequest that their expenses be reimbursed. It isstrongly recommended that arrangements be madeunder which the costs will be charged to theconfiscating authority rather than directly to theimporter or owner of the animals.

Advice to authorities regardingplacement of animals

When confiscating animals, the authorities will haveto take the basic decision whether the animals shouldbe:

a. Returned to the wild;

b. Maintained in human care for the remainderof their natural lives; or

c. Euthanized.

To facilitate this basic decision, both the CITES andIUCN Guidelines contain decision trees. WAZA andits association members will not interfere with thisstage of the decision making process. Individual zoosand aquariums will also refrain from influencing theauthorities, unless they are (part of) the CITESScientific Authority or belong to another governmentestablished consultative body and are approachedby the authorities in that capacity.

Acceptance of confiscatedanimals for permanent keeping

Zoos and aquariums will accept confiscated animalsonly if they have the necessary expertise and canensure appropriate care and accommodation of theanimals in the long term.

The animals may be accepted under a permanentloan agreement or as donations. A permanent loanagreement should also define the ownership of theoffspring.

While the receiving institutions may pay fortransportation costs, they should refrain from buyingthe animals.


13

Zoos and aquariums accepting animals will do soonly if the transaction will not result in any benefitsto the person or institution from which the animalswere confiscated.

If the animals belong to a species for which acoordinated regional conservation breedingprogramme exists, they should be integrated into thatprogramme, if appropriate.

Acceptance of confiscated animals forreturning them to the wild

If zoos or aquariums are requested by the confiscatingauthority to accept animals for returning them to thewild, they will accept only if the requirements ofthe IUCN guidelines for re-introductions are met. Theywill make sure that, during the whole process, theseguidelines are fully respected.

Creating awareness and fundraisingfor conservation

Zoos and aquariums having confiscated animals ondisplay should take the opportunity to inform thepublic about the reason which led to theconfiscation. In particular, they should make thepublic aware of the threats unsustainable and illegaltrade poses to wild species and of the role CITESplays in combating such trade.

Efforts should be made to raise funds for supportingin situ projects for the species concerned, especiallyin the case of high profile species, such as primates,large carnivores, elephants, rhinos, parrots or marineturtles.

Adopted at the WAZA Plenary Session of 20 November 2003 –58th Annual meeting, held at San José, Costa Rica, 2003.

Taking stock: experiences ofelephant ivory and rhino hornstockpile management in Africa

‘Ivindo 3’ might sound like the final part of some epicfilm trilogy, but it does indeed tell an interesting three-stage journey highlighting the close links betweenivory confiscations and stockpiles. Taking its namefrom the clear markings, ‘Ivindo 3’ was one of fivetusks seized near Lope, Gabon, during a field patrolin early 1999. Following presentation as evidence ina court case in Makokou, it rapidly left governmentcustody and subsequently re-entered illegal trade. Byremarkable coincidence, the same ‘Ivindo 3’ultimately became one of 330 ivory tusks seizedduring a routine inspection by Huang Pu Customs inGuangzhou, China on 18 March 1999. Clearmarkings on this tusk enabled it to be traced back toGabon, despite the fact that its disappearancefollowing the court case was not known. Clearly, gapsin the initial stages of stockpile management hadfacilitated its return into illegal trade, and there arelikely to be similar cases involving other countries.

One of the most common measures applied to confis-cated wildlife products – deemed property of the State– is to store them in a secure room, warehouse or sa-fe. Such measures are commonly included in nationallegislation as a means to ensure that the illegally-tra-ded specimens are removed from the possession ofthe guilty individual(s) as well as allowing the Stateto dispose of the specimens as deemed fit, possibly tohelp recoup enforcement-related costs.

With regard to CITES provisions, ResolutionConf. 9.10 (Rev. CoP13) on Disposal of illegallytraded, confiscated and accumulated specimensrecommends that “Parties transfer confiscated andaccumulated dead specimens of Appendix-I species,including parts and derivatives, only for bona fidescientific / educational or enforcement / identifi-

Photo: T

om M

illiken TR

AF

FIC

Ivindo 3 in China

Photo: Sim

on Milledge T

RA

FF

IC

Mounted leopard skins in storage


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cation purposes, and that Parties save in storage ordestroy those excess specimens whose transfer forthese purposes is not practicable”. It alsorecommends that “confiscated dead specimens,including parts and derivatives, of Appendix-II andAppendix-III species be disposed of in the bestmanner possible to benefit enforcement andadministration of the Convention”.

In reality, stockpiles often include wildlife productsderived from legal sources (e.g. natural mortalities,managed off-take, problem animal control, etc.) inaddition to confiscated specimens.

Few people realize how wildlife product stockpilescan actually become so large, or how quickly theymay accumulate. In Africa, two of the highest profilewildlife products are stockpiled in significantquantities. TRAFFIC has documented over 18 tonnesof rhino horn, almost four-fifths of which are foundin just four locations and increasing at a rate of up to25% every four years. Even larger quantities ofelephant ivory exist, with individual warehouses nowholding volumes as much as around 100 tonnes andincreasing by up to six tonnes annually.

Disregarding the precise origin of the individual spe-cimens, and as illustrated by the ‘Invindo 3‘ case abo-ve, good stockpile management is key to minimizingthe risk of stockpiled wildlife products enteringillegal trade.

The term ‘stockpile management’ covers the entireprocess from confiscation and collection of a wildlifespecimen to secure storage (and subsequent disposal),which may see the wildlife product move throughmany pairs of hands and via many locations.

Accidental deficiencies or deliberate abuse ofstockpile management practices anywhere along thatprocess can therefore result in wildlife productsentering illegal trade. For example, at the field level,the accumulation rates of ivory and horn collectedfrom some of the largest elephant and rhino popu-lations in Africa are lower than expected levels. Atthe other end, there have been several examples ofivory thefts from strongrooms throughout East andsouthern Africa in the past two decades. Most recen-tly, the Ethiopian Wildlife Conservation Departmentundertook legal action and improvements tostockpile management practices in response to thetheft of at least 1,700 kg of ivory from the maingovernment store.

Indeed, it is increasingly evident that poor stockpilemanagement holds the potential to undermine otherefforts to prevent illegal trade, which havetraditionally focused on ensuring adequate fieldprotection and infiltrating illegal trade syndicates.

There are essentially four main components to goodstockpile management:

1. Collection and centralization – Adequateinvestigative procedures are required to ensurethe proper collection and recording of evidence,whilst timely centralization helps reduce theaccumulation of stockpiles in less securelocations with a higher risk of theft.

2. Marking and measuring – Individual specimensin the stockpile should be marked with a uniquenumbering system (which incorporates essentialmeasurements) using a proven markingtechnique. For example, ivory should be markedusing the CITES prescribed system (i.e. countryof origin two-letter ISO code, last two digits ofyear, serial number for year in question, andweight in kg) whilst a combination of visiblemarkings and hidden microchips are recom-mended for rhino horns.

Photo: Sim

on Milledge

Stockpiled ivory in undisclosed location in South Africa

Rhino stock in South Africa

Photo: M

egan Diam

ond TR

AF

FIC


15

3. Registration and audits – Registration is perhapsthe most important part of stockpile mana-gement, to ensure information is accuratelyrecorded and to minimize the risk of specimensnot reaching the final stockpile. Central toregistration is an auditable paper trail and use ofcomprehensive registers to record all locationsand persons holding or moving specimens, whichare in turn individually identifiable accordinglyto their unique numbering system. Auditmechanisms are required in the same way asperiodic checks are performed on other valuableassets.

4. Storage and security – Adequate storage facilitiesand security measures are required to preventtheft, decline in quality and prevent unauthorizedaccess.

Simon Milledge, Deputy Director,TRAFFIC East/Southern Africa

Handling confiscatedspecimens

The handling of confiscated specimens can be madeeasier if one is well-prepared and well-equipped. Asuitably-equipped location is of utmost importance,as in the case of live specimens there will always be arisk of an escape. Information should be kept at hand,such as a list of experts in animal and plant handling,identification and care; a list of rescue centres; andthe telephone numbers where the ManagementAuthority can be reached (keeping in mind thatconfiscations often occur in the evening and atweekends). Basic equipment can include a bird net,leather gloves, snake hooks, face masks, protectiveeyewear, surgical gloves, cloth sacks, a large cleancontainer (such as a rubbish container with a lid),towels and blankets, and antibacterial soap.

Handling wildlife can be dangerous, and it isimportant to take precautions for your safety, that ofyour colleagues, and for the safety of the specimens.Animals are often faster and much stronger than mightbe expected. Quite apart from the damage that can becaused by claws, teeth, beaks, toxins, spines or others,animals can also carry infectious diseases such ashepatitis A and B, psittacosis and salmonella. Deadspecimens may also pose a risk, for instance, huntingtrophies may have sharp claws, talons, horns orantlers, and they may have been treated with

chemicals which are poisonous if inhaled. Handlingplants can also be risky, as plants may secrete toxicsubstances or have sharp spines, and they may havebeen treated with chemicals and pesticides.

The Secretariat

2005 Checklist of CITESspecies now available

The Checklist of CITES species provides the officialalphabetical list of CITES species, their scientificsynonyms, their common names in English, Frenchand Spanish (to the extent that these were available tothe compilers) and an indication of the Appendix inwhich they are listed. The publication includes a CD-ROM that contains in PDF format all of theinformation above as well as the Annotated CITESAppendices and reservations. The latter provides theoriginal listing date of all taxa (orders, families,genera, species, subspecies) and populationsspecifically named in the current or past Appendices.It also indicates all reservations ever made by Parties,with the dates on which they entered into force and,in the case of past reservations, the dates on whichthey were withdrawn. This book should beparticularly useful to CITES Management andScientific Authorities, Customs officials and allothers involved in implementing and enforcing theConvention.

Paper copies can be ordered from the CITES website(USD 60 per copy). An electronic version can bedownloaded in PDF format from the website at nocost.


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CITES SecretariatInternational Environment House

Chemin des AnémonesCH-1219 Châtelaine, Geneva

Switzerland

Telephone: +41 (22) 917 81 39/40 Fax number: +41 (22) 797 34 17

Email: [email protected] Website: htpp://www.cites.org

If you would like to submit an article, or make suggestions or comments, please contact

the Capacity-Building Unit.

Although every attempt is made to ensure the accuracy of the articles, the opinions expressed are those of the individual authors. Thedesignations of geographic entities do not imply the expression of an opinion from the CITES Secretariat concerning the legal status of

any country, territory, or area, or of its frontiers and borders.

Updated trainingpresentations

The Secretariat has prepared an ID-ROM (card-sizedCD-ROM) with training presentations on CITES.Produced in the three working languages of theConvention (English, French and Spanish), itcontains 16 training presentations in PowerPointformat, the text of the Convention, CITESAppendices I, II and III (valid from 23 June 2005)and the standard CITES export/import permit andre-export certificate.

The PowerPoint presentations include anintroductory section and cover the following topics:definitions, roles of CITES Authorities, role andfunction of the Scientific Authority, permits andcertificates, special procedures, reading theAppendices, using the Appendices, science, non-detriment findings and data, role of quotas in CITES,trade with non-Parties, permit management systems,filling in permit forms, reservations and plants.

This ID-ROM is an updated and improved versionof the CD-ROM that was distributed in November2003, and the Secretariat hopes that Parties willagain find it a useful tool in their CITES trainingprogrammes.

The Secretariat has also updated the CD-ROMtraining programme for Customs. This self-instruction course was first provided to the Partiesin 2004, and has been updated to reflect changesadopted at the 13th meeting of the Conference of theParties (Bangkok, 2004).

Copies of these two training materials are availableon request from the Secretariat.

The Secretariat

Documents

The confiscation of illegally-traded or