By Christopher Niesche

Amanda Gore CA’s working day is different from the average chartered accountant’s. She could be in the office going through financial statements. She could also be driving around Namibia interviewing customs officials about illegally logged wood, or uncovering a cache of confiscated ivory and pangolin scales in the Ivory Coast capital, Abidjan.

Gore is the founder and CEO of the Centre for Global Advancement (C4GA), which investigates the financial side of environmental crimes such as illegal logging or mining or wildlife smuggling.

Headquartered in Kenya’s capital Nairobi, the business works alongside law enforcement bodies to investigate the financial aspects of environmental crimes and gather evidence for a prosecution.

Gore studied commerce at the University of Auckland then joined New Zealand Inland Revenue as an investigator in 2003 before deciding she’d prefer a more global role.

“I was always interested in global investigations and combating corruption and money laundering, so I just felt like I needed to do that on a global scale,” she says.

“It was all about combating all of these different types of crime that were going on and really trying to actually make a difference. It’s not easy all the time.”

So in 2007 she joined Deloitte Forensic & Dispute Services in the Cayman Islands, working in asset tracing and recovery.

Being a CA has opened many doors. Over the next 15 years, Gore had roles in financial crime investigations and asset tracing in locations including New York, Auckland, Botswana, Singapore, Zurich and Nairobi, her current base.

She worked for two years as a senior financial crime adviser to the United Nations Office on Drugs and Crime in Nairobi before starting C4GA in 2020.

Poaching and pangolins

In Africa, Gore focuses on wildlife crimes such as trafficking of ivory, pangolin scales or rhino horn, along with illegal logging and fisheries crimes where there is a financial element such as bribery or corruption involved in the issuing of fishing licences.

She gets called in, for instance, after a wildlife product is seized and authorities ask her to consider if there is a financial aspect to the crimes. “With financial investigations, we’re able to see the bigger networks that are involved in some of the crimes,” she explains.

“If we can apply money-laundering and corruption laws to those involved in wildlife crime, it can often lead to tougher sentencing. So it’s all about getting consequences, but also trying to understand who’s actually behind it, because the poacher’s never the guy that’s behind it and can be easily replaced.”

Wildlife trafficking often correlates with drug smuggling and other crimes, as criminal syndicates are commodity-agnostic and focus on anything they can make money on, says Gore.

“Often those that are caught with wildlife crime are charged with multiple other crimes like drugs, for example,” she says.

C4GA is all about finding alternative legal and financial pathways to prosecute people, because there are a lot of barriers to getting environmental criminal cases through the justice system, particularly in Asia and Africa.

Gore focuses particularly on the US justice system, because it yields several “tools” she can use. These can be prosecutions for financial crimes, travel bans or asset seizures.

“That’s what it’s all about. Putting the puzzle together and looking at how we can leverage different tools to get some outcomes.”

Following the money trail

Gore was heavily involved in what has become known as the “Fishrot” scandal in Namibia, when it was revealed in 2019 that six local MPs and officials had allegedly taken US$15 million in bribes from Icelandic fishing company Samherji in exchange for local fishing rights.

“In that particular case, we were evaluating a potential angle to get it through the US justice system. With most of the bribes being paid in US dollars, we were confident there may be a potential interest by US Authorities.

“But also, the Icelandic company appeared to shift its profits offshore as well as using offshore havens like Cyprus, and Mauritius and Dubai to administer some of the potential financial crimes,” she says. “So there were some pretty interesting global structures in terms of how the money was moving in that particular case.”

Along with chasing down organised crime groups involved in trafficking, Gore also looks into the supply chains of major companies and tries to hold them accountable for downstream illegal sourcing of products or components.

For example, a lot of illegally sourced timber is coming out of Zambia and the Democratic Republic of the Congo. It leaves the continent via a port in Namibia and is then shipped to Vietnam or China, where it is milled and turned into furniture and perhaps shipped to Australia, New Zealand or the US, where no-one knows it has been illegally sourced.

Gore also follows the money trail where a corporation may have been involved in bribing local officials for licensing to harvest timber or mining rights. “Are they involved in bribing officials for mining licences in other countries? Are they involved in a wider tax scheme where they are capturing profits offshore rather than paying any tax at the source country where the natural resources are extracted?”

Gore says she has always been interested in why people commit crimes and how they happen. She is also interested in the insights into different cultures. “The stories behind why people engage in crimes is just fascinating. Stories of meeting at hotels with big bags of cash – it’s incredible.”

A growing problem

Environmental crime is a growing problem globally. The United Nations Environment Programme (UNEP) and INTERPOL estimated in 2016 that the global cost of environmental crime was as high as US$258 billion, up 26% from just two years earlier. 

"Environmental crime is the world’s third most lucrative criminal business after drugs and counterfeit goods, ahead of human trafficking."

Awareness of environmental crime has grown in the past year or two, including among the financial community, which has a role in reporting suspicious transactions. Anti-money laundering group the Financial Action Task Force has recently published reports on the role of money laundering in environmental crime and the illegal wildlife trade.

Gore also teaches courses about the financial investigation of these crimes at the University of New Haven in Connecticut.

Where to next?

Gore feels her time in Africa is up and is planning to move her business to Europe.

“I’m looking at relocating [in 2022] to be more in the action and more in the environmental space that’s going on there,” she says.

“I want to educate people about the due diligence of their finance and investments into companies that might be involved in environmental crimes.”

But there’s plenty to remember from Africa.

In Abidjan, Gore was investigating wildlife trafficking with the local organised crime unit after a big seizure of ivory and pangolin scales.

She drove around the African port city conducting interviews as part of a financial investigation into large seizures of illicit wildlife products linked to a well-known Asian-based syndicate. Then she went to see the head of the financial investigation agency in his office to see if he knew where the seized ivory and pangolin scales were.

He was reluctant to interrupt the Sandra Bullock movie he was watching on TV, but became more interested when they asked about the ivory.

“He stands up and he’s so excited, he walks to the back of his room. He pulls a curtain and it’s in his office!” says Gore.

“There are a lot of unbelievable moments in that investigation that you just go, ‘Wow, this is the best part of the job. This is really interesting’.”

"There are a lot of unbelievable moments in that investigation that you just go, ‘Wow, this is the best part of the job. This is really interesting’."

Financial crime identikit

Accountants need to be alert to criminals who will seek to exploit their skills and involve them in serious criminal activity, the head of the Serious Financial Crime Taskforce (SFCT) warns.

An Australian Taxation Office (ATO)-led taskforce, the SFCT has outlined 10 identikits of people who might become involved in financial crime. They include hardcore criminals, cybercriminals, money launderers and tax cheats.

The profiles also include professional enablers who use their skills and networks to help facilitate financial crime.

“Accountants play a really important role in the tax and superannuation systems,” says Will Day, chief of the SFCT and the ATO’s deputy commissioner of integrated compliance. “We want to educate them on the signs of serious financial crime and very much warn them against playing the role of an enabler. We really want to help them look out for the signs, for example, of a hardcore criminal who will look to exploit accountants, often dragging them into even more serious offending,”Day says.

Hardcore criminals can deliberately set out to corrupt an accountant. “It can often start off relatively benignly but very rapidly you can be dragged into very direct attacks against the tax and superannuation systems and very quickly be in over your head.”

The criminals might start by asking accountants to set up arrangements to help transfer money offshore, which can then turn into putting in false claims and trying to hide the money trail.

The SFCT also wants accountants to spot activities that are risky to clients and help them avoid getting involved in arrangements that ultimately could result in very severe punishments for their client. Download the Serious Financial Crime Identikit here.

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