By Toby McIntosh
Finding endangered plants and animals for sale online remains easy.
So three major nonprofit groups tried something new to combat illegal wildlife trafficking (IWT) online — constructive engagement with Facebook and 46 other social media and e-commerce platforms.
But although officials from the Coalition to End Wildlife Trafficking Online say progress is being made, the evidence is scant.
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.
“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). “If one was being cynical, one would see it as an effort to forestall legal liability,” she said.
Activists outside the Coalition strongly criticize the social media platforms for inaction and they are pursuing more confrontational approaches. Facebook “is directly fueling the global extinction crisis,” according to Gretchen Peters, Executive Director of the Center on Illicit Networks and Organized Crime. Her group and others are filing lawsuits and backing legislation to regulate the platforms.
The three NGO members of the Coalition say they remain committed to the collaborative approach, but recently have indicated some support for government regulation.
Whether the Coalition engagement strategy is working after almost four years of existence is difficult to tell. The Coalition’s transparency is minimal. Its two-page “Progress Report” report issued in October 2021 provides figures on only a handful of topics.
More transparency by social media companies is often cited as a viable way hold them to account, not only regarding online IWT, but also for hate speech and disinformation. What’s provided by the Coalition is of limited value, according to not only Coalition critics, but also to experts who study social media companies.
A condensed version of this article appears in Mongabay. Follow EYE @tobyjmcintosh
80 Percent Reduction Goal Dropped
The Coalition’s original plan for gauging the success was to use one key number.
When the Coalition began in 2018, it announced a major goal — to cut IWT online by 80 percent 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 Allan said that measurement proved nearly impossible and too expensive. The other Coalition members are the International Fund for Animal Welfare (IFAW) and the World Wildlife Fund (WWF).
It was “a ridiculous target,” commented Haysom. “They never had a baseline, so how can you measure it?” she said.
Nonpublic Targets Set for Platforms
After dropping the 80 percent goal, the Coalition started developing “updated targets and indicators to monitor success internally,” Allan said. These “action plans” are customized for each corporate member. The plans are not disclosed.
“We have our strategic goals for what the company needs to do by certain dates,” Allan said. “They know we have these goals for them.” And, he added, “We are recording whether they are hitting those goals and how much time they have left.”
Giavanna Grein, a senior official at TRAFFIC and WWF, said each action plan “is targeted specifically” to the platform, covers multiple topics and include indicators. The action plans “are fluid,” Grein said, “allowing activities to evolve as the platforms do themselves and the nature of illegal wildlife trade on those platforms changes.”
Grein elaborated, “This can be something like, does the platform have a wildlife policy in place that aligns with that of the Coalition and is it published externally for users to see (Y/N), or include more quantitative data such as the number of staff trained in detection and the number of listings removed.”
The action plans can’t be released because they are based on internal information that if disclosed could harm the company’s competitiveness and help traffickers, according to Lionel Hachemin, a wildlife crime researcher with the IFAW in France.
“I am not sure the Coalition would be keen to say who are the good guys and who are the bad guys,” Hachemin said. “We don’t want too much negativity,” 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.”
Regular Meetings at Core of Coalition System
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 WWF — divided up primary “point of contact” duties. So, for example, IFAW works with eBay. Grein meets with Facebook.
The interactions are “not like a confrontation at all,” as described by Mark Hofberg, a Campaigns Officer with IFAW’s Washington D.C. office, who led the 2021 IFAW study that he said showed “rampant” trade is continuing. Of the Coalition, he said, “I think it’s definitely helping.”
Typical topics for discussion at the meetings, Coalition NGO officials said, are helping the companies understand what’s illegal, advising them on working with law enforcement and discussing warnings for consumers.
“We know we are going in the right direction,” said Hachemin. He continued: “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.”
TRAFFIC’s Allan said, “There has been a significant amount of progress made and there is most certainly disruption happening across online platforms.”
Coalition Disclosures Very Broad
The quantitative information provided by the Coalition makes it difficult to know how well the strategy is working.
The Coalition’s two-page progress report issued in October of 2021 highlights how many online listings were “removed or blocked.” The number is going up, but the increase largely reflects the growth in corporate members.
The Coalition said the 47 member companies collectively had “removed or blocked” 11,631,819 “endangered species listings” over three years (3,335,381 listings during the Coalition’s first two years and 8,296,438 in the third).
The terminology “removed or blocked,” is not defined. As a result, the companies are “grading their own homework,” wrote Heidi Tworek, a senior fellow at the Centre for International Governance Innovation, in a 2019 article.
Only limited context comes from the Coalition’s pointing out in its report that its members have 11 billion “combined global user accounts.”
Without an estimate of the overall scale of the IWT market online, the number of removals lacks context.
More Frequent Disclosures?
The release of more frequent numbers might indicate progress over time, but Coalition NGO officials differed on the feasibility of such disclosures.
IFAW’s Hofberg said monthly reporting would be “a pretty basic step that would help the general public to understand the scale of the problem.” He said, “They have it and they have the ability to crunch the numbers.” Several other Coalition officials concurred.
By contrast, the WWF’s Grein said, “Based on our conversations with companies, this frequency of an interval is not possible due to capacity constraints.” She elaborated, ”They have to detect, remove and collate removals for all illegal or socially unacceptable content across the board. Wildlife will not be the highest priority compared to other online content like child safety, drugs and terrorism. The volumes of all removals are enormous.”
Grein said the Coalition conveners “originally wanted to collect data down to the specific number of illegal wildlife items removed by species, though learned that the companies do not track this data to that minute of a level.”
She suggested that record-keeping is a work in progress.
“Yes, the Coalition continues to encourage companies to report actions taken to address illegal wildlife trade externally,” Grein said. “However, to achieve this, companies need to first enhance their own internal metrics to be able to better report. For example, some companies may still bundle illegal wildlife content removed with other illicit content, so it is difficult to track IWT specifically.”
Other Coalition Disclosures Limited
The Coalition’s annual report describes the broad goals:
- “to unite the tech industry to standardize prohibited wildlife policies,
- train staff to better detect illicit wildlife products,
- enhance automated detection filters and
- educate and empower users to report suspicious listings.”
But the Coalition’s reporting on each of these goals is limited or nonexistent.
Member IWT Policies Not Evaluated
The Coalition asks its members to “strong, enforceable wildlife policies in place.” Most appear to have posted a policy, although they vary in detail. The Coalition neither sets out a model language nor grades the policies.
Coalition NGOs officials said they work with corporate partners individually on their policies. Grein described one instance, reaching back to well before the Coalition was formed. “WWF started working with Google in this space in 2012, and in 2014, helped them revise their Google Shopping prohibited content policies.” She said that collaboration revealed “gaps in platform content policies regarding wildlife more broadly” that needed “an industry-wide approach.”
The Coalition’s progress report does not inventory or assess the companies’ policies, although all three NGO Coalition members have called for better company policies in recent reports.
“The large majority of the online platforms surveyed did not have clear guidance for users regarding wildlife trade legislation or a clear policy of steps being taken to curtail illegal wildlife trade from their platform,” according to a July 2020 report by two of the main Coalition members, WWF and TRAFFIC, about online sales of reptile and bird species.
Similarly, a 2021 IFAW report concluded, “Online marketplaces should adopt clear, comprehensive, and enforceable wildlife trade policies that ensure their platforms do not contribute to wildlife trafficking.” IFAW said the companies should “improve the clarity of their related polices.”
Asked what policy improvements the platforms should make, Grein said there needs be “streamlining” of terminology. “Additional guidance is needed beyond just buying and selling wildlife, looking at user promotion of and engagement in activities that harm endangered wildlife,” she said. “For example, this could include selfies with an endangered animal which encourages others to do the same.”
Peters is skeptical of the platforms’ stated policies, commenting: “Facebook has great policies. They just don’t bother to enforce them.”
Content Moderation Processes Undisclosed
More useful than disclosing the numbers of postings removed or blocked would be information about the “process” used in getting there, “content moderation” practices, according to analysts of social media companies. “Sometimes you need to know how things are being done, not just statistics,” said Tworek.
In this regard, the Coalition discloses two things.
One is “the number of enforcement staff trained to detect illegal content” for all 47 member companies. It says 470 persons were trained in the first two years, 1,906 in the third year.
The Coalition also reports on how many online wildlife products were “flagged” by volunteer “cyber spotters” trained by the Coalition through its “Owlet” program. This figure grew from 4,500 in the 2020 report (covering two years) to 7,500 in the third year. The Coalition encourages public reporting with a Coalition reporting page.
The Coalition does not report on how many moderators, trained or not, work on IWT, or how much time is spent on IWT moderation.
The numbers of staff trained and findings by Owlet cyber-spotters would seem to be a drop in the bucket compared to the IWT content moderation efforts of 47 companies.
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” Grein said, except for the staffers from member companies assigned to work with a Coalition member. She noted that these representatives usually handle multiple subject matters besides IWT.
Another reporting option 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.
Limited Accounting of Use of Automated Systems to Detect IWT
A stated Coalition goal is “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.” For short, this called “machine learning” or “artificial intelligence” (AI).
The progress report provides no information on how this effort to increase the use of AI is going.
“We push them” on machine learning, Hachem said. “We are encouraging the platforms to get the AI to be open source, so everyone can use it,” he added, noting that some companies are not financially able to institute machine learning.
Grein responded, “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.”
This is unfortunate according to Peters, who said, “There’s a ton of stuff that would be really helpful for us to understand,” such as how the algorithms work. “We’d like to see under the hood on that.” She is interested not only in what AI is used to catch IWT, but what algorithms are used by the platforms to extend the reach of sellers.
Even without AI, the platforms could do a better job of content moderation, according to Peters and other researchers, who point out that “manual” key word searches can find a lot of IWT. “You don’t need artificial intelligence to find and eliminate this content,” Peters said.
Transparency about content moderation is addressed in The Santa Clara Principles, a set of guidelines for social media companies developed by NGOs. The Santa Clara principles state that companies “are encouraged to publicly share data about the accuracy of their systems and to open their process and algorithmic systems to periodic external auditing.”
IFAW’s Hofberg suggested some additional questions to help evaluate AI efforts. “You could ask have you increased your allocation of resources, personnel or dollars, to your machine learning department, and are you training those people on IWT trafficking?” He said this could be followed up by monitoring and a look at the companies’ own evaluations of effectiveness.
The Coalition NGOs contribute to the discovery of IWT and the functioning of AI by maintaining “a key search words database with over 2,500 known search terms in multiple languages.” The nonpublic list is “shared regularly with companies to enhance automation,” according to the 2021 report.
Mike Carson, an eBay official wrote in a June 2021 blog post published by WWF that eBay has “utilized the key search words identified by the Coalition and academia to expand block filters and enhance automated detection of prohibited items.”
Public Awareness Efforts Tallied
The Coalition also reports on 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, Coalition members altogether had more than one billion “social media engagements through user messaging.” No similar figure is found in the 2020 report.
The 2021 report provides no additional breakdown or elaborate on these messages, but Coalition officials said referred to such things as “pop up” messages that occur when suspicious postings are reached. Facebook in 2018 announced a “pop-up interstitial alert message that informs users about illegal wildlife trade when certain wildlife-related search words are entered.” Grein offered, “Several companies have a pop-up in place to help educate users. Some of these include Alibaba, Baidu, Pinterest, TikTok, Instagram and Facebook, with Facebook’s including eight languages.”
“We are pushing them to use pop ups…,” according to IFAW’s Hachem, who said this topic is brought up in the regular meetings.
Peters likes pop-ups, too, saying they have been shown to be effective. But besides such warnings, she would like to see stronger action. Those searching for certain terms, she said, should have their accounts flagged and the search results should be blocked.
Cooperation with Law Enforcement
Increasing corporate reporting about IWT to law enforcement agencies, is an “upcoming priority” for the Coalition, according to the 2021 report. A stated goal is “increased collaboration with law enforcement agencies to build out a coordinated approach to tackling organized criminal groups trading online.” The annual report does not elaborate on this goal.
Hachemin said the Coalition has helped members “share best practices on interactions with law enforcement.”
Grein said, “We are helping make connections between company representatives and law enforcement agencies, creating a safe space for both to better understand how to collaborate. We’re also working on a simplified guidance infographic to help companies understand what data is most important to report to law enforcement and how to do that. It will also help law enforcement understand how to request data from companies.”
Peters said more information should be handed over to law enforcement. A policy of “delete and forget” is “absolutely the wrong approach,” she said. Facebook, she said, “is very reluctant” to work with enforcers. This won’t change until there’s a legal mandate to disclose illegal activity, Peters said.
Another IWT activist recalled meeting with a Facebook executive on the subject in 2017, reporting, “He made it clear that they would handle illegal activities themselves, no collaboration needed (or wanted).”
Some IWT activists have called for the companies to retain information about deleted posts that can be shared with law enforcement. “[M]aterial should not simply be deleted,” recommended Haysom of GITOC. She is co-author with Rowan Martin, director of the World Parrot Trust, of a 2021 study about online sales of African grey parrots in several African countries.
‘Rampant’ IWT Continuing
The extent of illegal wildlife trafficking online remains difficult to ascertain.
Snapshots of IWT online are taken of small portions of the overall market.
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 asked not to be quoted.
IWT is “rampant” and “remains a significant challenge in the US,” the IFAW said in a September 2021 report entitled Digital Markets: Wildlife Trafficking Hidden in Plain Sight.
After a six-week investigation of 34 online marketplaces, IFAW found nearly 1,200 advertisements for almost 2,400 animals, animal parts, derivatives, or products of protected species advertised for sale on US-based platforms. Most of the advertisements were found on large platforms with international reach. Only eight of the nearly 1,200 advertisements had supporting documentation that the showed the sales to be legal.
The study no doubt undercounted the online sales, IFAW said, explaining that “these numbers are just a snapshot of the true number of specimens for sale since the investigators only recorded advertisements where species could be identified, and species-level identification is notoriously difficult when the only evidence is a few photos and some context clues.”
Hofberg of IFAW’s Washington D.C. office, headed up the research was asked by EYE what direction overall IWT sales are going. “I would say up, he replied.”
Agreeing with this assessment, Jedsada Taweekan, a WWF regional programme manager, said the volume of wildlife products sold online had approximately doubled since 2015. “It’s increasing in every country,” Taweekan was quoted as saying in an August 2020 article in Aljazerra.
TRAFFIC in 2019 repeated research first done in 2016 and found the weekly average number of items for sale rose 46.3% in 2019. The authors commented that “the true scale of the current online trade may be considerably larger than observed.”
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.
Researchers Continue to Find IWT Online
Academic researchers and investigative journalists also have found ample evidence of online IWT.
For example, a 2021 academic study, Prevalence of illegal turtle trade on social media and implications for wildlife trade monitoring, concluded, “The high number of sellers offering potentially illegal and CITES-listed species suggests that the lower barrier to start an online business allows amateur sellers to participate in illegal trade.”
Chetah trafficking specialist and ACCO member Patricia Tricorache documented online advertisements involving 2,298 cheetahs suspected as wild-sourced from 2010-2019.
A journalistic investigation, by TechJournalist in July 2021, headlined Dodgy wood trafficking continues on Facebook, questioned Facebook’s AI-supported curation approach. The authors commented, “Yet, if our simple in-platform searches expose two dozen accounts offering questionably sourced timber, it raises questions if Facebook does enough and what may happen in closed groups and communication between private accounts.” Periodically, other also journalists easily find things for sale, such as protected birds in Bangladesh.
Two Clicks Away, a 2020 study by Peters’ group , the Alliance to Combat Crime Online (ACCO), focused on Facebook, concluded “that wildlife trafficking content for multiple endangered species appears to have increased since 2018, and that Facebook’s rules banning wildlife sales are sporadically enforced.”
Peters thinks legislation is necessary, but the Coalition NGOs are not currently allies in this US lobbying endeavor.
Shift by NGO Coalition Members?
There are signs. however, that some of the NGO members of the Coalition are growing supportive of more aggressive approaches that involve government regulation. Such moves are not supported by the Coalition’s corporate members.
The most notable shift has been IFAW’s support for the Digital Security Act in the European Union. Recently passed by Parliament (but with some other hurdles to go), the bill was praised as “much needed” by the IFAW in a Jan. 21 press release. “The DSA proposal defines clear responsibilities and accountability for providers of intermediary services, and in particular online platforms, such as social media and marketplaces, to ensure that ‘what is illegal offline is illegal online.“
The legislation “is a good step in the right direction,” the IFAW said, because ” it introduces new transparency requirements for companies.”
TRAFFIC and WWF in the EU were “not able to work on this topic at the moment due to a lack of human and financial resources,” according to an official source, “but we fully support IFAW’s actions as we share the same position.” Less specifically, Grein said, “Neither WWF nor TRAFFIC specifically lobbied for this to my knowledge, though through the Coalition we do support the need for increased action against illegal wildlife trade online and the transparent reporting of those activities.”
Peters and the ACCO alliance she leads praised the EU bill, but said it did not go far enough. “We are pleased to see the bill identify the illegal trade of animals within its definition of “illegal content,” according to a Jan. 23 statement. “We wish the bill would address more clearly a duty of care for platforms to restrict and remove illicit conduct, and that it would hold platforms liable for illicit content deemed to be distributed with the help of algorithmic amplification.”
“To put that in less legalese,” Peters explained, “I’m concerned this bill could let social media platforms off the hook for machine-learning tools that help connect criminals and buyers on an unprecedented scale. We’d like to see legal incentives for platforms to dial-back these algorithms.”
Coalition Members Not Lobbying for Liability Bill in US
Peters’ conviction that the online companies are doing too little to fight IWT led her and ACCO members to support legislation in the US to modify the legal immunity provided to online companies in Section 230 of the Communications Decency Act. They would like to see a “duty of care” requirement imposed so that the firms could lose their immunity from lawsuits unless they take reasonable steps to remove criminal activity, including wildlife crime, from their platforms.
Peters endorses more transparency as well as more legal liability. She said, “I think what we have now is very little transparency about what is going on inside these platforms and that is very unfair to the innocent creatures on the planet.”
The Coalition NGOs all have identified the lack of transparency as a problem, but mostly have steered clear of the liability legislation.
IFAW in its 2021 report concluded that “[p]latforms must become far more transparent and proactive in addressing the issue of wildlife trade.” The report was not more specific. A tweet by IFAW on Nov. 10, 2021, said: “Online marketplaces must put the burden on the seller to prove the legality of wildlife products and live animals for sale.”
IFAW’s Hofberg said, “There are talks of reform around online commerce in general and within that reform we want there to be explicit language around illegal wildlife trafficking and more or less putting the burden on the seller to prove that their products are above water.”
Asked for IFAW’s position on Section 230 reform, a spokesman said, “Section 230 reform is an issue much bigger than wildlife trafficking. It is a conversation that extends significantly beyond the remit and expertise of a conservation and animal welfare organization like ours. However, it is extremely important that wildlife trafficking should be clearly incorporated into any relative legislative reform related to online commerce and communications.”
Both the IFAW and WWF are supporters of other, less stringent, legislation such as the “Wildlife Conservation and Anti-Trafficking Act” (H.R. 6059) that would not reform Section 230. The bill would bolster other laws and establish a whistleblower program to provide financial incentives, plus crucial anonymity protections, for relators of wildlife crime.
TRAFFIC has said that it, too, is supportive of certain governmental action, though not directly affecting the online platforms,
In a report issued Dec. 2, 2021, TRAFFIC found 3,354 animals for sale in 44 Singapore-based Facebook groups from December 2018 to April 2019. TRAFFIC reported that online sellers “were unlicensed and therefore acting illegally.” Almost 99% of the wildlife found in the study were birds. TRAFFIC said the report “highlights the critical need for a compulsory wildlife-pet registration system to make buyers more accountable and deter unlicensed sellers operating online.”
TRAFFIC called on legislators to impose documentation requirements not just on traders but also owners of wildlife. “Implementing a system that requires owners to register wildlife pets will increase owner accountability and allow tracking of the bird trade from both the seller and consumer end of the trade chain,” said Serene Chng, a TRAFFIC program officer who co-authored the report.
Kanitha Krishnasamy, Director of TRAFFIC in Southeast Asia, wrote an op-ed praising passage in Malaysia of a bill with a clause that limits the promotion of wildlife for business purposes to a licensed dealer.
Transparency Prescribed
More transparency is frequently cited as the best way hold social media companies to account, not only concerning wildlife trafficking, but also for things such as political or health disinformation.
Frances Haugen, the former Facebook employee turned whistleblower, said, “A critical starting point for effective regulation is transparency: full access to data for research not directed by Facebook.” Her statement came Oct. 4, 2021, during testimony before a US Senate committee.
Transparency about content moderation is addressed in The Santa Clara Principles. Similarly, an Aspen Institute Commission recommended, “Congress should require all social media platforms to disclose information about their content moderation policies and practices….”
More transparency by the platforms “may sound like a feeble form of accountability,” wrote Evelyn Douek, a lecturer at Harvard University, in a 2020 article in the Harvard Law Review. “But it’s hard to overstate both how ineffective platforms are at enforcing their rules, and how little is known about what systems they have in place to do so.
Douek suggests requiring platforms to publish “content moderation plans,” disclose the resources employed to carry out the plans out and describe how they ensure the plans are operating as intended.
Reporting requirements are not just theoretical.
In India, monthly reporting by significant social media intermediaries (SSMI) is required under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (Rule 4(1)(d). The rules require disclosure of details on the complaints received by the intermediaries and of their actions in response.
The disclosures in Indian are far from perfect, according to a recent analysis by the Internet Freedom Foundation (IFF) which said the companies “are opaque about the process/algorithms followed by them for proactive takedown of content.” The group keeps track of positive developments, too, noting that Twitter has introduced 3 new initiatives, including redesigning labels for potentially misleading tweets.
The idea of requiring more transparency about content moderation is embodied in pending legislation in the US and the EU.
In the European Union, the Digital Security Act would require various reports by the platforms and provide for researcher access to platform data.
In the US, the proposed Platform Accountability and Transparency Act would compel the platforms to share data with outside researchers, under prescribed rules, and give the Federal Trade omission authority to collect information.
Looking to the future, Dourek wrote, “While there will never be agreement on what constitutes “good” content moderation, there is growing convergence around one thing: the status quo of private companies determining matters of such public significance without any form of accountability, transparency or meaningful public input is inadequate.”
