Geographic/Jurisdictional Indicators

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This section contains information relating to the following types of jurisdictions, predominantly those operating in one of the following capacities: 

Themis Source Countries

Source countries – Countries or regions that produce and export high levels of commodities, goods, and products with links to land conversion.

Themis Transit Countries

Transit countries – Countries or regions serving as intermediaries for the transit/transport of the products of land conversion or their associated illicit financial flows.

Themis Destination Countries

Destination countries – Countries or regions that purchase high levels of goods linked to land conversion.

 

Countries can operate in more than one capacity (e.g. as both source and transit countries).

This toolkit focuses on 34 countries across Southeast Asia and Pacific, Sub-Saharan Africa, and South and Central America, as three of the highest-risk and most forest-dense regions.

Close attention should be paid to the geographical source and destination of financial transactions, as well as the transit routes of any related physical products, which may indicate illicit activity (e.g. criminals may reroute illegally derived commodities through certain countries in an attempt to obscure their origins).

For more information on the financial crime risks typologies associated with particular commodities in specific countries, please see the Risk Assessment toolkit panel.

 
High-risk source countries for the products of land conversion by region

Transactions originating in the following source countries for the products of land conversion should be considered higher risk. However, please note that these are not intended to be exhaustive lists, and that not all transactions under each of these categories are necessarily linked to illicit activity.

South and Central America:

Show Table
Country Commodities
Argentina Hard and soft commodity production including soy, cattle (beef), palm oil, sugar, timber, and copper.
Bolivia Agricultural commodities (especially soy, cattle (beef and leather), and coffee) and gold.
Brazil Agricultural commodities including soy, cattle, coffee, sugarcane, and palm oil, illegal timber and illegal gold.
Chile Timber and related products, including those derived from pine and eucalyptus, and paper products.
Colombia Illegally mined minerals, illegally logged timber, and agricultural products.
Ecuador Oil exploration, palm oil, and timber, especially balsa.
French Guiana Illegally mined gold.
Guatemala Livestock and the products of commercial agriculture (especially rubber, coffee, and palm oil).
Guyana Minerals including gold, diamonds and bauxite.
Honduras Driven by subsistence agriculture, cattle farming, industrial agriculture, plantations, and illegal logging.
Mexico Gold and avocados.
Paraguay Agricultural products, particularly cattle and soy.
Panama Cattle, palm oil, minerals, and illegally logged timber.
Peru Illegally logged timber, coffee, oil and gas exploration and illegally mined gold.
Suriname Minerals.
Venezuela Minerals, agricultural products (especially cattle), and commercially logged timber.

Sub-Saharan Africa:

Show Table
Country Commodity
Cameroon The products of small and large scale agriculture, particularly rubber and palm oil, and timber from large-scale logging operations.
Central African Republic products of small-holder farming (especially cassava, oil palm, cocoa and maize), charcoal, large-scale agriculture (particularly rubber, soy and cocoa), timber and minerals.
Cote d’Ivoire Agricultural commodities, particularly rubber and cocoa.
Democratic Republic of Congo The agricultural products of small-holder farming (especially cassava, oil palm, cocoa and maize), charcoal, large-scale agriculture (particularly rubber, soy and cocoa), timber and minerals.
Equatorial Guinea Timber from illegal logging.
Gabon Timber from illegal logging and rubber.
Ghana Rubber, cocoa and minerals (particularly bauxite, iron and copper).
Kenya Agricultural products including cattle, maize, pulses, beans and vegetables (predominantly consumed domestically); export-oriented cash crops including tea, coffee and tobacco.
Liberia Agricultural products associated with informal shifting cultivation, timber, charcoal and minerals (predominantly from small-scale and artisanal mining).
Madagascar Coffee production, rare earth elements and marijuana.
Mozambique Timber from illegal logging and charcoal.
Nigeria Illegally logged timber, cocoa, and rubber.
Senegal Illegally logged rosewood.
Uganda Timber from illegal logging.
Republic of Congo Charcoal, fuelwood, minerals and timber from industrial logging.
Zambia Timber, cattle and soy.

Southeast Asia and Pacific:

Show Table
Country Commodity
Cambodia Illegally logged timber, rubber and cashews.
Indonesia Palm-oil and minerals such as laterite nickel ore.
Laos Agricultural products associated with ‘slash and burn’ practices and illegally logged timber.
Malaysia Commercially logged timber and palm oil.
Myanmar Timber and rare earth heavy metals.
Papua New Guinea Palm oil, copper and illegally logged timber.
Thailand Large-scale and small-scale agricultural products, especially palm oil and tea, and illegally logged timber.
The Philippines Illegally logged timber.
Vietnam Illegally logged timber and the products of commercial agriculture.

 

High-risk transit countries for the products of land conversion by region

Transit countries play a crucial role in the global trade of high-risk land conversion commodities. These countries, often strategically located, serve as key points in the supply chain for high-risk commodities such as timber, palm oil, soy, beef, and minerals. Their roles and advantages vary significantly, ranging from porous borders and weak enforcement to their importance as key processing hubs to logistics and financial centres, further export points, and key infrastructure providers.

While new routes for high-risk commodities (such as illegal gold or timber) are continuously being identified by law enforcement and regulatory authorities, several locations consistently emerge as critical transit hubs.

Transactions originating in the following transit countries for the products of land conversion should be considered higher risk, although these should not be considered exhaustive lists.

 

Asia and Middle East

Show Table
Country Commodity
India Illegal timber from Myanmar has often been exported via overland borders in India.
Hong Kong SAR

Hong Kong SAR is one of the world’s largest gold trading hubs.

In April 2024, Hong Kong SAR authorities made the city's largest ever gold smuggling bust, seizing 146kg of gold disguised as machinery parts that was intercepted en route to Japan.

Malaysia Malaysia is a a key transit hub for illegal Indonesian timber exports destined for China.
Thailand Illegal timber from Myanmar has often been exported via overland borders in Thailand.
Vietnam Vietnam plays a central role for the transit of timber illegally logged in Thailand, Laos and Cambodia, and destined for China.
United Arab Emirates Billions of dollars’ worth of gold is smuggled out of Africa every year through the United Arab Emirates, where it is a gateway to international markets.

South and Central America

Show Table
Country Commodity
Bolivia Bolivia is a key transit country for illegal gold originating in Peru.
Brazil

Illegal teak from Peru and West Africa may be imported into the EU via Brazil to give the impression of alternate legitimate origin.

Gold mined illegally in Venezuela has been reported to have been transported via Brazil to international markets.

Ecuador Ecuador is a key transit country for illegal gold originating in Peru.
Mexico The transit of illegal timber (rosewood) from Honduras has been observed, destined for Hong Kong SAR.
Paraguay Soy has been been smuggled from Argentina into Paraguay to avoid paying Argentina’s 30 percent export tariffs.

Europe

Show Table
Country Commodity
Croatia Some EU countries have used companies in low enforcement zones in Croatia to import illegally harvested timber from Myanmar into the EU.
Greece Some EU countries have used companies in low enforcement zones in Greece to illegally harvest timber from Myanmar into the EU.
Italy Some EU countries have used companies in low enforcement zones in Italy to import illegally harvested timber from Myanmar into the EU.
The Netherlands The Netherlands imports deforestation-risk commodities that are then transported for consumption in other EU states.

Sub-Saharan Africa

Show Table
Country Commodity
Cameroon

The transit of illegal timber from countries such as the Republic of Congo and the DRC has been observed. Illegal gold from the CAR has been observed transiting through Cameroon before being smuggled by air towards the UAE or China (using airlines or private jets).

Gambia Illegal rosewood exports originating from Senegal’s Casamance region are smuggled via Gambia before export to international markets.
Kenya Timber trade often flows from the forests of the eastern DRC to Kenya through the Busia Border post.
Mozambique A southern trade route involves timber from the Northern Province in Zambia crossing into the border of Mozambique for onward export to China.
Namibia Zambia exports timber mainly to the DRC and South Africa, in some cases routing via Namibia.
Nigeria Illegal timber from Cameroon is transported via Nigeria to international markets.
Tanzania Timber sourced from the eastern DRC forests often flows through Tanzania by road through the border crossing at Mutukula on the Ugandan border, and through Kigoma Port.
Uganda

Around 80% of illegal timber from the DRC is transported through Uganda to other markets in East Africa.Gold from South Sudan and the DRC is transported through Uganda, before onward export to international markets.

South Africa Durban in South Africa is a common trade route for Zambian timber and minerals such as copper from the DRC.

 

High-risk trade routes for the products of land conversion

The following trade routes (detailing source and destination countries for specific commodities) should be considered particularly high-risk, and have been compiled based on supply chain and geospatial data analysed by Trase. 

This is not intended to be an exhaustive list but instead an indicative sample that shows how companies can use such data and resources to map out risk exposure and compile relevant red flags to their business areas.

For those routes that involve overseas transit, special attention should be paid to those countries with sea access.

 

Show Trade Descriptions

Beef

Trade Description
The trade of beef from Brazil to China, Hong Kong SAR, Egypt, the US, Russia or the UK.
The trade of beef from Paraguay to Russia, Chile, Israel, Brazil, Taiwan or Vietnam.
The trade of beef from Colombia to Russia, Lebanon, Iraq, Jordan, Vietnam, Egypt or Hong Kong SAR.

Soy

Trade Description
The trade of soy from Brazil to China, Brazil, Thailand, the Netherlands, Singapore or Spain.
The trade of soy from Paraguay to Argentina, Russia, Chile, the Netherlands, Peru, India, Poland, the UK or Italy.
The trade of soy from Argentina to China, Vietnam, Indonesia, India, Spain, Italy, Algeria, Iran, Malaysia or Poland.
The trade of soy from Bolivia to Colombia, Peru, Ecuador or Chile.

Palm Oil

Trade Description
The trade of palm oil from Indonesia to China, India, Pakistan, Bangladesh, and the US.
The trade of palm oil from Colombia to the Netherlands, Brazil, Spain, Mexico, Germany or Chile.
The trade of palm kernel from Colombia to the Netherlands, Brazil, Argentina, Germany, Italy or Mexico.
The trade of palm kernel from Brazil to Argentina, the Netherlands, the United States, Paraguay, and Uruguay.
The trade of palm oil from Brazil to Colombia, Germany, the US, Mexico or the Netherlands.

Coffee

Trade Description
The trade of coffee from Colombia to the US, Japan, Germany, Canada, Belgium, South Korea, Italy, the UK or Spain.
The trade of coffee from Peru to the US, Germany, Belgium, Colombia, Sweden, Canada, Italy, the UK, the Netherlands or South Korea.
The trade of coffee from Brazil to the US, Germany, Italy, Japan, Belgium, Turkey, France, Canada, Spain or Sweden.

Cocoa

Trade Description
The trade of cocoa from Ecuador to the EU states, Malaysia, the US, Indonesia, Mexico or Canada.
The trade of cocoa from Peru to the Netherlands, the US, Indonesia, Mexico, Malaysia, Spain, Germany, Chile, Brazil or Argentina.
The trade of cocoa from Colombia to the EU, Mexico, Malaysia, the US, Argentina, Russia, Canada, Costa Rica or Trinidad and Tobago.
The trade of cocoa from Brazil to Argentina, the US, Chile or the Netherlands.

Wood Pulp

Trade Description
The trade of wood pulp from Colombia to Peru.
The trade of wood pulp from Argentina to Brazil, China or Singapore.
The trade of wood pulp from Indonesia to China, India, South Korea or Bangladesh.

Miscellaneous

Trade Description
The trade of rosewood sourced from Senegal through Gambia to Asia.
The trade of CITES Appendix II protected red sanders(red sandalwood) from India to China and Gulf States (export is restricted).
The trade of cocoa from Cote d’Ivoire to the Netherlands, the US, Belgium, Malaysia, Germany, France, the UK, Estonia or Indonesia.
The trade of cocoa from Ghana to the Netherlands, Malaysia, the US, Spain, Germany, Japan, Belgium, France or Turkey.

 

The following table provides a breakdown of certain trade routes, including transit countries and ports, as they relate to particular high-risk commodities.

This is not intended to be an exhaustive list but rather an indicative sample that demonstrates how companies can use such data and resources to map out risk exposure and identify relevant red flags within their business areas.

For more information on how certain commodities and proceeds of land conversion linked financial crime are laundered or transit through certain countries and key routes, please refer to the Risk Assessment panel of the toolkit.

High-risk destination countries for the products of land conversion by region

Transactions involving the following destination countries for the products of land conversion should be considered higher risk—although this is not intended to be an exhaustive list.

 

Europe

Show Details
Country Commodity
The Netherlands The Netherlands is Europe’s largest importer of deforestation linked products, including wood and wood-based products from China and Brazil, palm oil from Indonesia, and Brazilian beef and soy.
Belgium Belgium is exposed to land conversion risk through coffee, cocoa, tobacco, soy, cattle, and palm oil.
Denmark Denmark is a key importer of commodities linked to deforestation, conversion, and social exploitation.
Spain Spain is one of the largest importers by volume of deforestation-risk commodity imports.
Finland Finland is one of the largest importers by volume of deforestation-risk commodity imports.
France French imports include soy and beef from Brazil and Paraguay, and palm oil from Indonesia.
Germany Germany is one of the largest importers by volume of deforestation-risk commodity imports.
Poland Polish imports include soy from Paraguay, Argentina, and Brazil.
Russia Russian imports include beef and soy from Paraguay and Brazil, and palm oil from Indonesia.
Sweden Swedish imports include palm oil and wood pulp from Indonesia.
Turkey Turkish imports include palm oil and wood pulp from Indonesia, and beef and soy from Brazil.
Italy Italy is one of the largest importers by volume of deforestation-risk commodity imports.
The United Kingdom UK imports include Brazilian and Paraguayan beef and soy.

North America

Show Details
Country Commodity
The United States US imports include palm oil and wood pulp from Indonesia, Brazilian beef and soy, and Paraguayan beef and soy.
Canada Canadian imports include Brazilian beef and cocoa, and palm oil from Indonesia.

Asia

Show Details
Country Commodity
Bangladesh Imports include soy from Brazil, Argentina, and Paraguay, and palm oil and wood pulp from Indonesia.
China Imports include soy, wood pulp, beef, and sugarcane from Brazil, palm oil from Indonesia, and soy from Argentina.
Hong Kong SAR Imports include wood pulp from Indonesia, and beef, soy, and wood pulp from Brazil.
India India is a key importer of timber from Malaysia. Indian imports also include sugarcane from Brazil, and palm oil from Indonesia.
Japan Japan is one of the main destinations for timber and timber products in the Asia–Pacific and is, after China, the greatest consumer in the region. Japan relies heavily on log imports from Russia and from tropical countries such as Malaysia, Indonesia, and Papua New Guinea.
Pakistan Imports include beef from Brazil and Paraguay, and soy from Bolivia and Brazil.
South Korea Imports include beef and soy from Brazil, and palm oil and wood pulp from Indonesia.
Taiwan Taiwan is a key destination for Indonesian plywood. Other imports include beef and soy from Paraguay and Brazil.

Middle East and North Africa region (MENA)

Show Details
Country Commodity
Lebanon Imports include beef from Paraguay and Brazil.
Jordan Imports include beef from Brazil and palm oil from Indonesia.
Israel Imports include beef from Brazil and Paraguay, palm oil from Indonesia, and soy from Brazil, Paraguay, and Argentina.
The United Arab Emirates Imports include beef from Brazil, palm oil from Indonesia, and beef and soy from Paraguay. The UAE is also a key importer of gold.
Saudi Arabia Imports include beef from Brazil, and palm oil from Indonesia.
Yemen Imports include palm oil from Indonesia, soy from Paraguay and Brazil, and cocoa from Cote d'Ivoire.
Algeria Imports include beef and soy from Brazil, and Indonesian palm oil.
Egypt Imports Imports beef from Brazil and Paraguay, soy from Paraguay and Argentina.

South America

Show Details
Country Commodity
Argentina Argentinian imports include soy from Paraguay and Bolivia.
Chile Chilean imports include sugarcane from Brazil, and soy from Argentina and Paraguay.

Jurisdictional Red Flags

High-Risk Source Countries: Shipments or transactions from regions known for land conversion issues. Refer to the Risk Assessment panel in the toolkit for details.

Politically Exposed Persons (PEPs): Transactions involving PEPs from higher-risk areas are a red flag. Check the Risk Assessment panel for specifics.

Offshore and Higher-Risk Jurisdictions: Be cautious of intermediaries or shell companies based in these locations. Consult the toolkit for more information.

Low Penalty Regions: Transactions from countries with minimal penalties for environmental crimes warrant extra scrutiny.

Conflict Zones Rich in Resources: Watch for shipments from conflict-prone areas abundant in resources like minerals and timber.

Drug Cartel Presence: Watch for transactions from resource-rich countries where drug cartels are active or where there has been a recent crackdown on drug crimes, leading to diversification into natural commodities.

Increased Local Crime: Transactions from countries with rising crime rates around forested or protected areas may indicate higher risks.

Money Laundering Risk Zones: Monitor transactions involving jurisdictions flagged for money laundering activities, such as those on the FATF Black or Grey Lists.

 

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