Combating Wildlife Trafficking: Opportunities Exist to Improve the Use of Financial Rewards

Wildlife trafficking—the poaching and illegal trade of plants, fish, and wildlife—is a multibillion-dollar, global criminal activity that imperils thousands of species. FWS and NOAA enforce laws prohibiting wildlife trafficking that authorize the agencies to pay financial rewards for information about such illegal activities.

GAO was asked to review FWS's and NOAA's use of financial rewards to combat wildlife trafficking. This report examines (1) laws that authorize FWS and NOAA to pay rewards for information on wildlife trafficking and the extent to which the agencies paid such rewards from fiscal years 2007 through 2017, (2) the agencies' reward policies, (3) information available to the public on rewards, and (4) the extent to which the agencies reviewed the effectiveness of their use of rewards.

GAO reviewed laws, examined FWS and NOAA policies and public communications on rewards, analyzed agency reward data for fiscal years 2007 through 2017 and assessed their reliability, interviewed FWS and NOAA officials, and compared agency policies and public communications on rewards to federal internal control standards.

Multiple laws—such as the Endangered Species Act and Lacey Act—authorize the Departments of the Interior's U.S. Fish and Wildlife Service (FWS) and Commerce's National Oceanic and Atmospheric Administration (NOAA) to pay rewards for information on wildlife trafficking. FWS and NOAA reported paying few rewards from fiscal years 2007 through 2017. Specifically, the agencies collectively reported paying 27 rewards, totaling $205,500. Agency officials said that the information was complete to the best of their knowledge but could not sufficiently assure that this information represented all of their reward payments.

FWS and NOAA have reward policies that outline the general process for preparing reward proposals, but FWS's policy does not specify factors for its agents to consider when developing proposed reward amounts. Some FWS agents GAO interviewed said that in developing proposals, they did not know whether their proposed reward amounts were enough, too little, or too much. By augmenting its policy to specify factors for agents to consider, FWS can better ensure that its agents have the necessary quality information to prepare proposed reward amounts, consistent with federal internal control standards.

FWS and NOAA communicate little information to the public on rewards. For example, most agency websites did not indicate that providing information on wildlife trafficking could qualify for a reward. This is inconsistent with federal standards that call for management to communicate quality information so that external parties can help achieve agency objectives. FWS and NOAA officials said they have not communicated general reward information because of workload concerns, but they said it may be reasonable to provide more information in some instances. By developing plans to communicate more reward information to the public, the agencies can improve their chances of obtaining information on wildlife trafficking that they otherwise might not receive.

FWS and NOAA have not reviewed the effectiveness of their use of rewards. The agencies have not done so because using rewards has generally not been a priority. FWS and NOAA officials agreed that such a review would be worthwhile but provided no plans for doing so. By reviewing the effectiveness of their use of rewards, FWS and NOAA can identify opportunities to improve the usefulness of rewards as a tool for combating wildlife trafficking.

GAO is making seven recommendations, including that FWS and NOAA track reward information, FWS augment its reward policy to specify factors for agents to consider when developing proposed reward amounts, FWS and NOAA develop plans to communicate more reward information to the public, and FWS and NOAA review the effectiveness of their reward use. Both agencies concurred with these recommendations.

According to the Department of State, wildlife trafficking—the poaching  and illegal trade of plants, fish, and wildlife—is a growing, multibillion- dollar, transnational criminal activity that imperils the continued viability of  thousands of plant and animal species worldwide, threatens global  security, and harms legitimate businesses. Estimates place wildlife  trafficking among the top-ranked illicit types of trade alongside trafficking  in drugs, weapons, and humans; in 2016, a United Nations report  estimated the illegal trade in wildlife to be worth from $7 billion to $23  billion annually. The United States is one of the world’s largest trafficking  markets and is increasingly becoming a source for illegal wildlife and  wildlife products, according to a Department of the Interior document. It  also serves as a transit point for wildlife that are illegally trafficked from  their source countries to other countries for sale.

Wildlife trafficking undermines conservation efforts and continues to push  some protected and endangered species to the brink of extinction,  according to Department of State documents. As we have previously  found, the capture and slaughter of animals are devastating wild  populations of elephants, rhinoceroses, tigers, pangolins, turtles, exotic  birds, and many other species. Moreover, wildlife trafficking threatens  global security by fueling corruption and violence and destabilizing  communities that depend on wildlife for biodiversity and ecotourism  revenues. Wildlife trafficking can also have adverse economic impacts.  For example, the trafficking of illegally harvested timber can harm  legitimate businesses by causing products made with legally harvested  timber to be less competitive with similar products made using illegally  harvested timber.

In recent years, the federal government has emphasized strengthening  law enforcement efforts to combat the escalating scope and scale of  wildlife trafficking. For example, in 2014, the White House released a  national strategy for combating wildlife trafficking that identified  strengthening enforcement—including federal interdiction and  investigative efforts—as one of three strategic priorities for the United  States. In addition, in 2017, an executive order made it executive branch  policy to strengthen enforcement of federal law to thwart the illegal  smuggling and trafficking of wildlife, among other things.

Paying rewards to people who provide critical information about illegal  trafficking activities that leads to results, such as fines or criminal  convictions, is one of many tools that law enforcement agents can use to  help them investigate and enforce wildlife trafficking laws. Certain laws that prohibit wildlife trafficking authorize federal agencies to pay financial  rewards to people who provide information on such illegal activities. For  example, the Endangered Species Act and the Lacey Act authorize the  Secretaries of Commerce and the Interior to pay financial rewards to  people who provide information that leads to arrests, criminal convictions,  civil penalties, or property forfeitures for violations of those laws. The law  enforcement offices for the Department of the Interior’s U.S. Fish and  Wildlife Service (FWS) and the Department of Commerce’s National  Oceanic and Atmospheric Administration (NOAA) are responsible for  enforcing certain federal laws prohibiting wildlife trafficking. Specifically,  FWS generally enforces federal laws that prohibit trafficking of terrestrial  wildlife, freshwater fish and other species, and birds, and NOAA generally  enforces federal laws that prohibit trafficking of marine wildlife and  anadromous fish.

You asked us to review FWS’s and NOAA’s use of financial rewards to  combat wildlife trafficking. This report examines (1) laws that authorize  FWS and NOAA to pay financial rewards for information on wildlife  trafficking and the extent to which these agencies paid such rewards from  fiscal years 2007 through 2017, (2) the agencies’ policies on financial  rewards, (3) information available to the public on financial rewards, and  (4) the extent to which the agencies reviewed the effectiveness of their  use of financial rewards in combating wildlife trafficking.

To identify laws that authorize FWS and NOAA to pay financial rewards  for information on wildlife trafficking, we asked FWS and NOAA attorneys  to compile a list of laws each of their agencies implements or enforces that prohibit wildlife trafficking and authorize the agency to pay rewards  for providing information about wildlife trafficking. We then compared the  list provided to the results of our search of the United States Code for  such laws. To identify the extent to which FWS and NOAA have paid  financial rewards for information on wildlife trafficking, we analyzed FWS  and NOAA data on financial rewards the agencies reported paying from  fiscal years 2007 through 2017. We took steps to assess the reliability of  these data, such as interviewing agency officials knowledgeable about  the data and comparing the data to case records. Specifically, FWS and  NOAA officials said they track all expenditures, including reward  payments, in their financial databases, but they are not able to readily  identify reward payments because their financial systems do not include a  unique identifier for such payments and their reward information is  located in multiple databases and formats. As a result, FWS and NOAA  officials said they identified the rewards they reported to us by manually  reviewing their financial and law enforcement records, and officials said  the information was complete to the best of their knowledge. Based on  these steps, we found the data the agencies provided to be sufficiently  reliable for reporting information on the rewards the agencies reported  paying. However, as we discuss in the report, FWS and NOAA officials  could not provide sufficient assurance that the data included all the  financial rewards they had paid from fiscal years 2007 through 2017. To  obtain additional detail about cases where financial rewards were paid,  we reviewed a nongeneralizable sample of 10 wildlife trafficking cases.  We selected these cases based on several factors, including amount of  the reward payment. While the findings from our review cannot be  generalized to cases we did not select and review, they illustrate how  FWS and NOAA have used financial rewards in wildlife trafficking cases.

To evaluate FWS and NOAA policies on financial rewards, information  available to the public, and the extent to which FWS and NOAA reviewed  the effectiveness of their use of financial rewards in combating wildlife  trafficking, we reviewed relevant agency policies, publications, websites,  and examples of public communications on rewards for specific cases.  We also interviewed agency officials and requested any reviews the  agencies conducted regarding their use of financial rewards. We  compared available FWS and NOAA policies, public communications,  and reviews on their use of financial rewards with federal internal control  standards.

Additionally, for all four objectives, we interviewed a nongeneralizable  sample of 20 stakeholders whom we selected using factors such as the  individuals’ experience investigating wildlife trafficking cases or their  expertise in the use of financial rewards as a law enforcement tool. Our  sample included

FWS and NOAA law enforcement agents,  federal officials responsible for programs that use financial rewards to  combat illegal activities in contexts outside of wildlife trafficking, academics with expertise in the use of financial rewards as a law members of the federal Advisory Council on Wildlife Trafficking, and  representatives of nongovernmental organizations that investigate  wildlife trafficking.

Views from these stakeholders cannot be generalized to those whom we  did not select and interview. Appendix I presents a more detailed  description of our objectives, scope, and methodology.

We conducted this performance audit from February 2017 to April 2018 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

As reported by the United Nations, the International Criminal Police  Organization, and other organizations, wildlife trafficking networks span  the globe. These organizations have attempted to measure the value of  illegally traded wildlife, but available estimates are subject to uncertainty.  In 2016, for example, the United Nations Environment Programme  (UNEP) reported that various sources estimated the global scale of illegal  wildlife trade to be from $7 billion to $23 billion annually. UNEP also  estimated that the scale of wildlife crime has increased in recent years in  part based on a rise in environmental crime.

U.S. trade in wildlife and related products includes a variety of species,  such as live reptiles, birds, and mammals, as well as elephant ivory,  according to law enforcement reports and government and  nongovernmental officials. FWS and NOAA data on wildlife products  seized at U.S. ports provide examples of the diversity of illegally traded  plants, fish, and wildlife imported into or exported from the United States.  For example, from 2007 to 2016, the top 10 plant, fish, and wildlife  shipments seized nationally by FWS were coral, crocodiles, conchs, deer,  pythons, sea turtles, mollusks, ginseng, clams, and seahorses. During  that time, FWS reported that more than one-third of the wildlife shipments  it seized were confiscated while being imported from or exported to  Mexico (14 percent), China (13 percent), or Canada (9 percent).

FWS and NOAA law enforcement offices are responsible for enforcing  certain laws and treaties prohibiting wildlife trafficking.

FWS Office of Law Enforcement. This office enforces certain U.S.  laws and regulations as well as treaties prohibiting the trafficking of  terrestrial wildlife, freshwater species, and birds. Among other  things, the office aims to prevent the unlawful import, export, and  interstate commerce of foreign fish and wildlife, as well as to protect  U.S. plants, fish, and wildlife from unlawful exploitation. As of fiscal  year 2016, the office had a budget of $74.7 million and employed 205  special agents to investigate wildlife crime, including international and  domestic wildlife trafficking rings. Most of these special agents  report to one of eight regional offices, which receive national  oversight, support, training, and policy guidance from the FWS Office  of Law Enforcement headquarters. The office’s headquarters houses  a special investigative unit focused on conducting complex, large- scale criminal investigations of wildlife traffickers. In addition, the FWS  Office of Law Enforcement has deployed special agents to serve as  international attachés at seven U.S. embassies. These attachés  provide countertrafficking expertise to embassy staff, work with host  government officials to build law enforcement capacity, and contribute  directly to casework or criminal investigations of wildlife traffickers.

According to FWS data, the FWS Office of Law Enforcement opened  more than 7,000 investigations on wildlife trafficking and other illegal  activities in fiscal year 2016, including nearly 5,000 cases involving  Endangered Species Act violations and nearly 1,500 cases involving  Lacey Act violations. FWS Office of Law Enforcement investigations  have disrupted wildlife trafficking operations. For example, Operation  Crash—an ongoing rhino horn and elephant ivory-trafficking  investigation launched in 2011—has led to over 30 convictions and  more than $2 million in fines.

NOAA Office of Law Enforcement. This office enforces certain U.S.  laws and regulations as well as treaties prohibiting the trafficking of  marine wildlife, including fish, as well as anadromous fish. Among  other things, the office aims to prevent the illegal, unregulated, and  unreported harvesting and trade of fish as well as the trafficking of  protected marine wildlife. As of fiscal year 2016, the office had a  budget of $68.6 million and employed 77 special agents to investigate  wildlife crimes within its jurisdiction. These agents report to one of  five regional offices, and those offices receive national oversight,  support, and policy guidance from the NOAA Office of Law  Enforcement headquarters.

According to NOAA data, the NOAA Office of Law Enforcement  initiated more than 5,000 investigations in fiscal year 2016. About half  of those investigations involved violations of the Magnuson-Stevens  Fishery Conservation and Management Act, as amended, and some  of the 5,000 investigations involved violations of the Endangered  Species Act or the Lacey Act. NOAA Office of Law Enforcement  investigations have disrupted wildlife trafficking operations. For  example, in fiscal year 2016, a NOAA Office of Law Enforcement  investigation led to the conviction of a company and five individuals  for illegally trafficking whale bone carvings, walrus ivory carvings,  black coral carvings, and other products derived from protected  species into the United States.

The FWS and NOAA law enforcement offices collaborate with other  government agencies and organizations to combat wildlife trafficking.  Both agencies work with other federal, state, and tribal law enforcement  officers as well as their international counterparts as needed during  wildlife trafficking investigations. For example, FWS and NOAA work with  U.S. Customs and Border Protection, U.S. Immigration and Customs  Enforcement, and the U.S. Department of Agriculture to maintain import  and export controls and interdict smuggled wildlife and related products at  U.S. ports of entry. In addition, FWS and NOAA collaborate with  Department of Justice prosecutors on criminal cases that result from  agency investigations.

Both agencies also collaborate with nongovernmental organizations to  combat wildlife trafficking. For example, FWS and NOAA officials said  that nongovernmental organizations have, in some cases, offered  financial rewards (in addition to rewards offered by FWS and NOAA) for  information on a wildlife crime. In addition, some nongovernmental  organizations proactively provide information to FWS and NOAA on  wildlife trafficking activities in the United States or foreign countries that  violate U.S. laws. For example, in 2017, a nongovernmental  organization created a website to collect tips on wildlife crime and to  connect the sources of those tips with relevant U.S. authorities for  potential financial rewards.

FWS may pay financial rewards from moneys in two accounts.

Law Enforcement Reward Account. FWS may pay rewards under  the Endangered Species Act, the Lacey Act, and the Rhinoceros and  Tiger Conservation Act from moneys in the agency’s Law  Enforcement Reward Account. The moneys in this account come from  fines, penalties, and proceeds from forfeited property for violations of  these three laws. According to FWS officials, these moneys are  available until expended. These moneys can be used to (1) pay  financial rewards to those who provide information that leads to an  arrest, criminal conviction, civil penalty assessment, or forfeiture of  property for any violation of the Endangered Species Act, the Lacey  Act, or the Rhinoceros and Tiger Conservation Act or (2) provide  temporary care for plants, fish, or wildlife that are the subject of a civil  or criminal proceeding under the Endangered Species Act, Lacey Act,  or the Rhinoceros and Tiger Conservation Act. As of the beginning  of fiscal year 2017, the balance of the Law Enforcement Reward  Account was about $7 million.

Law Enforcement Special Funds Account. FWS may also pay  rewards from moneys in its law enforcement office’s Special Funds  Account. The moneys in this account come from an annual line item  appropriation and are available until expended. Since fiscal year  1988, this appropriation has provided FWS up to $400,000 each year  to pay for information, rewards, or evidence concerning violations of  laws FWS administers, as well as miscellaneous and emergency  expenses of enforcement activity that the Secretary of the Interior  authorized or approved.

NOAA generally pays rewards from moneys available in the Fisheries  Enforcement Asset Forfeiture Fund. The moneys in this account come  from fines, penalties, and proceeds from forfeited property for violations of  marine resource laws that NOAA enforces, including the Magnuson- Stevens Fishery Conservation and Management Act, the Endangered  Species Act, and the Lacey Act. According to NOAA officials, moneys are  available until expended and can be used to pay certain enforcement- related expenses, including travel expenses, equipment purchases, and  the payment of financial rewards. As of the beginning of fiscal year 2017,  the Fisheries Enforcement Asset Forfeiture Fund had a balance of about  $18 million.

Academic literature on the use of financial rewards to combat illegal  activities and stakeholders we interviewed identified several advantages  and disadvantages of using financial rewards to obtain information on  wildlife trafficking. Potential advantages of using financial rewards include  the following:

Providing incentives. The potential for a financial reward can  motivate people with information to come forward when they  otherwise might not do so.

Increasing public awareness. Financial rewards may bring greater  public attention to the problem of wildlife trafficking, including federal  efforts to combat wildlife trafficking.

Saving resources. Using financial rewards may save agency  resources by enabling agents to get information sooner and at a lower  cost than they could have through their own efforts.

Potential disadvantages of using financial rewards include the following:

Eliciting false or unproductive leads. Financial rewards may  generate false or unproductive leads.

Affecting witness credibility. Financial rewards may lead to a  source’s credibility being challenged at trial by defense attorneys  since sources receive compensation for the information they provide.

Consuming resources. The potential for a financial reward may  create a flood of tips that take agency time and resources to follow up  on or corroborate.

Outside of wildlife trafficking, multiple federal agencies and federal courts  are authorized to pay financial rewards for information on illegal activities  under certain circumstances. For example, U.S. Customs and Border  Protection—which controls, regulates, and facilitates the import and  export of goods through U.S. ports of entry—is authorized, under certain  circumstances, to pay rewards for original information about violations of  any laws that it enforces. The Department of State may also pay  rewards under certain circumstances, including for information leading to  the disruption of financial mechanisms of a transnational criminal group.  Similarly, the U.S. Securities and Exchange Commission (SEC) and  Internal Revenue Service (IRS) may pay rewards for information about  violations of federal securities laws and the underpayment of taxes,  respectively, if certain conditions are met. Federal judges may award money to persons who give information leading to convictions for violating  treaties, laws, and regulations that prohibit certain pollution from ships,  including oil and garbage discharges.

Multiple Laws Authorize FWS and NOAA to Pay Rewards for Wildlife Trafficking Information, but the Agencies Reported Paying Few Rewards from Fiscal Years 2007 through 2017

FWS and NOAA officials identified multiple laws, such as the Endangered  Species Act and the Lacey Act, that authorize the payment of financial  rewards to people who provide information on wildlife trafficking. FWS  and NOAA reported paying few financial rewards under these laws from  fiscal years 2007 through 2017. However, agency officials could not  provide sufficient assurance that the reward information they provided to  us represented all of their reward payments for this period.

The Endangered Species Act, Lacey Act, and Other Laws Authorize the Payment of Financial Rewards

FWS and NOAA officials identified over 10 laws prohibiting wildlife  trafficking—including the Endangered Species Act, Lacey Act, and Bald  and Golden Eagle Protection Act—that specifically authorize the  payment of financial rewards in certain circumstances to people who  provide information on violations of the law (see app. II for a complete list  of the laws). These laws provide discretion to the agencies to choose  whether to pay rewards but have varying requirements for who is eligible  to receive a reward and the payment amounts. For example, the Bald  and Golden Eagle Protection Act caps rewards at $2,500 for information  that leads to a conviction. In contrast, the Endangered Species Act does  not cap reward amounts and authorizes rewards for information that leads  to a conviction as well as to an arrest, civil penalty, or forfeiture of  property. Table 1 identifies the laws that FWS and NOAA officials  indicated they have used to pay financial rewards for information on  wildlife trafficking from fiscal years 2007 through 2017, along with  information on these laws’ requirements for payment of rewards.

FWS and NOAA Reported Paying Few Rewards for Information on Wildlife Trafficking but Could Not Assure the Completeness of the Information

FWS and NOAA reported paying few financial rewards for information on  wildlife trafficking from fiscal years 2007 through 2017, but agency  officials could not provide sufficient assurance that this information was  complete. Officials from both agencies said that their agencies have not  prioritized the use of rewards, and they believed that the reward  information they identified—such as the number, dollar amount, and year  that rewards were paid—appropriately captured the few reward payments  they made during this time frame. Based on the agencies’ reviews of their  records, FWS reported paying 25 rewards for a total of $184,500 from  fiscal years 2007 through 2017, and NOAA reported paying 2 rewards for  a total of $21,000 during that same period (see table 2). See appendix III  for additional details on the cases where financial rewards were paid.

FWS reported paying rewards in trafficking cases involving a variety of  wildlife species, such as eagles, bears, reptiles, and mollusks, across the  11-year period. FWS officials said they generally paid rewards to thank  sources who proactively provided information. For example, based on our  review of a reward case, FWS paid a reward in 2010 because the source  provided information that was crucial in uncovering an attempt to illegally  traffic leopards into the United States from South Africa. FWS would not  have known about this illegal activity if the source had not come forward  with the information. In several cases we reviewed, FWS officials said  that the sources did not know about the possibility of receiving a reward  when they contacted the agency with information.

The two rewards NOAA reported paying from fiscal years 2007 through  2017 involved the illegal trafficking of sea scallops and a green sea turtle.  NOAA officials said that in both cases they paid a reward to thank the  source who proactively provided information to law enforcement agents.  For example, the agent who investigated the sea scallop case reported  requesting the reward because the information the source proactively  provided was timely, credible, and led to the criminal conviction of several  individuals.

FWS and NOAA officials could not provide sufficient assurance that the  reward information they reported to us represented all of the rewards their  agencies had paid from fiscal years 2007 through 2017, but they said the  information was complete to the best of their knowledge. Specifically,  FWS and NOAA officials said they track all their expenditures, including  reward payments, in their financial databases. However, they are not able  to readily identify reward payments because their financial systems do not  include a unique identifier for such payments and their reward information  is located in multiple databases and formats. As a result, FWS and NOAA  officials said they identified the rewards they reported to us by manually  reviewing their financial and law enforcement records. In particular, FWS  officials said they reviewed their paper records to identify instances when  the agency paid rewards and then retrieved additional information from  their financial and law enforcement databases, such as final payment  amounts. NOAA officials said they identified instances when the agency  paid rewards by using a combination of paper and electronic records  located at NOAA’s headquarters office. NOAA officials also contacted  their regions to obtain additional information located at the regional offices  to confirm information about the rewards NOAA had paid.

Seventeen stakeholders we interviewed who had experience investigating  wildlife trafficking or expertise in using financial rewards as a law   enforcement tool said that it would be useful for FWS and NOAA to  maintain comprehensive information on the rewards they paid. For  example, two stakeholders said that maintaining comprehensive  information and making that information available to law enforcement  agents could motivate agents to make greater use of rewards as a law  enforcement tool. Two other stakeholders said that maintaining  information on and monitoring reward use would allow the agencies to  make ongoing adjustments, such as adjusting payment amounts, to make  the most effective use of rewards in combating wildlife trafficking.

Federal internal control standards say that management should clearly  document internal control and all transactions and other significant events  in a manner that allows the documentation to be readily available for  examination. Control activities can be implemented in either an  automated or a manual manner, but automated control activities tend to  be more reliable because they are less susceptible to human error and  are typically more efficient.

FWS and NOAA officials agreed that maintaining reward information so  that complete information is easily retrievable may be beneficial. FWS  officials said having clearly documented and readily available reward  information could improve how they manage rewards and enable them to  monitor and examine their use of rewards more holistically. The officials  said they may analyze options for creating a single repository for reward  information but did not commit to doing so. They said that creating a  single repository for reward information may involve some drawbacks,  such as duplicating some data entry in separate databases. Similarly,  NOAA officials said having clearly documented and readily available  reward information would provide agency management with easier and  more consistent access to that information. As a result, they said that they  are exploring modifications to their financial and law enforcement  databases to better identify and track rewards. For example, NOAA  officials said they may be able to create a unique identifier to flag  payments that are for rewards in their financial system to enable them to  identify payment amounts more easily. NOAA officials did not provide a  time frame for completing modifications to their financial system. By  tracking reward information so that it is clearly documented and readily  available for examination, FWS and NOAA can better ensure that they have complete information on the rewards they have paid to help manage  their use of rewards as a law enforcement tool.

FWS and NOAA Have Policies for Administering Reward Payments, but FWS’s Policy Does Not Specify Factors to Consider When Developing Reward Amounts

FWS and NOAA have policies to guide their law enforcement agents on  the process for preparing and submitting a request to pay a financial  reward. Specifically, both agencies’ policies call for agents to include a  description of the case, the nature of the information that the source  provided, a justification for providing a reward, and an explanation of how  a proposed reward amount was developed. These policies also outline  the general review and approval process, how payments are to be made  upon approval of a request, and eligibility criteria to receive a reward. For  example, FWS and NOAA policies prohibit paying rewards to foreign  government officials as well as paying rewards to any person whose  receipt of a reward would create a conflict of interest or the appearance of  impropriety.

NOAA’s policy explicitly states that the NOAA Office of Law Enforcement  is to use statutorily authorized rewards as a tool to obtain information  from the public on resource violations and that rewards can help promote  compliance with marine resource laws. NOAA’s policy suggests that  agents consider advertising reward offers to assist investigations,  encourages press releases, and describes the process agents should  follow to do so. Moreover, NOAA’s policy specifies factors that agents  might include in their reward requests to support the proposed reward,  such as (1) the benefit to the marine resources that was furthered by the  information provided; (2) the risk, if any, the individual took in collecting  and providing the information; (3) the probability that the investigation  would have been successfully concluded without the information  provided; and (4) the relationship between any fines or other collections  and the information provided.

FWS’s policy specifies that rewards may be provided in situations in  which an individual furnishes essential information leading to an arrest,  conviction, civil penalty, or forfeiture of property. However, it does not  discuss the usefulness of financial rewards as a law enforcement tool or  the types of circumstances when rewards should be used or advertised to  the public. Further, FWS’s policy does not communicate necessary  quality information internally that agents may need when deciding to  request the payment of rewards. In particular, it does not specify factors  for agents to consider when developing proposed reward amounts.  Instead, the policy leaves it to the discretion of field and regional agents  to develop proposed reward amounts within any limitations specified in  law. Some FWS agents we interviewed said that they developed  proposed reward amounts on a case-by-case basis and did not know  whether their proposed amounts were enough, too little, or too much. In  addition, some agents said that because FWS’s policy does not specify  factors for agents to consider, the reward approval process is subjective  and unclear and this has made it challenging for the agents to develop  proposed reward amounts. For example, one agent we interviewed said  he submitted a request to his supervisor to pay a $10,000 reward to a  source who provided information on a major wildlife trafficker. But, for  reasons unknown to the agent, his supervisor reduced the amount to  $1,000. FWS headquarters officials said field agents submit reward  requests to headquarters for approval, and these officials were not aware  of instances of proposed reward amounts being changed or denied during  the review process.

Seven of the 20 stakeholders we interviewed suggested that FWS  augment its reward policy to specify factors for agents to consider when  developing proposed reward amounts. For example, helpful factors to  consider when developing a proposed reward amount may include (1) the  number of hours the source dedicated to the case, (2) the risk the source  took in providing the information, (3) the significance of the information  provided by the source, and (4) the amount of fines or other penalties  collected as a result of the information. Two stakeholders expressed  concern that some of FWS’s reward payments were insufficient,  especially when comparing the amount of time and effort or the risk a  source faced in providing the information. A couple of stakeholders also  said that without a policy that specifies factors for agents to consider,  reward amounts may be subjective and could vary depending on which  agent develops the reward proposal. Another stakeholder said that it was  important to specify factors for agents to consider when developing  proposed reward amounts so that the agency has a reasonable and  defensible basis for the reward amounts it pays across cases.

According to federal standards for internal control, management should  internally communicate the necessary quality information to achieve an  agency’s objectives. For example, management communicates quality  information down and across reporting lines to enable personnel to make  key decisions. FWS officials said they believe that their reward policy is  sound, indicating they believe that law enforcement agents have the  information they need to develop proposals for reward amounts in cases  where rewards are warranted. However, they also agreed that it may be  helpful to review their policy but did not commit to doing so. By  augmenting its policy to specify factors for agents to consider when  developing proposed reward amounts, FWS can better ensure that its  agents have the necessary quality information to prepare defensible  reward proposals.

FWS and NOAA Communicate Little Information to the Public on Financial Rewards

Based on our review of the agencies’ websites and other  communications, we found that FWS and NOAA communicate little  information to the public on financial rewards for reporting information on  wildlife trafficking, such as the potential availability of rewards and  eligibility criteria. Specifically, some FWS and NOAA law enforcement  websites provided information to the public on ways to report violations of  the laws that the agencies are responsible for enforcing, such as via tip  lines. Some of the websites also provided examples of the types of  information the public can report, such as photos or other documentation  of illegal activities. However, most of the agencies’ websites did not  indicate that providing information on illegal activities could result in a  reward. In contrast, the FWS Alaska regional office’s website provided  information on the potential availability of rewards and ways the public  may submit information for a potential reward. For example, this website  provided phone numbers and an e-mail address for the public to use  when submitting information. Figure 1 shows the information available on  FWS’s and NOAA’s national and regional websites relevant to reporting  violations of the laws the agencies enforce in general and on receiving  rewards in particular.

In addition, FWS and NOAA headquarters officials said their field agents  have used other means to communicate the potential availability of  rewards in specific cases when the agents had no other information that  could help solve those cases. For example, a FWS field official said that  the agency advertised a reward offer for information on a case of bald  eagle killings by distributing reward posters and posting news releases in  the vicinity where the killings occurred. Similarly, NOAA officials said they  have advertised reward offers through various means, including  circulating reward posters in specific geographic areas after an illegal  activity has occurred. Figure 2 shows a reward poster that NOAA  distributed in Guam in 2017 advertising a $1,000 reward for information  leading to the arrest and conviction of sea turtle poachers.

Instead of having a plan for communicating general information to the  public on rewards, FWS and NOAA grant discretion to their regional  offices and law enforcement agents to determine the type and level of  communication to provide, according to FWS and NOAA policies. FWS  officials explained that because they typically use financial rewards to  thank individuals who come forward on their own accord—rather than  using rewards to incentivize individuals with information to come  forward—they have not seen the need to communicate more information  to the public on the potential availability of rewards. NOAA officials said  they have targeted their communications on rewards by publicizing  reward offers for specific cases where they do not have leads. They  added that they want to receive quality information and already receive a  substantial amount of information from sources who reach out to them  proactively, so NOAA has not seen the need to communicate more  information to the public on the potential availability of rewards.

Sixteen of the 20 stakeholders we interviewed said that it would be useful  for FWS and NOAA to advertise the potential availability of financial  rewards. Several stakeholders said that if the public does not know about  the possibility for rewards, then some people with information may not be  incentivized to come forward. Two stakeholders added that agencies  should carefully consider how and which reward information to  communicate to the public so that people who are most likely to have  information on illegal wildlife trafficking learn about the potential for  rewards. For example, one stakeholder suggested advertising rewards at  ports where international shipments are offloaded or placing  advertisements at wildlife trafficking nodes, such as entrances to African  wildlife refuges. This stakeholder suggested advertising rewards along  with wildlife trafficking awareness-raising posters that nongovernment  organizations place in some airports.

In addition, 14 stakeholders suggested that it would be useful for FWS  and NOAA to provide information to the public on the process for  submitting information to potentially receive rewards. Several other  stakeholders said that it is important for the public to understand whether  they may be eligible for a reward, how to submit information, and whether  or to what extent their confidentiality will be protected. Another  stakeholder provided examples of how other agencies provide information  about their reward programs on their websites. SEC and IRS, for  instance, use their websites to communicate information to the public on  the process for reporting illegal activity for financial rewards. This  information includes the types of information to report, confidentiality  rules, eligibility criteria, and the process for submitting information to  obtain a reward. In addition, the Department of State posts instructions on  its websites on how to submit information on an illegal activity and  potentially receive a reward.

Federal internal control standards say that management should externally  communicate the necessary quality information to achieve an agency’s  objectives. For example, using appropriate methods to communicate,  management communicates quality information so that external parties,  such as the public, can help the agency achieve its objectives. This could  include communicating information to the public on the types of  information and eligibility requirements for potentially receiving rewards  for reporting information on wildlife trafficking.

FWS officials said that making more reward information available could  lead to a significant increase in the amount of information the agency  receives, which, in turn, could strain FWS’s resources in following up on  that information. However, FWS officials also agreed that it was  reasonable to consider making more reward information available to  relevant members of the public, particularly in targeted circumstances, but  did not commit to doing so. Similarly, NOAA officials said they had some  concerns about the additional resources it might take to investigate  potentially unreliable or false tips that may result if they make reward  information broadly available to the public, but they agreed that it would  be reasonable for the agency to consider doing so. NOAA officials also  said they may consider making more reward information publicly available  at the conclusion of our audit but provided no plans for doing so. By  determining the types of additional information to communicate to the  public on rewards—such as providing information on the agency’s  website on the potential availability of rewards—and then developing and  implementing plans to do so, FWS and NOAA can improve their chances  of obtaining information on wildlife trafficking activities that they otherwise  might not receive.

FWS and NOAA Have Not Reviewed the Effectiveness of Their Use of Financial Rewards

FWS and NOAA have not reviewed the effectiveness of their use of  financial rewards or considered whether any changes might improve the  usefulness of rewards as a tool for combating wildlife trafficking. FWS  officials said their agency has not reviewed or considered changes to its  use of rewards because the agency has not prioritized the use of  rewards. NOAA officials said their agency has not focused on using  rewards or identified the need to review its use of this tool, particularly in  light of other, higher mission priorities.

Nine of the 20 stakeholders we interviewed said that FWS and NOAA  should review the effectiveness of their use of rewards and consider  potential improvements. Several stakeholders said that it would be useful  for FWS and NOAA to compare their respective approaches to those of  federal agencies that use rewards in contexts outside of wildlife trafficking  to identify best practices or lessons learned that might be applicable in  the context of combating wildlife trafficking. For example, one stakeholder  said that SEC has an effective whistleblower program and may have  lessons learned that are relevant for FWS and NOAA to consider.  Another stakeholder we interviewed separately indicated that in 2010,  before SEC had a whistleblower program that publicized rewards and  provided detailed instructions on how members of the public could report  information on illegal activities, SEC received few tips. Once SEC  implemented a whistleblower program that publicized rewards and  provided detailed instructions on its public website, the agency’s use of  the program grew substantially, according to the stakeholder. Other  stakeholders said it would be useful for the agencies to consider potential  improvements to their use of rewards, such as making a standing reward  offer for information on wildlife trafficking targeted at high-priority  endangered species or particular criminal networks. Two of these  stakeholders said such an offer might improve FWS’s and NOAA’s use of  rewards by generating more tips than reward offers focused on individual  cases. At the same time, they said such an offer would likely filter out  some of the false or unproductive tips that the agencies might receive if  they made an untargeted standing reward offer.

Federal internal control standards state that management should design  control activities to achieve objectives and respond to risks by, for  example, conducting reviews at the functional or activity level by  comparing actual performance to planned or expected results and  analyzing significant differences. Further, under the standards,  management should periodically review policies, procedures, and related  control activities for continued relevance and effectiveness in achieving  an agency’s objectives or addressing related risks. FWS and NOAA  officials agreed that reviewing the effectiveness of their use of rewards  would be worthwhile. Specifically, FWS officials said that it would be  useful to compare their approach to those of other federal agencies that  use rewards in investigating crimes that involve interstate and foreign  smuggling of goods. Similarly, NOAA officials said that reviewing the  agency’s use of financial rewards would be worthwhile but cautioned that  such a review would need to be balanced against the agency’s  constrained resources and many mission requirements. FWS and NOAA  officials said they may consider conducting such a review at the  conclusion of our audit but provided no plans for doing so. By reviewing  the effectiveness of their use of rewards, FWS and NOAA can identify  opportunities to improve the usefulness of rewards as a tool for  combating wildlife trafficking.

Wildlife trafficking is a large and growing transnational criminal activity,  with global environmental, security, and economic consequences. The  federal government has emphasized strengthening law enforcement  efforts to combat wildlife trafficking, and using financial rewards to obtain  information on illegal activities is one tool that some federal agencies  have used. However, to date, FWS and NOAA have not prioritized the  use of rewards and were unable to provide sufficient assurance that the  27 rewards they paid during fiscal years 2007 through 2017 represented  all of the rewards they provided during that period. By tracking reward  information so that it is clearly documented and readily available for  examination, FWS and NOAA can better ensure that they have complete  information on the rewards they have paid to help manage their use of  rewards as a law enforcement tool.

Additionally, FWS and NOAA have policies outlining the processes their  law enforcement agents are to use in making reward payments, and  NOAA’s policy specifies factors for its agents to consider in developing  proposed reward amounts, such as the risk the individual took in  collecting the information. FWS’s policy does not specify such factors that  could inform agents in achieving the agency’s objectives, which is not  consistent with federal internal control standards. By augmenting its  policy to specify factors for its agents to consider when developing  proposed reward amounts, FWS can better ensure that its agents have  the necessary quality information to prepare defensible reward proposals.

Both agencies have also advertised the potential for rewards in specific  cases when agents had no other information, but FWS and NOAA have  otherwise communicated little information to the public on the potential  availability of rewards. If the public does not know about the possibility of  rewards, then some people with information may not be incentivized to  come forward. By determining the types of additional information to  communicate to the public on rewards—such as providing information on  the agency’s website about the potential availability of rewards—and then  developing and implementing plans to do so, FWS and NOAA can  improve their chances of obtaining information on wildlife trafficking  activities that they otherwise might not receive.

Finally, FWS and NOAA have not reviewed the effectiveness of their use  of financial rewards or considered whether any changes might improve  the usefulness of rewards as a law enforcement tool. By undertaking such  reviews, the agencies can identify opportunities to improve the usefulness  of rewards as a tool for combating wildlife trafficking.

We are making a total of seven recommendations, including four to FWS  and three to NOAA. Specifically:

The Assistant Director of the FWS Office of Law Enforcement should  track financial reward information so that it is clearly documented and  readily available for examination. (Recommendation 1)

The Director of the NOAA Office of Law Enforcement should track  financial reward information so that it is clearly documented and  readily available for examination. (Recommendation 2)

The Assistant Director of the FWS Office of Law Enforcement should  augment FWS’s financial reward policy to specify factors law  enforcement agents are to consider when developing proposed  reward amounts. (Recommendation 3)

The Assistant Director of the FWS Office of Law Enforcement should  determine the types of additional information to communicate to the  public on financial rewards and then develop and implement a plan for  communicating that information. (Recommendation 4)

The Director of the NOAA Office of Law Enforcement should  determine the types of additional information to communicate to the  public on financial rewards and then develop and implement a plan for  communicating that information. (Recommendation 5)

The Assistant Director of the FWS Office of Law Enforcement should  review the effectiveness of the agency’s use of financial rewards and  implement any changes that the agency determines would improve  the usefulness of financial rewards as a law enforcement tool.  (Recommendation 6)

The Director of the NOAA Office of Law Enforcement should review  the effectiveness of the agency’s use of financial rewards and  implement any changes that the agency determines would improve  the usefulness of financial rewards as a law enforcement tool.  (Recommendation 7)

We provided a draft of this report for review and comment to the  Departments of Commerce and the Interior. The departments transmitted  written comments, which are reproduced in appendixes IV and V of this  report. The Department of Commerce concurred with the three  recommendations directed to NOAA and stated that NOAA is developing  procedures to ensure that its rewards are closely tracked, clearly  documented, and better communicated. In written comments from NOAA,  NOAA stated the report fairly and thoroughly reviews NOAA’s use of  financial rewards. NOAA outlined the steps it plans to take in response to  our recommendations, including developing a procedure to track financial  reward information, reviewing information currently disseminated to the  public and evaluating whether additional information may be useful, and  reviewing the agency’s reward policy to determine whether changes are  needed to enhance reward effectiveness.

In its written comments, the Department of the Interior concurred with the  four recommendations directed to FWS. Interior stated that it appreciated  our review of the challenges faced by FWS’s Office of Law Enforcement  in combating wildlife trafficking and identifying areas where FWS and  NOAA can improve the use of financial rewards as a tool for combating  wildlife trafficking. Interior also provided technical comments, which we  incorporated as appropriate.

As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the appropriate  congressional committees, the Secretaries of Commerce and the Interior,  and other interested parties. In addition, the report will be available at no  charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-3841 or fennella@gao.gov. Contact points for our Offices  of Congressional Relations and of Public Affairs may be found on the last  page of this report. GAO staff who made major contributions to this report  are listed in appendix VI.

Appendix I: Objectives, Scope, and Methodology

The objectives of our review were to (1) identify laws that authorize the  U.S. Fish and Wildlife Service (FWS) and the National Oceanic and  Atmospheric Administration (NOAA) to pay financial rewards for  information on wildlife trafficking and the extent to which these agencies  paid such rewards from fiscal years 2007 through 2017, (2) evaluate  FWS’s and NOAA’s policies on financial rewards, (3) evaluate the  information available to the public on financial rewards, and (4) determine  the extent to which FWS and NOAA reviewed the effectiveness of their  use of financial rewards in combating wildlife trafficking.

To address these objectives, we reviewed academic literature on the use  of financial rewards to combat illegal activities and United Nations  Environment Programme reports on the scope and scale of wildlife  trafficking. We also interviewed officials from federal agencies that play a  role in combating wildlife trafficking or manage programs that pay  financial rewards for information on illegal activities. Specifically, we  interviewed officials from the Departments of Agriculture, Commerce,  Homeland Security, the Interior, Justice, and State, as well as officials  from the Internal Revenue Service, the U.S. Securities and Exchange  Commission, and the U.S. Agency for International Development. In  addition, we reviewed documentation that the Department of the Treasury  provided on its role in paying financial rewards. We did not compare  FWS’s and NOAA’s use of financial rewards in combating wildlife  trafficking to federal agencies’ use of financial rewards in other contexts  because the different contexts are not directly comparable. However, we  reviewed information on other federal agencies’ use of financial rewards  as examples of how financial rewards are used in contexts outside of  wildlife trafficking. In addition, we interviewed representatives of six  nongovernmental organizations that we selected based on those  organizations’ knowledge or experience in combating wildlife trafficking.

Specifically, we interviewed representatives from the Elephant Action  League, the Environmental Investigation Agency, the National  Association of Conservation Law Enforcement Chiefs, the National  Whistleblower Center, TRAFFIC, and the World Wildlife Fund.

To identify laws that authorize FWS and NOAA to pay financial rewards  for information on wildlife trafficking, we asked FWS and NOAA attorneys  to compile a list of laws that each of their agencies implements or  enforces that prohibit wildlife trafficking and authorize the agency to pay  rewards for providing information about trafficking. We then compared  that list to the results of our search of the United States Code for such  laws. We also reviewed FWS and NOAA documentation for accounts  where the fines, penalties, and proceeds from forfeited property that are  used to pay rewards are deposited as well as the accounts where  appropriations available to pay rewards were deposited. To identify the  extent to which FWS and NOAA have paid financial rewards for  information on wildlife trafficking, we analyzed FWS and NOAA data on  financial rewards the agencies reported paying from fiscal years 2007  through 2017. The data included information on, among other things,  the fiscal years in which rewards were paid,  laws under which rewards were paid,  types of wildlife involved in those cases,  the amounts of civil penalties or criminal fines imposed in those  cases,  the numbers of arrests and convictions as a result of those cases, and whether reward recipients were individuals or groups and U.S. or  foreign citizens.

To assess the reliability of the data FWS and NOAA provided on financial  rewards, we interviewed agency officials knowledgeable about the data  and compared the data to case records the agencies provided.

Specifically, FWS and NOAA officials said they track all expenditures,  including reward payments, in their financial databases, but they are not  able to readily identify reward payments because their financial systems  do not include a unique identifier for such payments and their reward  information is located in multiple databases and formats. As a result,  FWS and NOAA officials said they identified the rewards that they  reported to us by manually reviewing their financial and law enforcement  records, and officials said the information was complete to the best of  their knowledge. Based on these steps, we found the data that the  agencies provided to us to be sufficiently reliable for reporting information  on the rewards the agencies reported paying. However, as we discuss in  the report, FWS and NOAA officials could not provide sufficient  assurance that the data included all the financial rewards that they had  paid from fiscal years 2007 through 2017.

To obtain additional detail about cases where financial rewards were  paid, we reviewed a nongeneralizable sample of 10 wildlife trafficking  cases. We selected these cases based on  the agency that investigated the case (to include both FWS and  NOAA cases),  the amount of the reward paid in the case (to reflect both low and high  amounts),  the year in which the reward was paid (to include rewards paid more  recently), and  the type of wildlife trafficked in the case (to include both fish and  wildlife cases—there were no plant trafficking cases to select).

While the findings from our review cannot be generalized to cases we did  not select and review, they illustrate how FWS and NOAA have used  financial rewards in wildlife trafficking cases.

To evaluate FWS and NOAA policies on financial rewards, we reviewed  relevant FWS and NOAA policies and compared them to each other;  interviewed FWS and NOAA officials about those policies; and compared  the information in the policies with federal internal control standards on  information and communication. To evaluate information available to the  public on rewards, we reviewed relevant FWS and NOAA publications  and examples of communications to the public on the availability of  rewards in specific cases and interviewed FWS and NOAA officials. We  also reviewed information available on FWS’s and NOAA’s national and  regional websites as of December 2017 and January 2018, respectively,  relevant to reporting violations of the laws that the agencies enforce in  general and on receiving rewards in particular. We compared the  agencies’ public communications on rewards with federal internal control  standards on information and communication. To evaluate the extent to  which FWS and NOAA reviewed the effectiveness of their use of financial  rewards in combating wildlife trafficking, we interviewed FWS and NOAA  officials and requested any reviews the agencies had conducted  regarding their use of financial rewards to compare with federal internal  control standards on control activities. FWS and NOAA did not have any  such reviews to provide.

In addition, for all four objectives, we interviewed a nongeneralizable  sample of 20 stakeholders who had experience investigating wildlife  trafficking or expertise in the use of financial rewards as a law  enforcement tool. To select stakeholders to interview, we first identified a  list of stakeholders by reviewing (1) FWS and NOAA data on law  enforcement agents with at least 5 years of experience who had  investigated wildlife trafficking cases and used financial rewards, (2)  Department of Justice data on federal prosecutors who had prosecuted  wildlife trafficking cases since fiscal year 2014, (3) literature search  results identifying academics with expertise in the use of financial rewards  as a law enforcement tool and federal programs that use financial  rewards to combat illegal activities in contexts outside of wildlife  trafficking, (4) the biographies of members of the federal Advisory Council  on Wildlife Trafficking, and (5) recommendations from stakeholders we  interviewed. From this list, we then used a multistep process to select the  20 stakeholders to interview. To ensure coverage and a range of  perspectives, we selected stakeholders from the following groups:

FWS and NOAA law enforcement agents, including field and  federal prosecutors responsible for prosecuting wildlife trafficking  cases;  federal officials responsible for programs that use financial rewards to  combat illegal activities in contexts outside of wildlife trafficking; academics with expertise in the use of financial rewards as a law members of the federal Advisory Council on Wildlife Trafficking; and  representatives of nongovernmental organizations that investigate  wildlife trafficking.

We conducted semistructured interviews with the 20 selected  stakeholders using a standard set of questions. We asked questions  about stakeholder views on the usefulness of financial rewards in  combating wildlife trafficking; the strength and weaknesses of the  statutory provisions that authorize federal agencies to pay financial  rewards for information on wildlife trafficking; FWS’s and NOAA’s use of  financial rewards to combat wildlife trafficking; and how, if at all, the two  agencies could improve their use of financial rewards to combat wildlife  trafficking. We analyzed the stakeholders’ responses to our questions,  grouping the responses into overall themes. We summarized the results  of our analysis and then shared the summary with relevant FWS and  NOAA officials to obtain their views. Views from these stakeholders  cannot be generalized to those whom we did not select and interview.

Appendix II: Laws Implemented or Enforced by FWS and NOAA That Prohibit Wildlife Trafficking and Authorize Financial Rewards

The Department of the Interior’s U.S. Fish and Wildlife Service (FWS) and  the Department of Commerce’s National Oceanic and Atmospheric  Administration (NOAA) implement or enforce multiple laws that  specifically authorize the payment, under specified circumstances, of  financial rewards to persons for information about violations of laws that  prohibit wildlife trafficking. The laws that FWS officials identified are  listed and summarized in table 3, and the laws that NOAA officials  identified are listed and summarized in table 4.

In addition, as noted above, the reward provisions in the Magnuson- Stevens Fishery Conservation and Management Act as amended and the  Fish and Wildlife Improvement Act as amended authorize the payment of  rewards for information about violations of multiple laws. Specifically, the  Magnuson-Stevens Fishery Conservation and Management Act as  amended authorizes the payment of rewards for information about  violations of the act as well as any other marine resource law that the  Secretary of Commerce enforces. Further, the Fish and Wildlife  Improvement Act as amended authorizes the payment of rewards for  information about violations of any law administered by NOAA’s National  Marine Fisheries Service relating to plants, fish, or wildlife. NOAA officials  identified 14 such laws that prohibit wildlife trafficking (see table 5). If a  violation of the laws listed in table 5 occurs, NOAA officials said they  could use the Magnuson-Stevens Fishery Conservation and Management  Act or Fish and Wildlife Improvement Act reward provision to pay a  reward for information on the violation. None of the laws listed in table 5  specifically authorize the payment of financial rewards.

Appendix III: FWS and NOAA Cases in Which the Agencies Reported Paying Rewards, Fiscal Years 2007 through 2017

Table 6 provides information on U.S. Fish and Wildlife Service and  National Oceanic and Atmospheric Administration cases where these  agencies reported paying rewards for information on wildlife trafficking  from fiscal years 2007 through 2017.

Appendix IV: Comments from the Department of Commerce

Appendix V: Comments from the Department of the Interior

Appendix VI: GAO Contact and Staff Acknowledgments

In addition to the contact named above, Alyssa M. Hundrup (Assistant  Director), David Marroni (Analyst-in-Charge), Cindy Gilbert, Keesha  Luebke, Jeanette Soares, Sheryl Stein, Sara Sullivan, and Judith Williams  made key contributions to this report.

Wildlife trafficking is a multibillion-dollar, global criminal activity that imperils thousands of species. To help combat it, the U.S. Fish and Wildlife Service and the National Oceanic and Atmospheric Administration can offer rewards in certain circumstances for information on wildlife trafficking activities.

We found that these agencies have not prioritized offering rewards, and they have paid few of them—27 rewards in 11 fiscal years, totaling about $205,000.

We made seven recommendations to these agencies, including telling the public about the possibility of rewards and reviewing how effectively the agencies are using rewards.