INTERPOL For official use only
11th INTERPOL Global Programme on Anti-
Corruption, Financial Crimes and Asset Recovery:
Anti-Corruption in the Forestry Sector
1-5 June 2015, Kuala Lumpur, Malaysia
ACKNOWLEDGEMENTS
INTERPOL would like to thank the Norwegian Agency for Development (NORAD) for its generous support of
Project LEAF (Law Enforcement Assistance for Forests).
This report is issued under the umbrella of INTERPOL’s Project LEAF, a global initiative to combat illegal
logging—a crime type that is estimated to cost the global economy between USD 30 and 100 billion, and is
linked to other forms of organized and transnational crimes.
DISCLAIMER
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The content of this publication does not necessarily reflect the views or policies of INTERPOL, its Member
countries, or contributory organizations, nor does it imply any endorsement. The boundaries and names shown
and the designations used on any maps do not imply official endorsement or acceptance by INTERPOL. The
designations employed and the presentation of the material in this publication do not imply the expression of
any opinion whatsoever on the part of INTERPOL concerning the legal status of any country, territory, city or
area or of its authorities, or concerning the delimitation of its frontiers or boundaries.
Front cover photograph: Participants, comprising 27 officials from 8 South East Asian countries.
Table of Contents
EXECUTIVE SUMMARY ................................................................................... 4
1 OVERVIEW OF THE TRAINING ............................................................. 6
1.1 Opening and closing ceremonies ........................................................ 6
1.2 Training Sessions ................................................................................ 6
1.2.1 Country experiences............................................................................................ 7
1.2.2 Expert presentations ........................................................................................... 9
1.2.3 INTERPOL modules .............................................................................................. 9
1.2.4 Anti-corruption investigations using digital and mobile forensics ....................... 10
2 GROUP DISCUSSIONS ........................................................................ 10
2.1 Priorities, challenges and risks and related to fighting corruption in
the forestry sector ............................................................................. 11
2.2 Opportunities and priorities for the region ........................................ 12
3 PARTICIPANT FEEDBACK .................................................................... 13
EXECUTIVE SUMMARY
From 1 to 5 June 2015, INTERPOL conducted a regional training event in Kuala Lumpur,
Malaysia under the title of 11th INTERPOL Global Programme on Anti-Corruption, Financial
Crimes and Asset Recovery: Anti-Corruption in the Forest Sector. This five-day training event
brought together twenty-seven (27) participants from eight South East Asian countries -
Cambodia, Indonesia, Malaysia, Myanmar, Papua New Guinea, Philippines, Thailand and
Vietnam. This program was designed to share techniques on how to investigate and mitigate
corruption and financial crimes related to illegal logging and illicit timber trade in the region.
Participants were forest police, officers and investigators from countries’ forest law
enforcement agencies, Anti-Corruption Commissions and Ombudsman Offices, Financial
Intelligence Units, CITES Management Authority, as well as Malaysia’s Wildlife Department
and Maritime Enforcement Agency.
The training was delivered by INTERPOL and co-hosted by the Malaysian Anti-Corruption
Commission (MACC) and Malaysia Anti-Corruption Academy (MACA) located in Kuala
Lumpur, Malaysia.
Participants were required to complete an INTERPOL online e-learning module prior to the
training: “Forest Crime: An Officer’s Guide to Illegal Logging and Forest Crime”. The e-
learning module provided the background training material and pre-requisite knowledge on
identifying and combatting illegal logging and forestry crime. Requiring participants to
complete the module ensured that all participants commenced the training with a general
level of understanding regarding forestry crime.
The training course enabled participants to exchange best practices in the detection,
investigation as well as prosecution of corrupt acts related to illegal logging and the illicit
timber trade. It also served to encourage collaboration and information sharing between
countries’ anti-corruption agencies and forestry departments.
The training course covered different subjects, such as:
1. Detection, investigation and prosecution of corruption in exploitation of natural
resources
2. Challenges in successful investigation and prosecution
3. Role of intelligence in developing a corruption case in the forestry sector
4. Good governance in the forestry sector
5. Measures taken to reduce incidences of corruption in contracting and licensing
6. Best practices to tackle corruption in forestry sector
7. Digital and mobile forensics for anti-corruption investigations
Conclusion
The course provided an important opportunity for both investigators and forest
enforcement officers from key forest-rich countries in South East Asia to share experiences,
network and create a spirit of cooperation which will greatly benefit international
coordination in future anti-corruption and forestry crime cases.
Next steps Participants
The expertise gained by participants will be shared with other investigators and officials to
assist future anti-corruption investigations and illegal logging and illicit timber trade cases.
Participants also requested additional trainings on the topics and the hands-on practical and
operational techniques, specifically with the available open source tools that could be used
in future mobile and computer forensics for investigations into corruption and forestry
crimes cases.
Participants
In total, twenty-seven (27) officials from eight countries attended the training: Cambodia (2
representatives), Indonesia (3), Malaysia (13), Myanmar (2), Papua New Guinea (2),
Philippines (2), Thailand (2), Vietnam (1). The module on computer and mobile forensics was
provided by an expert from India’s Directorate of Forensic Science Services. United Nations
Office on Drugs and Crime (UNODC) also attended and presented on the legal framework
around wildlife and forest crime in ASEAN member states. The President of Transparency
International’s Malaysia chapter presented on their work in supporting good governance in
the forestry sector.
“All countries must be united in combating all forms of crimes, including corruption and
crimes against the environment. We share a collective responsibility to prevent these
crimes from threatening the security of our citizens. When it comes to fighting
corruption, prevention is always better than cure.”
Tan Sri Dr. Abu Kassim bin Mohamed
Chief Commissioner
Malaysian Anti-Corruption Commission
“Corruption in the forestry sector undermines not only the profitability and
sustainability of the world’s forest resources, but also weakens countries’ broader
forest governance systems.”
Stanley Ude
Criminal Intelligence Officer
Anti-Corruption and Financial Crimes Sub-Directorate
INTERPOL
Extracts from opening day ceremony
1 OVERVIEW OF THE TRAINING
1.1 Opening and closing ceremonies
On the first day, an opening ceremony was organized. Mr. Stanley Ude from INTERPOL’s
Anti-Corruption and Financial Crimes Sub-Directorate gave the opening remarks and an
overview of the training programme. Mr. Abdul Razak bin Hamzah, the Head of the
International Studies Centre of MACA, also provided welcome remarks and highlighted the
importance of the subject being addressed at the training for both Malaysia and the region.
On the last day, a large closing ceremony was organized where participants received
certificates for their completion of the training. Deputy Chief Commissioner of MACC
delivered a closing speech on behalf of Chief Commissioner Mr. Tan Sri Dr. Abu Kassim bin
Mohamed, where he stressed the importance of tackling corruption in the region, especially
corruption related to environmental degradation. The Second Secretary of Papua New
Guinea’s High Commission in Kuala Lumpur, Mr. Stanley Arua, was in attendance as well as
Directors and senior officials from MACC.
1.2 Training Sessions
The training was divided into various sessions over the five day period. A mix of group
discussions, lectures and breakout sessions were designed to enable countries to share and
compare experiences on the subject and to work together with colleagues from other
agencies that they may not traditionally work with.
Group photo after the closing ceremony on 5 June 2015
1.2.1 Country experiences
Over the course of the training, each country presented their experiences in combatting
corruption in the forestry sector, including lessons learned, challenges, good practices, and
specific relevant cases or operations.
Countries with extensive experience in investigating and tackling corruption in the forestry
sector, particularly Malaysia and Indonesia, were given more time to present their
experiences and best practices for the benefit of the other countries.
Malaysia 1.2.1.1
Two presentations were given by MACC regarding the role of intelligence in developing
corruption cases in forestry with a case study on ‘Operation Tukul’ and measures taken to
reduce corruption in contracting and licensing procedures. Here countries learned how
MACC collaborated with a number of law enforcement agencies (Police, Forestry
Department, Customs, Tax Department, Maritime Enforcement, General Operation Forces)
to conduct law enforcement operations that gathered intelligence on where illegal logging is
happening, the different modus operandi used by criminals, and why. It was found that
bribery of local law enforcement agencies and forest departments was allowing the illegal
loggers to log without permits, outside permit areas and also to transport undeclared logs.
Operation Tukul resulted in:
The arrest of 14 people (including police officers)
Seven of the arrested charged
Total of RM (Malaysian Ringgit) 50,100 in bribes
Total of RM 160,000 in fines
Three ongoing cases
MACC also froze 30 bank accounts belonging to 10 logging companies totaling RM 18
million [USD 5.7 million]
The importance of a multi-agency task force was stressed for the success of this operation
and efforts to combat illegal logging and other related crimes. The taskforce includes MACC,
Inland Revenue Department, Customs, Police, Forestry Department and the Financial
Intelligence Unit. The high level of political will from the Prime Minister and the current
Sarawak Chief Minister also contributed to the success of this Operation and other anti-
corruption activities in Malaysia’s forestry sector.
Malaysia’s Peninsular Forestry Department also gave a presentation and described the main
factors for corruption as being:
Lack of political will
Individual weaknesses
Unscrupulous loggers/foresters/rangers/officers who help each other
Lack of supervision
Conflict of interest over department or area where logging is happening
The highest risk for corruption in forestry are the following stages:
1. The application stage is seen to have systemic corruption throughout, particularly
with front desk staff requesting payments to process applications
2. The approval of the application is when officers and staff process applications by
visiting and confirming the area in consideration. Abuse of power and conflict of
interest occur here. Locals may be asked to pay for their applications to be
processed sooner
3. Logging operations are riddled with bribery, illegal gratuities and forgery
MACC works with police and the forestry department in order to take on cases together and
address the risks outlined above.
Indonesia 1.2.1.2
An anti-corruption and forestry expert from Indonesia, Mr. Mas Santosa, was invited to
present the country’s extensive experience in combatting corruption in the forest sector. Mr.
Santosa described the work of Indonesia’s Anti-Corruption Commission (KPK) to reduce
corruption in the Ministry of Fisheries and Ministry of Forests, among others. Through this
work, KPK has found that most logging licensing processes in Indonesia are riddled with
corruption, mostly in the form of bribery, state capture and/or trade in influence.
Indonesia’s experience with the multi-door approach to tackle corruption in forestry was
presented by Mr. Santosa in order for other countries to understand Indonesia’s successes
and challenges. The multi-door approach is the use of numerous laws or a multi-regime law
to tackle forest crimes, since crimes in forestry often come hand-in-hand with corporate
criminal liability, money laundering, tax avoidance and corruption. When applying all
applicable laws to cases of illegal logging, the sanctions are much higher for the criminals.
Indonesia has a Memorandum Of Understanding (MoU) signed between the heads of six
different law enforcement agencies to implement the multi-door approach and strengthen
coordination among the six agencies. The challenges of this approach stemmed from the low
level commitment or motivation of investigators. This therefore called for a certain level of
coordination and facilitation among agencies to avoid the silo mentality and encourage
active application of the multi-door approach by investigators and prosecutors.
1.2.2 Expert presentations
To compliment country presentations and INTERPOL’s modules, a few presentations were
given by experts in the field of anti-corruption and forestry. Transparency International’s
President of Malaysia’s national chapter presented a session on “Forestry Governance and
Integrity: Good Governance in the Forestry Sector” where he discussed the importance of
corruption prevention and awareness raising. Particularly, he discussed Transparency
International’s Forest Watch Project, which entails the public becoming the eyes and ears of
corruption in forests.
UNODC presented their rapid assessment of the
“Legal Framework around Wildlife and Forest
Crime in ASEAN Countries”. This assessment
identified similarities and differences in national
legal frameworks and how ASEAN countries
criminalize wildlife and timber trafficking. It was
found that all 10 ASEAN Member States frame
offences against wildlife and forests as ‘serious’
crimes. Further, all ASEAN Member States
criminalize wildlife and timber trafficking and include in their domestic legal frameworks
certain provisions that punish these wildlife and forest crimes. A priority highlighted from
the study was the need to harmonize regional standards for criminal penalties, due to the
significant variation from country to country in the level of penalties.
The importance of investigating wildlife and forestry crimes under anti-corruption and anti-
money laundering laws was recognized because in nearly all ASEAN Member States, wildlife
and timber trafficking are considered predicate crimes under the anti-money laundering
laws.
1.2.3 INTERPOL modules
INTERPOL experts presented a number of different topics tailored to the region and training.
Issues around the prevention, detection, investigation and prosecution of corruption in the
exploitation of natural resources was discussed. INTERPOL encouraged anti-corruption
practitioners to investigate both past and present cases, without fear or favor. Participants
raised the challenge of getting these cases to court, and once in the court, to receiving
adequate sentencing.
Transparency International presentation
INTERPOL insisted on the proactive approach to combatting corruption, and for forest law
enforcement and anti-corruption agencies to be proactive in their actions to investigate
cases of corruption and forestry crimes. To do this, dedicated anti-corruption agencies must
be independent and given the opportunity and encouragement to conduct pre-emptive
investigations.
The importance of awareness and protection for whistleblowers was discussed. It is crucial
to raise awareness and encourage more whistleblowers to come forward and provide
information which could assist countries’ fight against corruption and illegal logging.
INTERPOL also held a session on asset recovery and why going after criminal’s money is the
best deterrence to future crimes. INTERPOL’s role with the Stolen Asset Recovery Initiative
“StAR”, in partnership with the World Bank and UNODC, was described so that countries
could join and count on INTERPOL’s assistance when tracing and locating criminal assets in
international cases, such as those related to corruption and illegal logging.
INTERPOL held another session on financial investigations for public officials in possession of
unexplained assets. Such investigations aim to identify public servants in possession of
assets disproportionate to their known sources of income and where they are not able to
account for the disproportion. INTERPOL discussed the basics to conducting these kinds of
investigations and the challenges that come along with successful investigations and
prosecutions.
1.2.4 Anti-corruption investigations using digital and mobile forensics
A full day was dedicated to the module on digital and mobile forensics, run by Mr. Krishna
Pendyala, a Digital Crime and Forensic Evidence expert from India. This session,
overwhelmingly the most popular of the entire training as indicated by participants in their
post-workshop questionnaire, allowed participants to understand how to use simple
computer and mobile forensics to assist investigators in corruption related investigations.
The session included a number of practical exercises for participants to learn how to handle
computers seized from criminals, the characteristics of digital evidence and how to preserve
this kind of evidence. Participants also learned the various ways in which data can be hidden
and how to recover deleted files and enter encrypted files with specific cases and examples
related to anti-corruption investigations of public officials.
2 GROUP DISCUSSIONS
Participants were broken out into groups of four throughout the training and asked to
answer a number of questions related to corruption in forestry in their countries. A summary
of these group discussions are below.
2.1 Priorities, challenges and risks and related to fighting corruption in the
forestry sector
Countries overwhelmingly identified information
sharing and awareness raising as priorities in
combatting corruption in the forestry sector.
Public awareness raising programmes for
stakeholders, including the private sector was
raised as a priority so stakeholders and
companies are aware of relevant laws and can
be pressured to conduct their due diligence.
Likewise, information sharing amongst countries
in the South East Asian region was highlighted as
a priority, with suggestions ranging from the
creation of a regional information network,
special investigations group, and/or taskforce related to combatting timber crimes and
associated corruption.
Weak enforcement of forest laws and/or weak existing laws, policies and regulations are
challenges in the eight countries that were present. Countries mentioned different obstacles
that they face, especially at the judicial level with corruption and illegal logging cases that
are brought to court receiving very low sentences and punishments. These low sentences do
not effectively deter criminals from engaging in illegal logging and corrupt acts and likewise
diminish the spirit of law enforcement who work hard to bring the cases to justice.
All countries stated they faced the following challenges in combatting corruption and illegal
logging:
- Inadequate budgets for law enforcement agencies
- High living costs and low salaries of law enforcement officers
- Limited access to technology and the equipment needed to conduct investigations
- Lack of sufficient enforcement officers and staff resources
- The remoteness of forested lands and difficulty of reaching these lands
- Environmental factors such as heavy rains or poor roads, which hamper effective
enforcement and investigation efforts
- Lack of interagency cooperation between forest agencies and other law enforcement
agencies
- Lenient sentences or very light punishment for offenders
- Lack of information sharing
- Limited knowledge of INTERPOL tools and services
In terms of coordinating cross-border law enforcement operations and information sharing,
the challenges identified were:
- Difficulty in information sharing, due to confidentiality of information i.e. classified
documents, security concerns, diplomatic implications, and/or language differences
- Limited and lack of cross border collaboration between governments
Group Work
- Differences among countries and within countries in terms of laws and customary
beliefs
- Geographic landscape and unclear and/or porous borders between countries
The main risks in combatting corruption in the forestry sector:
- Security and safety of law enforcement personnel
- Information leakage from law enforcement agency and loss of intelligence
2.2 Opportunities and priorities for the region
It was agreed amongst participants that opportunities should be sought to strengthen the
cooperation between forest agencies and other law enforcement agencies. Additionally, the
lack of political influence and distance between law enforcement and law makers is a
challenge which could be alleviated by raising awareness among politicians and law makers
and strengthening cooperation between different agencies.
Another main challenge is the
high costs of living and low
salaries for law enforcement
officers, which makes officers
more susceptible to accept bribes
and engage in corruption.
Countries highlighted that an
increase in forest law
enforcement officers’ salaries
could reduce the likelihood of
corruption.
Other opportunities were agreed
as follows:
- Information can be shared with INTERPOL through countries’ NCBs
- An MoU between INTERPOL and countries could be established for timely
information sharing related to cases of corruption and forestry crimes
- Committees, taskforces and special investigative groups on specific timber species,
for example Rosewood, can be created resulting in joint operations in the region
- Capacity building and training needs of law enforcement can be met with
international cooperation
- Increase use of INTERPOL’s international databases through entering and retrieving
information in a quick and efficient manner
The main priorities of participants were:
- Targeting corruption during the timber licensing and concessions processes
- Strengthening forest law enforcement and cooperation; increasing law enforcement
staff
- Understanding customary practices in harvesting timber trees in the forest owned by
local communities
Group meeting with Director General of Peninsular Malaysia Forest
Department
- Strengthening or reviewing penalties and charges of existing laws, policies and
regulations
3 PARTICIPANT FEEDBACK
At the conclusion of the training, participants provided feedback through standardized
questionnaires. Responses are compiled below.
0
2
4
6
8
10
12
14
16
Extent to which
course objective
were achieved
Usefulness of
course content
Quality of venue
and facilities
Quality of visual
aids (if any)
Quality of
handouts (if any)
Effectiveness of
the trainers
Overall rating of
this course
Ratings
Excellent Very Good Good Fair Poor
Are you interested in attending other training courses
conducted by Interpol in the future ?
Yes No Not answered
How do you intend to use the information and knowledge received from this training in
the future?
- Share it with colleagues and/or other agencies in my country/abroad
- By applying it in my current job
- To train/instruct other people, in train-the-trainers workshops
- Conduct digital forensic investigations
- For networking opportunities during cross border investigation
- Cooperate and coordinate with relevant law enforcement agencies nationally and
internationally
- Draft a proposal to the Commissioner of Police to set up a separate investigation
branch related to forestry crime
- Include elements in law enforcement strategies
Recommendations
- Longer sessions and more time for sessions and the concluding plenary
- Include sessions on how to formulate an anti-corruption task force
0
10
20
30
40
50
60
70
80
90
Excellent Very Good Good Fair Poor
Overall Rating
Do you plan to use the information you learned during this
course ?
Yes No Not answered
- Invite Ministry level officials
- Invite/contact more agencies from countries in the Pacific
- Conduct a similar training but for a more advanced level
- Include topics on criminal psychology, behavior and intention
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