DOJ’s Smallest Largest Priority: Pangolins

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Federal wildlife trafficking and animal cruelty enforcement is alive and well even as the Trump administration re-allocates U.S. Department of Justice (DOJ) resources. At first blush, enforcing wildlife trafficking crimes may not seem like a priority for the Administration. However, recent publicity, driven in particular by a new streaming documentary featuring the pangolin, and the potential for wildlife trafficking crimes to intersect with the Administration’s publicly-stated Border enforcement priorities will result in an increased focus on Lacey Act prosecutions.

Legal Framework

The primary statute involved in wildlife crime enforcement is the Lacey Act, though other statutes have relevant criminal provisions. The Lacey Act makes it unlawful to import, export, transport, sell, receive, acquire, certain exotic animals and plants. It applies not just to live plants and animals but also to deceased. Violators can face both civil and criminal penalties.

The Administration’s Current Wildlife Crimes Policies

Multiple agencies within the Trump administration continue to tout their commitment to enforcing wildlife crimes. Immigration and Customs Enforcement (ICE) notes on its website that it “remains steadfast in its commitment to combat wildlife trafficking and the illegal trade of natural resources.” The Federal Bureau of Investigation (FBI) states that it investigates crimes related to a variety of environmental statutes, including Lacey Act Enforcement. So far in 2025, DOJ has brought criminal charges and obtained guilty pleas in crimes including trafficking sperm whale teeth and bones, importing spider monkeys, illegally purchasing snakes, and trafficking bird mounts.

Enforcement Trends and Notable Cases

While wildlife trafficking crimes can be standalone charges, they are often brought as part of more complex cases, including cases more closely aligned with the Trump administration’s publicly stated policy goals involving the Border.

Most notably, wildlife trafficking charges often accompany investigations and cases against transnational criminal smuggling organizations. In 2020, during the first Trump administration, DOJ indicted 12 defendants and two businesses for crimes related to, among other things, conspiracy to circumvent wildlife trafficking laws. The alleged conduct included laundering money gained from illegal wildlife trafficking. This investigation, named Operation Apex, resulted in federal agents seizing more than $3.9 million in cash, $4 million in precious metals and gemstones, multiple firearms, drugs, and tons of animal products, including shark fins and fish bladders. Officials lauded the investigation not just for its effect on protecting wildlife but also for its impact on transnational criminal organizations. In the era where transnational criminal organizations are the target of the current Trump administration, wildlife trafficking investigation and enforcement may be an option for targeting individuals who are members of these organizations.

Other criminal charges like conspiracy, obstruction, perjury, drug, and firearm crimes are routinely brought alongside Lacey Act cases or independently in cases that may appear to look like wildlife trafficking cases. For example, one woman pled guilty to two counts of perjury and one count of obstruction following an investigation into her treatment of a pet chimpanzee. Where there is an investigation into conduct that may implicate the Lacey Act, parties should also be aware of the potential for these other types of criminal statutes to be in play.

Public sentiment may also fuel increased prioritization of enforcing wildlife trafficking and related crimes. Pangolins, the most trafficked mammal in the world, were just the subject of a popular documentary. And this documentary is not alone in shining a light on wildlife trafficking. Cultural phenomena like Tiger King and Chimp Crazy have similarly captured the public’s attention and led to an outcry regarding the treatment of animals.

The Administration also continues to enforce not just wildlife trafficking crimes but related crimes, including animal cruelty and the distribution of videos depicting violent and obscene acts against animals. Statements from top officials like Attorney General Pam Bondi and FBI Director Kash Patel on a recent animal cruelty case may signal the Administration’s focus on animal rights as a priority.

Individuals and companies should be aware of the implications associated with importing, exporting, and transporting materials that could implicate the Lacey Act or other wildlife crime enforcement statutes.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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