Globally, illegal wildlife trade is the fourth largest smuggling crime, just behind drug, arms and human trafficking. The crime is similarly severe in Bangladesh. In Bangladesh, threatened wildlife is protected by the Wildlife (Conservation and Security) Act 2012. This law specifies which native species can be traded. Though trade, meaning import and export, of exotic species is permitted under the law, the de facto policy is practised restrictively by Bangladesh’s wildlife affairs agency, the Forest Department. The agency usually gives permission only for importing non-native birds.

Trade ban

The Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) has temporarily banned Bangladesh from trading CITES-listed birds, resulting in revenue loss for the country. This is an undesirable situation because it hampers the standing of the country. This situation will push some traders to resort to illicit methods. For instance, a trader may import a CITES-listed bird under the guise of it being a non-CITES bird.

Meanwhile, Bangladesh doesn’t have screening expertise, through the presence of its Forest Department, at points of entry like airports. Without this capacity to identify legal bird species, it becomes challenging to intercept these illegal shipments.

Returning to the wild

Seizing of illegal wildlife is an effective strategy to deter wildlife crime. However, seizures alone cannot recover species populations since individuals have already been removed from their natural habitat. Some species are in a precarious situation, and removal of even a few individuals can be detrimental. For example, in August 2023, 31 CITES-listed birds (which were prohibited for trade) were seized in Bangladesh’s Dhaka Airport and subsequently taken to a safari park. But such actions are not very effective unless the birds are returned to their native habitat to support population recovery.

Releasing seized foreign exotic birds into the wild in Bangladesh is not sustainable. Exotic birds can be an ecosystem hazard. They also have low survival capacity and risk spreading zoonotic diseases. For true conservation, the only option is to return them to their native habitat without delay.

In 2023, three Lear’s macaws were seized alive at Dhaka Airport. A Lear’s macaw is a CITES-listed bird, with only a few hundred left in Brazil. The seized birds were sent to a safari park for rehabilitation. However, they died within a few weeks. This raises concerns about the aftercare procedures for these seizures. In Bangladesh, there are no modern medical facilities for exotic species. These facilities can be established through multi-agency collaboration between the country’s Forest Department, the Livestock Services Department and veterinary science institutes.

Authorities release birds that were illegally captured for sale, Dhaka, Bangladesh, 29 September 2016 | Photo by Mahmud Hossain Opu.

Bangladeshi law enforcers have also seized many native wildlife species that were being trafficked. For example, two bear cubs were seized in January 2023 from the south-eastern town of Chakaria. In April 2024, two bear cubs were seized in the southern hills of Alikodom. These bears then ended up in safari parks.

In May 2024, two pangolins were seized from different stations. Pangolins are critically endangered. For such a critical species, clearly defined reintegration plans need to be in place. Government agencies can collaborate with local researchers to reintegrate any seized native animals into their natural habitat.

Shark and ray trade           

Bangladesh has over 100 species of sharks and rays. This also is a special group of endangered species. The population status of many is unknown – but many are endangered. Many threatened sharks and rays are caught as bycatch during fishing. They are later size-sorted between large and small fins for trade purposes.

Larger sharks are cut into pieces after the fins are removed. Dried fins, dry flesh, skin, vertebral cartilage, liver, teeth and jaws, and dried intestines are processed. Dried fins, flesh and skin are made export-ready. As with sharks, guitarfish are also prepared. In Bangladesh, this is an age-old practice dating back to the 1960s.

Traders collect sharks and rays throughout the fishing season. Large volumes of high-value sawfish and guitarfish are sourced from fishing vessels. Sharks and rays are auctioned or sold. Shipment destinations include Thailand, China, India, the US and Vietnam. Most exports are destined for China. This is a 40-year-old trade. Since 2013, all Bangladeshi shark and ray-related goods have been exported through Myanmar.

Bangladesh introduced protection measures on the majority of species in 2021. But most shark and ray traders are unaware of their protected status. They often don’t have alternative income sources, and hence tend to disregard the law. Bangladesh’s trade in sharks and rays has operated with no regulation or reporting oversight.

Legal protection at sea

In Bangladesh, legislation is currently the only tool for protecting sharks and rays. There are only punitive actions to tackle their catch and trade. However, in developing nations like Bangladesh, laws and bans can fail to improve species protection given insufficient enforcement, data unavailability, institutional weakness and public unawareness.

Stringent regulations (like bans, raids and fines) force traders either to find alternative trade channels or to turn to the black market. For example, case studies of China and Hong Kong show that the majority of traders are willing to adopt mechanisms to control their bycatch. In Bangladesh’s case, traders can easily ship shark and ray products through Myanmar as ‘fish products.’

A technical workshop of CITES convening stakeholders to categorise wildlife species taken from areas beyond national jurisdictions, Geneva, Switzerland, 25 April 2024 | Photo by CITES Secretariat.

Line between trade and trafficking

Bangladesh’s regulations do not factor-in the socioeconomic vulnerabilities of those in the fishing supply chain. The blanket nature of laws is a primary cause of non-compliance. Understanding the socioeconomic drivers of catch and trade will enhance compliance. An umbrella ban on catch and trade can be economically detrimental to Bangladeshi fishers and traders. Top-down regulatory measures do more harm than good. Bangladeshi policy-makers can design shark and ray management strategies smartly to fulfil the country’s conservation objectives.

Bangladesh’s catch and trade accounting system for sharks and rays also has notable shortcomings. Only a small portion of trade data is published; the bulk of trade goes undocumented. United Nations’ specialised agency the Food and Agriculture Organisation (FAO) ranked Bangladesh 19th in fin export, with an export of 95 tonnes of shark fins, between 2000 and 2011.

The FAO database, FishStatJ, reported fewer than 20 tonnes for most of these years, which is likely an understatement. Meanwhile, there are also data anomalies between local and global datasets.[1] Therefore, Bangladesh must immediately review its current procedures for collecting fishing data to protect rare species.

In Bangladesh, fins (from protected and non-protected species) are traded with other general fishery products. Owing to a lack of monitoring knowhow, differentiating between species is troublesome. Market demand means bycatch (like sharks and rays) retention is high, leading to their trade.

In Bangladesh, fishers and traders hail from different locations and backgrounds. Fishers are mostly small in scale. Incentives targeting fishers are instrumental and can have very limited benefits. For example, fin trade profits are smaller for fishers than for traders. Hence, a fisher is unlikely to adopt conservation actions.

The global fin market is supply-driven. This means that supply-side measures can mitigate the unsustainable trade of fins. Profits attract traders to trade in shark and ray products. Fishers are similarly motivated.

Small-scale fishers are among the most disadvantaged groups in Bangladesh. They often do not have access to credit or are ill-equipped to adopt management activities. This means they are not ready for compliance. It is necessary to provide positive incentives for local management to balance the expenses of enforcement. Incentives like stable financial structures to raise fishers’ earnings can improve compliance with regulations.

In Bangladesh, wildlife stakeholders are often unsure about the legality of trade. In particular, identifying protected shark and ray species at landing locations is difficult for untrained individuals.

A fisherman sews his net, southern tip of Bangladesh, 14 July 2018 | Photo by Khurshid Alam.

Policy suggestions

Some basic steps that Bangladeshi policy-makers can take to counter illegal wildlife trade include:

  1. Establish a verification system for permits, certificates and legal acquisition of species to ensure CITES compliance. This will remove the commercial trade ban and generate revenue.
  2. Remove bureaucratic barriers to increase multi-agency collaboration. For example, Customs and the Forest Department need to work in collaboration at the ports of entry and exit. Meanwhile, the Forest Department and the Livestock Services Department need to ensure proper treatment of seized animals.
  3. Initiate programmes to send seized exotic animals from overseas back to their native habitat.
  4. Develop rehabilitation centres for seized native wildlife and initiate processes for reintegration to the wild.
  5. Review the list of protected ‘fishes’ of the Wildlife (Conservation and Security) Act of 2012. Along with sharks and rays, this list includes bony fishes; this needs to be amended for easy enforcement. The list’s amendment should be done in consultation with implementing agencies.
  6. Enhance monitoring at fish landing sites, on fishing vessels and in trading hubs using low-cost and easy-to-use methods. Collaborative monitoring regimes that incentivise fishers to share catch data can be used. Adopt smart technology such as eDNA, vessel trackers and on/off-line log books. This will help categorise whether a species is safe or unsafe for trade.
  7. Design context-appropriate and culturally sensitive incentives for fishing communities to increase compliance.
  8. Introduce forensic equipment for shark and ray species identification at trade checkpoints.
  9. Enable science-backed policies, especially in the case of protected shark and ray species.
  10. Design dynamic marine protected areas by means of which both fish and fishers can enjoy the benefits of conservation equally.

 

[1] There are shark and ray export data discrepancies between Bangladesh’s Department of Fisheries, CITES and UN Comtrade datasets.

 

Cover © Sawfish rostrum of an adult large sawfish caught in the Bay of Bengal by a trawl net, Chattogram, Bangladesh, 20 January 2020 | Photo by Bengal Elasmo Lab/Oliver Deppert.

Photo © Mahmud Hossain Opu

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Alifa Bintha Haque is Associate Professor of Zoology at the University of Dhaka. She is a marine biologist. She is Team Lead at the Bengal Elasmo Lab and a Board member of the WildTeam Bangladesh. Her research focuses on evidence-based marine conservation in Bangladesh. She received the WINGS Women of Discovery Award and the Bangabandhu Scholarship. She pursued her doctoral studies at the University of Oxford, UK.
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Samia Saif is Programme Lead at the International Criminal Investigative Training Assistance Program (ICITAP). She is a conservationist. She specialises in tiger poaching and tiger trade. She has received the Future for Nature Award. She pursued her doctoral studies in biodiversity management at the University of Kent, England.