Transnational Environmental Crime as a Security Threat: Toward an International Framework for Forest Finance Due Diligence

The COP28 Global Stocktake's call to halt and reverse deforestation and forest degradation by 2030 (paragraphs 33 and 34, GST1) confronts a structural obstacle that no amount of forest finance, carbon crediting architecture, or national law enforcement capacity can resolve on its own: the systematic integration of illegal deforestation into transnational organised crime networks financed through the legitimate global financial system. According to the Financial Action Task Force (FATF), the global money laundering and terrorist financing watchdog, environmental crimes — principally illegal logging, deforestation and mining — are the highest-value crime types linked to associated financial crimes, generating annual revenues of up to USD 280 billion globally, a figure that exceeds the combined profits of human trafficking and the illegal arms trade. These revenues do not remain in forests or in producing countries. They flow through shell companies, commodity trade finance chains, correspondent banking networks, and real estate markets in financial centres across North America, Europe and the Middle East, where they are laundered, invested and recycled into further criminal enterprise. The COP30 Presidency Roadmap on deforestation therefore faces a choice: it can address the symptom — the loss of forest cover — while leaving the financial engine of that loss untouched, or it can articulate, for the first time in a dedicated climate roadmap, the governance architecture required to interdict the illicit financial flows that make large-scale deforestation economically rational for those who perpetrate it. This submission argues unequivocally for the latter.