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Tracing Trade Patterns of Alleged Wildlife Traffickers: The Wu Criminal Organization

09/21/20 5 minute read

A transnational network engaged in wildlife trafficking, shark finning, drug trafficking, and money laundering was dismantled by federal and local law enforcement earlier this month, according to a United States Department of Justice (DOJ) announcement. The Wu criminal organization spanned multiple U.S. states — including California, Michigan, Georgia, and Florida — and operated across borders from Hong Kong to Mexico and Canada for over a decade.

The 37-page indictment charges 12 defendants and two businesses. The criminal organization unlawfully operated a shark fin business in California, though they purported to use a front company in Florida, and shipped the shark fins to Hong Kong. The group shipped marijuana from California to Savannah, Georgia and for at least a decade, they attempted to hide drug trafficking proceeds through seafood transactions rather than the actual drug transactions. Members of the conspiracy deposited “bulk cash from illegal activities, including wildlife trafficking and drug trafficking, into third-party business accounts that dealt in gold, precious metals, and jewels, to hide the illegal activities,” according to the DOJ press release. To hide illegal profits, conspirators deposited millions of dollars into third-party business accounts around the world.

Front companies, fake invoices, and precious metals

The two businesses charged are Serendipity Business Solutions LLC of San Bruno, California and Phoenix Fisheries LLC based in Southport, Florida.

Phoenix Fisheries was created as a front company in Florida because “possessing, selling, and distributing certain shark fins” is lawful in Florida, according to the indictment. Serendipity operated in California where it directed the trade and distribution of shark fins to Hong Kong. The company created fake invoices and paperwork to make it appear as if the Florida company, Phoenix Fisheries, was financing and controlling the shark fin business.

Illegal profits from the shark fin business were wired to third party businesses, and bulk cash was mailed to California for advanced payment of marijuana sent from California to Georgia. Illegal drug proceeds were masked as purported seafood transactions — then drug trafficking funds were deposited into business accounts that dealt in gold, precious metals, and jewels, as well as third party business accounts to hide illegal profits.

Tracing additional transactions with trade data

Although the indictment indicates that Serendipity Business Solutions exported shark fins to East Asia, commercial trade data suggests the company reportedly received shipments of seafood products from Hong Kong, too. Serendipity consigned three shipments from 2017-2019 from Hong Kong and China-based company Shun Fat Sea Product Trading, according to commercial trade data provided by Panjiva. The shipments included nearly 29 thousand pounds of goods marked as “cooked frozen elephant fish fin” and sea cucumber.

Shun Fat Sea Product Trading, itself, has a history of importing a variety of seafood products from Mexico. According to trade data, from 2016-2020 Shun Fat Sea Product Trading received at least 25 shipments of various seafood products — including dried shark fins, sea cucumbers, snails, and corvina swim bladders — from several Mexico-based entities and individuals. A company by the name of Shun Fat Sea Product Trading Inc. is also registered in California, according to corporate records from the California Secretary of State. Neither the company nor its owners and operators, based in Las Vegas, were named in the indictment.

Trade data also reveals that in January and March 2016, Phoenix Fisheries LLC, the Florida front company, purportedly received two shipments from a Mexico-based seafood supplier totalling over 4,400 pounds of “frozen corvina bladder.” In May and June 2017, Phoenix Fisheries received over 9,000 pounds of frozen sea cucumber and over 2,000 pounds of “frozen bladders” from a Mexican individual, according to trade records from Panjiva. Neither the company nor individual were named in the indictment.

Provided that the items listed on these shipments are accurate, this suggests Phoenix Fisheries, and by extension Serendipity Business Solutions, may have also been involved in illegally trading other types of seafood products beyond shark fins. When U.S. law enforcement arrested the defendants and searched their homes and workplaces, they uncovered 18 totoaba fish bladders — a delicacy in Asia harvested illegally from a critically endangered species endemic to Mexico. There is a lucrative black market for totoaba bladders, often referred to as “cocaine of the sea.”

Panjiva Data: Copyright 2020, S&P Global Market Intelligence (and its affiliates as applicable). All rights reserved.

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