U.S. Government Accountability Office Urges Federal Government to Take Stronger Action to Promote Wildlife Crime Whistleblowers

Whistleblower Law Expert Responds to GAO Report on Combating Wildlife Trafficking

Washington, D.C. May 8, 2018. In a report released today, the U.S. Government Accountability Office (GAO) issued wide-ranging recommendations to increase the effectiveness of paying informants and whistleblowers to report illegal wildlife trafficking.

The GAO report found that wildlife trafficking is among the top-ranked illicit trades, valued at approximately $23 billion a year, and that “the United States is one of the world’s largest trafficking markets.” According to the Report, trafficking has “pushed several endangered species to the brink of extinction” and has devastated “wild populations of elephants, rhinoceroses, tigers, pangolins, turtles, exotic birds, and many other species.”

“The GAO got it right,” said whistleblower law expert Stephen M. Kohn. “Paying rewards to those who come forward with information about illegal wildlife trafficking is the key to the enforcement of anti-trafficking laws,” Kohn continued. Kohn, a partner in the whistleblower rights law firm of Kohn, Kohn & Colapinto, is an internationally-recognized expert in whistleblower law. His article “Monetary Rewards for Wildlife Whistleblowers: A Game-Changer in Wildlife Trafficking Detection and Deterrence” (Environmental Law Reporter, January 2016), triggered the critical review of the efforts to utilize whistleblower rewards to stop the global extinction crisis.

Kohn urged Congress, the Fish and Wildlife Service, and the National Oceanic and Atmospheric Administration to take steps to incentivize whistleblowers to report illegal wildlife trafficking. The GAO report substantiates Kohn’s concerns and recommendations for reforms.

“The Government Accountability Office’s investigation shows the agencies responsible for combating wildlife trafficking and protecting endangered species are simply not doing enough,” said Senator Ron Wyden (D-OR), who requested the GAO investigate the underuse of financial incentives meant to encourage whistleblowers. “At a minimum, the agencies must begin using the authority Congress has given them to truly encourage whistleblowers to come forward and report illegal smuggling and harvesting at our borders and in our backyards.”

The GAO recommended a top-down review of how to best utilize the payment of rewards to combat illegal wildlife trafficking, and how to effectively publicize the whistleblower reward program to the public.

“The GAO proposals could revolutionize the detection and enforcement of the wildlife trafficking laws. The GAO documented weaknesses in the current system and made important recommendations for reforms. Congress needs to act on this report and modernize wildlife trafficking whistleblower laws consistent with the highly effective Foreign Corrupt Practices Act, False Claims Act, and IRS whistleblower qui tam provisions,” said Kohn.


In Stephen Kohn’s role as pro bono executive director of the National Whistleblower Center, he oversaw the implementation of the Global Wildlife Whistleblower Program. This program was named a Grand Prize Winner in the 2016 Wildlife Crime Tech Challenge, an initiative of USAID in partnership with the National Geographic Society, the Smithsonian Institution, and TRAFFIC. Kohn is an Adjunct Professor at the Northeastern University School of Law where he teaches a seminar on whistleblower law. Mr. Kohn has a long history of representing whistleblowers and has helped establish important whistleblower protections. He successfully represented the UBS bank whistleblower Bradley Birkenfeld, who won the largest whistleblower reward ever to an individual — $104 million. In 1985, Kohn published the first-ever book on whistleblower law, and his eighth book on the subject is the highly respected The New Whistleblower’s Handbook (Lyons Press, 2017). Mr. Kohn can be reached for interviews at wildlife@whistleblowers.org

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