Pagolin Scales timeline

In Africa, the scales are sourced by representatives of the criminal networks from local villages in areas where pangolins are found.

Transportation is arranged to consolidation locations.

The contraband is consolidated and packed usually in plastic sacks.

Criminal networks use a legal supply of commodities – usually agricultural produce, timber or plastic waste – to conceal the contraband. The contraband is consolidated and packed usually in plastic sacks.

A container is loaded with both legal and illegal products outside of the port, unique-coded seals are placed on the locks of the container.

Vulnerability 1 The loading and placing of the seals can be carried out by the consignor (the party interested in sending the cargo), the carrier (shipping company, freight forwarder or non-vessel operating carrier) or an undeclared third party.

A Bill of Lading is issued to ship the container loaded with the consignment to Asia: Cargo, container, consignor, consignee and carrier details are included in the document.

Vulnerability 2 There is no requirement to declare the ownership of the cargo.

The container is transported to the port and loaded onto the vessel by the carrier.

Vulnerability 3 The vessel owner cannot control whether the Bill of Lading matches the contents of the container. Customs authorities do have this power, but they do not inspect every container, instead they rely on targeted inspections.

At transit ports where the carrier operates, the Bill of Lading might be legitimately switched – replaced by a new one – with completely dierent details than the original one. The container might even be unloaded from one vessel and loaded onto another.

Vulnerability 4 This lawful procedure – used legitimately for commercial reasons – may help conceal the consignment’s origin, the companies or individuals originally linked to it and it may aid in presenting the cargo as a whole different shipment. It is even possible to nominate a carrier as a consignee, avoiding disclosure of the actual importer. Switched Bills of Lading do not contain any reference that indicates they are not the original bills.

Depending on the Bill of Lading details, the carrier will deliver the container at the port of discharge – where the consignee or the consignee’s transport company will take over – or to a place of delivery elsewhere in the country

Vulnerability 5 The delivery address might not be formally associated with the declared consignee.

Upon reaching destination, the contraband is distributed to safe locations.

The scales are further smuggled into China in smaller batches (possibly by land).

Integration of the illegal contraband into the legal market takes place through the production of TCM in China.

Legal TCM is distributed legally in China and Southeast Asia.