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Parliamentary Joint Committee on Law Enforcement
Trade in elephant ivory and rhinoceros horn

COLLINS, Mrs Monica, Chief Compliance Officer, Department of the Environment and Energy


CHAIR: I now welcome Mrs Monica Collins of the Department of the Environment and Energy. I thank you for appearing before us. The committee has received your submission as submission 30. Do you wish to make any amendments to the submission?

Mrs Collins : No, I don't, thank you.

CHAIR: I remind committee members and officers that the Senate has resolved that an officer of a department of the Commonwealth or of a state shall not be asked to give opinions on matters of policy and shall be given reasonable opportunity to refer questions asked of the officer to superior officers or to a minister. This resolution prohibits only questions asking for opinions on matter of policy and does not preclude questions asking for explanations of policies or factual questions about when and how policies were adopted. Would you like to make a brief opening statement?

Mrs Collins : No, thank you.

CHAIR: On the issue of the CITES certificates, if someone came to the department and said, 'I want a certificate to export this particular piece of rhino,' do they have to state which country they're exporting it to? Or is it a general permit for it to depart Australia?

Mrs Collins : I can probably start by thanking you for the opportunity to come before the committee. It's worth noting that as Chief Compliance Officer, I'm responsible for the enforcement side of any international wildlife trade crime activity. The department, as you are aware, has a wildlife trade and biosecurity branch that deals with the administration of the CITES permits. That's not in my area. Unfortunately, I'm not able to answer that question.

CHAIR: Okay. Maybe I'll ask you another question in relation to it. I'm more referring to the export of illegal Australian wildlife, coming back to the issue before the committee. What permits can someone get to export native Australian wildlife, currently?

Mrs Collins : Maybe it's helpful if I run through the offences. The import and export of native Australian wildlife is regulated under the Environment Protection and Biodiversity Conservation Act. Under that act there are offences relating to export or import of CITES species, exports of regulated native species and imports of regulated live species. They're the offences under the legislation that we administer.

CHAIR: Are they blanket bans?

Mrs Collins : There are exemptions, that relate to each of those, that are outlined in the relevant sections of the act.

CHAIR: Could you run us through some of the exemptions?

Mrs Collins : Yes. Under section 303CC it's an offence for a person to export a CITES specimen. The exemptions from those are: except in accordance with the certificate issued by the minister, that the specimen was acquired before CITES provisions applied. So that's pre-CITES. If they hold a permit that's issued under the act, if they export as part of a registered non-commercial exchange of scientific specimens between scientific organisations or if they export a personal or household effect, there are penalties that apply for that. They are imprisonment for 10 years or 1,000 penalty units, or both.

Similarly, under section 303CD it's an offence to import a CITES specimen. The exemptions are in accordance with a permit that has been issued if it has been the import of a personal or household effect, if it has been an import as part of a registered non-commercial exchange of scientific specimens between scientific organisations, if the country of export has issued pre-CITES certificates or if the country has granted permission to export and the specimen is below the quantitative limit, which is listed in the CITES agreement. Again, the penalty for that is imprisonment for 10 years or 1,000 penalty units, or both. Section 303DD says it's an offence for a person to export a regulated native specimen.

CHAIR: On the exports of native Australian wildlife, are you seeing any trends over recent years in any particular direction? We've got some information here that you provided with us for rhino horns, but in other Australian native species for export are we seeing trends?

Mrs Collins : Yes, we are. We're seeing a lot of activity in relation to unlawful organised criminal wildlife trade activity. In fact, in the last 12 months we've had four successful prosecutions. I can run through those. In the last financial year, on 11 October 2017, there was a New South Wales woman who was given a two-year good-behaviour bond for breaking the Australian environmental law after being caught with wildlife specimens of several internationally threatened species.

CHAIR: Do you know what those species were?

Mrs Collins : I would have to come back to you with the specific detail.

CHAIR: Okay. Did you say that was a two-year good-behaviour bond?

Mrs Collins : In that case, yes; it was a two-year good-behaviour bond. My understanding is that it was a person not linked to syndicates or anything like that. It was a person who had a personal collection.

CHAIR: Was that person smuggling them on their own person to take them out of the country?

Mrs Collins : I haven't got all of the specific details, but certainly at a high level—

CHAIR: The point I was coming to is that this illegal trade, and you said there's a criminal element involved, is driven by the demand for those animals or native Australian species overseas.

Mrs Collins : This one wasn't so much trade as possession. It's up to the courts to determine what an appropriate penalty is, but this one didn't involve organised criminal trade activity, whereas we do have other matters that are currently before the courts that we can demonstrate, with evidence, that they're part of organised criminal wildlife—

CHAIR: But I'm saying that organised crime is inspired, for want of a better word, because of the demand that comes from overseas for native Australian wildlife.

Mrs Collins : Yes, certainly. Obviously, there's a demand and supply issue.

CHAIR: On that, do you think there is a case that Australia should have some type of more lawful trade in this to increase the supply and therefore suppress the illegal demand, and some of that funding could flow back into protecting those species in Australia, or would you think that if you actually made it lawful, you could actually encourage more illegal trade?

Mrs Collins : My role is around the enforcement of the legislation as it stands. As I have outlined, there are offences that relate to import, export and possession. That's what we're here to enforce. In the office of compliance, we're not the lead in terms of driving the policy development. We're just implementing the legislation as it stands.

Senator SINGH: What resources does the Department of Environment and Energy devote to compliance and, in that sense, combatting the illegal wildlife trade?

Mrs Collins : In the office of compliance, we currently have funded positions for 54 full-time-equivalent positions. Those resources cover a range of environmental legislation that we administer compliance for. We have teams that are dedicated to compliance, intelligence, and environmental auditing, and we do engagement activities to help improve compliance with environmental laws. So, we have a range of tools available to us. It's not that those tools are dedicated for particular activities; it's just the suite of legislation that we administer.

Senator SINGH: Under the act?

Mrs Collins : Under a range of legislation.

Senator SINGH: We heard previous evidence from the department that the ivory market in Australia is insignificant. Do you agree with that conclusion and how is that conclusion reached?

Mrs Collins : We recently put together an intelligence report around, specifically, ivory trade in Australia. That report was based on data and analysis that was put together over a five-year period, 2012-16. From that data, we found that the illicit imports are small on an international scale, and largely inadvertent, with the majority of seized items declared by importers. It might be people travelling and bringing trinkets home and that sort of thing. We found that Australia is not a significant end destination country for ivory products. Most seized items were small and trinkets in nature. Our analysis didn't reveal clear indicators of sophisticated criminal involvement in the trade of elephant and rhino products in Australia. As I was mentioning, in some of our other wildlife trade investigations, there certainly are indicators of sophisticated wildlife crime activity.

Senator SINGH: When you say 'seized items', are they being brought by a person into the country—seized at the airport type of thing? What are the pathways you are referring to?

Mrs Collins : Of the seizures I am referring to there, 76 per cent were declared by the person importing. Across wildlife trade, we make seizures through mail or through passenger traffic.

Senator SINGH: I asked that because this inquiry went to Western Australia, where we actually went out to some of the locations by which cargo coming into Western Australia is then dispersed—it's something like 30 difference locations. Australian Border Force made it clear that there's no way they can screen all of that cargo. So, obviously, your report is only referring to that which has been screened and that which has been declared by the passenger.

Mrs Collins : Our report was based on data from a range of sources. Seizure was one of those. There's a range of sources that were relied on to create that report. Obviously, we work really closely with Border Force. The department has conducted training for Border Force and for other co-regulators or other avenues in the supply chain as well.

Senator SINGH: I recognise that. But I think it needs to be noted on the Hansard that not all cargo is screened. There is ivory and rhino horn being smuggled into Australia and whilst your report of intelligence that you refer to—which I'm not sure if we can have a copy of, but we will ask you that after—has data in it, which you've referred to, it needs to be noted that's only data that refers to that which has been either seized or screened.

Mrs Collins : The intent of an intelligence report is to paint a picture. Part of it is analysing what the data is specifically saying. But it also paints the bigger picture of what the trends are that we're seeing, what methods are we seeing, who are the players, are there repeat offenders, are there networks and contacts, and those sorts of things. From an intelligence product perspective, it's not so much about catching every single item that comes through as it is about painting the picture, which allows us then to direct resources to where we are seeing greatest risk. From that perspective, it doesn't necessarily need to be a complete 100 per cent picture of everything that is going on.

Senator SINGH: Okay. And I understand the organised crime nature of a bit of what you're referring to. What you have referred to is what comes in at the border, but the committee has been told by a number of witnesses, including the department, that the department does no active monitoring of the domestic market of ivory and rhino horn. So, how can the department continue to make this assertion that the Australian market is insignificant and doesn't contribute to the global poaching crisis when you are not doing any monitoring of the domestic trade?

Mrs Collins : There are a few things in there. The offences relate to export, import or possession of something that's been illegally imported, so it's appropriate for us to monitor at the borders. We do that through engagement and liaison with Australian Border Force in particular. I mentioned that the department has provided training over periods of time. We also have an embedded officer, who has access directly into the Border Intelligence Fusion Centre. We therefore have access into Border Force databases and also the intelligence community, which is part of the fusion centre. Through those sorts of avenues, there is a good opportunity for us to have access to live information about what is going across the border, particularly in areas that we're interested in monitoring. I'm not sure if you can call that a monitoring program, but we have that access to live information and use that information to then tailor where we need to target in terms of looking for sophisticated illegal wildlife activity?

Senator SINGH: Other than this one employee in the fusion centre, what monitoring does the office of compliance itself do to ensure that the illegally imported ivory and rhino horn is not being traded within Australia?

Mrs Collins : The other activities we've been involved in recently included attending an Interpol wildlife trade conference. A big discussion point at that conference was around current and modern techniques and methods that are being used to detect illegal trade around ivory and rhino products. So, we're talking with the international community about methods and those things. So, if our intelligence does start to show that activity in that area may be increasing, we have the connections and the networks to step up, if needed, our monitoring in response to that. Combined with that, as I said, we have access to live information. So we can really see, as it's coming in, if there are illegal activities. We get early notification.

Senator SINGH: IFAW, as you know, has provided the department with two investigative reports into the trade of ivory in Australian antique stores, one in August 2017 and one in June this year, 2018. Has the compliance unit read these reports?

Mrs Collins : We've certainly got access to those reports. With the most recent one, we've been involved in internal discussions analysing what it's telling us. So, yes, we've got access to both of those.

Senator SINGH: Have any further actions arisen out of those reports?

Mrs Collins : The intelligence work that we did has said to us that Australia is not a key destination for illegal ivory activity. In the Office of Compliance we take an outcomes based approach to compliance activity, so we use the whole range of compliance tools available to us to achieve environmental outcomes. We do that based on intelligence and based on risk. With the small team that we've got, we focus our activities to where there are higher risks. At the moment, the intelligence is telling us that it's low level, usually inadvertent. There aren't the signs of organised criminal activity. The responses to any criminal activity should be proportionate to the amount of environmental harm and the level of criminal activity. If it's somebody bringing in personal trinkets from a holiday, for example, seizure of those trinkets is enough of a deterrent to stop that continuing.

Senator SINGH: Sorry, Mrs Collins; I was asking about those two reports and what further actions, if any, are being taken by the Office of Compliance in relation to those.

Mrs Collins : Yes. So, as I mentioned, the Office of Compliance is involved in discussions with the Wildlife Trade and Biosecurity Branch around the most recent once. Apart from that, the intelligence is telling us it's not a key focus area for us at the moment. Certainly, the intelligence is telling us that broader wildlife trade activity is a key focus area for us. We are picking up organised syndicates of environmental crime, and that's where our focus is at the moment for wildlife crime activities.

Senator SINGH: So, because the department has decided that's the focus, you're going to ignore these two reports and no action's going to be taken—is that what you're saying?

Mrs Collins : No, that's not what I'm saying. As I said—and I'll say it again—we are in discussions with the Wildlife Trade and Biosecurity Branch inside our department in relation to the most recent report. We haven't yet come to any conclusions in relation to that; it was a relatively recent report. That's what's happening internally with us for that report.

Senator SINGH: There have been a number of investigations into the illegal wildlife trade that have occurred due to information provided to the department by concerned citizens and civil society. That information, an investigation shows, is that it's not insignificant and that there's a proportion of illegal poaching that Australia is contributing to. We've had evidence throughout this inquiry that has actually talked about poachers in Africa knowing that there is a market here. Say I'm a concerned citizen and I contact the department because I'm aware of a $120,000 rhino horn that looks pretty fresh and new for sale in an auction house—this is actually true; it's something I found recently online—what is the process of the department in handling that kind of matter?

Mrs Collins : If you are aware of things like that, by all means we really encourage you to report that to the Office of Compliance.

Senator SINGH: Let's just say I have. What happens then?

Mrs Collins : We've got skilled investigators and skilled intelligence officers. We work very, very closely with co-regulators on a Commonwealth and international scale. We've done joint operations, for example, with the Australian Federal Police, with border forces, with the department of agriculture. We've done joint intelligence operations as well with those agencies and also through Interpol. We're sharing intelligence with countries like the United Kingdom, Canada, New Zealand, Sweden.

Senator SINGH: What would be the process? I've called you. I've identified this. It hasn't got any provenance documentation. For all intents and purposes, it seems to be illegal. What is the process to investigate that?

Mrs Collins : Once a report comes in, our investigators will commence an investigation. There are all sorts of different techniques that we can apply. We have a range of powers that we can use as well. There are powers under the legislation.

Senator SINGH: This is section 303GN—is that right?—of the EPBC Act, where it provides that it is an offence for a person to be in possession of illegally imported CITES species.

Mrs Collins : Yes. But then I'm referring to the powers. If you refer to section 444A, we've got power to seize specimens. If you go to section 445, it refers to the seizure of things other than specimens—so, if we have reasonable grounds to suspect that this would contribute evidentiary material in terms of our investigation. Section 413 is when search warrants can be used as well. Sections 417 and 418 outline our warrant powers. You might be surprised to know also that section 430 includes powers of arrest.

Senator SINGH: That is what would happen? Your investigation team would look into my reporting?

Mrs Collins : Those are the powers that are available to us. In terms of what we do, it can be a whole range of things, including exercising use of those powers. We might do online searches. We might engage with the Australian Federal Police, for example, who bring their powers and do joint operations. I won't go into too much detail in terms of how we run an operation, because, obviously, the success of the operation depends on an element of surprise. But what I can say is that, over the last financial year, we had four successful prosecutions in wildlife crime activities, and that demonstrates that we do have really well-skilled intelligence and investigation officers and the ability to put together breach reports and successfully prosecute and have courts issue penalties in relation to those.

Senator SINGH: But you basically sit back and wait for those reports to come in?

Mrs Collins : No. That's not true.

Senator SINGH: So you do actively go out and monitor—

Mrs Collins : Yes.

Senator SINGH: within Australia?

Mrs Collins : Yes, based on the intelligence that we're constantly getting. Every investigation leads us to other intelligence. If there are packages seized at borders or if there are packages identified through other sources that are intercepted, we'll go straightaway and assess the contents of those packages.

Senator SINGH: But I'm talking about when you haven't got intelligence When you've got civil society providing you with a report that shows that there is suspect illegal wildlife being sold in auction houses, for example, do you act on that or do you do any of your own outreach to some of those potential places?

Mrs Collins : Certainly, if we are receiving information which indicates that there is illegal wildlife activity, we follow up on any of those reports.

Senator SINGH: So you will be following up on IFAW's report?

Mrs Collins : As I mentioned, we are currently internally looking at that IFAW report. If we do find any indications of illegal wildlife trading activity, we will be following up on that.

Senator SINGH: In your capacity as a compliance expert, do you think Australia having an unregulated domestic ivory and rhino horn market, as it is, and items coming in that escape intelligence, as they currently do—we have had a lot of evidence to show that—create an opportunity for this illegal activity?

Mrs Collins : It's difficult for me to comment on that, because, as a compliance officer, we're here to enforce the legislation as it stands, as I've outlined what the offences are, and that is what we're here to enforce.

Senator SINGH: Do you collaborate with the states and territories on the illegal trade of wildlife?

Mrs Collins : Yes, we do.

Senator SINGH: How do you do that?

Mrs Collins : We are collaborating, and we have collaborated, for example, with New South Wales, with Western Australia and with Victoria. Basically, we keep in touch with co-regulators in the other states and territories. Normally the states and territories have domestic offences in relation to wildlife trade and possession of wildlife. If we're coming across activity, we'll usually have conversations with the two jurisdictions about the nature of the crime and which pathway would be most suitable to follow in terms of whether it be a state offence or a Commonwealth offence.

Senator SINGH: I think you said in your opening statement that you do some sort of communication or education or something? Did I hear you correctly?

Mrs Collins : Yes. We have been involved in providing education to a range of parties, including sometimes states and territories in relation to Commonwealth offences.

Senator SINGH: Do you want to explain that in a bit more detail?

Mrs Collins : If we're talking about the states and territories, they've usually got more people on the ground, so they've usually got more direct access to seeing things that might be moving around. We might get tip-offs from states, in relation to what they're seeing, for potential illegal wildlife activity. It can involve, for example, states having authorisations under the Commonwealth legislation to use some of our powers. It can also involve our officers going down, when we get a tip-off, if there's been a seizure of wildlife or those sorts of things.

Senator SINGH: So this education is only to the other state governments, is it?

Mrs Collins : No.

Senator SINGH: Who are you educating?

Mrs Collins : A range of people.

Senator SINGH: Can you tell us?

Mrs Collins : I won't go into too much detail but you mentioned you'd been to Western Australia, the border forces and other places—I think you went to Australia Post.

Senator SINGH: Yes.

Mrs Collins : We've engaged with them. Where our investigations lead us in terms of supply chains, persons of interests or those sorts of things, we'll follow up whatever avenues are available to us.

Senator SINGH: Let's talk about the internal supply chain that is Australia. Do you provide any education to auction houses and antique stores?

Mrs Collins : In the Office of Compliance, to my knowledge, we haven't. But I believe that the department has in the past.

Senator SINGH: A lot of evidence from civil society but also antique stores and auction houses themselves has shown that a lot of these businesses simply don't understand the law, don't know what the law is or obfuscate the law by telling buyers, 'Put it in your handbag and leave the country.' There is clearly a lack of education about what the current law is, and it seems to me that there isn't anything going on, in that sense, from the government to rectify that.

Mrs Collins : I understand that the department has provided evidence previously to this committee about engaging with the auction houses, education programs and those sorts of things.

Senator SINGH: No; there hasn't been any.

Mrs Collins : Okay. It's my understanding that the Wildlife Trade and Biosecurity Branch has done outreach and education with the auction houses on those sorts of things.

Senator SINGH: Can we have details of that? It can be taken on notice.

Mrs Collins : I will take that on notice, because it's not the area that I manage in my branch.

Senator SINGH: That would be very useful for our reporting on this inquiry. Thank you.

Senator COLBECK: You have gone a little bit towards the other agencies and the pathways, like Australia Post, so you would have a good understanding, through your broader intelligence work, of the usual pathways where you would see illegal products coming into Australia?

Mrs Collins : That's correct, yes.

Senator COLBECK: You've only got 54 positions, so you would rely on a lot of eyes within other agencies that you're engaged with, within those pathways, to notify you of any detections of events. For example, the four convictions that you've had this year would have relied on those chains through Customs, biosecurity and all the various agencies that have eyes throughout that system?

Mrs Collins : Yes. Part of our strength in being able to deliver those sorts of outcomes is very much being connected with the intelligence and investigations communities both at the Commonwealth level and the state and territory level, and internationally.

Senator COLBECK: That would give you reasonable coverage over ports of entry but you are still restricted by the scope of inspection for anything other than product that was effectively declared?

Mrs Collins : I wouldn't say we are restricted by that. That's because we do rely on collecting and analysing information and forming intelligence products. Because we're analysing trends, pathways and those sorts of things, it's not keeping—

Senator COLBECK: Your engagement would potentially give you some vision through potential supply chains?

Mrs Collins : That's right, yes. In fact, there are examples, from the intelligence sharing that we've been doing, where some of our intelligence has been used in other countries to make arrests.

Senator COLBECK: So there is information flowing both ways?

Mrs Collins : That's right.

Senator COLBECK: Are there any formal arrangements that you have in respect of that information sharing, or does that rely on some of the broader information sharing arrangements that Australia has?

Mrs Collins : At the moment, we haven't formalised particular arrangements with the Department of Environment and Energy and those broader agencies, other than with the border forces, where we have got access to the border fusion centre. I say that because the Office of Compliance commenced in this new structure just over 12 months ago—we started as the Office of Compliance from July 2017. Part of that is about a new way of doing business, having that outcomes-based focus, investing in our intelligence capability and investing in our risk assessment capability. Part of where we will take next steps in our change process will be to formalise some more of those arrangements. We do find that we do have credibility in the enforcement and intelligence communities that we're working within. We have had joint operations, as I say, both from an investigations perspective and an intelligence perspective. I'm not seeing any blockages at the moment where we are seeing priority activities. We are getting cooperation.

Senator COLBECK: What about direct relationships with similar agencies in source countries for some of these illegally-traded products?

Mrs Collins : We are developing direct relationships with some countries. We're developing close relationships with New Zealand and, as I mentioned, some of the other countries that we've been engaging with in terms of intelligence products and sharing of intelligence resulting in compliance outcomes. Within Australia and some of the Pacific, we are members of the Australasian Environmental Law Enforcement and Regulators network, or AELERT. Through that network, there are working groups that are operational investigations working groups, intelligence working groups and other working groups associated with that. Being Australasian, it does have memberships from environmental law enforcement agencies from the Commonwealth and the states and territories but also, for example, from New Zealand. I think Canada is also a member, and there are a number of Pacific Islands members there as well. That's part of one of the networks that we're involved in, in sharing operational experience and learning from each other.

Senator COLBECK: Any African or South-East Asian nations?

Mrs Collins : In the African and South-East Asian nations, I would say our contacts are more through Interpol and those sorts of arrangements at the moment.

Senator COLBECK: Thank you.

Senator SINGH: Mrs Collins, do you work collaboratively with the UNODC on the combatting of wildlife trafficking?

Mrs Collins : I would probably say that at this stage our engagement would be more through Interpol rather than directly with that group.

Senator SINGH: Is the department, particularly the Office of Compliance, aware of Australians being charged with wildlife trafficking offences in overseas jurisdictions?

Mrs Collins : I would probably have to take that one on notice. I don't have that information in front of me.

Senator SINGH: Okay. I'm referring to a Sydney Morning Herald story on 19 November 2017, 'Australian antiques dealer facing prison term in US for wildlife smuggling'. It's about an Australian, Graham Chen, who was arrested in the US for trafficking ivory and rhino horn in 2017. I'd be surprised if the department, or some part of the department, is not aware of it, because it's a pretty big story, but what I'm interested to know is: do you monitor Australians charged with wildlife-trafficking offences overseas?

Mrs Collins : That would certainly be of interest to us. At that time, I was new to the Commonwealth. I started in October 2016. That's obviously a year later. As I say, I will have to take that one on notice.

Senator SINGH: Okay, I'm happy for you to take it on notice. It says:

His case is part of an underground trade in wildlife items that is thriving in Australia …

That kind of refutes your previous statement about it not being significant.

Mrs Collins : Yes. Okay, I'll look into that and get back to you on notice.

Senator SINGH: Okay. Does the department monitor such people as Mr Chen when they return to Australia?

Mrs Collins : We do have the means to do that, certainly. Particularly where we think that people—whether they're Australian or not Australian—might be engaging in ongoing illicit wildlife trade activity, we have the ability to monitor movements and that sort of thing.

Senator SINGH: Was that yes?

Mrs Collins : Yes.

Senator SINGH: Okay, thanks. I think that's it from me, other than those items that have been taken on notice.

Senator COLBECK: For items that are moved through the conventions and with certificates, is there a process that the department goes through to verify documentation that comes along with those?

Mrs Collins : I understand there is. I'm not hugely familiar with that, because it's dealt with in another area of my department, but I understand that there is, yes.

Senator COLBECK: Okay. That makes the next question hard. I was curious to know to what lengths those inquiries might go. Is it effectively just an examination of the documents and acceptance that they're okay or, for example, are there any databases that reflect some of the certificates that have been issued to give a way to verify their veracity or otherwise?

Mrs Collins : Again, my understanding is that the answer is yes, but I would like to confirm that on notice, because it's managed out of another branch.

Senator COLBECK: Thanks.

CHAIR: There is one more from Senator Singh.

Senator SINGH: You said that you operate under various legislation. I just want to know—and this can be taken on notice—whether there is a kind of specific function, capacity or terms of reference for the Office of Compliance within the department in how you go about fulfilling your work under those pieces of legislation. Obviously we've covered today the fact that the department can only investigate when there is reasonable suspicion, and there is the education, which sounds fairly limited. So I'm just wondering whether there is some kind of specific function or principles that you use?

Mrs Collins : I'm happy to take that on notice. I do know that there's a web page, but it's probably a little out of date. We are working on identifying and publishing what our compliance priorities will be. We're also working on updating our compliance policy. We're well down the pathway of having a compliance framework, with all of those elements from risk assessment to intelligence to our operations and strategies and those sorts of things. I don't think that there's something published at the moment that's up to date, and so I will look—

Senator SINGH: That's fine. I asked that because, obviously, when we talk about this trade, it's seen very much as part of organised crime and as in association with drugs and illegal firearms. If you look at those two distinct illegal activities, there's quite a lot of resources devoted to them by the AFP and Border Force and the like. But it seems to me that, as to ivory and rhino horn—which is just as serious a crime, and is leading to the poaching of tens of thousands of elephants each year, for example, and to the extinction of rhinos—there doesn't seem to be quite as much focus, emphasis or up-to-dateness on this part of organised crime. I know you can't say whether or not you have enough resources, but do you regard the department of environment, where this illegal wildlife trade currently sits, as the most appropriate fit compared to those other kinds of illegal items?

Mrs Collins : I'm not sure exactly what you're asking, but what I can say is that wildlife crime activity is a priority for the Office of Compliance and the department. As I've mentioned, there were four successful prosecutions and convictions last year. We've still got three matters before the court. We've got, as I understand it, about 13 criminal investigations underway. We've got joint activities, from an intelligence and an investigations perspective, with a range of different co-regulators.

Senator SINGH: Notwithstanding that, there is a lot that is not being reported and there is a lot that is being domestically traded within Australia. I referred you to the case of Mr Chen, which is another example, as well as what is online. This afternoon I saw, just by going on Facebook, that in Victoria there is quite a lot of ivory online, which didn't look like it fitted under the CITES requirements, so there is a lot that's not being monitored or investigated and the like. That's why I asked the question as to whether this compliance unit of however many people you have, spread across a range of areas and lots of other different legislation, is the right fit and place for us in seriously combatting and meeting our requirement under CITES to stop this illegal trade?

Mrs Collins : Again, I'm in a position where—

Senator SINGH: It might be hard for you to answer that?

Mrs Collins : Yes. On behalf of the department, that's part of our job. But, to maximise our impact, we do work quite closely with all the co-regulators, as I've said. We do develop intelligence pictures and we've invested quite heavily in our intelligence capability over the last 12 to 18 months, and I'm seeing big differences in terms of what our intelligence is telling us, not only in wildlife trade but across other commodities as well. So, like any other agency, if you were to ask us if we could do with more resources, the obvious answer would be yes, but we are very focused in terms of what the intelligence is telling us, what our risk assessment is telling us and where we're investing our capabilities.

CHAIR: Thank you, Mrs Collins. We've greatly appreciated your time today.