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enforcement of CITES. Consequently, CITES (and related legislation) is not
easy to enforce. In the UK, for example, it requires the cooperation and
coordination of numerous government agencies, non-ministerial departments, criminal justice agencies, government advisory groups and multiagency groups (Maher and Sollund 2016). Prioritising the IWT as a serious
and organised crime in the UK coincided with the development of specialised enforcement units, training for non-specialist enforcers, a commitment
to the collection of intelligence and intelligence-led enforcement, and the
development of partnership work with other enforcement agencies and key
stakeholders. Transnational enforcement displaying effective co-operation,
communication and data-sharing (for example, EU-TWIX—an online
forum and database) has also resulted in successful operations targeting
organised crime groups, (for example, Operation Charm) and has, albeit
rarely, facilitated the return of endangered wildlife to their native habitat
(Border Force 2014).
Animal welfare must also be considered during enforcement. CITES
requires Member States to provide for the welfare of seized and confiscated
wildlife (for example, the UK Heathrow Animal Reception Centre [HARC]),
and includes the IATA LAR, as discussed above, as part of its compliance
expectation. In the UK, these regulations can simplify prosecution in IWT
abuse cases as ‘suffering’ need not be ‘proved’ (as is required by the UK Animal
Welfare Act 2006). Nonetheless, even with these conditions in place, as
previously discussed, animals will suffer harm in transit/trade. The protection
provided for wildlife through LAR, is limited by EU Regulations that employ
old standards (2004)—although the new Memorandum of Understanding
signed between CITES and IATA June 8, 2015, may go some way to rectify
this (IATA 2015). Additionally, CITES (and related legislation) fails to
adequately consider the welfare of seized/confiscated wildlife by not stipulating
rehoming requirements. Few individuals are returned to the wild—most,
thereby, require costly long-term care and rehoming. Consequently, countries

like Norway, which have limited funding and capacity for caring for or
rehoming these animals, resort to euthanasia (Maher and Sollund 2016). In
other cases (UK), wildlife may also be returned to the offending owners or
rehomed to unregulated collectors. It is impossible to determine how prevalent
these practices are as CITES does not require Member States to publicly record
outcomes.
Given the difficulty in enforcing CITES and protecting animal’s welfare in
the wildlife trade, there have been calls to ban the trade in many species (and
their derivatives). Although consideration has previously been given by the
EC to ban the ownership and trade of reptiles, Norway (alongside Iceland) is