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CHINA’S ROLE IN THE FENTANYL CRISIS

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Testimony


CHINA’S ROLE IN THE FENTANYL CRISIS

Vanda Felbab-Brown Friday, March 31, 2023


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Editor's Note:

The following testimony was submitted to the House of Representatives
Subcommittee on National Security, Illicit Finance, and International Financial
Institutions on March 23, 2023, for the “Follow the Money: The CCP’s Business
Model Fueling the Fentanyl Crisis” hearing.

 

Dear Chairman Luetkemeyer, Ranking Member Beatty, and Distinguished Members of
the Subcommittee on National Security, Illicit Finance, and International
Financial Institutions of the Committee on Financial Services:

Thank you for holding this hearing entitled, “Follow the Money: The CCP’s
Business Model Fueling the Fentanyl Crisis.” This is an important issue that
deserves the attention of the House Financial Services Committee and its
Members. I am honored to have this opportunity to submit this testimony as a
statement for the record.


VANDA FELBAB-BROWN


DIRECTOR - INITIATIVE ON NONSTATE ARMED ACTORS


CO-DIRECTOR - AFRICA SECURITY INITIATIVE


SENIOR FELLOW - FOREIGN POLICY, STROBE TALBOTT CENTER FOR SECURITY, STRATEGY,
AND TECHNOLOGY

Twitter VFelbabBrown

I am a senior fellow at the Brookings Institution where I direct The Initiative
on Nonstate Armed Actors and co-direct the Africa Security Initiative. Illicit
economies, such as the drug trade and wildlife trafficking, organized crime,
corruption, and their impacts on U.S. and local security issues around the world
are the domain of my work and the subject of several of the books I have
written. I have conducted fieldwork on these issues in Latin America, Asia, and
Africa. In addition to studying China’s and Mexico’s role in various illegal
economies over the past two decades, I have been directing over the past three
years a new Brookings workstream on China’s role in illegal economies and
Chinese criminal groups around the world.

This testimony draws extensively on two detailed reports I published last year:
“China’s Role in the Smuggling of Synthetic Drugs and Precursors” and “China’s
Role in Poaching and Wildlife Trafficking in Mexico.”

The Brookings Institution is a U.S. nonprofit organization devoted to
independent research and policy solutions. Its mission is to conduct
high-quality, independent research and, based on that research, to provide
innovative, practical recommendations for policymakers and the public.  The
testimony that I am submitting represents solely my personal views, and does not
reflect the views of Brookings, its other scholars, employees, officers, and/or
trustees.


EXECUTIVE SUMMARY

The structural characteristics of synthetic drugs, such as fentanyl, including
the ease of developing similar, but not scheduled, synthetic drugs and their new
precursors — increasingly a wide array of dual-use chemicals — pose immense
structural obstacles to controlling their supply.

U.S. domestic prevention, treatment, harm reduction, and law enforcement
measures are fundamental and indispensable to countering the devastating
fentanyl crisis.

However, given the extent and lethality of the synthetic opioid epidemic in
North America and its likely eventual spread to other parts of the world, even
supply control measures with partial and limited effectiveness can save lives
and thus need to be designed as smartly and robustly as possible.

Three U.S. presidential administrations — those of Barack Obama, Donald Trump,
and Joe Biden — have devoted diplomatic focus to induce and impel China to
tighten its regulations vis-à-vis fentanyl-class drugs and their precursor
chemicals and to more diligently enforce these regulations. China, however, sees
its counternarcotics enforcement, and more broadly its international law
enforcement cooperation, as strategic tools that it can instrumentalize to
achieve other objectives. Unlike the U.S. Government, which seeks to delink
counternarcotics cooperation with China from the overall bilateral geostrategic
relationship, China subordinates its counternarcotics cooperation to its
geostrategic relations. As the relationship between the two countries
deteriorated, China’s willingness to cooperate with the United States declined.
Since 2020, China’s cooperation with U.S. counternarcotics efforts, never high,
declined substantially. In August 2022, China officially announced that it
suspended all counternarcotics and law enforcement cooperation with the United
States.

There is little prospect that in the absence of significant warming of the
overall U.S.-China bilateral relationship, China will meaningfully intensify its
anti-drug cooperation with the United States. U.S. punitive measures, such as
sanctions and indictments, are unlikely to change that.

While China takes counternarcotics diplomacy in Southeast Asia and the Pacific
very seriously, its operational law enforcement cooperation tends to be highly
selective, self-serving, limited, and subordinate to its geopolitical interests.
Beijing rarely acts against the top echelons of Chinese criminal syndicates
unless they specifically contradict a narrow set of interests of the Chinese
Government. Chinese criminal networks provide a variety of services to Chinese
legal business enterprises, including those connected to government officials
and the Chinese Communist Party (CCP).

China’s enforcement of precursor and fentanyl analog controls is also
complicated by the challenge of systemic corruption in China and the incentive
structures within which Chinese officials operate. Chinese Government officials
also unofficially extend the umbrella of party protection and government
authority to actors who operate in both legal and illegal enterprises as well as
to outright criminal groups.

There is little visibility into China’s enforcement of its fentanyl regulations.
But in the case of fentanyl and its precursor chemicals, small and middle-level
actors in the chemical and pharmaceutical industries also appear to be the key
perpetrators of regulatory violations and source for Mexican criminal groups. In
the case of fentanyl and its precursors, Chinese triads – mafia-like organized
crime groups — do not dominate drug production and trafficking.

Chinese actors have come to play an increasing role in laundering money for
Mexican cartels, including the principal distributors of fentanyl to the United
States — the Sinaloa Cartel and Cartel Jalisco Nueva Generación (CJNG). Chinese
money laundering brokers mostly manage to circumvent the U.S. and Mexican formal
banking systems. Other money laundering and value transfers between Mexican and
Chinese criminal networks include trade-based laundering, value transfer
utilizing wildlife products, such as protected and unprotected marine products
and timber, real estate, cryptocurrencies, casinos, and bulk cash.

The increasing payments for drug precursors originating in China in wildlife
products coveted there is particularly noteworthy. This method of payment
engenders multiple threats to public health and safety, economic sustainability,
food security, and global biodiversity. If this wildlife trafficking spreads
dangerous zoonotic diseases, it could even pose a threat to national security.

But this convergence of illicit economies also provides the United States with
new opportunities for intelligence gathering and law enforcement actions, even
as China-Mexico law enforcement cooperation against the trafficking of fentanyl
and precursor agents for meth and synthetic opioids remains minimal.

Mexican drug cartels are expanding their role into crimes against nature, and
they are also increasingly infiltrating and seeking to dominate a variety of
legal economies in Mexico, including fisheries, logging, and agriculture and
extorting an even wider array of legal economies. For example, Mexican organized
crime groups, especially the Sinaloa Cartel, seek to monopolize both legal and
illegal fisheries along the entire vertical supply chain.

There may also be a growing involvement of Chinese fishing ships in facilitating
drug trafficking.

And there is the possibility that Chinese fishing flotillas or individual
vessels operating around the Americas and around the world may be equipped with
spy equipment for collecting intelligence on behalf of China.

Just like with China, Mexico’s cooperation with U.S. counternarcotics efforts is
profoundly hollowed out. The March 2023 crisis in U.S.-Mexico law enforcement
cooperation is merely the visible tip of the iceberg of how Mexico has
eviscerated counternarcotics and law enforcement cooperation with the United
States since 2019 and particularly since 2020 when U.S. law enforcement
activities in Mexico became shackled and undermined by Mexican Government
actions after the U.S. arrest of former Mexican Secretary of Defense Gen.
Salvador Cienfuegos.

Because of the diversification of the economic portfolio of Mexican cartels and
Chinese criminal networks, to focus primarily on drug seizures close to their
source is no longer an adequate approach for effectively countering drug
smuggling networks that send pernicious drugs to the United States or their
financial systems.

Countering poaching and wildlife trafficking from Mexico and thwarting illegal
fishing in Mexican and Latin American waters are increasingly important aspects
of countering Mexican drug-trafficking cartels and their damaging effects in the
United States and Mexico.

I submit that to attempt to induce better cooperation from China, the United
States should:

 * continue to emphasize Beijing’s interests in China’s reputation as a global
   counternarcotics policy leader and leverage multilateral fora to do so;

 * continue requesting that China take down websites that illegally sell
   synthetic opioids to Americans or to Mexican criminal groups;

 * strengthen U.S. cooperation with allies and partners to send coordinated
   messages to push Beijing in preferred directions germane to law enforcement
   efforts, including greater monitoring and enforcement against sale of
   precursors chemicals to criminal groups and more robustly and broadly-cast
   anti-money laundering efforts;

 * engage China bilaterally and multilaterally to adopt more robust anti-money
   laundering standards in its banking and financial systems and trading
   practices;

 * encourage the spread of best practices developed in the China’s
   pharmaceutical and chemical sectors, including encouraging the industries to
   adopt self-regulation systems to detect and police suspicious activities, by
   adopting “know-your-customers” policies, not selling precursors to likely
   drug traffickers, and alerting law enforcement authorities about such buyers;

 * be ready to sanction, including through termination of access to U.S.
   markets, Chinese firms that violate the best practices protocols and take
   further actions against those indicted by the U.S. Government;

 * develop packages of leverage on prominent Chinese pharmaceutical and chemical
   industry officials;

 * continue developing legal indictment portfolios against Chinese traffickers
   and their companies, and

 * incentivize international partners to act seriously against Chinese drug
   trafficking and criminal networks.

To attempt to induce better cooperation from Mexico, the United States also has
new Policy tools to explore.

Designating Mexican cartels as Foreign Terrorist Organizations (FTOs) would
enable intelligence gathering and strike options for the United States military,
such as against some fentanyl labs in Mexico. But the number of available strike
targets in Mexico would be limited and would not robustly disrupt the criminal
groups. Nor would the FTO designation add authorities to the economic sanctions
and anti-money laundering and financial intelligence tools that the
already-in-place designation of Transnational Criminal Organization (TCO)
carries.

Moreover, such unilateral U.S. military actions in Mexico would severely
jeopardize relations with our vital trading partner and neighbor and the FTO
designation could significantly limit and outright hamper U.S. foreign policy
options and measures.

Instead, the United States should:

 * consider significantly intensifying border inspections; and
 * develop packages of leverage, including indictment portfolios, against
   Mexican national security and law enforcement officials and politicians who
   undermine and sabotage rule of law cooperation with the United States.

Importantly, to effectively counter the fentanyl-smuggling actors, the United
States should expand and smarten up its own measures against criminal actors,
including by:

 * truly adopting a whole-of-government approach to countering
   fentanyl-smuggling entities;

 * authorizing a wide range of U.S. Government agencies, including the
   Departments of State and Defense, to support U.S. law enforcement against
   Mexican and Chinese criminal actors and fentanyl trafficking and crimes
   against nature;

 * collecting relevant intelligence on crimes against nature to understand
   criminal linkages to foreign governments and criminal groups and elevate such
   intelligence collection in the U.S. National Intelligence Priorities
   Framework;

 * expanding the number and frequency of participation of U.S. wildlife
   investigators and special agents in Organized Crime Drug Enforcement Task
   Forces (OCDETF);

 * increasing the number of U.S. Fish and Wildlife Service special agents and
   investigators, flatlined since the 1970s even as the value of wildlife
   trafficking has significantly increased since then; and

 * designating wildlife trafficking as a predicate offense for wiretap
   authorization.


KEY ASPECTS OF CHINA’S ROLE AS SOURCE OF FENTANYL AND FENTANYL PRECURSORS

Synthetic opioids are the source of the deadliest and unabating U.S. drug
epidemic ever. Since 1999, drug overdoses have killed over 1 million
Americans,[1] a lethality rate that has increased significantly since 2012 when
synthetic opioids from China began supplying the U.S. demand for illicit
opioids. In 2021, the number of fatalities was 106,699;[2] and in 2022, it is
estimated at 107,477.[3] Most of the deaths are due to fentanyl, consumed on its
own or mixed into fake prescription pills, heroin, and increasingly
methamphetamine and cocaine.

Since the Barack Obama administration, the United States has devoted significant
diplomatic capital to get China to tighten its regulations vis-à-vis
fentanyl-class drugs and to more diligently enforce these regulations.

After years of intense U.S. diplomacy, Chinese President Xi Jinping announced at
the December 2018 G-20 summit that China would place the entire class of
synthetic opioids on a regulatory schedule.[4] According to former and current
U.S. Government officials and international drug policy and China experts, the
U.S. request that China schedule an entire class of drugs that had precipitated
the announcement was a significant ask within the U.S.-China bilateral
relationship.[5] China had to pass new laws to be able to do so.[6]

The United States is the only other major country that has controlled the entire
class of fentanyl drugs — in the U.S. case, only on a temporary basis, a
decision that the U.S. Congress has yet to make permanent.[7]

But even though China placed the entire class of fentanyl-type drugs and two key
precursors under a controlled regulatory regime in May 2019, it remains the
principal (if indirect) source of U.S. fentanyl. Fentanyl scheduling and China’s
adoption of stricter mail monitoring has created some deterrence effects.
Instead of finished fentanyl being shipped directly to the United States, most
smuggling now takes place via Mexico. Mexican criminal groups source fentanyl,
fentanyl precursors, and increasingly pre-precursors from China, and then
traffic finished fentanyl from Mexico to the United States. Scheduling of
fentanyl and its precursors in China is not sufficient to stem fentanyl flows to
the United States.

China sees counternarcotics and more broadly international law enforcement
cooperation as strategic tool that it can leverage to achieve other objectives.
As Beijing’s hopes for prospects of improvements in U.S.-China relations have
declined, so too has China’s willingness to coordinate with Washington on
counternarcotics objectives.

The United States blames China for poor domestic enforcement of its regulations,
inadequate actions against Chinese drug smugglers and money launderers, and
insufficient regulatory oversight of its non-scheduled chemicals. Highlighting
that it does not have any fentanyl abuse problem and thus that its regulatory
actions are motivated purely to help the United States, China rejects
Washington’s claims and blames the opioid epidemic solely on America’s internal
failings. The extent of counternarcotics cooperation — or its absence — remains
determined by the state of the U.S.-China overall geopolitical relationship,
which has deteriorated over the past decade and shows few prospects for
improvement. Thus, the hope that despite the geopolitical rivalry,
counternarcotics could prove a domain of U.S.-China cooperation has not yet
materialized.

There is little visibility into China’s enforcement of its fentanyl regulations,
but China’s enforcement likely remains limited. U.S.-China counternarcotics
cooperation remains fraught, and from the U.S. perspective deeply inadequate.
Rejecting U.S. blame of China for the opioid epidemic and emphasizing U.S.
responsibilities for that calamity, Beijing used to point to its “benevolence”
in anti-drug cooperation.[8] However, China’s willingness to act on
U.S.-provided intelligence to counter Chinese fentanyl- and fentanyl-precursor
smuggling rings has been long limited and has significantly tapered off since
2019.

The enforcement of precursor and fentanyl analog controls is also complicated by
with the challenge of systemic corruption in China and the incentive structures
within which Chinese officials operate. Even with President Xi’s intensive
anti-corruption efforts,[9] designed mainly to consolidate his own power,
eliminate independent sources of influence, and improve the image of the Chinese
Communist Party (CCP), many mid-level and senior CCP officials remain
rent-seeking, with their bureaucratic and power advancement still linked
principally to job creation and economic growth in their jurisdictions, even if
those objectives are accomplished through means that are illegal or
problematic.[10] Given the political power of China’s chemical and
pharmaceutical industries and the extent of tax revenue and jobs they generate,
many Chinese officials are reluctant to monitor, investigate, prosecute, or
otherwise cross significant industry players. Small and middle-level actors are
more likely to become targets if and when enforcement action is taken.

But in the case of fentanyl and its precursor chemicals, small and middle-level
actors in the chemical and pharmaceutical industries also appear to be the key
perpetrators of regulatory violations and source for Mexican criminal groups.
Moreover, given that fentanyl is a very small source of earnings for China’s
chemical industry, powerful Chinese industry actors have little interest in
protecting fentanyl and fentanyl precursor production, beyond simply seeking to
minimize any oversight into their production and business practices.

Informally, Chinese Government officials have long become accustomed to
unofficially extending the umbrella of party protection and government authority
to actors who operate in both legal and illegal enterprises as well as to
outright criminal groups.[11] The frequent appointments of former party
officials to business boards could facilitate monitoring and oversight, but
frequently enables this unofficial protection and facilitates corruption.
However, this clear pattern of behavior is not centrally organized, systemically
endorsed, or openly tolerated behavior. It has also been weakened by Xi’s
post-2012 anti-corruption drives.[12] Even so, a seemingly very dominant and
all-powerful state is riddled with “bureaucratic slack,” enforcement
inefficiencies, and a proclivity to seek legal and bureaucratic loopholes.
Moreover, different provinces often develop distinct forms of illegal
bureaucratic protection, complicating uniform, systemic, and efficient
application of rule of law.[13]

Overall, as with other countries such as Australia, China subordinates its
counternarcotics cooperation to the geostrategic relationship with the United
States. As the relationship between the two countries deteriorated, China’s
willingness to cooperate with the United States declined. There is little
prospect that in the absence of significant warming of the overall U.S.-China
bilateral relationship, China would significantly intensify its anti-drug
cooperation with the United States. U.S. punitive measures, such as sanctions
and drug indictments, are unlikely to change that.

The evolution of China’s posture toward illicit methamphetamine production in
China and the trafficking of meth precursors from China provides important
insights into the patterns and limitations of China’s international law
enforcement cooperation. As with fentanyl precursors, China emphasizes that it
cannot act against nonscheduled substances.

China takes counternarcotics diplomacy in Southeast Asia and the Pacific very
seriously, but its operational law enforcement cooperation tends to be highly
selective, self-serving, limited, and subordinated to its geopolitical
interests.

Nonetheless, after years of refuting international criticism for its role in
methamphetamine precursor smuggling amid burgeoning meth production in Asia,
China has intensified its regional law enforcement cooperation at least with
some countries. It has also mounted stronger internal regulatory measures even
for nonscheduled drugs and has undertaken monitoring and interdiction
operations.

Yet Beijing rarely acts against the top echelons of Chinese criminal syndicates
unless they specifically contradict a narrow set of interests of the Chinese
Government. Chinese criminal groups cultivate political capital with Chinese
authorities and government officials abroad by also promoting China’s political,
strategic, and economic interests.

The intermeshing and mergers between Chinese legal and illegal economic
enterprises across the Southeast Asia significantly takes places in Special
Economic Zones in Southeast Asia, such as the Golden Triangle Special Economic
Zone (SEZ) in northern Laos near the border with Myanmar and Thailand. Various
U.S. and regional law enforcement officials and international drug policy
experts believe that the presence of Chinese and regional organized crime groups
in the many of the Mekong region’s at least 74 SEZs[14] is large and that the
SEZs feature extensive illegal economies, such as drug, wildlife, and human
trafficking.[15] Yet it does not appear that the Chinese Government has
exhibited interest in cooperating with authorities in those countries in sharing
intelligence or acting against Chinese nationals in China implicated in likely
criminality in the SEZs.[16]

Nonetheless, in the case of fentanyl and its precursors, Chinese triads —
mafia-like organized crime groups — do not dominate drug production and
trafficking. The trafficking of fentanyl and its precursors is conducted by a
wide panoply of Chinese criminal actors, from small family-based and specialized
groups to businesses that also conduct highly diverse legal trade with organized
crime groups. Fentanyl and fentanyl-precursor trafficking from China does exist
in stark contrast to methamphetamine trafficking in the Asia-Pacific region
which is thoroughly controlled and dominated by the Chinese triads.

In the Western Hemisphere, Mexican drug trafficking groups, especially the
Sinaloa Cartel and CJNG, dominate the trafficking and wholesale distribution of
fentanyl and methamphetamine into the United States. They have become the
principal buyers of finished fentanyl from China and India as well as fentanyl
precursors and pre-precursors from both countries. Increasingly, the precursor
and pre-precursor trade is the method in which the illicit transactions between
China and Mexico take place,[17] with fentanyl produced from the precursors and
pre-precursors in Mexico.

The triads’ franchise-like network organization enhances the groups’ resilience
and allows them to absorb considerable financial losses resulting from seizures
without bankrupting the groups. The ease of production and smuggling of
synthetic drugs further enhance this resilience.

Many of the Chinese smuggling networks are connected in complex ways to legal
Chinese businesses. Indeed, the growth of their power in the second half of the
20th century is deeply connected to the growth of China’s legal economy from the
late 1970s onward. After their destruction during Mao’s era, the triads in
southern China resurrected themselves on the coattails of the growth of China’s
legal economy and businesses. But as an expert of Chinese organized crime groups
put it, “it is really the synthetic drugs revolution that brought bags of money
back to the triads and put a spring into their step.”[18]

The triads’ connections to China’s legal economy and enterprises remain
significant and essential. Like many criminal groups around the world, the
triads use legal businesses as fronts for their illegal operations and
money-laundering, and they plug into the infrastructure and transportation
networks of legal businesses. But they also provide a variety of services to
Chinese legal business enterprises, including those connected to government
officials and the CCP, such as in the promotion and facilitation of Chinese
businesses abroad, the building up of networks of political influence for China
abroad, and the informal information gathering and enforcement against Chinese
fugitives and Chinese diaspora outside of China, such as to prevent criticism of
the regime.

China-Mexico law enforcement cooperation against the trafficking of fentanyl and
precursor agents for meth and synthetic opioids remains minimal. As with the
United States, China rejects co-responsibility and emphasizes that controls and
enforcement are matters for Mexico’s own customs authorities and other Mexican
law enforcement to address. China has maintained this posture even as the
presence of Chinese criminal actors in Mexico, including in money laundering and
illicit value transfers (which increasingly feature barter of wildlife products
for synthetic drug precursors) are expanding rapidly.


MONEY LAUNDERING BY CHINESE ACTORS AND VALUE TRANSFER THROUGH WILDLIFE TRADE AND
TRAFFICKING

Chinese actors have come to play an increasing role in laundering money for
Mexican cartels and criminal groups across Latin America (as well as Europe) by
using Chinese businesses located in Mexico, the United States, and China, and
Chinese informal money transfer systems.[19] These informal systems emerged in
an effort to avoid banking fees and scrutiny and China’s capital flight
controls: China’s laws allow Chinese citizens to move only $50,000 from China
abroad per year.

Drug trafficking groups, including in Latin America, are in turn flush with vast
sums of hard cash, such as euros and dollars, sought after in China. The
National Drug Intelligence Center of the U.S. Department of Justice estimated in
2008 that Mexican and Colombian drug trafficking groups earned between $18
billion and $39 billion a year from wholesale drug sales.[20] In 2010, the U.S.
Department of Homeland Security (DHS) estimated bulk cash smuggling to Mexico at
between $19 billion and $29 billion annually.[21] Other estimates from the
United Nations Office on Drugs and Crime, research organizations, and news media
have assessed Mexico’s drug export revenues to have been in the range of $6
billion to $21 billion a year between 2010 and 2018.[22]

Although it is not clear what percentage of the cartels’ illicit profits is
laundered through Chinese money transfer networks, U.S. officials fear that the
effectiveness of the Chinese networks’ money laundering is such that it is even
displacing established Mexican and Colombian money launderers and putting the
flows of cartel money even more out of reach of U.S. law enforcement.[23]
Chinese operators heavily tax Chinese citizens eager to get money out of China,
and are thus able to tax the drug cartels lightly and undercut other money
launderers.[24] In some cases, a particular Chinese money laundering network
managed to get itself hired by both the Sinaloa Cartel and the CJNG; in other
cases, they worked exclusively with just one of them.[25]

As described in detail in Drazen Jorgic’s Reuters special report,[26] the
Chinese brokers mostly manage to bypass the U.S. and Mexican formal banking
systems, thus evading anti-money laundering measures and simplifying one of the
biggest challenges for the cartels, namely moving large amount of bulk money
subject to law enforcement detection. The only interface with the formal banking
system takes place in China, into which U.S. law enforcement agencies have
little-to-no visibility. Using encrypted platforms, burner phones, and codes,
cartel representatives hand over bulk cash to Chinese contacts. The contact
brings the money to U.S.-based Chinese businesses with bank accounts in China,
and via a phone app from that account transfer the yuan equivalent to other
accounts in China, bypassing U.S. bank fees and scrutiny. Chinese money
launderers then perform similar “mirror transactions” to convert the money into
pesos, utilizing Chinese businesses with Mexican bank accounts.


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   By Vanda Felbab-Brown
   2025

 * URBAN VIOLENCE, RESILIENCE AND SECURITY: GOVERNANCE RESPONSES IN THE GLOBAL
   SOUTH
   
   Edited by Michael R. Glass, Taylor B. Seybolt, and Phil Williams;
   Contributions by Enrique Desmond Arias, Roberto Briceño-Leon, Jon Coaffee,
   Savannah Cox, Daniel E. Esser, Vanda Felbab-Brown, Michael R. Glass, Kim
   Gounder, Brij Maharaj, Eduardo Moncada, Daniel Núñez, Taylor B. Seybolt, and
   Phil Williams
   2022

 * ORGANIZED CRIME AND ILLICIT TRADE: HOW TO RESPOND TO THIS STRATEGIC CHALLENGE
   IN OLD AND NEW DOMAINS
   
   Contributions by Vanda Felbab-Brown
   2018

U.S. investigations and court cases revealed that the Bank of China was among
the Chinese financial firms utilized by Chinese operators to launder the money
of Mexican cartels.[27] In the investigations of the role of Chinese money
laundering networks for Mexican cartels, U.S. officials have often been
frustrated with the lack of cooperation from Chinese officials. Chinese
officials have, however, emphasized that China is ready and willing to “destroy
drug cartels and drug-related money laundering networks” and cooperate with the
U.S. on the “principle of respecting each other’s laws, equality, and mutual
benefit,” adding that the U.S. anti-money laundering requests focused on
“legitimate enterprises and individuals” in China without the United States
providing evidence of their criminal and drug involvement.[28]

Other money laundering and value transfers between Mexican and Chinese criminal
networks include trade-based laundering, value transfer utilizing wildlife
products, such as protected and unprotected marine products and timber, real
estate, cryptocurrencies, casinos, and bulk cash — though it is not clear what
percentage of laundering any of these methods account for.[29] An example of
trade-based laundering includes Chinese launderers for CJNG buying shoes in
China and reselling them in Mexico to give the cartel the necessary cash.[30]
The casino laundering takes place in ways similar to the informal money
transfers: Bulk cash is brought to a casino in Vancouver, for example, where the
cartel-linked individual loses it while his money laundering associate in Macau
wins and pays the Chinese precursor smuggling networks.[31]

The increasing payments for drug precursors in wildlife products coveted in
China — for Traditional Chinese Medicine, aphrodisiacs, other forms of
consumption, or as a tool of speculation, such as in the case of the highly
prized swim bladder of the endemic and protected Mexican totoaba fish poached
for Chinese markets — constitute yet other method of illicit value transfer.[32]
Other wildlife commodities used for money laundering, tax evasion, and as barter
payments between Mexican cartels and Chinese precursor networks include abalone,
jellyfish, and lobster.[33] Instead of paying in cash, Chinese traffickers are
paid in commodities. The amount of value generated by wildlife commodity
payments, likely in the tens of millions of dollars, may not cover all of the
precursor payment totals, though the latter likely also amount to tens of
millions of dollars.[34] Wildlife barter may not displace other methods of money
laundering and value transfer. But the increasing role of this method can
devastate natural ecosystems and biodiversity in Mexico as the cartels steadily
seek to legally and illegally harvest more and more of a wider range of animal
and plant species to pay for drug precursors.

The connections between the illegal drug trade and the timber and wildlife trade
and trafficking from Mexico to China are all the more significant as poaching
and wildlife trafficking in Mexico is increasing and Mexican drug cartels are
expanding their role in crimes against nature.

They are also increasingly taking over legal economies in Mexico, including
logging, fisheries, and various agricultural products such as avocados, citrus,
and corn in parts of Mexico.

Wildlife trafficking from Mexico to China receives little international
attention, but it is growing, compounding the threats to Mexican biodiversity
posed by preexisting poaching for other markets, including the United States.
Since Mexican criminal groups often control extensive territories in Mexico
which become no-go-zones for government officials and environmental defenders,
visibility into the extent of poaching, illegal logging, and wildlife
trafficking in Mexico is limited. It is likely, however, that the extent of
poaching and trafficking, including to China, is more pervasive and widespread
than commonly understood or even considered. Poaching and wildlife trafficking
can rapidly deplete this biodiversity.

Terrestrial and marine species, as well as timber, illegally harvested in Mexico
for Chinese markets increasingly threaten Mexico’s biodiversity, that accounts
for some 12 percent of the world’s biodiversity. Among the species poached in
Mexico and smuggled to China, sometimes via the United States, are reptiles, sea
cucumbers, totoaba, abalone, sharks, and increasingly also likely jaguars as
well as various species of rosewood.

Legal wildlife trade from Mexico to China, such as in sea cucumbers and
crocodilian skins, provides cover for laundering poached animals. Illegal
fishing accounts for a staggering proportion of Mexico’s fish production, but
even the legitimate fishing and export industry provides a means to channel
illegally-caught marine products to China.

In Mexico, far more so than in other parts of the world, poaching and wildlife
trafficking for Chinese markets is increasingly thickly intermeshed with drug
trafficking, money laundering, and value transfer in illicit economies.

Organized crime groups across Mexico, especially the Sinaloa Cartel, seek to
monopolize both legal and illegal fisheries along the entire vertical supply
chain. Beyond merely demanding a part of the profits, they dictate to legal and
illegal fishers how much the fishers can fish, insisting that the fishers sell
the harvest only to the criminal groups, and that restaurants, including those
catering to international tourists, buy fish only from the criminal groups.
Mexican organized crime groups set the prices at which fishers can be
compensated and restaurants paid for the cartels’ marine products. The criminal
groups also force processing plants to process the fish brought in by the
criminal groups and issue it with fake certificates of legal provenance for
export into the United States and China. And they charge extortion fees to
seafood exporters.

This takeover of the fisheries by Mexican criminal groups puts Chinese traders
further into direct contact with them and alters the relationship patterns.
Whereas 10 to 15 years half ago, Chinese traders in legal wildlife commodities
and illegal wildlife products dealt directly with local hunters, poachers, and
fishermen, increasingly Mexican organized crime groups forcibly inserted
themselves as middlemen, dictating that producers need to sell to them and that
they themselves will sell to the Chinese traders and traffickers who move the
product from Mexico’s borders to China.

Mexican criminal groups are also expanding into illegal fishing outside of
Mexico. For example, when the overharvesting of sea cucumber in Yucatán, Mexico
for markets in China tapered off as a result of the sea cucumber population
crash, Mexican organized crime groups that operate in Yucatán started bringing
to their seafood collection hubs fish illegally caught in Costa Rica and
elsewhere in Latin America.[35] Yucatán is also an important hub for cocaine
trafficking.

There have long been suspicions about the extent to which Latin American fishing
fleets are also engaged in the smuggling of drugs such as cocaine to the United
States.[36] The penetration of legal fisheries by Mexican cartels further
facilitates their drug smuggling enterprise.

Similarly, massive Chinese fishing fleets have long engaged in illegal fishing,
sometimes devastating marine resources in other countries’ exclusive economic
zones. However, there also appears to be a growing involvement of Chinese
fishing ships in drug trafficking, compounding the extensive problem of Chinese
cargo vessels carrying contraband such as drugs and their precursors as well as
wildlife.[37]

And there is the possibility that Chinese fishing flotillas or individual
vessels operating around the Americas and elsewhere in the world may carry spy
equipment collection intelligence for China.

As in illegal logging in Mexico, the interest of Chinese traders in an animal or
plant species and efforts to source them in Mexico on a substantial scale for
Chinese markets attract the attention of Mexican criminal groups. The Chinese
Government, for the most part, rejects China’s responsibility for poaching and
wildlife trafficking in Mexico and insists that these problems are rather for
the Mexican Government to solve. Prevention and enforcement cooperation has been
minimal and sporadic. The Chinese Government has not been keen to formalize
either China-Mexico or China-Mexico-United States cooperation against wildlife
trafficking, preferring informal case-by-case cooperation.

Nonetheless, under intense international pressure, the Chinese Government moved
beyond seizures of the totoaba swim bladder smuggled to China from Mexico and in
2018 mounted several interdiction raids against retail markets. These raids
ended the openly-visible and blatant sales of illegal wildlife commodities. Such
retail sales moved behind closed doors and onto private online platforms. But it
does not appear that China has sustained efforts to counter the now-more hidden
illegal retail and has mounted raids against clandestine sales.

Mexican environmental protection regulations and enforcement agencies have been
weakened by actions of the Andrés Manuel López Obrador administration, even as
Mexican natural resources are increasingly under threat from organized crime and
wildlife traffickers. Mexican environmental agencies lack mandates, personnel,
and equipment to prevent and stop environmental crime. Government officials,
legal traders in wildlife commodities, and even law enforcement agencies in
Mexico are systematically corrupted and intimidated by organized crime and the
poor rule of law environment facilitates poaching, illegal logging, and wildlife
trafficking to China.

Preventing far greater damage to Mexico’s biodiversity from illegal harvesting
and poaching and wildlife and timber trafficking requires urgent attention in
Mexico with far more dedicated and potent resources, as well as meaningful
international cooperation, to identify and dismantle smuggling networks and
retail markets.

Importantly, countering poaching and wildlife trafficking from Mexico and acting
against illegal fishing off Mexico and around Latin America is increasingly an
important element in countering Mexican drug-trafficking cartels. They have
diversified their business portfolios into various other forms of illegal trade
beyond as well as into legal economies. Primarily focusing on drug seizures
close to their source is no longer sufficient to effectively counter their
networks or finances.


THE COLLAPSE OF CHINA’S AND MEXICO’S COOPERATION WITH U.S. COUNTERNARCOTICS
EFFORTS

Even for U.S. and international law enforcement and drug policy officials, let
alone drug policy experts, there is limited visibility into China’s internal law
enforcement actions. This lack of visibility has only intensified since January
2020 when China became the focus of a negative international spotlight due to
the outbreak of the COVID-19 pandemic. As a result, China reduced and even
stopped sharing information about how many inspections of pharmaceutical
companies it undertook, how many anti-fentanyl and anti-precursor raids it
conducted within China, and how many Chinese nationals authorities apprehended
or indicted on fentanyl or precursor trafficking charges.[38]

The most prominent case of prosecution and sentencing of fentanyl traffickers in
China resulted in the conviction of nine Chinese nationals for drug trafficking
in Hebei province. In 2017, the U.S. Drug Enforcement Administration (DEA)
provided their Chinese counterparts with its intelligence that led to the
arrests.[39] U.S. officials were invited to the sentencing. The case remains
perhaps the high mark of U.S.-China counternarcotics cooperation. But it took
place when Beijing was still hoping that an improvement in U.S.-China relations
was possible and saw counternarcotics cooperation as a mechanism to obtain it.
As Beijing’s perception of the likelihood of any improvement in relations has
eroded, so too has its willingness to explore coordination on counternarcotics
issues.

It does not appear that other high-profile prosecutions have taken place in
China since. There also do not appear to be cases of Chinese law enforcement
officials prosecuting other individual companies or traders for violations of
the May 2019 regulation. However, it is difficult to make assessments of China’s
internal law enforcement actions as China has become a black hole for visibility
into its internal law enforcement actions.[40] That said, after years of U.S.
requests, China finally agreed to allow the DEA to open an office in Shanghai,
somewhat expanding access for U.S. law enforcement agents in the country.[41]

Worrisomely, since the 2017 collaboration, Beijing has not followed up on other
major U.S. indictments of Chinese nationals on drug trafficking charges.
Consequently, in August 2019, the U.S. Treasury Department designated the Zheng
Cartel, its leader Fujing Zheng, and his father Guanghua Zheng as violators of
the Kingpin Act. In July 2020, Treasury added four other cartel operatives and
the Global United Biotechnology Inc. (a storefront for the Cartel) to the
designation.[42] With operations in Mexico and cover companies including
veterinary care, computer and other retail, and chemical companies, the cartel
has been manufacturing and selling fentanyl and other drugs to the United States
and 24 other countries. But Chinese authorities have not moved against the
indicted individuals who remain at large.

After the visit of then House Speaker Nancy Pelosi to Taiwan in August 2022,
China officially announced that it suspended all of its counternarcotics and law
enforcement cooperation with the United States.[43]

Just like with China, Mexico’s cooperation with U.S. counternarcotics efforts is
profoundly hollowed out. In recent weeks, Mexican President Andrés Manuel López
Obrador has taken to falsely denying that fentanyl is produced in Mexico,
deceptive statements echoed at his behest by other high-level Mexican officials
and agencies.[44] Blaming fentanyl use in the United States on U.S. moral and
social decay, including American families not hugging their children enough (the
statement an apparent nod to his strategy of confronting Mexican criminals with
“hugs and not bullets”), the Mexican President also proceeded to deny that
fentanyl is increasingly consumed in Mexico.[45] With his statements, President
López Obrador is not just unwittingly (or knowingly) echoing China’s rhetoric,
but also publicly dismissing two decades of a policy of shared responsibility
for drug production, trafficking, and consumption between United States and
Mexico.

But this latest crisis is merely the visible tip of the iceberg of how Mexico
has eviscerated counternarcotics and law enforcement cooperation with the United
States during the López Obrador administration. When President López Obrador
assumed office in December 2018, he started systematically weakening that
collaboration. From the beginning of his administration, he has sought to
withdraw from the Merida Initiative, the U.S.-Mexico security collaboration
framework signed during the Felipe Calderón administration. And he sought to
redefine the collaboration extremely narrowly as merely U.S. assistance to
Mexico in reducing demand for drugs in Mexico while the United States focused on
stopping the flow of drug proceeds and weapons to Mexico and reducing demand at
home. Previous Mexican governments also certainly sought a significant increase
in U.S. law enforcement focus on those two types of illicit flows, but were
willing to collaborate also inside Mexico.

After the United States arrested former Mexican Secretary of Defense Gen.
Salvador Cienfuegos in October 2020 for cooperation with a vicious Mexican drug
cartel, President López Obrador threatened to end all cooperation and expel from
Mexico all U.S. law enforcement personnel.[46] To avoid that outcome, the Trump
administration handed Gen. Cienfuegos over to Mexico where he was rapidly
acquitted.

But despite this significant U.S. concession, Mexico’s counternarcotics
cooperation remained limited. Meanwhile, U.S. law enforcement activities in
Mexico became shackled and undermined by a December 2021 Mexican national
security law on foreign agents.[47] As a former high-level Drug Enforcement
Administration (DEA) official Matthew Donahue stated, since then and because of
the continually immense level of corruption and cartel infiltration in Mexican
security agencies, Mexican law enforcement spends more time surveilling DEA
agents than it does cartel members.[48]

With the threat of Mexico’s unilateral withdrawal from the Merida Initiative,
the United States government worked hard to negotiate a new security framework
with Mexico — The U.S.-Mexico Bicentennial Framework for Security, Public
Health, and Safe Communities[49] — in the fall of 2021. The United States
emphasized the public health and anti-money-laundering elements of the
agreement, as the Mexican government sought. The Framework reiterates multiple
dimensions of counternarcotics cooperation, including law enforcement.

In practice, however, the Mexican government actions and cooperations on its
side of the U.S.-Mexico border remain profoundly inadequate, including and
particularly in law enforcement actions to counter the Mexican criminal groups
and their production and trafficking of fentanyl.

The U.S.-Mexico law enforcement cooperation has thus been only limping. The
Mexican government has conducted some interdiction operations based on U.S.
intelligence, and some collaboration has persisted at the sub-federal level in
Mexico. While the DEA operations in Mexico remain hampered and limited, other
U.S. law enforcement actors in Mexico have been able to induce some cooperation,
with some Mexican government agencies even sharing some intelligence with the
United States.

Crucially, as DEA Administrator Anne Milgram stated in her recent Senate
testimony,[50] the Mexican government continues to be unwilling to share samples
and information from its claimed lab busts and fentanyl and fentanyl precursor
seizures. It is still not allowing the participation of DEA agents, even in only
an observer role, in the interdiction operations it claims it has conducted.
Extraditions of indicted drug traffickers to the United States from Mexico also
remain limited.

There is no doubt that Mexico’s law enforcement cooperation with the United
States has dramatically weakened and is troublingly inadequate.


CONCLUSIONS AND POLICY IMPLICATIONS AND RECOMMENDATIONS

As vast numbers of Americans are dying of fentanyl overdose and Chinese and
Mexican criminal groups expand their operations around the world and into a vast
array of illegal and legal economies, the United States finds itself in hollowed
out and weak cooperation with both China and Mexico. Below I offer some policy
implications and recommendations on how the United States can attempt to induce
China and Mexico to better cooperate with U.S. counternarcotics and law
enforcement objectives. I also provide suggestions for what law enforcement and
policy measures the United States can undertake independently, and even if
Mexico and China continue to reject robust cooperation.

Structural characteristics of synthetic drugs, including the ease of developing
similar, but not scheduled synthetic drugs and their new precursors —
increasingly a wide array of dual-use chemicals — pose immense structural
obstacles to controlling supply, irrespective of political will to prohibit and
regulate their use and enforce the regulations. These structural characteristics
impose large limitations on supply-side control effectiveness even if China were
to radically alter its posture toward counternarcotics cooperation against
Chinese drug trafficking networks and start robustly engaging in supply control
measures toward synthetic opioids, methamphetamine, and their precursors
originating in China with the United States and other countries.

U.S. domestic prevention, treatment, harm reduction, and law enforcement
measures remain indispensable and fundamental for countering the devastating
fentanyl crisis. It is likely that the most powerful measures to address the
opioid crisis are internal policies such as expanded treatment and supervised
use.

However, given the extent and lethality of the synthetic opioid epidemic in
North America and its likely spread in time to other parts of the world, even
supply control measures with partial and limited effectiveness can save lives.
That is a worthwhile objective. The Commission on Combatting Illicit Opioid
Trafficking stressed that targeted supply reduction and the enforcement of
current laws and regulations are essential to disrupting the availability of
chemicals needed to manufacture synthetic opioids.[51] The Commission also
highlighted how improved oversight of large chemical and pharmaceutical sectors
and enhanced investigations of vendors or importers in key foreign countries can
help disrupt the flow.[52] The Report’s supply-side control recommendations
include reducing online advertising; encouraging enhanced anti-money laundering
efforts in China and Mexico; enhanced interdiction efforts; increased
international scheduling of at least  synthetic drug precursors that are only
used for illicit purposes and enhanced control of precursor flows through
collaboration with China and international counternarcotics organizations.[53]

My recommendations below focus on how to get China to accept such enhanced
controls as well as highlight the difficult constraints on shaping China’s
behavior toward such desired outcomes.

Yet the effectiveness of all U.S. policy actions vis-à-vis China will be limited
by the fact that China subordinates its counternarcotics cooperation with the
United States to the overall geopolitical relationships between the two
countries and, unlike the United States, refuses to delink it: Without a
significant improvement in the geopolitical relationship, there is little
prospect of China’s increasing its law enforcement actions against fentanyl and
cooperating more robustly with the United States. The greater the rivalry and
tensions, the less cooperation China will deliver.

Even so and beyond the direct goal of preventing drug misuse and overdose in the
United States and around the world, the United States also has broad global
order objectives in its attempt to motivate China to share responsibility for
illicit economies in which Chinese actors play a prominent role and for reducing
the impunity of Chinese criminal networks, meaningfully sharing intelligence,
acting on international indictments, and fostering rule of law at home and
abroad.

My recommendations below also analyze and recommend tools to induce Mexico to
cooperate more robustly with U.S. law enforcement measures.

U.S. counternarcotics and law enforcement bargaining with Mexico is also
constrained by the U.S. reliance on Mexico to stop migrant flows to the United
States.  If the United States were able to conduct a comprehensive immigration
reform that would provide legal work opportunities to those currently seeking
protection and opportunities in the United States through unauthorized
migration, it would have far better leverage to induce meaningful and robust
counternarcotics and law enforcement cooperation with Mexico and would be better
able to save U.S. lives. Nonetheless, even absent such reform, the United States
can take impactful measures that I discuss below.


INDUCING COOPERATION FROM CHINA

With the Chinese government, Washington can continue to emphasize Beijing’s
interests in China’s reputation as a global counternarcotics policy leader and
leverage multilateral fora such the United Nations Office on Drugs and Crime and
the International Narcotics Control Board. The United States should also
continue to emphasize China’s self-interest in preventing the emergence of a
devasting synthetic opioid epidemic in the country as the prescription of
opioids in China grows, even though Beijing has thus far been dismissive of
these concerns. And Washington should continue requesting that China take down
websites that sell synthetic opioids illegally to Americans or to Mexican
criminal groups.

The United States should also strengthen its cooperation with allies and
partners, such as Australia and Europe, to send coordinated messages to push
Beijing in preferred directions of law enforcement efforts, including greater
monitoring and enforcement against sales of precursors chemicals to criminal
groups and more robust and broadly-cast anti-money laundering efforts. Such
coordinated messages will raise reputation costs for China of its law
enforcement inactions. There is reason to believe that such coordination among
the U.S. and allies as well as regional partners in Asia-Pacific could result in
greater Chinese willingness for and diligence in law enforcement collaboration.
In other cases where China came to be faced with sustained criticism from
countries with which it sought to cultivate influence, such as in Southeast
Asian regarding meth precursors or globally regarding ivory trafficking, Beijing
has over time altered its stance and adopted more cooperative and accommodating
policies.

The United States should continue to engage China bilaterally and multilaterally
to adopt more robust anti-money laundering standards in its banking and
financial systems and trading practices. Getting China to adopt such more
stringent regulatory measures will take considerable time. Meanwhile, China may
occasionally be incentivized by the United States to use anti-money laundering
measures against particular trafficking networks or chemical companies who are
clearly selling precursors to drug traffickers, such as in Mexico. But beyond
sporadic actions, there is little likelihood that China will rapidly alter its
anti-money laundering stance away from selective focus on Chinese capital flight
and toward broader counternarcotics measures. Nor is there high likelihood that
any time soon China would allow the U.S. or other countries greater visibility
into its banking and financial systems, since it will continue to seek to
obfuscate the many problems of both. However, in time, U.S. and multilateral
support for China’s implementation of more robust anti-money laundering measures
could produce some positive counternarcotics outcomes. There is no evidence to
suggest that even stringent anti-money laundering measures would end or
significantly reduce the supply of fentanyl to the United States. However,
anti-money laundering cooperation could at least help dismantle smuggling
networks and perhaps also deter some, thus making it more difficult for the
networks to operate. At minimum, it would reduce their ability to operate with
wide impunity and to strengthen the enforcement of the rule of law.

With the Chinese government and Chinese pharmaceutical companies, the United
States could encourage the spread of best practices developed in the
pharmaceutical sector. Over time, Chinese pharmaceutical companies should be
encouraged to adopt the full array of global control standards, including the
development of better training, certification, and inspection.

Even so, the shift toward precursors and pre-precursors with widespread dual use
poses massive structural obstacles to control. The United States should remain
deeply engaged in a global discussion on how to develop enhanced special
surveillance lists and monitoring and enforcement mechanisms for dual-use
chemicals, as those that are not scheduled do not have to be declared in
exports.

With no global industry and countries’ willingness to move toward scheduling
many dual-use chemicals, the United States should be encouraging the industry to
adopt self-regulation systems to detect and police suspicious activities, by
adopting know-your-customers policies, not selling precursors to likely drug
traffickers, and alerting law enforcement authorities about such buyers.

But even in the banking sector, such post-September 11 know-your-customer,
due-diligence policies, and reams of reports of suspicious activities, had
limited impact while generating problematic side-effects.[54] In comparison with
banking, the global chemical industry is far larger and more fragmented,
comprised of hundreds of thousands of firms and millions of facilities,
including not merely producers but also many brokers. So achieving widespread
and diligent adoption of self-regulation and incentivizing it through the
punishment of violators is highly challenging. Moreover, in various parts of the
world, including China and India, criminal groups have deeply infiltrated the
chemical industry,[55] making it easy for them to falsify and subvert such
self-regulation measures. Reducing criminal infiltration into and corruption
within the pharmaceutical sectors in both countries would be necessary to make
such measures more effective.

Moreover, these types of public-private partnerships are not common in China and
could pose difficulties both for the government and industries. China’s
operating practices have largely been that the government writes regulations and
the industries implements them (and often seeks to subvert them). And to the
extent that many of the unscrupulous sellers of nonscheduled precursors are
medium and small firms with smaller legal global market access and thus fewer
incentives for compliance, the monitoring and enforcement challenge remains
large and resource-intensive.

Firms that violate agreed-upon standards should be put on probation and, if no
significant improvement and compliance takes place, should be cut out of the
U.S. market and/or indicted by the U.S. government. Washington can insist that
Beijing shut down the worst offenders.

Of course, there is a risk that U.S. indictments, or any new U.S. laws mandating
that only chemical firms with certain standards can sell to the U.S. market,
might stimulate China to retaliate against U.S. businesses seeking access to
China’s market — whether by finding reasons to bring criminal investigations
against U.S. companies or by organizing social media-led boycotts. China has
previously resorted to both.[56] Moreover, many unscrupulous sellers are likely
to sell their precursors or finished synthetic drugs to drug traffickers abroad,
such as the Mexican groups, instead of directly into the United States.

With respect to prominent Chinese pharmaceutical and chemical industry
officials, the United States can develop packages of leverage, such as denying
them visas if their companies fail to adopt global standards of preventing
diversion. Powerful Chinese industry actors may thus be incentivized to promote
stricter regulatory standards and their enforcement within China.

But as in the case of U.S. actions against Chinese companies, the Chinese
government might retaliate against U.S. individuals and look for ways to charge
them with criminal conduct or espionage and arrest them.[57] Thus, the
implementation of such a sanctioning mechanism would need to be judged very
carefully within the broad context of U.S.-China relations.

With respect to Chinese traffickers, the United States should of course continue
to develop legal indictment portfolios against them and their companies, even if
China will not arrest, prosecute, and extradite them. Because of the poor state
of human rights in China, the U.S. should continue to refuse to sign an
extradition treaty with China. But Washington can and should deploy other
punitive measures, such as limiting traffickers’ access to the international
financial system, preventing their international travel, or attempting to have
third countries arrest them and extradite them to the United States.
Nonetheless, such indictments, particularly if the indicted individuals are
linked to the Chinese government or the CCP, may not stimulate China to engage
in more extensive counternarcotics cooperation with the United States.

Working with other international partners, the United States could encourage
China to start moving more seriously against Chinese drug trafficking networks
in Southeast Asia and the Pacific. But as long as these criminal groups also
serve China’s economic and internal control interests, such as against Chinese
diasporas, Beijing’s willingness to move against them will remain small. Thus,
the United States will need to rely on and incentivize other regional partners
to vigorously undermine those networks, even as new will emerge in their wake.
However, particularly if in the future the replacement networks were not
Chinese, the U.S. law enforcement challenges could diminish.


INDUCING COOPERATION FROM MEXICO

Various U.S. lawmakers have proposed designated Mexican criminal groups as
Foreign Terrorist Organizations (FTO).

An FTO designation would enable intelligence gathering and strike options of the
United States military, such as against some fentanyl labs in Mexico or visible
formations of large Mexican cartels — principally CJNG.

However, such unilateral U.S. military actions in Mexico would severely
jeopardize relations with our vital trading partner and neighbor whose society
is deeply intertwined with ours through familial connections.  Calls for U.S.
military strikes against fentanyl-linked targets in Mexico has already been
condemned by Mexican government officials, politicians, and commentators.

Meanwhile, the number of available targets in Mexico would be limited. Most
Mexican criminal groups do not gather in military-like visible formations. Many
fentanyl labs already operate in buildings in populated neighborhoods of towns
and cities where strikes would not be possible due to risks to Mexican
civilians. Moreover, fentanyl labs would easily be recreated.

Nor would the FTO designation add authorities to the economic sanctions and
anti-money laundering and financial intelligence tools that the already-in-place
designation of Transnational Criminal Organization (TCO) carries. The latter
designation also carries extensive prohibitions against material support.

But an FTO designation could significantly limit and outright hamper U.S.
foreign policy options and measures. Clauses against material support for
designated terrorist organizations have made it difficult for the United States
to implement non-military and non-law-enforcement policy measures in a wide
range of countries, such as to provide assistance for legal job creation or
reintegration support for even populations that had to endure the rule of brutal
terrorist groups. To be in compliance with the material support laws, the United
States and other entities must guarantee that none of their financial or
material assistance is leaking out, including through coerced extortion, to
those designated as FTOs.

Yet such controls would be a significant challenge in Mexico where many people
and businesses in legal economies, such as agriculture, fisheries, logging,
mining, and retail, have to pay extortion fees to Mexican criminal groups. The
attempted controls could undermine the ability to trade with Mexico as many U.S.
businesses would not be able to determine whether their Mexican trading or
production partner was paying extortion fees to Mexican cartels, and thus
guarantee that they were not indirectly in violation of material support
clauses.

The FTO designation could hamper the delivery of U.S. training, such as to local
police forces or Mexican federal law enforcement agencies, if guarantees could
not be established that such counterparts had no infiltration by criminal
actors.

Instead, if the López Obrador administration continues to deny meaningful law
enforcement cooperation, the United States may have to resort to significantly
intensified border inspections, even if they significantly slow down the legal
trade and cause substantial damage to Mexican goods, such as agricultural
products. Under optimal circumstances, U.S.-Mexico law enforcement cooperation
would be robust enough to make legal border crossings fast and efficient. Joint
fentanyl and precursor busts and seizures could take place near production labs
and at warehouses. The inspections of legal cargo heading to the United States
could take place close to production and loading site in Mexico. Under the
Merida Initiative, the Obama administration, in fact, sought to develop with
Mexico such systems of legal cargo inspection inside Mexico and away from the
border. But if Mexico refuses to act as a reliable law enforcement partner to
counter the greatest drug epidemic in North America, which is also decimating
lives in Mexico, the United States may have to focus much intensified
inspections at the border, despite the economic pains.

Packages of leverage, including indictment portfolios, could also be developed
against Mexican national security and law enforcement officials and politicians
who undermine and sabotage rule of law cooperation with the United States.


EXPANDING AND SMARTENING UP U.S. MEASURES AGAINST CRIMINAL ACTORS

Importantly, the United States has significant opportunities rapidly to
strengthen and smarten up its own measures against Chinese and Mexican criminal
actors participating in fentanyl and other drug trafficking while simultaneously
also enhancing U.S. measures to counter wildlife trafficking and protect public
health and global biodiversity.

Mexican drug cartels have diversified their activities into a wide array of
illicit and licit commodities. Similarly, some Chinese actors smuggling fentanyl
are also involved in wildlife trade and trafficking. Some are connecting to the
CCP and Chinese government officials. Corruption networks permeate all levels of
the Mexican government.

Primarily focusing on drug seizures close to source is no longer sufficient for
effectively disrupting fentanyl smuggling and criminal networks implicated in
it.

Rather, countering poaching and wildlife trafficking from Mexico and illegal
logging and mining in places where the Mexican cartels have a reach, acting
against illegal fishing off Mexico and around Latin America and elsewhere, and
shutting down wildlife trafficking networks into China are increasingly an
important element of countering Mexican and Chinese drug-trafficking groups and
reducing the flow of fentanyl to the United States.

To effectively counter fentanyl-smuggling actors requires a whole-of-government
approach — not simply on paper, but truly in implementation. A wide range of
U.S. government agencies should be authorized to support U.S. law enforcement
against Mexican and Chinese criminal actors, fentanyl trafficking, and crimes
against nature. These include U.S. intelligence agencies, the Department of
State, the Department of Defense, and U.S. Fish and Wildlife Service (USFWS).

Moreover, the focused collection, analysis, and reporting of intelligence by a
variety of U.S. government actors against wildlife trafficking, illegal fishing,
and illegal mining could beget new opportunities to understand the criminal
linkages to foreign governments, including China’s, to confirm or dismiss
concerns as to whether Chinese fishing vessels carry spy equipment, and to
identify the crucial vulnerabilities of Mexican and other dangerous cartels.

To such end, crimes against nature should be elevated as a Collection and
Reporting priority of the U.S. Intelligence Community, and within the U.S.
National Priorities Framework.

Stove-piping in information and intelligence gathering across a wide set of
illicit economies should be ended. Gathered information and intelligence should
be shared with interagency analysis groups intent upon interdicting the illicit
international flow of scheduled drugs and endangered species. Such efforts could
be enabled by increasing the number of USFWS special agents and by augmenting
their respective participation in interagency Organized Crime Drug Enforcement
Task Forces (OCDETF) investigations.

The relevant intelligence on crimes against nature to understand and dismantle
criminal networks could include names, phone number, license plates, courier
accounts, bank accounts, and wiretapped conversations. Conversely, countering
groups perpetrating crimes against nature could be productive in terms of
freezing accounts and visas to interdict the smuggling of drugs, guns, and
humans that they’re conducting.

Enhancing intelligence collection and law enforcement action opportunities
stemming from such an expanded lens to cover all of the activities, including
crimes against nature, of dangerous and nefarious actors, such as Mexican
cartels and Chinese criminal groups, requires enlarging the pool of USFWS
special agents and uniformed wildlife inspectors at the U.S.-Mexico border and
at transportation hubs within the United States.  The DEA appropriately enjoys
strong capacities, currently maintaining a force of 4000 agents.[58] In
contrast, the number of USFWS special agents has for years hovered at a mere and
insufficient 220.[59] For years, this inadequate number has not increased even
though poaching, illegal logging, and mining, and trafficking in natural
resource commodities have grown enormously over the past three decades, continue
expanding, and increasingly involve Mexican drug cartels as well as Chinese
criminal networks.

As a corollary and imperative effort, U.S. law enforcement agencies’ legal
authorities to counter wildlife trafficking should be expanded. Importantly,
wildlife trafficking should be designated as a predicate offense for wiretap
authorizations.[60 ]Such expanded authority would bring about multiple benefits:
including the enabling, understanding, and demonstration of the connections
between wildlife and transnational organized crime networks and foreign bad
actors, enhancing the ability to disrupt fentanyl trafficking, and allowing for
more expeditious and pointed prosecution of wildlife trafficking crimes.
Currently, federal legislation at the foundation of wildlife crime prosecution,
at the core of which is the Lacey Act, often entails proof of knowledge on the
part of the defendant, a requirement that wiretap authorization would greatly
facilitate, in the interest of prosecuting transnational wildlife trafficking
and convicting criminal syndicates.

Many fentanyl-trafficking networks are not narrowly specialized in fentanyl or
drugs only. Many Mexican cartels and criminal groups no longer solely focus on
drug smuggling. Fentanyl smuggling networks have powerful protectors among
corrupt government officials worldwide. Incentivizing better cooperation from
the Chinese and Mexican criminal governments is important. But particularly
given the challenges in inducing such cooperation in the current geopolitical
environment and given the policy orientation of the current Mexican government,
it is equally crucial to enhance the United States’ own policy tools to counter
fentanyl-trafficking networks. Expanding the intelligence-gathering aperture and
mandating and resourcing a whole-of-government approach in support of U.S. law
enforcement will save U.S. lives currently decimated by fentanyl overdoses.


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FOOTNOTES

 1.  1 Julie O’Donnell, Lauren J. Tanz, R. Matt Gladden, Nicole L. Davis, and
     Jessica Bitting, “Trends in and Characteristics of Drug Overdose Deaths
     Involving Illicitly Manufactured Fentanyls—United States, 2019–2020,”
     Morbidity and Mortality Weekly Report, 70, No. 50, December 17, 2021.
 2.  2 Merianne Rose Spencer, Arialdi M. Miniño, and Margaret Warner, “Drug
     Overdose Deaths in the United States, 2001–2021,” NCHS Data Brief No, 457,
     Centers for Disease Control and Prevention National Center for Health
     Statistics, U.S. Department of Health and Human Services, December 2022,
     https://www.cdc.gov/nchs/data/databriefs/db457.pdf.
 3.  3 The White House, Office of National Drug Control Policy, “Dr. Rahul Gupta
     Releases Statement on CDC’s New Overdose Death Data,” January 11, 2023,
     https://www.whitehouse.gov/ondcp/briefing-room/2023/01/11/dr-rahul-gupta-releases-statement-on-cdcs-new-overdose-death-data-2/#:~:text=Rahul%2520Gupta%252C%2520Director%2520of%2520the,period%2520ending%2520in%2520August%25202022.
 4.  4 Mark Landler, “U.S. and China Call Truce in Trade War,” The New York
     Times, December 1, 2018,
     https://www.nytimes.com/2018/12/01/world/trump-xi-g20-merkel.html.
 5.  5 Vanda Felbab-Brown’s interviews with eight former and current U.S.
     officials and international policy and China experts, by virtual platforms,
     November and December 2021.
 6.  6 Vanda Felbab-Brown’s interviews with six current and former international
     drug policy officials, by virtual platforms, November and December 2021.
 7.  7 Rahul Gupta, Director of the Office of National Drug Control Policy,
     “Statement for Hearing on Countering Illicit Fentanyl Trafficking,” Foreign
     Relations Committee United States Senate Wednesday, February 15, 2023,
     https://www.foreign.senate.gov/imo/media/doc/f4597c23-de04-fa71-e612-bcbc49b6826c/021523_Gupta_Testimony.pdf.
 8.  8 See, for example, “Chinese Foreign Ministry Spokesperson: The US should
     look for causes of the abuse of fentanyl from within,” Embassy of the
     People’s Republic of China in the United States of America, December 16,
     2021,
     http://www.china-embassy.org/eng/zmgx/zxxx/202112/t20211217_10470769.htm;
     “Remarks by spokesperson of the Chinese Embassy in the United States on the
     fentanyl issue,” Embassy of the People’s Republic of China in the United
     States of America, September 2, 2021,
     https://www.mfa.gov.cn/ce/ceus//eng/sgxw/t1904232.htm; and “China pushes
     back at Trump in war of words over opioid flows,” Bloomberg, August 27,
     2019,
     https://www.bloomberg.com/news/articles/2019-08-27/china-pushes-back-at-trump-in-war-of-words-over-opioid-flows;
     Yusha Zhao, “Ministry urges US to stop slandering China over its own opioid
     problem,” Global Times, September 3, 2019,
     https://www.globaltimes.cn/content/1163493.shtml; and Yeping Yin, “U.S.
     blames China for drug trafficking to disguise its own failure: experts,”
     Global Times, July 22, 2020,
     https://www.globaltimes.cn/content/1195344.shtml.
 9.  9 See for example Roderic Broadhurst and Peng Wang, “After the Bo Xilai
     Trial: Does Corruption Threaten China's Future?” Survival 56, no. 3 (May
     2014): 157-178, https://doi.org/10.1080/00396338.2014.920148.
 10. 10 Vanda Felbab-Brown’s interviews with two international experts on China
     and two former law enforcement officials who were posted in China, by
     virtual platforms, December 2021. See also Iza Ding and Michael
     Thompson-Brussar, “The Anti-Bureaucratic Ghost in China’s Bureaucratic
     Machine,” The China Quarterly 248, no. S1 (November 2021): 116-140,
     https://doi.org/10.1017/S0305741021000977. For an insider’s account of
     corruption in China, see Desmond Shum, Red Roulette: An Insider’s Story of
     Wealth, Power, Corruption, and Vengeance in Today’s China (New York: Simon
     and Schuster, 2021).
 11. 11 Vanda Felbab-Brown’s interviews with two international experts on China
     and two former law enforcement officials who were posted in China, by
     virtual platforms, December 2021
 12. 12 Peng Wang and Xia Yang, “Bureaucratic Slack in China: The
     Anti-corruption Campaign and the Decline of Patronage Networks in
     Developing Local Economies,” The China Quarterly 243 (November 19, 2019):
     1-24, https://doi.org/10.1017/S0305741019001504.
 13. 13 Vanda Felbab-Brown’s interviews with two international experts on China
     and two former law enforcement officials who were posted in China, by
     virtual platforms, December 2021.
 14. 14 Estimating the number of SEZs in the Mekong region is difficult because
     of the lack of data and different typologies of “economic zones.” The
     Heinrich Böll Stiftung and Land Watch Thai estimate that there are at least
     74 “special economic zones” at various stages of development in the Mekong
     region, and that if various different kinds of “economic zones” are
     included (e.g., industrial zones, industrial estates and parks, coastal
     economic zones, cross-border special zones, etc.), the number increases to
     some 500. See Pornpana Kuaycharoen, Luntharima Longcharoen, Phurinat
     Chotiwan, Kamol Sukin, and Lao independent researchers, “Special Economic
     Zones and Land Dispossession in the Mekong Region,” (Bangkok: Heinrich Böll
     Stiftung Southeast Asia and Land Watch Thai, May 24, 2021),
     https://th.boell.org/en/2021/05/24/special-economic-zones-and-land-dispossession-mekong-region.
 15. 15 Vanda Felbab-Brown interviews with former and current U.S., Southeast
     Asian, and Australian law enforcement officials, international drug policy
     officials, and international experts on drug and wildlife trafficking in
     Southeast Asia, by virtual platforms, November and December 2021.
 16. 16 Ibid.
 17. 17 Vanda Felbab-Brown’s interviews with U.S. and international law
     enforcement officials, by virtual platforms and in Mexico City, October,
     November, and December 2021. See also Lauren Greenwood and Kevin Fashola,
     “Illicit Fentanyl from China and “DEA Intelligence Report: Fentanyl Flow to
     the United States,” U.S. Drug Enforcement Administration.”
 18. 18 Vanda Felbab-Brown’s interviews with an expert on China’s organized
     crime groups, by virtual platform, December 2021.
 19. 19 For background, see John Langdale, “Chinese money laundering in North
     America,” The European Review of Organised Crime 6, no. 1 (2021): 10-35,
     https://standinggroups.ecpr.eu/sgoc/wp-content/uploads/sites/51/2021/05/4-Researchnote.pdf.
 20. 20 “Illicit Finance,” in National Drug Threat Assessment 2009 (Washington,
     DC: National Drug Intelligence Center, U.S. Department of Justice, December
     2008).
 21. 21 Ibid.
 22. 22 See “Estimating Illicit Financial Flows Resulting from Drug Trafficking
     and Other Transnational Organized Crimes: Research Report,” (Vienna: United
     Nations Office on Drugs and Crime, October 2011); Beau Kilmer, Jonathan P.
     Caulkins, Brittany M. Bond, and Peter Reuter, “Reducing Drug Trafficking
     Revenues and Violence in Mexico: Would Legalizing Marijuana in California
     Help?” (Santa Monica, Calif.: RAND Corporation, 2010); and Gabriel
     Stargardter, “Mexico’s Drug Cartels, Now Hooked on Fuel, Cripple the
     Country’s Refineries,” Reuters, January 24, 2018,
     https://www.reuters.com/investigates/special-report/mexico-violence-oil/.
 23. 23 Drazen Jorgic, “Special report: Burner phones and banking apps.”
 24. 24 Ibid.
 25. 25 Vanda Felbab-Brown’s interviews with U.S. government and law enforcement
     officials, Mexico City and by virtual platforms, October and November 2021.
 26. 26 Drazen Jorgic, “Special report: Burner phones and banking apps.”
 27. 27 Ibid.
 28. 28 Chinese officials cited in Drazen Jorgic, “Special report: Burner phones
     and banking apps.”
 29. 29 Vanda Felbab-Brown’s interviews with current and former U.S. and Mexican
     officials and law enforcement officers, Mexico City and by virtual
     platforms, October and November 2021.
 30. 30 Drazen Jorgic, “Special report: Burner phones and banking apps.”
 31. 31 For further details, see various hearings of the Commission of Inquiry
     into Money Laundering in British Columbia,”
     https://www.cullencommission.ca; and Sam Cooper, “Exclusive: How B.C.
     casinos are used to launder millions in drug cash,” Vancouver Sun,
     September 29, 2017,
     https://vancouversun.com/news/national/exclusive-how-b-c-casinos-are-used-to-launder-millions-in-drug-cash.
 32. 32 For background, see Vanda Felbab-Brown and Alejandro Castillo, “Restore
     US-Mexico seafood trade & save the vaquita,” Mexico Today, May 7, 2021,
     https://mexicotoday.com/2021/05/07/opinion-restore-us-mexico-seafood-trade-save-the-vaquita/;
     and Enrique Sanjurjo-Rivera, Sarah L. Mesnick, Sara Ávila-Forcada, Oriana
     Poindexter, Rebecca Lent, Vanda Felbab-Brown, Andrés M.
     Cisneros-Montemayor, Dale Squires, U. Rashid Sumaila, Gordon Munro, Rafael
     Ortiz-Rodriguez, Ramses Rodriguez, and Jade F. Sainz, “An Economic
     Perspective on Policies to Save the Vaquita: Conservation Actions, Wildlife
     Trafficking, and the Structure of Incentives,” Frontiers in Marine Science
     (August 27, 2021), https://doi.org/10.3389/fmars.2021.644022.
 33. 33 Vanda Felbab-Brown’s interviews with current and former U.S. and Mexican
     officials and law enforcement officers and Mexican fishery experts and
     high-level fishery operators, Mexico City and by virtual platforms, October
     and November 2021.
 34. 34 Vanda Felbab-Brown’s interviews with U.S. law enforcement officials,
     Mexico City and by virtual platforms, October 2021.
 35. 35 Vanda Felbab-Brown’s interview with a top executive of a large Mexican
     seafood exporter, Mexico, November 2021.
 36. 36 Vanda Felbab-Brown’s interviews with Latin American law enforcement
     officials, December 2017, November 2021, and February 2022.
 37. 37 Vanda Felbab-Brown’s interviews with U.S. Government and law enforcement
     officials, October 2021.
 38. 38 Vanda Felbab-Brown’s interviews with current and former U.S. and
     international drug policy officials in Southeast Asia, Australia, and New
     Zealand, by virtual platforms, November and December 2021.
 39. 39 Steven Lee Meyers, “China sentences man to death for trafficking
     fentanyl to the U.S.,” The New York Times, November 7, 2019,
     https://www.nytimes.com/2019/11/07/world/asia/china-fentanyl-death-penalty.html.
 40. 40 Vanda Felbab-Brown’s interviews with seven international diplomats and
     international drug policy officials, by virtual platforms, November and
     December 2021.
 41. 41 Vanda Felbab-Brown’s interview with two U.S. diplomats, by virtual
     platform, December 2021.
 42. 42 Michael R. Pompeo, “Designation of P.R.C. Foreign Nationals and Entities
     Under the Foreign Narcotics Kingpin Designation Act,” U.S. Department of
     State, July 17, 2020,
     https://2017-2021.state.gov/designation-of-prc-foreign-nationals-and-entities-under-the-foreign-narcotics-kingpin-designation-act/index.html.
 43. 43 Ministry of Foreign Affairs of the People’s Republic of China, “The
     Ministry of Foreign Affairs Announces Countermeasures in Response to Nancy
     Pelosi’s Visit to Taiwan, August 5, 2022,
     https://www.fmprc.gov.cn/eng/zxxx_662805/202208/t20220805_10735706.html.
 44. 44 Ken Dilanian, “Drug war cooperation between the U.S. and Mexico is at
     its lowest point in decades. What went wrong?” NBCNews.com, March 17, 2023,
     https://www.nbcnews.com/politics/national-security/no-cooperation-us-mexico-drug-war-rcna75093;
     and Vanda Felbab-Brown, “The U.S.-Mexico Fentanyl Meltdown – Part I: The
     State of Noncooperation,” Mexico Today, March 19, 2023,
     https://mexicotoday.com/2023/03/19/opinion-the-u-s-mexico-fentanyl-meltdown-part-i-the-state-of-noncooperation/.
 45. 45 Mark Stevenson, “Mexican president to US: Fentanyl is your problem,”
     Associated Press, March 9, 2023,
     https://apnews.com/article/mexico-fentanyl-epidemic-overdoses-26f735a54ee0ba075c394ce85aef03d0;
     “Mexican president blames US fentanyl crisis on ‘lack of hugs’ among
     families,” Associated Press, March 17, 2023,
     https://www.theguardian.com/world/2023/mar/17/mexico-president-fentanyl-hugs-children-amlo#:~:text=%25E2%2580%259CThere%2520is%2520a%2520lot%2520of,said%2520of%2520the%2520US%2520crisis;
     and Vanda Felbab-Brown, “AMLO’s Security Policy: Creative Ideas, Tough
     Reality,” The Brookings Institution, March 2019,
     https://www.brookings.edu/wpcontent/uploads/2019/03/FP_20190325_mexico_anti-crime.pdf.
 46. 46 Vanda Felbab-Brown, “A Dangerous Backtrack on the US-Mexico Security
     Relationship,” Mexico Today,  December 21, 2020,
     https://www.brookings.edu/blog/order-from-chaos/2020/12/21/a-dangerous-backtrack-on-the-us-mexico-security-relationship/.
 47. 47 “Mexico softens rules for controversial new foreign agents law,”
     Reuters, January 14, 2021,
     https://www.reuters.com/article/us-mexico-usa-security/mexico-softens-rules-for-controversial-new-foreign-agents-law-idUSKBN29J24M.
 48. 48 Dilanian.
 49. 49 U.S. Department of State, “Summary of the Action Plan for U.S.-Mexico
     Bicentennial Framework for Security, Public Health, and Safe Communities: A
     Fact Sheet,” January 31, 2022,
     https://www.state.gov/summary-of-the-action-plan-for-u-s-mexico-bicentennial-framework-for-security-public-health-and-safe-communities/.
 50. 50 Questions and answers period, U.S. Senate Foreign Relations Committee
     hearing “Countering Illicit Fentanyl Trafficking,” February 15, 2023,
     https://www.foreign.senate.gov/hearings/countering-illicit-fentanyl-trafficking.
 51. 51 Commission on Combatting Synthetic Opioid Trafficking, The Final Report,
     February 2022,
     https://www.rand.org/hsrd/hsoac/commission-combatting-synthetic-opioid-trafficking:
     xiv.
 52. 52 Ibid.
 53. 53 Ibid: 36-44; and 54-57; 61-64.
 54. 54 For details, see Vanda Felbab-Brown, The Extinction Market: Wildlife
     Trafficking and How to Counter It (London: Hurst, 2017), Chapter 9:
     “Anti-money laundering efforts”: 205-218.
 55. 55 Vanda Felbab-Brown’s interview with an international drug policy
     official, by virtual platform, November 2021.
 56. 56 Yang Ge, “FedEx Caught in Crossfire of U.S.-China Trade War — Again,”
     Caixin Global, August 19, 2019,
     https://www.caixinglobal.com/2019-08-19/fedex-caught-in-crossfire-of-us-china-trade-war-again-101452506.html;
     and Amy Qin and Julie Creswell, “China Is a Minefield, and Foreign Firms
     Keep Hitting New Tripwires,” The New York Times, October 8, 2019,
     https://www.nytimes.com/2019/10/08/world/asia/china-nba-tweet.html.
 57. 57 Javier C. Hernández and Catherine Porter, “China Indicts 2 Canadians on
     Spying Charges, Escalating Dispute,” The New York Times, June 19, 2020,
     https://www.nytimes.com/2020/06/19/world/asia/china-canada-kovrig-spavor.html;
     Javier C. Hernández, “The Foreign Billionaires, Activists and Missionaries
     Detained in China,” The New York Times, December 12, 2018,
     https://www.nytimes.com/2018/12/12/world/asia/china-foreigners-detained.html;
     Edward Wong and Michael Forsythe, “China’s Tactic to Catch a Fugitive
     Official: Hold His Two American Children,” The New York Times, November 25,
     2018, https://www.nytimes.com/2018/11/25/us/politics/china-exit-ban.html.
 58. 58 DEA Administrator Anne Milgram, DEA Leadership profile,
     https://www.dea.gov/about/dea-leadership#:~:text=As%20Administrator%2C%20she%20leads%20an,foreign%20offices%20across%20the%20globe
 59. 59 U.S. Fish and Wildlife Service, Office of Law Enforcement, “Law
     Enforcement at a Glance,” Fiscal Year 2022, October 28, 2022.
 60. 60 See 18 USC 2516, Authorization for interception of wire, oral, or
     electronic communications.


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