Environmental Crime and Trade-Based Money Laundering in Colombia: Case Study Analysis and Recommendations

Special Edition with Guest Student Authors from the Schar School of Policy and Government at George Mason University (https://traccc.gmu.edu/)

I have been honored to be an Adjunct Professor at GMU’s TraCCC (The Terrorism, Transnational Crime and Corruption Center) for several years. Many AML/Sanctions experts have joined me as guest lecturers as we work with graduate students either in or contemplating a career in our community. This past summer, in my International Money Laundering, Corruption, and Terrorism class, the challenge was to educate and stay current with the plethora of changes occurring in the US and internationally.

The students were required to submit a final paper on a topic related to the vast areas covered in class, and I have selected several papers that I know will be of interest to many.

  John Byrne

  Chair, AML RightSource Advisory Board

In recent years, the Amazon rainforest has become a focal point in the global fight against environmental crime, specifically observed through illegal logging, mining, and wildlife trafficking.[i] These crimes threaten ecosystems and fund extensive criminal networks through the commerce of natural resources and trade-based money laundering (TBML), a sophisticated method to integrate illicit financial gains into legitimate domestic and transnational economies.[ii] The increasing complexity of TBML operations has prompted governments and international bodies to intensify efforts to combat these illicit activities, emphasizing the need for rigorous data collection and collaboration between local law enforcement, indigenous populations, artisanal laborers, governments, and multilateral groups.[iii]

This report examines environmental crime in Colombia, specifically focusing on illegal gold mining and the linked TBML patterns with gold commerce. Colombian illicit actors, such as anti-state guerilla groups or drug cartels, employ a collective of government officials, lawyers, traders, and bankers to effectively formalize illegally extracted natural resources – and the funds obtained from this trading – into the licit economy. The corruption and deliberate exploitation of commerce will continue to cripple Colombia’s government and its ability to develop economically, promote democracy, reinforce lawful governance, and ensure its citizens’ security and well-being.

This report presents the following three recommendations for the Colombian government and international stakeholders interested in preventing the proliferation of TBML through commercial systems in the Americas.

• Target Demand and Top-down Financing: Stakeholders must combine efforts to regulate natural resource extraction and consequential environmental crime with large-scale financing emerging from TBML and illicit transnational commercial entities.
• Promote Data Transparency: To enable corporate accountability and supply chain compliance, stakeholders must address corporate beneficial ownership and trade data transparency. This will aid law enforcement, civil society and journalistic investigations that hold corporations and public officers accountable.
• Empower Local Communities: Stakeholders should enable programs that engage the local economic centers, enabling the first stage of environmental crime, trade-based money laundering, and the refining and processing of natural resources.

This report emphasizes the first recommendation. The perspective that environmental crime is a local issue, highlighted by the extractive industries that threaten sustainability and conservation efforts, is limited and ignores a top-down approach. The transnational financing of environmental crime and TBML harms the environment and funds multi-level criminal activity, threatening democracy, the rule of law, and the security of domestic populations.

Background: Environmental Crime

Environmental crime covers various activities, from illegal extraction and trade of forestry products and minerals to illegal land clearance and waste trafficking. These activities often become illegal when undertaken without state permission, orchestrated through contracts or concessions obtained by corruption or intimidation, and recording extractive activity is fraudulent, such as ignoring quotas or other requirements.[iv] The proliferation of these crimes emerges from their low-risk, high-reward nature, securing a safe and highly rewarding source of revenue for criminal actors.[v] Environmental crimes are the world’s third-largest criminal activity by value annually.[vi] According to reports by the G7 Financial Action Task Force (FATF), forestry crimes and illegal mining generate an estimated $152 billion and $48 billion, respectively.[vii]

The actors involved in these crimes vary from organized crime groups, drug cartels, and guerilla groups to multinational enterprises and individuals.[viii] These transnational criminal operations engage in diverse criminal activities such as human trafficking, drug trafficking, corruption, and tax evasion.[ix] Furthermore, the financial gains from environmental crime and the sale of natural resources are integrated into the larger criminal network.[x] Despite the interplay with crime networks, FATF notes that environmental crime is often ignored in public policy dialogue on environmental protection.[xi] The integration of financial gains from environmental crime into broader criminal networks highlights the nuanced complexity of these operations, underscoring the need for comprehensive approaches to combat them and effectively address and mitigate the financial and environmental impacts of such crimes. The Colombia case study offers a vital example of criminal actors collaborating with transnational operations to sell gold to buyers in the United States and Europe, legitimizing these natural resources and illicit funds through Trade-based money laundering.

Background: Trade-Based Money Laundering

TBML involves disguising the proceeds of illegal activities and moving money through trade transactions to legitimize illicit funds.[xii] Through multi-faceted TBML operations, criminal organizations and terrorist financers strategically target and exploit the international trade systems’ vulnerabilities.[xiii] Examples of these vulnerabilities include the enormous volume of trade flows, which obscures individual transactions; the complexities associated with the use of multiple foreign exchange transactions and the diverse trade financing arrangements; commingling of legitimate and illicit funds; and the limited resources that most customs agencies have available to detect suspicious trade sanctions.[xiv] TBML not only weakens the international trade system, it can undermine domestic financial systems, distort competition, and erode government tax systems and economic stability.

Between 2003 and 2006, FATF research indicated a transition towards TBML as authorities targeted other money laundering methods.[xv] This shift underscored a direct relationship between aggressive policy actions and enforcement measures, which increased the risk of detection, raising the economic cost of previous money laundering operations.[xvi] In this period, comprehensive Anti-Money Laundering activity unintendedly increased the attractiveness of the international trade system for money laundering and terrorist financing activities, enabling the development of TBML patterns.[xvii] The transition away from previous methods continued through the 2010s, and TBML patterns are currently present, highlighting the dynamic nature of illicit finance.[xviii] Regulatory actions in one area can inadvertently push criminal activities into less regulated or harder-to-detect pathways. As TBML patterns evolve, so must the strategies and tools governments and multilateral organizations use to combat these illicit activities. A key aspect of this fight against TBML is understanding TBML methodologies and collaborating between private and public stakeholders to act upon these methodologies by updating regulations, supporting private sector due diligence efforts, and mobilizing law enforcement responses.

TBML Methodologies and Invoice Fraud

TBML leverages corruption and the manipulation of customs and trade documents to exploit international trade. To actively launder illicit funds, criminal actors use the practice of Invoice Fraud or Mis-invoicing,[xix] where buyers and sellers collude and conspire to manipulate information about shipments, such as their value or contents.[xx] By manipulating the value or contents of a shipment, illicit actors can transfer large amounts of value across multiple trading jurisdictions, effectively avoiding scrutiny associated with direct forms of money transfer.[xxi]

According to a report by the Terrorism, Transnational Crime and Corruption Center (TRACCC) at George Mason University, mis-invoicing as a methodology of TBML allows the transfer of value from the sender to the receiver, or vice-versa.[xxii] In the figure below, the sender (exporter) transfers value to the receiver (importer) and creates a paper trail that makes the transfer proceeds look legitimate.[xxiii] Through this method, illicit transnational actors can move large sums of value and utilize formal markets to exchange product value for clean currency.[xxiv] In the scenario below, the exporter ships 2 million USD of boxed goods to the importer. Then, the exporter under-invoices the importer for 1 million USD, misrepresenting the real value, and receiving 1 million USD. The importer then resells the goods at market price for 2 million USD and keeps the difference of 1 million USD. In this under-invoicing scenario, illicit actors could effectively launder the proceeds from the sale of goods into legitimate cash while avoiding scrutiny associated with the direct form of a money transfer. In an over-invoicing scenario, the importer would invoice the exporter 3 million USD for a shipment of goods valued at 2 million USD. The importer will then re-sell the goods for 2 million USD, effectively laundering 1 million USD in payment to the exporting partner. In either of these previously discussed Mis-invoicing examples, legitimacy is achieved by using official-looking documentation or avoiding port inspections, both obtained through the corruption of local officials.[xxv] The corruption of officials and the enabling of TBML is especially prevalent in the commerce of natural resources, which can be linked to environmental crime and unlawful extractive industries.

TBML and Natural Resource Corruption

TBML remains a common method for laundering the proceeds of environmental crime and natural resource corruption. Actors who utilize TBML tactics often engage in more than one type of illicit activity and will include natural resources in their broader operations because of the lucrative gains and access to formal markets.[xxvi] Natural resources, such as timber or minerals, are legal to purchase in some markets but not others, allowing an irregular grey space to emerge.[xxvii] In this grey space, illicit actors are able to launder and sell natural resource products, even if the extraction is illegal or achieved through corrupt practices.[xxviii] A natural resource product’s originality is difficult to determine,[xxix] especially after the processing stage, such as sawing timber or refining gold. Moreover, Illicit activity, such as mis-invoicing and fraudulent species-identifying documents, can hide the products’ illicit origins.[xxx] For example, a shipment of illicit rosewood could be invoiced as another type of licit wood or various agricultural products could be combined to obfuscate wildlife products such as pangolin scales.[xxxi] From the initial illegal extraction to the refining of metals and sawing of timber, and eventually, to shipping and selling of these products, TBML operations employ and corrupt a variety of public officials. For example, customs officials who can provide appropriate trade documents, port officials who fail to inspect a shipment, and even law enforcement officials who do not enforce environmental or trade laws.[xxxii]

TBML and natural resource corruption schemes involve complex global trade patterns, the corruption of ports, customs, and environmental officials, and the cooperation of numerous legitimate or illegitimate companies. To expand on the nexus between environmental crime, natural resource corruption, and TBML, the following section explores environmental crime related to gold mining, trading, and laundering in Colombia and the emerging TBML trends with buyers across the Americas, Europe, and Asia.

Environmental Crime and Trade-based Money Laundering in Colombia

This case study examines environmental crime in Colombia, specifically focusing on illegal gold mining and Trade-based money laundering patterns(TBML) with gold commerce. Colombian illicit actors, such as anti-state guerilla groups or drug cartels, employ a collective of government officials, lawyers, traders, and bankers to effectively formalize illegally extracted natural resources – and the funds obtained from this trading – into the licit economy. The corruption and deliberate exploitation of commerce will continue to cripple Colombia’s government and its ability to develop economically, promote democracy, reinforce lawful governance, and ensure its citizens’ security and well-being.

Colombia faces significant challenges related to environmental crime and TBML specifically linked to illegal gold mining in its territory. According to a 2022 OECD report on illicit gold flows, Colombia is South America's third largest gold producer, reaching an all-time high of 61 tons produced in 2021.[xxxiii] In 2022, illegally extracted gold accounted for up to 80% of the country’s total production.[xxxiv] The illicit exploitation of Colombian gold and other gold, such as jewelry or scrap, smuggled into the country has remained a troubling issue domestically and across the global gold supply chain.[xxxv] According to a 2023 FACT Coalition report, the illegal gold mining industry is growing at such a rate that domestic reporting estimated that gold has become the most lucrative commodity for Colombian criminal networks, even surpassing cocaine.[xxxvi] Moreover, illegal gold mining in the Amazon is a burgeoning industry because, for gold miners, traffickers, and money launderers, gold is a portable and untraceable item to trade across international borders.[xxxvii] From its extraction to the refining process and eventually the exportation to international buyers, gold-based money laundering in Colombia is a concrete example of the nexus between environmental crime, natural resource corruption, and TBML.

In the illegal extraction or ‘production’ stage, illicit actors such as the Clan del Golfo and other armed groups like the National Liberation Army (ELN) or dissident groups of the Revolutionary Armed Forces of Colombia (FARC-D) directly and indirectly conduct extensive gold mining operations, which violate Colombia’s environmental laws.[xxxviii] These illicit extractive operations capitalize on a lack of governmental presence in gold-rich areas to exploit local small and mid-scale artisanal mining communities. [xxxix] According to one report, small and mid-scale mines routinely underreported their gold mine production to account for the payments in gold enforced by criminal groups.[xl] In a separate example, artisanal and small-scale gold mining supplied local illicit traders (compraventas) with mined gold, who aggregated it with the gold from local mid-scale formal mines and sold it to major traders and transnational companies in gold hubs like Medellin.[xli] In this example, licit and illicit gold commingling could have occurred in any of the exchanges.[xlii] Lastly, small miners are also incentivized to sell their own extracted gold on the black market for laundering purposes, depending on the black market or legitimate market price for mined gold.[xliii] The black-market gold can then re-enter the legitimate supply chain after being linked with the necessary paperwork acquired through fraud.[xliv] The aforementioned case of organized crime groups breaking environmental and domestic trading laws highlights the intricate dynamic between environmental crime (mining) and natural resource corruption (the trading and forging of gold legitimacy certificates). Nevertheless, the Colombia case study still offers examples of TBML.

Following the production stage, illicit actors utilize formal trading patterns to launder illicit gold into licit economies. According to a report by the OAS, an analysis of Colombian gold exports from 2010 to 2020 revealed multiple discrepancies in the trade data, possibly associated with inconsistencies in the trade data and potentially linked to gold mining and TBML.[xlv] From 2010 to 2013 and 2016 to 2019, yearly gold exporting exceeded the reported national production.[xlvi] The report suggested that the trade data indicated potential large-scale export of unreported and allegedly illegal gold, hinting at the use of TBML through the mis-invoicing of Colombia’s gold exports.[xlvii] A 2021 report by Global Financial Integrity (GFI) found that between 2010 and 2018, trade mis-invoicing in Colombia’s mineral sector represented over 5.6 billion USD in illicit financial flows.[xlviii] From 2012 to 2019, Switzerland reported excess imports of Colombian gold, which failed to align with Colombia’s gold export data.[xlix] From 2014 to 2018, Colombian gold exports to India were 1.134 billion USD less than reported Indian imports of Colombian gold. Lastly, disparities signaling possible TBML patterns existed in Colombia’s gold trade with the United States and Italy.[l] A possible cause for these patterns is the TBML practice of mis-invoicing Colombian gold shipments to launder large amounts of unreported gold value from Colombia to formal buyers in various markets.

Colombian illicit gold exporters may have strategically mis-invoiced shipments to move alleged illicitly mined gold from Colombia to international buyers. The exported Colombian illicit gold was initially exchanged for a fraction of its true market value. Following the first stage, the total amount of exported gold was obscured by Colombian customs officials’ mis-invoicing the true amount per shipment, effectively moving larger amounts of gold than what was reported to be legally produced in Colombia. When the shipments arrived in the importer country, importing customs officials reported the amount and value of gold, as demonstrated by the GFI trade data,[li] and highlighted by the reported disparities. The alleged illicit gold was then laundered into the formal economy in the importer's domestic market. Eventually, the gold was sold to the final customer at the market price without scrutiny surrounding its origin, effectively using formal trade patterns to launder illicit gold allegedly linked to environmental crime and corruption in Colombia.

Discrepancies in Colombia’s gold trade data, as indicated by the OAS and GFI reports, allegedly revealed mis-invoicing practices that facilitated the movement of illicit gold into international markets. One concrete example of TBML-linked illicit gold flows is Colombia’s Goldex case.[lii] Goldex was once Colombia's second largest gold export company, allegedly linked to Colombia’s “gold wars” and “blood gold” exports to United States markets.[liii] In the 2010s, according to Colombian prosecutors, Goldex exported illegal gold mined around Colombia, and laundered more than 1 billion dollars for organized crime groups,[liv] utilizing an array of corrupt officials, shadow companies, and false beneficial ownership.[lv] In the final six years of its operations, Goldex exported more than 47 tons of gold worth more than 1.4 billion USD to refineries in the United States.[lvi] The Goldex case highlights the overlap between various levels of environmental crime and TBML, with a distinct focus on the corruption schemes enforced across multiple jurisdictions to exploit commerce and finance systems.

Conclusion

 Addressing the intertwined issues of environmental crime and TBML requires approaches involving stricter enforcement of environmental laws, enhanced transparency in gold trading, and international cooperation to track and regulate the global gold supply chain. By understanding this nexus of TBML activity and corruption, policymakers can better formulate strategies to disrupt these illicit activities, safeguard natural resources, and promote sustainable development and financial practices in Colombia. This report presents three recommendations for the Colombian government and international stakeholders interested in preventing environmental crime and TBML proliferation.

• Target Demand and Top-down Financing: Stakeholders must combine efforts to regulate natural resource extraction and consequential environmental crime with large-scale financing emerging from TBML and illicit transnational commercial entities.
• Promote Data Transparency: To enable corporate accountability and supply chain compliance, stakeholders must address corporate beneficial ownership and trade data transparency. This will aid law enforcement, civil society, and journalistic investigations that hold corporations and public officers accountable.
• Empower Local Communities: Stakeholders should enable programs that engage the local economic centers, enabling the first stage of environmental crime and trade-based money laundering: the refining and processing of natural resources.

This report emphasizes the first recommendation. The perspective that environmental crime is a local issue, highlighted by the extractive industries that threaten solely sustainability and conservation efforts, is limited, and ignores a top-down approach. This oversight may lead to inadequate policy responses and missed opportunities to dismantle criminal operations comprehensively. The transnational financing of environmental crime and TBML harms the environment and funds multi-level criminal activity, threatening democracy, the rule of law, and the security of domestic populations. Coordinated international efforts by honest customs agents, law enforcement, and investigative reporting have effectively disrupted large-scale TBML operations and dismantled criminal networks. To counter future threats and developments in TBML methodologies, stakeholders must adopt strategies that enhance collaboration, strengthen regulatory frameworks, and support enforcement mechanisms at local and global levels.

[i] The FACT Coalition, Dirty Money and the Destruction of the Amazon: Uncovering the U.S. Role in Illicit Financial Flows from Environmental Crimes in the Amazon Basin, 2023, https://creativecommons.org/licenses/by/4.0/.

[ii] Financial Action Task Force, Money Laundering from Environmental Crimes, Financial Action Task Force, July 2021, https://www.fatf-gafi.org/en/publications/Environmentalcrime/Money-laundering-from- environmental-crime.html.

[iii] FACT, Dirty Money and the Destruction of the Amazon, 2023.

[iv] Financial Action Task Force, Money Laundering from Environmental Crimes, Financial Action Task Force, July 2021, https://www.fatf-gafi.org/en/publications/Environmentalcrime/Money-laundering-from- environmental-crime.html.

[v] FATF, Money Laundering from Environmental Crimes, July 2021.

[vi] INTERPOL, "Organized Crime Groups Pushing Environmental Security to Tipping Point," December 2023, https://www.interpol.int/en/News-and-Events/News/2023/Organized-crime-groups-pushing-environmental-security-to-tipping-point.

[vii] FATF, Money Laundering from Environmental Crimes, July 2021.

[viii] FATF, Money Laundering from Environmental Crimes, July 2021.

[ix] FATF, Money Laundering from Environmental Crimes, July 2021.

[x] FATF, Money Laundering from Environmental Crimes, July 2021.

[xi] FATF, Money Laundering from Environmental Crimes, July 2021.

[xii] Financial Action Task Force (FATF), Trade-Based Money Laundering, FATF Report, 2006, https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Trade%20Based%20Money%20Laundering.pdf.coredownload.pdf.

[xiii] Reference: FATF, Trade-Based Money Laundering, 2006.

[xiv] Reference: FATF, Trade-Based Money Laundering, 2006.

[xv] Reference: FATF, Trade-Based Money Laundering, 2006.

[xvi] Reference: FATF, Trade-Based Money Laundering, 2006.

[xvii] Reference: FATF, Trade-Based Money Laundering, 2006.

[xviii] Simmons & Simmons, Trade-Based Money Laundering, 05 April 2017, https://files.simmons-simmons.com/api/get-asset/Trade_based_money_laundering.pdf?id=bltf46079bfc4e90532

[xix] Simmons & Simmons, Trade-Based Money Laundering, April 2017.

[xx] Simmons & Simmons, Trade-Based Money Laundering, April 2017.

[xxi] Simmons & Simmons, Trade-Based Money Laundering, April 2017.

[xxii] Terrorism, Transnational Crime, and Corruption Center (TRACCC), Trade-Based Money Laundering and Natural Resource Corruption, George Mason University, October 2020, https://traccc.gmu.edu/wp-content/uploads/2021/06/Introductory-Overview-Trade-Based-Money-Laundering-and-Natural-Resource-Corruption.pdf

[xxiii] TRACCC, Trade-Based Money Laundering and Natural Resource Corruption, October 2020.

[xxiv] TRACCC, Trade-Based Money Laundering and Natural Resource Corruption, October 2020.

[xxv] Terrorism, Transnational Crime, and Corruption Center (TRACCC), Trade-Based Money Laundering and Natural Resource Corruption, George Mason University, October 2020, https://traccc.gmu.edu/wp-content/uploads/2021/06/Introductory-Overview-Trade-Based-Money-Laundering-and-Natural-Resource-Corruption.pdf

[xxvi] TRACCC, Trade-Based Money Laundering and Natural Resource Corruption, October 2020.

[xxvii] TRACCC, Trade-Based Money Laundering and Natural Resource Corruption, October 2020.

[xxviii] Jurum Duri, Corruption and environmental crime in Latin America, Anti-Corruption Resource Centre, Transparency International, 30 April 2020, https://www.u4.no/publications/corruption-and-environmental-crime-in-latin-america.pdf.

[xxix] TRACCC, Trade-Based Money Laundering and Natural Resource Corruption, October 2020.

[xxx] Duri, Corruption and environmental crime in Latin America, Anti-Corruption Resource Centre, April 2020.

[xxxi] TRACCC, Trade-Based Money Laundering and Natural Resource Corruption, October 2020.

[xxxii] Duri, Corruption and environmental crime in Latin America, Anti-Corruption Resource Centre, April 2020.

[xxxiii] OECD, Free Trade Zones and Illicit Gold Flows in Latin America and the Caribbean, OECD Business and Finance Policy Papers, no. 22 (Paris: OECD Publishing, 2022), https://doi.org/10.1787/7536db96-en. OECD, "Free Trade Zones and Illicit Gold Flows in Latin America and the Caribbean," OECD Business and Finance Policy Papers, no. 22 (Paris: OECD Publishing, 2022), https://doi.org/10.1787/7536db96-en.

[xxxiv] Daniela Quintero, David Riaño Valencia, David Escobar, and Sergio Silva, "Los vínculos de las empresas de oro y la minería ilegal en la Amazonía de Colombia," Ojo Publico, April 14, 2024.

[xxxv] OECD, Free Trade Zones and Illicit Gold Flows, 2022.

[xxxvi] FACT, Dirty Money and the Destruction of the Amazon, 2023.

[xxxvii] FACT, Dirty Money and the Destruction of the Amazon, 2023.

[xxxviii] OECD, Free Trade Zones and Illicit Gold Flows, 2022.

[xxxix] OECD, Free Trade Zones and Illicit Gold Flows, 2022.

[xl] OECD, Free Trade Zones and Illicit Gold Flows, 2022.

[xli] OECD, Free Trade Zones and Illicit Gold Flows, 2022.

[xlii] OECD, Free Trade Zones and Illicit Gold Flows, 2022.

[xliii] OECD, Free Trade Zones and Illicit Gold Flows, 2022.

[xliv] OECD, Free Trade Zones and Illicit Gold Flows, 2022.

[xlv] Organization of American States (OAS), On the trail of illicit gold proceeds, 2022, https://www.oas.org/en/sms/dtoc/docs/On-the-trail-of-illicit-gold-proceeds_Colombias-case.pdf

[xlvi] OAS, On the trail of illicit gold proceeds, 2022.

[xlvii] OAS, On the trail of illicit gold proceeds, 2022.

[xlviii] Global Financial Integrity, The Gold Standard: Addressing Illicit Financial Flows in the Colombian Gold Sector through Greater Transparency, February 10, 2021, https://gfintegrity.org/press-release/new-report-finds-colombian-gold-sector-vulnerable-to-illicit-financial-flows/

[xlix] GFI, The Gold Standard, Illicit Financial Flows, 2021.

[l] GFI, The Gold Standard, Illicit Financial Flows, 2021.

[li] GFI, The Gold Standard, Illicit Financial Flows, 2021.

[lii] The FACT Coalition, Dirty Money and the Destruction of the Amazon: Uncovering the U.S. Role in Illicit Financial Flows from Environmental Crimes in the Amazon Basin, 2023, https://creativecommons.org/licenses/by/4.0/.

[liii] FACT, Dirty Money and the Destruction of the Amazon, 2023.

[liv] Elyssa Pachico, “‘Crime Ring Laundered $1 Billion in Colombia Gold Exports,’” InSight Crime, January 19, 2015, https://insightcrime.org/news/brief/crime-ring-laundered-1-billion-colombia-gold-exports/.

[lv] Santiago Martínez Hernández, "Así se lavaron 2.3 billones producto del oro ilegal," El Espectador, January 21, 2015, https://www.elespectador.com/judicial/asi-se-lavaron-2-3-billones-producto-del-oro-ilegal-article-539297/.

[lvi] FACT, Dirty Money and the Destruction of the Amazon, 2023.