An in-depth and extremely useful report. Not one mention of Boko Haram as a source of ivory or role in poaching.  Ivory on sale in Nigeria comes from Cameroon, CAR, DRC and Gabon.  CXameroon has a major role at the centre of the smuggling networks. KS

Traffic Bulletin (UK)

H O R T R E P O R T
Report by Sone Nkoke Christopher
A snapshot survey of the illegal ivory market
26 TRAFFIC Bulletin Vol. 31 No. 1 (2019)
Introduction African elephants occur in a wide variety
of habitats, from tropical swamp forests
to deserts (Blanc et al., 2007). According
to Thouless et al., (2016), West Africa’s
elephant populations are mostly small,
fragmented and isolated. The estimated number of
elephants in areas surveyed within the last 10 years in
West Africa was 11,489 (± 2,582) at the time of the last
survey of each area, with estimates showing a decline
in Nigeria since 2006 (Thouless et al., 2016). In fact,
the African Elephant Status Report estimated Nigeria’s
total elephant population at only 94 animals and noted
five sites as having “lost” elephant populations since the
previous status report, but suggested that an additional
169–463 elephants may be in areas that were not surveyed
(Thouless et al., 2016). Indeed, the Yankari Game
Reserve, with an estimated 350 individuals (Dunn and
Nyanganji, 2011), is the largest surviving and only viable
elephant population in the country; the Okomu National
Park (ONP), and the Omo and Ifon (now Osse River
Park) Forest Reserves (OFR) are also said to support
only 33 and 28 elephants, respectively (Okekunle, 2016).
The future is not bright as threats faced by these elephant
populations include habitat destruction and poaching
for the international ivory trade, according to J. Onoja
of the Nigerian Conservation Foundation (pers. comm.,
17 July 2018).
Over the centuries, elephant hunters have
exterminated many elephant populations, particularly
those in North Africa in the early Middle Ages, in
South Africa in the eighteenth and nineteenth centuries
(Douglas-Hamilton, 1979), in West Africa in the late
nineteenth and early twentieth centuries, and in northern
Somalia in the mid-1950s (Bourgoin, 1949). Successive
reports of the Elephant Trade Information System (ETIS)
for the Convention on International Trade in Endangered
Species of Wild Fauna and Flora (CITES) document that
the illegal ivory trade has risen to the highest levels in
two decades following a sharp upturn in seizures of large
shipments of elephant tusks in recent years (Milliken et
al., 2012; 2016; 2018). These reports indicate that 2011
and 2012 were the worst years on record, with “major
surges” in the illegal trafficking of ivory, but some level
of decline in the total weight of ivory in trade was noted
in 2016 and 2017.
The movement of large-scale ivory shipments
out of Africa is controlled by organised syndicates.
According to Milliken (2014), it is believed that most
of these syndicates currently function as Asian-run,
African-based transnational operations. These criminal
networks increasingly operate like global multinational
businesses, connecting local resources to global markets
through complex and interlinked networks, often in
collusion with local business and political elites, even
sometimes including those tasked with protecting
wildlife (Nellemann et al., 2016). Another dimension
of the trade has involved the presence of unregulated
domestic ivory markets in African countries that openly
offer ivory products to local and foreign buyers without
government interference (Milliken et al., 2012). Nigeria
is no exception, with ivory openly traded in Lagos and
other parts of Nigeria.
Viewed against previous surveys, contemporary
ivory markets in Nigeria are reportedly holding steady,
with a thriving trade in ivory items. A 1989 survey found
1,081 kg of ivory items on display in Lagos, making up
70% by weight of ivory items seen in the country; another
study undertaken in 1994 estimated that there were
between 500 and 700 kg of ivory items openly for retail
sale in Lagos (Martin and Vigne, 2013). A third, more
detailed survey of the Lagos ivory market was carried out
in 1999, with an estimated weight of 1,742 kg of worked
ivory for retail sale from a count of 5,966 items in 40
outlets, and 3,681 ivory items were recorded at 16 outlets
at the Lekki souvenir market (Martin and Stiles, 2000). A
further study in 2002 counted 5,107 ivory items weighing
1,910 kg, mostly at the Lekki market (Courouble et al.,
2003), and another study in 2012 found 33 retail souvenir
outlets with 14,200 ivory items (Martin and Vigne,
2013). A recent study in 2015 showed that ivory trade
flourishes in some parts of Lagos State, with woodwork
and beadwork being used as a cover, especially in hotels
where such goods are easily accessible to foreign buyers
(Akeredolu et al., 2016).
Methodology
A rapid survey was undertaken between 28 and
29 September 2017 to ascertain the contemporary
dimensions of the existing ivory market in Lagos. A more
detailed survey was carried out in Lagos from 15 to 20
July 2018 with a focus on the Lekki market, Eko Hotel
and Suites, Murtala Mohammed International Airport,
Oriental Hotel Federal Palace Hotel, and Airport Hotel as
a comparative assessment to previous studies.
The methods used consisted mainly of physical visits
by the author—an experienced ivory market surveyor—
for direct observation and formal and informal discussions
with vendors and other stakeholders (wildlife and other
law enforcement authorities, NGOs, etc.), with recordings
and photographs used as a means of cross-checking and
verifying information, especially the number and types
of ivory items. The language used during the survey was
English. Some covert methods were employed given that
some vendors and carvers were suspicious and reluctant
to divulge information about their activities, and on other
occasions, a Nigerian national was engaged to facilitate
information exchange with certain vendors, acting as an
interpreter for those whose main language was Hausa,
a language spoken by about 80% of the vendors from
Nigeria and other countries of West Africa. The number
of stalls, the type and quantity of ivory on sale, prices,
numbers of carvers, the profiles of buyers as observed
and from information provided by the vendors were
recorded. In some instances, the size and weight of items
were estimated from experience.
The price of the items was generally recorded as
Nigerian Naira (NGN), but later converted to US dollars
for standardisation (USD1=NGN360, September 2018
rate: https://www.oanda.com/currency/converter/).
S H O R T R E P O R T
28 TRAFFIC Bulletin Vol. 31 No. 1 (2019)
Discussions were held with a number of government
law enforcement officials, as well as personnel from the
CITES Management Authority and the focal person of the
National Ivory Action Plan, the National Environmental
Standards and Regulations Enforcement Agency
(NESREA), the Nigerian Customs Services (NCS) and
the non-government organisation Nigerian Conservation
Foundation (NCF).
Legislation and Law Enforcement
Nigeria ratified CITES in 1974. At the national level,
elephants are protected under the First Schedule of The
National Wildlife Species Protection Act (NWSPA) which
was signed by the President of the Federal Republic
of Nigeria on 30 December 2016. This relatively new
Act provides for the conservation and management of
Nigeria’s wildlife and the protection of species in danger
of extinction as a result of overexploitation or habitat
change, as required under CITES, the Convention on
the Conservation of Migratory Species of Wild Animals
(CMS), and the Convention on Biological Diversity
(CBD), to which Nigeria is a signatory.
Section 1(1) of the NWSPA states that “the hunting
or capture of, or trade in, the animal and plant species
specified in the First Schedule to this Act (being wild
animal and plant species that are endemic to Nigeria or
otherwise considered to be threatened with extinction)
is prohibited”. Trade in specimens of species listed in
the First Schedule may be conducted under exceptional
circumstances. In Section 5(2) of the NWSPA it states
that “any person who, in contravention of the provisions
of this Act, hunts, captures, possesses, trades or otherwise
deals in a specimen of wild fauna and or flora without
the appropriate permits shall be guilty of an offence and
liable on conviction: (a) in respect of a specimen under
the First Schedule, to a fine of five hundred thousand
Naira (N500,000~USD1,400, at the rate of USD1.00
=NGN360, September 2018 average) or five (5) years
imprisonment or both such fine and imprisonment”.
However, enforcement of this law is lacking.
Akeredolu et al., (2016) states that the sale of ivory
has been banned in Lagos since 2011, but corruption, a
weak judicial system and light sentences undermine the
effective application of this law.
The CITES Management Authority (MA) is in
the Federal Ministry of Environment, Department of
Forestry, and the National Environmental Standards and
Regulations Enforcement Agency (NESREA) is charged
with enforcement. Nosa Aigbedion, the Co-ordinator of
the Lagos Office of NESREA stated that they are aware
of the existing ivory markets and that there is an active
ivory trade involving Chinese nationals (pers. comm.,
27 September 2017). He also referred to two wildlife
smuggling cases involving Chinese nationals arrested
with ivory in 2014 and 2016, respectively. Some products
seized by other State agencies such as the Nigerian
Customs are handed over to NESREA; an example is
the seizure of 71 ivory pieces (124 kg) on 22 July 2017
arriving at Lagos airport from Gabon (A. Abimbola,
Cargo Department of Lagos International Airport, pers.
comm., 27 September 2017).
In 2013, CITES Parties instituted a National Ivory
Action Plan (NIAP) process under the direction of the
Standing Committee in countries identified as being
the most heavily affected by the illegal ivory trade and
requiring strengthened controls to combat this trade.
Parties are selected for attention from analysis of ivory
seizure data held in ETIS (CITES, 2013). In Central and
West Africa, Cameroon, Congo, Democratic Republic
of the Congo, Gabon and Nigeria are all Category
B Parties (formerly called “countries of secondary
concern”) and have been requested to develop NIAPs.
The implementation of NIAPs by a number of countries
in Central Africa is currently under way in accordance
with recommendations adopted by the CITES Standing
Committee in March 2013 (Nkoke et al., 2016). Nigeria
is also implementing its NIAP, but its effectiveness is
questionable given the open ivory market in Lagos,
for example. In fact, Nigeria together with Malaysia,
Mozambique and Viet Nam are now regarded as priorities
for consideration under Category A (formerly called a
“country of primary concern”) owing to their links to the
greatest illegal ivory trade flows over the period under
examination (Milliken et al., 2018). Nigeria’s move from
a Category B country in the CoP16 and CoP17 analyses
to a Category A country shows its position has worsened
since the last CoP.
Retail Outlets and Prices for
Worked Ivory
Retail Outlets and Items
During the survey period in 2018, ivory items were
observed mainly in the Lekki market (Lekki Peninsula)
and in the curio market located at the Eko Hotel and
Suites on Victoria Island. No items were seen in the other
hotels visited or at the airport, as was also the case in
Lagos during the 2012 survey (Martin and Vigne, 2013)
and the 2015 survey (Akeredolu et al., 2016).
Two out of 51 stalls at the Eko Hotel and Suites
displayed six ivory items, four necklaces as well as two
bracelets which were on sale for NGN35,000 (USD96)
and NGN25,000 (USD69), respectively. One of the
vendors said the market was seasonal with more items
displayed during the months of December and January
to coincide with holidays and the presence of tourists,
mainly from Europe and Asia.
Place No. of No. outlets No of
outlets with ivory items
Eko Hotel/Suites curio centre 51 2 6
Lekki market 43 19 ~13,752
Total 94 21 ~13,758
Table 1. No. of ivory items in the Lekki market and
Eko Hotel and Suites, Lagos, Nigeria, July 2018.
Lagos, Nigeria: Investigation into a thriving illegal ivory market
S H O R T R E P O R T
22 TRAFFIC Bulletin Vol. 31 No. 1 (2019)
© SONE NKOKE CHRISTOPHER / TRAFFIC
TRAFFIC Bulletin Vol. 31 No. 1 (2019) 29
The Lekki market, by contrast, had more
outlets and ivory items displayed. The market
itself comprises several sections specialising in
different items (clothes and footwear, food and
vegetables), with the curio market (paintings,
stuffed animals and other products, wood and
ivory carvings) located in the centre. Of the 43
outlets selling souvenirs, 19 were selling ivory
products ranging from rings to carved tusks. In
total, approximately 13,752 ivory items were
counted, with smaller items (<10 cm weighing
<100 g) accounting for over 80% of the total.
Many other items were hidden under the stalls,
as indicated by the vendors and observed in some
cases, and their numbers were not included in the
total. The number of ivory items was therefore
concentrated in fewer outlets, an average of 724
per outlet, compared to the 14,200 items spread
over 33 outlets in 2013 (Martin and Vigne, 2013),
giving an average of 430 items per outlet. Some
outlets had fewer than 400 ivory items and others
as many as 2,000 pieces. Tables 1 and 2 give a
breakdown of the number of items seen in the
different markets and the type of products at the
Lekki market.
Prices of Ivory Items
Prices were generally given in Nigerian Naira
(NGN) and varied according to the size of the
item, the quality of carving, the nationality of
the buyer (lower prices were asked of Nigerian
nationals, and higher prices from foreigners,
especially non-Africans), and the bargaining
power of either the buyer or the vendor.
The prices ranged from as low as NGN1,000
(~USD3) for a ring to NGN540,000 (~USD1,500)
for a two kilogrammes-carved tusk. Table 3 shows
the buying prices of ivory items seen at the Lekki
market in July 2018.
Ivory item Approximate
percentage
Necklaces 20
Bracelets 17
Pendants 15
Earrings 11
Rings 10
Chopsticks 7
Name Seals 6
Rosaries (Muslim and Christian) 5
Animal figurines 3
Human figurines 3
Whole tusks (carved and polished) 2
Others (cigarette holders, combs, etc.) 1
Total 100
Table 2. A breakdown of the different types of
ivory items in the Lekki market, Lagos, Nigeria,
July 2018.
S H O R T R E P O R T
30 TRAFFIC Bulletin Vol. 31 No. 1 (2019)
Compared to the 2012 survey (Martin and Vigne, 2013), prices
have increased over time. Some vendors used a mix of bones and
wood with ivory, while others were made wholly of animal bone and
sold as ivory, though in very small quantities.
Association of Ivory Sellers
A number of outlets had posted on their glass cabinets the by-laws
of an association of ivory sellers known as the African Art Dealers’
Association. Upon discussion with some vendors, it became apparent
that this association, which was specific to Lagos, was created roughly
ten years earlier (before the 2016 law made trading ivory explicitly
illegal), but was not functional, and as of July 2018, most vendors
(about 95%) were unaware of its existence nor did they adhere to
the by-laws. According to one of the few vendors who knew about
the association, there was a register for membership but given that
adherence was not mandatory, they found no interest in being part of
the association and membership had declined as a result.
Fines set out by the association for violating any article of the bylaws
range from between NGN10,000 and NGN20,000 (~USD27–
56)—less than the price of a pendant. Some of the articles cover
the sale of fake rhino horns and other fake products, as well as the
sale of ivory items by non-members. Further discussions with some
NCF and NESREA personnel, and the NIAP Focal Person (CITES
MA) however, showed that the association was not known within
government circles. According to a CITES MA spokesperson (pers.
comm., 17 September 2018), “the Association is not documented
Table 3. Prices of ivory items in the Lekki ivory market, Lagos,
Nigeria, September 2018. Exchange rate: USD1=NGN360
and registered by the Federal Government
therefore it does not exist … and none of
the vendors had a permit from the CITES
MA or any other authority to trade in ivory
items nationally or internationally”. Hence,
vendors are clearly contravening Article 2,
Sub-section 3 (a) of the National Wildlife
Species Protection Act of 2016, which
states that such trade is permitted only in
exceptional circumstances, accompanied
by valid permits. All vendors in the Lekki
market are consequently operating illegally,
however many of the vendors interviewed
were aware of the illegality of the trade but
did not seem to be concerned.
Carving workshops
No carving workshop was observed in the
curio market of Eko Hotel and Suites. By
contrast, 11 out of the 43 outlets selling
souvenirs in Lekki market had carvers
working mostly with wood and animal
bone, and one was seen working on an ivory
piece (a carving of an elephant). The outlet
belonged to a Malian national and the carver
was also from Mali. Two other workshops
located behind the vegetable section were
seen processing ivory pieces, bracelets and
rosaries; the first had two carvers reportedly
from Guinea; the two carvers at the second
workshop were reportedly Nigerian. Not
many pieces were displayed but discussions
with an informant revealed that some pieces
were kept in metal boxes behind the carvers.
Unfortunately, it was not possible from
discussions and observations to ascertain the
proportion of ivory items that were carved
locally and those imported from elsewhere,
but it was clear that carving activities were
being carried out in the Lekki market.
Recent studies in Central Africa that
focused on Cameroon, Central African
Republic, Congo, the Democratic Republic
of the Congo and Gabon found that most
worked ivory markets with ivory pieces
targeting the Asian market had declined
substantially (Nkoke et al., 2017). However,
in Lagos there is still a high degree of
targeted processing of ivory destined for
the Asian market, as was apparent from the
quantity of chopsticks, name seals and other
products for sale in the Lekki market during
the present survey. This follows the same
pattern seen in the 1999 study (Martin and
Stiles, 2000), where declines of worked ivory
targeting Asian markets were evident in other
countries while a marginal rise was observed
in Lagos from 1989.
Ivory item Size/Description Av. price Av. price
(NGN) (USD)
Necklace small beads 14,000 39
large beads 33,000 92
Bracelet ~1 cm width 12,500 35
>1 cm width 25,000 70
Pendant 3–5 cm 25,000 70
Earring pair 9,000 25
Ring 5–10 g 3,000 8
Cigarette holder 3–5 cm 25,000 70
Chopstick pair 30,000 83
Name seal round base (personal): 2×7 cm 60,000 167
square base (business): 3×7 cm 90,000 250
Rosary Muslim+Christian 20,000 56
Animal figurine 1–10 cm, ~200 g 83,000 230
10–30 cm, ~700 g 160,000 445
>30 cm, ~ 1 kg 215,000 600
Human figurine 1–10 cm, ~200 g 145,000 402
10–30 cm, ~700 g 250,000 690
>30 cm, ~1 kg 390,000 1,080
Carved tusk <2 kg 325,000 900
>2 kg 540,000 1,500
Polished tusk <2 kg 252,000 700
>2 kg 430,000 1,200
Carved tusk base <1 kg 290,000 805
Polished tusk base <1 kg 180,000 500
Polished tusk tip ~300 g 160,000 450
Comb 10–20 cm 18,000 50
Key holder 2–5 cm 20,000 56
TRAFFIC Bulletin Vol. 31 No. 1 (2019) 31
S H O R T R E P O R T
Profile of actors in the trade
The profile of the ivory trade actors varies across the trade chain
and related activities. About 85% of vendors and other middlemen
in the Lekki market were Nigerians, with a mixture of other African
nationals, including individuals from Mali, Senegal and Guinea.
According to Martin and Stiles (2000), most of the buyers were
Nigerian traders, but, on occasion, some Chinese railway repair
workers came to buy products. During the 2018 survey, however,
many buyers observed were East Asian nationals, including 13
buyers seen in the market (nine males and four females), 10 Chinese
and three Japanese nationals (all females), which is a significant shift
from earlier surveys. This is not a surprising development given that
China is the main ivory market globally and the number of Chinese
immigrants in Africa has risen sevenfold over less than two decades,
with the African continent said to be home to more than 1.1 million
Chinese immigrants in 2012, compared with fewer than 160,000 in
1996 (Zhou, 2017). It is believed that Chinese nationals are running
ivory processing operations in Nigeria and exporting the worked
products by courier to Asia. According to EIA (2017), increased
enforcement effort and the high-profile arrests and prosecutions of
Chinese nationals involved in ivory trafficking in one of their former
sourcing areas of Tanzania, was one of the reasons for their move to
Nigeria because of purported lax enforcement and corruption in that
country. In an assessment of ETIS data, Nigeria ranked first amongst
25 African nations that had been identified as countries of origin
or export for commercial consignments of worked ivory products
moving from Africa to Asia; in total, 51 out of 214 seizures (24%) of
ivory products (ca. one tonne), involved Nigeria (CITES, 2017).
Akeredolu et al., (2016) reports that most of the customers
encountered during the 2015 survey were Chinese nationals who
came to Nigeria to buy ivory with the intention of reselling items at
higher prices in other countries, in Asia in particular, where there is a
ready market for ivory products. It was reported that communication
between the local traders and their Chinese customers was mainly in
Pidgin English, with a few of the traders speaking Chinese with their
Asian customers.
In the open markets, Chinese buyers tend to prefer smaller
objects, especially jewellery, name seals and chopsticks that can be
easily transported back to China in their personal luggage (Martin
and Vigne, 2013).
The source and movement of raw ivory
With so few elephants found in Nigeria,
given the quantity of ivory on sale and seizure
information linked to Nigeria, it is highly
unlikely that Nigeria itself is a viable source
of raw elephant tusks. In fact, illegal exports
of raw ivory from Lagos to Hong Kong
were forensically examined and found to
comprise ivory from Congo, Gabon, Central
African Republic and Cameroon (Wasser et
al., 2015). The ETIS report to CITES CoP16
reported that “Nigeria was the destination for
nearly one tonne of ivory seized in Cameroon
in 2009 and 1.3 tonnes of ivory seized in
Kenya in 2011” (Milliken et al., 2012), and
Nigeria continues to depend on ivory from
other parts of Africa, especially neighbouring
Central African countries.
According to the vendors, other sources
of ivory were the Central African countries
of Central African Republic, Congo, the
Democratic Republic of the Congo (DRC)
and Gabon, and Togo in West Africa. The
MIKE (Monitoring the Illegal Killing of
Elephants) report on poaching for CoP18
shows that both Central and West Africa
mark another year with unsustainable levels
of poaching well above the 5% mark where
population decline characterises the situation
in the two sub-regions that supply most of the
ivory to Nigeria’s ivory trade (T. Milliken, in
litt., 20 February 2019).
Unadjusted prices for raw ivory in Lagos
during a previous study were found to range
from NGN3,200–4,800/kg (USD24–36/
kg), depending on the size and quality of
the piece, with USD30/kg regarded as the
average benchmark price (Courouble et
al., 2003). In Cameroon, there has been a
consistent increase in the price of raw ivory
for every weight class in successive surveys,
with a five-fold price increase between
2007 and 2015 for small tusks (<5 kg)
ranging from between USD52–73 in 2007
and USD262–284 in 2015 in Yaounde and
Douala, respectively (Nkoke et al., 2017).
During the 2018 survey, a pair of raw
tusks of <5 kg was found in the outlet of the
aforementioned Malian. The source of the
ivory was reported to be Cameroon and the
going price was NGN230,000 (~USD640)
per kg, a price which seems to be untypical.
Apart from Cameroon, other Central African
source countries were also reported in the
2012 survey (Martin and Vigne, 2013).
The regional movement of ivory has not
changed much during the last decades, with
traffickers using the same traditional routes,
roads, coastal zones and rivers, with two
basic scenarios prevailing: one involves
Fig. 1. Principal source countries (grey) for ivory entering Nigeria.
S H O R T R E P O R T
32 TRAFFIC Bulletin Vol. 31 No. 1 (2019)
Cameroon and Gabon, with constant movements of
poached ivory across the border of northern Gabon
into southern Cameroon, and then westward by road to
coastal ports in Cameroon and Nigeria (Nkoke et al.,
2017). Some seizure information such as that reported
by the Nigerian Customs, e.g. 71 ivory pieces (124 kg)
arriving from Gabon and seized on 22 July 2017 at Lagos
airport, confirm such routes. Another route is from northwest
Congo, south-west Central African Republic (CAR)
and north-east Cameroon, all going either to Yaounde
or Douala or into Nigeria (D. Stiles, in litt., 13 January
2019). Another highly probable source of raw tusks
is leakage from government-held stocks in West and
Central Africa given the poor security and management
of seized ivory.
According to TRAFFIC’s wildlife trade information
database consulted in September 2018 and covering the
period between 12 March 2017 and 1 August 2018, over
8.2 t of tusks or raw ivory pieces were seized in Nigeria
or in other places with the consignments linked to Nigeria
in terms of the known trade chains. Some of the places
cited include Cameroon and Côte d’Ivoire in Africa, and
Hong Kong SAR, Malaysia, Singapore, Thailand and
Viet Nam in Asia, clearly showing Nigeria as a major
exit point and a crucial link between Africa and Asia.
Government-held ivory stocks
Similar to the law enforcement structure in Nigeria,
the management of government-held ivory stocks is
an overlapping and conflicting responsibility between
NESREA and the Nigerian CITES MA. According to
a spokesperson from the CITES MA for Nigeria (pers.
comm, 28 September 2017), NESREA has the remit to
store seized wildlife products, but there are no clear links
to the CITES MA and this is a source of confusion for
the management of wildlife products, particularly ivory.
The spokesperson went further to say that ETIS forms
in Nigeria are not filled out at the point of seizure, but
centrally at the federal level by NESREA. The impact
of this approach on traceability and leakage is obvious,
especially if one considers that ivory is also not marked,
and is a breach of CITES recommendations as set out in
Resolution Conf. 10.10 (Rev. CoP17).
A spokesperson from NESREA in Lagos (pers.
comm., 27 September 2017) affirmed that although
NESREA is responsible for wildlife law enforcement
and for the collation and management of national ivory
stockpiles in Nigeria, he had never heard about ETIS
as an official CITES system for tracking illegal trade in
ivory nor had he heard of the NIAP.
Other law enforcement agencies do transfer seized
wildlife products to NESREA, but there are no clear
mechanisms for doing so. For example, seizures carried
out by Customs at Lagos airport were transferred to
NESREA using simple “Handing-over Forms” registered
at the level of the Customs but not tracked at the level of
NESREA to check for consistency and to ensure that the
wildlife products handed over are registered correctly.
Such “Handing-over Forms” are also used by NESREA
in Lagos to transfer ivory and other wildlife products to
the national stockpile in Abuja.
As stated in the Nigeria NIAP Report to CITES in April
2016 (Anon, 2016), an audit of the national stockpile in
Abuja was carried out in 2016 covering the period March
2010 to January 2016, and it is estimated that there were
about 3,318 ivory specimens (raw tusks, semi-processed
and processed ivory items), weighing about 1,173 kg
being held in a government store in Abuja. The weight
for all the specimens was not reported, hence the total
weight reported here is not exact, but it gives a general
picture of the ivory stockpile in Nigeria. According to
the CITES MA for Nigeria, there has been a net increase
in the quantity of ivory in the national stock given that
several seizures were carried out in Nigeria in 2017 and
2018 (pers. comm., 16 September 2018) but no inventory
has been undertaken to get the exact quantity.
Conclusions
In line with previous market surveys, the ivory market in
Lagos, Nigeria, is still thriving, with the Lekki market the
main sales point. This market has been operating illegally
and with impunity for decades with the full knowledge of
the law enforcement authorities.
This survey provides a snapshot of the estimated
quantity and weight of ivory items observed when
compared to the comprehensive survey of 2012 by Martin
and Vigne (2013), and the level of trade is not conclusive.
The fact that there is a robust market for worked ivory
items, however, and considering the seizure information
with links to Nigeria, and Lagos in particular, the country
not only plays a role as one of the major sources of
worked ivory in Africa, but is also an important hub for
raw tusks from at least two African sub-regions, notably
Central and West Africa, and sometimes even as far away
as East Africa. The ramifications are thus far reaching,
negatively impacting elephant populations in those subregions
and by inference, in Africa as a whole. China is
pointed to as one, if not the major destination for both
worked ivory products and raw elephant tusks, with
large-scale exports of mainly raw ivory by Lagos-based
high-level operatives (mainly Chinese) and worked ivory
transported from Lekki and other markets by smallscale
courier traders, including via mail/courier parcels
(D. Stiles, in litt., 13 January 2019). It will be interesting
to see how the closure of the China’s domestic markets
announced on the last day of December 2017 impacts the
direct trade between the two countries.
Increased law enforcement pressure was cited as one
of the principal reasons for the documented decline in
the quantity of ivory on open display in most Central
African markets (Nkoke et al., 2017), the others being
an increase in raw ivory prices, and a decline in elephant
populations. Chinese nationals are buying up most of the
tusks at prices that local carvers cannot compete with,
(D. Stiles, in litt., 13 January 2019). It is important for
the Nigerian government to exert more law enforcement
effort to discourage open trade in ivory items. It is also
imperative for the Nigerian government to implement
fully the CITES NIAP in order to check the illegal ivory
trade in the country.
Recommendations
The following recommendations are proposed to address
the continued and thriving ivory market in Lagos:
i. The Nigerian government and other stakeholders
need to implement fully the provisions of the National
Wildlife Species Protection Act of 2016, which bans
and criminalises the illegal trade of elephant products
in that country.
ii. Action needs to be taken to close down the Lekki
ivory market completely through a strategic approach
including education targeting vendors and potential
buyers from Nigeria and China through awareness
campaigns, behaviour change communication and
other communication strategies; scaled up and
sustained law enforcement efforts; and promotion of
alternatives, especially animal bone and wood for the
production of artefacts. CITES Parties may wish to
consider the option of introducing trade sanctions in
the case of Nigeria’s failure to close down its ivory
market.
iii. As a priority, efforts should be made to build the
capacity of wildlife and other law enforcement
authorities, amongst others, in relation to the
conservation of elephants, CITES processes, law
enforcement procedures, identification of products
and other related tools.
iv. Promotion at the national level in Nigeria of
inter-agency co-operation, collaboration and
communication, especially between the CITES MA
and NESREA as well as other law enforcement
agencies (Customs, police, airport/port authorities,
coast guards, prosecution services, etc.), clearly
defining their different roles and responsibilities and
monitoring implementation.
v. At the regional level, Nigeria and its CITES MA, as a
member of ECOWAS (Economic Community of West
African States) should seek collaboration both within
ECOWAS and its recently agreed law enforcement
action plan, and with its eastern neighbours of Central
Africa, and collaborate regionally with COMIFAC
(Central African Forest Commission) on their strategy
to combat wildlife crime as a whole.
vi. The Nigerian government should work more
closely with key airlines known to be used in the
transportation of wildlife products including ivory.
vii. Greater collaboration with Cameroon is needed to
establish joint coastguard/border patrols at land and
sea points of entry to target illegal wildlife trade.
viii. In view of the apparent key role and involvement
of Chinese nationals in illegal buying and trading
of ivory in and from Nigeria, the governments of
Nigeria and China should consider closer bilateral
collaboration to implement the agreements
pertaining to illegal wildlife trade reached in Beijing
in September 2018 under the Forum on China-
Africa Cooperation (FOCAC) Beijing Action Plan
(FOCAC, 2018). Such bilateral collaboration should
include joint training of government law enforcement
agencies (see TRAFFIC, 2019) as well as consider
working towards a mutual legal assistance treaty
(MLAT) between both countries.
ix. Effectively implement the NIAP as requested by
CITES, broadly covering legislation, prosecution,
intelligence and investigation actions, co-operation
at the national and international levels, law
enforcement and operation actions, communication
etc. In addition to the NIAP implementation, the
Nigerian authorities also need to increase reporting
of ivory seizure cases to ETIS for a better analysis of
their law enforcement actions.
x. Put in place an effective ivory stockpile management
system according to CITES Resolution Conf. 10.10
(Rev. CoP17, https://www.cites.org/sites/default/
files/document/E-Res-10-10-R17.pdf).
xi. The minimum standards developed by TRAFFIC
must be applied to help guide ivory stockpile
management. These include information on the
source of ivory, how to measure and mark each piece
of ivory in the stockpile, centralisation of the ivory
in a national government stockpile, security issues,
and procedures for audits and periodic verification
(Ringuet and Lagrot, 2013).
Forest elephant
Loxodonta africana cyclotis,
lone male in early morning mist,
Dzanga Bai, Dzanga-Ndoki National Park,
Central African Republic,
one of the source countries of ivory
reported by the vendors in
Lekki market, Lagos.
S H O R T R E P O R T
TRAFFIC Bulletin Vol. 31 No. 1 (2019) 33
© MARTIN HARVEY / WWF
S H O R T R E P O R T
34 TRAFFIC Bulletin Vol. 31 No. 1 (2019)
Acknowledgements
The author thanks the United States Agency for
International Development (USAID) for providing the
financial support for this survey through the Wildlife
Trafficking, Response, Assessment and Priority Setting
Project (Wildlife-TRAPS) and IUCN, International
Union for Conservation of Nature. Special thanks to
the team of the Nigerian Conservation Foundation,
especially Onoja Joseph, Adedayo Memudu and Joshua
Dazi for their technical, logistics and field support and to
Nosa Aigbedion of NESREA, Nigeria, for his availability
and valuable information. Special acknowledgement is
made of the time, valuable assistance and collaboration
provided by the late Ehi-Ebewele Elizabeth, of the CITES
MA for Nigeria and focal person for Nigeria’s NIAP, who
sadly passed away on 8 February 2019. Grateful thanks
to Daniel Stiles for his review of this paper and helpful
comments, and to TRAFFIC staff members Steven
Broad, Paulinus Ngeh, Nick Ahlers, Roland Melisch,
Tom Milliken, Richard Thomas, Kim Lochen and Lauren
Brown for their inputs and for enriching this report.
References
Akeredolu, O.E., Babalola, F.D., Ehi-Ebewele, E.E. and Uzu,
T.J. (2016). Investigation into ivory trade in selected markets
and hotels in Lagos, Nigeria. Journal of Agricultural
Research and Development. 15(2):2016.
Anon. (2016). Progress Report on Nigeria National Ivory
Action Plan (December 2016). Prepared by the Federal
Ministry of Environment (Department of Forestry).
Submitted to the CITES Secretariat. https://cites.org/sites/
default/files/common/prog/niaps/Nigeria_NIAP_PR_Post-
SC69_posted%20on%20website.pdf
Blanc, J.J., Barnes, R.F.W., Craig, G.C., Dublin, H.T., Thouless,
C.R., Douglas-Hamilton, I. and Hart, J.A. (2007). African
Elephant Status Report 2007—an Update from the African
Elephant Database. Occasional Paper of the IUCN Species
Survival Commission No. 3.
Bourgoin, P. (1949). Les principaux Animaux de Chasse de
l’Afrique Noire. Edition de Bretagne, Lorient.
CITES (2017). Status of Elephant Populations, Levels of Illegal
Killing and the Trade in Ivory: A Report to the CITES
Standing Committee. SC69 Doc. 51.1, Annex. Sixty-ninth
meeting of the Standing Committee, CITES Secretariat,
Geneva, Switzerland. 31 pp.
CITES (2013). Sixteenth meeting of the Conference of the
Parties to CITES. Bangkok (Thailand), 3–14 March.
Provisional agenda and working documents. https://www.
cites.org/eng/cop/16/doc/index.php
Courouble, M., Hurst, F. and Milliken, T. (2003). More Ivory
than Elephants: Domestic Ivory Markets in Three West
African countries. TRAFFIC, Cambridge, UK.
Douglas-Hamilton, I. (1979). African Elephant Trade Study,
Final Report. Laebra 1979/005.
Dunn, A. and Nyanganji, G. (2011). Improving Protection for
Nigeria’s Largest Elephant Population in Yankari Game
Reserve. Wildlife Conservation Society. https://elephantconservation.
org/downloads/pdf/RPT%20Final_IEF_Yankari%
20Elephants_AF_FINAL%20June_2011.pdf
EIA (2017). The Shuidong Connection: Exposing the global
hub of the illegal ivory trade. EIA, London, UK.
FOCAC (2018). Forum on China-Africa Cooperation Beijing
Action Plan (2019–2021). Viewed at https://focacsummit.
mfa.gov.cn/eng/hyqk_1/t1594297.htm
Martin, E. and Stiles, D. (2000). The Ivory Markets of Africa.
Save the Elephants, London, UK.
Martin, E. and Vigne, L. (2013). Lagos, Nigeria: One of the
largest retail centres for illegal ivory surveyed to date.
TRAFFIC Bulletin 25(1):35–40.
Milliken, T. (2014). Illegal Trade in Ivory and Rhino Horn: an
Assessment to Improve Law Enforcement Under the Wildlife-
TRAPS Project. TRAFFIC, Cambridge, UK.
Milliken, T., Burn, R.W., Underwood, F.M. and Sangalakula, L.
(2012). The Elephant Trade Information System (ETIS) and
the Illicit Trade in Ivory: a Report to the 16th meeting of
the Conference of the Parties. CoP16 Doc. 53.2.2 (Rev. 1),
CITES Secretariat, Geneva, Switzerland. 30 pp.
Milliken, T., Underwood, F.M., Burn, R.W. and Sangalakula,
L. (2016). The Elephant Trade Information System (ETIS)
and the Illicit Trade in Ivory: a Report to the 17th meeting
of the Conference of the Parties. CoP17 Doc. 57.6 (Rev.
1) Annex, CITES Secretariat, Geneva, Switzerland. 29 pp.
Milliken, T., Underwood, F.M., Burn, R.W. and Sangalakula,
L. (2018). The Elephant Trade Information System (ETIS)
and the Illicit Trade in Ivory: a Report to the 18th meeting
of the Conference of the Parties to CITES. CoP18 Doc. 69.3
Annex 1, CITES Secretariat, Geneva, Switzerland. 26 pp.
Nellemann, C., Henriksen, R., Kreilhuber, A., Stewart, D.,
Kotsovou, M., Raxter, P., Mrema, E. and Barrat, S. (Eds)
(2016). The Rise of Environmental Crime—A Growing
Threat to Natural Resources Peace, Development
and Security. A UNEP/INTERPOL Rapid Response
Assessment. UN Environment Programme and RHIPTO
Rapid Response–Norwegian Center for Global Analyses.
Nkoke, S.C., Ngeh, C.P. and Ahlers, N. (2016). Workshop
Proceedings: Sub-Regional Action Planning to Strengthen
Regional Collaboration. Support of the Implementation
of National Ivory Action Plans (NIAPs) in Central Africa.
TRAFFIC. Yaounde, Cameroon. 30 pp.
Nkoke, S.C., Lagrot, J.F., Ringuet, S. and Milliken, T. (2017).
Ivory Markets in Central Africa—Market Surveys in
Cameroon, Central African Republic, Congo, Democratic
Republic of the Congo and Gabon: 2007, 2009, 2014/2015.
TRAFFIC. Yaounde, Cameroon and Cambridge, UK.
Okekunle, A.T. (2016). Spatial Distribution and Conservation
of Forest Elephants (Loxodonta africana cyclotis) in Southwestern
Nigeria. Rufford Small Grants Foundation.
Ringuet, S. and Lagrot, J.F. (2013). Développement d’un Système
de Gestion des Stocks D’Ivoire au Gabon; Proposition des
Standards Minimums. Un Rapport TRAFFIC.
Thornton, A. and Currey, D. (1991). To Save an Elephant.
Doubleday. ISBN 0-385-40111-6
Thouless, C.R., Dublin, H.T., Blanc, J.J., Skinner, D.P., Daniel,
T.E., Taylor, R.D., Maisels, F., Frederick, H.L. and Bouche,
P. (2016). African Elephant Status Report 2016: an Update
of the African Elephant Database. Occasional Paper No.
60, IUCN/SSC, Gland, Switzerland.
TRAFFIC (2019). TRAFFIC supports Asia-Africa Customs
Workshop on improved collaboration. Viewed at: https://
http://www.traffic.org/news/traffic-supports-asia-africa-customsworkshop/
Wasser, S.K., Brown, L., Mailand, C., Mondol, S., Clark, W.,
Laurie, C. and Weir, B.S. (2015). Genetic assignment of
large seizures of elephant ivory reveals Africa’s major
poaching hotspots. Science 349(6243):84–87.
Zhou, S. (2017). Number of Chinese immigrants in Africa
rapidly increasing. China Daily. http://www.chinadaily.
com.cn/world/2017-01/14/content_27952426.htm
Sone Nkoke Christopher, Project Officer, Wildlife TRAPS
(Wildlife Trafficking, Response, Assessment and Priority
Setting), Central Africa, TRAFFIC.
E-mail: sone.nkoke@traffic.org
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