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I am honored to have this opportunity to submit this testimony as a statement for the record. Illicit economies, such as the drug trade and wildlife trafficking, organized crime, corruption, and their impacts on U. I have conducted fieldwork on these issues in Latin America, Asia, and Africa. The Brookings Institution is a U. 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 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. 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. 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. Government, which seeks to delink counternarcotics cooperation with China from the overall bilateral geostrategic relationship, China subordinates its counternarcotics cooperation to its geostrategic relations. In August , 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. 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. 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. 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 money laundering brokers mostly manage to circumvent the U. 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. The March crisis in U. 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:. 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. Importantly , to effectively counter the fentanyl-smuggling actors, the United States should expand and smarten up its own measures against criminal actors , including by:. Synthetic opioids are the source of the deadliest and unabating U. Since , drug overdoses have killed over 1 million Americans, 1 a lethality rate that has increased significantly since when synthetic opioids from China began supplying the U. In , the number of fatalities was ,; 2 and in , it is estimated at , After years of intense U. Government officials and international drug policy and China experts, the U. The United States is the only other major country that has controlled the entire class of fentanyl drugs — in the U. Congress has yet to make permanent. But even though China placed the entire class of fentanyl-type drugs and two key precursors under a controlled regulatory regime in May , it remains the principal if indirect source of U. 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. 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. The extent of counternarcotics cooperation — or its absence — remains determined by the state of the U. Thus, the hope that despite the geopolitical rivalry, counternarcotics could prove a domain of U. Rejecting U. 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. Small and middle-level actors are more likely to become targets if and when enforcement action is taken. 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. However, this clear pattern of behavior is not centrally organized, systemically endorsed, or openly tolerated behavior. Moreover, different provinces often develop distinct forms of illegal bureaucratic protection, complicating uniform, systemic, and efficient application of rule of law. Overall, as with other countries such as Australia, China subordinates its counternarcotics cooperation to the geostrategic relationship with the United States. 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. Various U. 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 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. 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. 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. 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. 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 only interface with the formal banking system takes place in China, into which U. Using encrypted platforms, burner phones, and codes, cartel representatives hand over bulk cash to Chinese contacts. The contact brings the money to U. Michael R. Glass, Taylor B. Seybolt, Phil Williams. 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. 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. 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. 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. 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. Mexican criminal groups are also expanding into illegal fishing outside of Mexico. 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. 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. 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. 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 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 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. 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. Even for U. This lack of visibility has only intensified since January when China became the focus of a negative international spotlight due to the outbreak of the COVID 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. 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 , the U. Drug Enforcement Administration DEA provided their Chinese counterparts with its intelligence that led to the arrests. The case remains perhaps the high mark of U. But it took place when Beijing was still hoping that an improvement in U. 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 regulation. Consequently, in August , the U. 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 , China officially announced that it suspended all of its counternarcotics and law enforcement cooperation with the United States. From the beginning of his administration, he has sought to withdraw from the Merida Initiative, the U. And he sought to redefine the collaboration extremely narrowly as merely U. Previous Mexican governments also certainly sought a significant increase in U. Cienfuegos over to Mexico where he was rapidly acquitted. But despite this significant U. Meanwhile, U. 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. The U. The Mexican government has conducted some interdiction operations based on U. 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. 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. 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. 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. Yet the effectiveness of all U. 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. 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. Nonetheless, even absent such reform, the United States can take impactful measures that I discuss below. 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 s end 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. 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. However, in time, U. 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. 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. 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. 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. Washington can insist that Beijing shut down the worst offenders. Of course, there is a risk that U. China has previously resorted to both. 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. 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. 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. 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. 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. Calls for U. 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. The latter designation also carries extensive prohibitions against material support. But an FTO designation could significantly limit and outright hamper U. 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. The FTO designation could hamper the delivery of U. Under optimal circumstances, U. 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. 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. 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. These include U. Moreover, the focused collection, analysis, and reporting of intelligence by a variety of U. To such end, crimes against nature should be elevated as a Collection and Reporting priority of the U. Intelligence Community, and within the U. 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. 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. 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. The DEA appropriately enjoys strong capacities, currently maintaining a force of agents. As a corollary and imperative effort, U. Importantly, wildlife trafficking should be designated as a predicate offense for wiretap authorizations. 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. Expanding the intelligence-gathering aperture and mandating and resourcing a whole-of-government approach in support of U. Foreign Policy. China Mexico. Initiative on Nonstate Armed Actors. Sections Sections. Sign Up. Vanda Felbab-Brown. Related Books Narco Noir. Urban violence, resilience and security: Governance responses in the Global South. Seybolt, Phil Williams January 21, Organized crime and illicit trade: How to respond to this strategic challenge in old and new domains. Related Content China-linked wildlife poaching and trafficking in Mexico. China and synthetic drugs control: Fentanyl, methamphetamines, and precursors. China China and synthetic drugs control: Fentanyl, methamphetamines, and precursors Vanda Felbab-Brown March 23, China and synthetic drugs: Geopolitics trumps counternarcotics cooperation. Tanz, R. Matt Gladden, Nicole L. Merianne Rose Spencer, Arialdi M. Vanda Felbab-Brown interviews with former and current U. Drug Enforcement Administration. Department of Justice, December Caulkins, Brittany M. Cisneros-Montemayor, Dale Squires, U. Government and law enforcement officials, October What went wrong? Questions and answers period, U. Ibid: ; and ; Javier C. See 18 USC , Authorization for interception of wire, oral, or electronic communications. More On. Czin, Ryan Hass October 18,