On September 18, 2020, the Deputy Secretary of the U.S. Department of the Interior signed a memorandum to the Director of the U.S. Fish and Wildlife Service. The subject line was clinical: "Programmatic Review and Implementation of International Conservation Grants." The document itself was a finding. After a bipartisan Congressional investigation and an internal departmental review, the Department had concluded that taxpayer funds had been used by grant recipients in ways connected to murder, rape, torture, and abuse of indigenous people across Africa and Asia. Tens of millions of dollars were withheld pending the development of new controls. The recipient at the center of the findings was the World Wildlife Fund.
The figures, drawn directly from the memorandum, are not in dispute. Between 2004 and 2019, WWF received an average of $21 million annually in U.S. taxpayer funds, totaling $333 million across the period. Nearly half of that, approximately $156 million, supported anti-poaching and park management activities, including funding for armed rangers and law enforcement officers operating in countries where the FWS itself acknowledged it could not maintain a consistent physical presence on the ground.
The abuses tied to those activities are detailed in the memorandum's findings section, drawn from internal WWF reports, U.N. Development Program investigations, and reports by Survival International, Rainforest Foundation UK, and the German Development Bank. At Salonga National Park in the Democratic Republic of Congo, where a WWF employee served as the park's top official overseeing hundreds of eco-guards, the memorandum cites the gang-rape of four women in 2015 by forest rangers. WWF posted on its website a photograph of Congolese officials handing that employee an assault rifle. In Cameroon, the memorandum cites incidents in which eco-guards beat a farmer's family in their home, raped his wife, and imprisoned the farmer and his father. A separate incident describes a woman detained by guards, forced to cook for them, and tortured for four days.
The memorandum's most consequential finding is not about any single incident. It is about the system that allowed those incidents to remain unaddressed for years.
WWF, by continuing to work with or supporting governments that fail to protect human rights, was contributing to human rights violations, in contravention of its own policies and of international law. — WWF internal report, cited in the memorandum
The Department found that WWF's own internal investigations had substantiated many of the underlying allegations. Those findings were not shared with U.S. government officials through standard channels. When the Department requested documentation, WWF stated it had been told by other federal parties not to provide internal reports documenting wrongdoing. The Government Accountability Office found that officials at the State Department, USAID, and Fish and Wildlife Service had been "widely surprised" by the allegations. The State Department, the memorandum notes, had been relying on WWF itself to investigate misconduct involving WWF-funded actors. Bipartisan Congressional staff described the practice as troubling.
The oversight funding the FWS dedicated to monitoring these grants averaged about 3% of the total award value, well below any reasonable standard for activities involving armed personnel operating in countries with documented patterns of corruption and human rights violations.
RELYING ON A PRIVATE PARTY TO INVESTIGATE ITSELF, ESPECIALLY WHERE SEVERE HUMAN RIGHTS ABUSES ARE ALLEGED, IS A TROUBLING PRACTICE. — U.S. Department of the Interior memorandum, September 18, 2020, citing bipartisan Congressional staff
The Deputy Secretary's determination at the close of the memorandum is direct: no further funding may be awarded until the deficiencies identified in the review are corrected.
In April and May of 2015, when Pembient announced its intention to manufacture bio-identical synthetic rhino horn and flood the market, the institutional response was led by WWF and TRAFFIC, the wildlife trade monitoring network WWF co-founded. Their position, repeated across science and conservation press over the following six weeks, was that synthetic horn would normalize demand and undermine demand reduction. Pembient's strategy, if it worked, would have eroded the enforcement-based, demand-reduction model that the same organizations had built their international funding around.
By the time this memorandum was written, that model had generated a paper trail of internal investigations into systemic violence, suppressed findings, and a State Department asking the suspect to investigate itself.
That is not a conspiracy. It is an institutional dynamic with a paper trail.
