In August, the International Criminal Police Organization released a report on increased organized environmental crime. In their analysis, INTERPOL warned that “the organized crime-pollution crime nexus is a global phenomenon, involving a wide variety of perpetrators and organizational structures.”

Based in Lyon, France, INTERPOL is the world’s largest international police organization. It’s also the only multi-national law enforcement group with a focus on illegal polluters.

INTERPOL examined 27 cases of international environmental crime. They discovered:

Organized criminal groups of any size have been found involved in cases of pollution crime in many countries worldwide, with illicit operations ranging from local activities to large-scale intercontinental trafficking worth millions USD.


legitimate companies operating in the environmental compliance sector shift towards illegal business practices and commit pollution crime to increase their profits.

Mafia-style organizations profiting off the destruction of our planet is not new. Robert Saviano’s 2007 Gomorrah: A Personal Journey into the Violent International Empire of Naples’ Organized Crime System, devotes a whole chapter to the Camorra crime syndicate’s illegal dumping business.

The bosses have had no qualms about saturating their towns with toxins and letting the lands that surround their estates go bad. The life of a boss is short; the power of a clan, between vendettas, arrests, killings, and life sentences, cannot last for long. To flood an area with toxic waste and circle one’s city with poisonous mountain ranges is a problem only for someone with a sense of social responsibility and a long-term concept of power. In the here and now of business, there are no negatives, only a high profit margin.

On a trip to Italy in 2017, I saw the dumping firsthand on Mount Vesuvius. The villainous Italian volcano that dropped lethal ash on Pompeii is now, thanks to the Camorra, a superfund site. The smoke isn’t volcanic activity. They set fire to the pollutants after they dump them.

Toxic waste burning on Mount Vesuvius
photo credit Don Carr

The revelations in Saviano’s book forced him into exile with fears of Camorra retaliation. But his reporting predicted the rise of environmental crime businesses worldwide.

Every year a million tons of high-tech waste from Europe are unloaded in China. The stakeholders relocate the waste in Guiyu, northeast of Hong Kong. Entombed, shoved underground, drowned in artificial lakes. Just as in Caserta, Guiyu has been contaminated so quickly that the groundwater is now completely polluted, and drinking water must be imported from neighboring provinces. The Hong Kong stakeholders’ dream is to make the port of Naples the hub for European refuse, a floating collection center where the gold of trash can be crammed into containers for burial in China.

According to the US Environmental Protection Agency, their Criminal Investigation Division has participated in four joint operations with INTERPOL. The first in 2017, resulted in cases against 483 individuals and 264 companies responsible for over 1.5 million tons of illegal waste. The latest in 2021, targeted marine pollution. “Operation 30 Days at Sea 3.0,” uncovered 500 illegal acts of pollution committed at sea.

What About Organized Environmental Crime in America?

“It is the most significant series of frauds on the environment ever prosecuted,” retired EPA investigator Doug Parker told me about the biofuel credit cartel that fleeced the US government for over a billion dollars. Scott Irwin, an agriculture economist at the University of Illinois, said of the biofuel crime syndicate “I half-expected the real Mafia to be involved in RIN fraud,” given organized crime’s connections in the waste management industry.

Lev Derman and Jacob Kingston
Lev Dermen, left, with Jacob Kingston, 2014. Federal prosecutors say to launder money from biofuels fraud, Kingston purchased the Bugatti, left, to give to Dermen, who purchased the Ferrari on the right to give to Kingston. Photo credit U.S. District Court for the District of Utah.

Historically, as Irwin alluded to, our mafia makes badda-green off price fixing and waste hauling contracts in the garbage business. (though they have done some illegal dumping in the past). Aside from biofuel fraud, most of the acts committed in the EPA quarterly crime bulletin are by independent actors. But according to an email exchange with an EPA enforcement spokesperson, the agency does believe there is more homegrown organized environmental crime.

A small percentage of our criminal case docket contains an organized crime nexus.

Transnational organized criminal networks engage in a broad range of criminal activities and pollution crimes are no exception. We have seen activity in the illegal trafficking and disposal of dangerous chemicals, including, hazardous waste, pesticides, and hydrofluorocarbon (HFC) refrigerants. Our border pesticide operation developed organized crime links and activity, some of which we are currently investigating. Several of our aftermarket defeat device cases have international money laundering implications, that we are also actively pursuing.

It’s a good thing that there’s a small percentage since Congress has strangled enforcement funding in recent years. Fossil fuel enthusiast Scott Pruitt abused the CID during the Trump administration, using EPA special agents as his personal Tokyo Drift chauffeurs.

In positive news, the DOJ’s Environment and Natural Resources Division has signaled a new direction. From remarks Assistant Attorney General Todd Kim delivered to the American Bar Association’s National Environmental Enforcement conference in December of 2021:

Although we may have fewer criminal cases than civil cases, criminal prosecutions are an indispensable and powerful deterrent to illegal behavior. A genuine threat of criminal prosecution can and will change the conduct of individuals and corporations who would not be deterred by the threat of civil enforcement alone.

Like the man said, “You can get much further with a kind word and a gun than you can with a kind word.”

Hampering the pro-enforcement posture was David Uhlmann’s stalled congressional confirmation. Tapped to lead EPA’s Office of Enforcement and Compliance Assurance, the highly qualified Uhlmann would ensure criminal polluters are relegated to a life of egg noodles and ketchup. Thankfully, he was just announced as a Senior Advisor to EPA Boss Michael Regan in the interim.

But, like old barrels of DDT illegally dumped off the Los Angeles coast, new threats keep surfacing. E&E’s Kevin Bogardus reported on September 9th about preparations for EPA investigators to “brace for Trump-fueled backlash.” Turns out Trump’s attacks on the FBI for raiding his illegal stash of classified material has spread to all federal officers.

Some staff at the agency are worried over how inspectors, who often travel alone and unarmed, will be received in the field going forward. One EPA compliance officer who was granted anonymity to speak candidly about the agency’s internal operations said they have seen colleagues blocked from accessing permitted sites.

We have seen people denied entry.

Intimidation and a belief the law doesn’t apply is at the core of any organized criminal operation. Here’s hoping EPA can find a way to keep inspectors sniffing out criminal polluters. Nothing less than our air and water is at stake.

Courtesy of Warner Brothers

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