In a bleak year for international cooperation, the 2025 G20 summit in South Africa reached a rare point of agreement: environmental crime can no longer be sidelined. In November, leaders issued their first statement recognizing the ‘urgent need’ to tackle the ‘serious threat’ crimes against the environment pose. This signals that governments in both the North and South are finally beginning to see the severity of the problem. But if a clampdown is to succeed, the most basic issue must first be confronted: many policymakers still do not regard environmental crime as organized crime. EU countries have an opportunity to get this right when sharpening their environmental criminal laws in 2026.

But is it really organized crime?   

Misconceptions around environmental crime run deep, including at multilateral meetings specifically designed to counter it. At a UN expert group meeting last year, it was clear in both formal and informal conversations that many countries are still not convinced that environmental crime is serious enough to warrant international attention. Even some transit and consumer countries that face serious environmental crime problems – especially those in which legal and illegal commodities are blended – have been dismissive. The dissonance is not unusual, however: when criminal networks successfully embed themselves in legitimate trade flows, they become invisible even to the authorities in countries they actively exploit.

Many continue to view organized crime as synonymous with drug cartels, which are notorious for extreme violence. Cartels fight wars to control routes; gangs battle over territory. Both are products of the regulatory environment around drugs, which are almost universally prohibited. Others conceive of organized crime as mafia-style groups, with their use of extortion and violence. These models tend to be organizationally hierarchical and known for their strong identity cultures.

But for the most part, criminal networks involved in environmental crime do not organize themselves like Colombian drug cartels or Italian mafias – they do not need to. The commodities they traffic are rarely completely prohibited and usually have routes to market that are legal. As a result, environmental crime has long relied on legitimate companies and businesses as fronts. These networks tend to deploy violence only sparingly, favouring coercion, intimidation or targeted killings – especially of those brave enough to be environmental defenders.

Environmental crime networks depend on upperworld technology and services (customs, logistics, financial markets), as well as expert understanding of regulatory frameworks and their loopholes, often engaging specialists only as needed and for short periods. The actors involved tend not to emerge from the regular criminal recruitment ground – such as the bouncer and security industries – or to develop marked criminal cultures. This makes the networks engaged in trafficking environmental commodities more difficult to define and identify. In fact, their protagonists frequently have public personas as legitimate businesspeople.

Nevertheless, environmental crime networks display many of the same hallmarks as traditional organized crime: they are transnational with multi-actor involvement, and have highly complex and intertwined business structures, professional money laundering tools, corruption strategies and sophisticated concealment practices. That environmental crime is less overtly violent in nature than drug markets and mafias does not justify a different legal and enforcement approach – especially given the global harm it causes.

Models for the future of organized crime

The differences in organizational structure and visibility between environmental crime networks and traditional mafias highlight a wider transformation in organized crime, as examined in Europol’s latest Serious and Organised Crime Threat Assessment. Today’s criminal networks are often fluid, with shifting membership and temporary partnerships formed according to need. Digital tools, like encrypted messaging and online markets, have lowered the barriers to entry, enabling small crews to transact globally without traditional gatekeepers. This produces a more atomized criminal ecosystem, where collaboration is opportunistic and even loosely connected actors can access global illicit markets.

Europol notes that criminal networks systematically use legitimate businesses, logistics chains and financial infrastructures to operate. In fact, an estimated 86% of Europe’s most threatening criminal networks are able to infiltrate the legal business world to disguise their activities and launder criminal profit. This integration has blurred the boundaries between licit and illicit trade, making organized crime harder to isolate from the global economy.

Seen in this light, the forms that environmental crime takes are not outliers, but ahead of the curve: timber laundered through respectable firms; hazardous waste moved through freight-forwarders under falsified paperwork; illegal catch from distant-water fleets discretely merged with global seafood supply chains under flags of convenience; exotic pets sold through social media; ‘dirty gold’ from informal Amazon mines legitimized by licensed brokers and international refineries.

It should not be the case, then, that environmental crime is seen as ‘insufficiently organized’ to warrant being considered an organized criminal activity. These are precisely examples of how environmental crime operations were early adopters of the technologically mediated, networked and economically integrated practices that now characterize the contemporary organized crime landscape. Misapprehending this can be costly. It means governments fail to equip their enforcement actors with the tools they need to be effective against environmental crime.

Europe grapples with the challenge

The test of whether governments grasp this reality now sits firmly with the EU, which has an unprecedented opportunity to get this right. EU states have until May 2026 to bring the revised Environmental Crime Directive into national law, and explicitly reclassify environmental crime as a form of serious crime requiring dedicated tools. These could include the powers and resources to carry out sophisticated investigations, undercover operations, controlled buys, financial and digital forensics, wiretapping and specialized skills to determine illegality in grey markets.

Adopted in April 2024, the directive states that environmental crime offences involve repeat criminality, corruption, fraud, intimidation and irreversible ecological damage. It mandates strict penalties – lengthier sentences and fines for businesses of up to €40 million or a percentage of their global turnover. But crucially, the deeper message sits in its enforcement provisions, which, if they were to be adopted, would enable states to use investigative tools normally reserved for serious organized crime – like asset tracing, surveillance and undercover work. It also sets out how national authorities will need training and capacity to use these tools, including cooperation mechanisms across agencies and borders. In other words, administrative enforcement is not enough; what is needed is the investigative muscle, financial tools and professional depth associated with major organized crime investigations.

The question now is, will European states rise to the challenge and treat environmental crime for what it is – organized crime? All policy changes are trade-offs, and not all European states appear to be convinced of the severity of the threat, meaning they may opt for a minimalist implementation. In Germany, for example, essential law enforcement tools to counter organized crime are not available to combat environmental crimes. The current government does not appear willing to change this – its draft bill to incorporate  the Environmental Crime Directive fails to embrace investigative instruments such as telecommunication surveillance, which is widely criticized by police unions and national experts. This may suggest that some member states will water down the directive’s intent.

However, experts and civil society organizations agree that a paradigm shift is overdue. If European states step up, they will achieve something more fundamental than meeting EU obligations or demonstrating environmental commitment. Their law enforcement systems will finally be aligned with the new reality of 21st-century organized crime.