Although the netting of nine genera and 52 species of marine fish, including whales, dolphins, sharks, and rays is prohibited in Bangladesh, hunting sharks and rays continues unabated.
Officials still believe that fishermen do not intentionally catch sharks and rays, and Bangladesh is still not considered a major exporter of shark derivatives, but conservationists have rung the alarm as fins, cartilage, gill plates, liver and other parts are smuggled in disguise of 'dry fish' from Cox's Bazar to some South-East Asian countries via Myanmar.
The Bay of Bengal shelters various cartilaginous fish, including the hammerhead shark, bull shark, graceful shark, thresher shark, pigeye shark, whale shark, broadfin shark, silky shark, tiger shark, blacktip shark, sawfish, manta and devil rays, guitarfish, wedgefish, Bleeker's whipray, white-spotted whipray, and eagle rays.
Exporting body parts of silky, tiger and blacktip sharks, banded eagle rays, guitarfish and manta rays could be carried out despite restrictions, as it is broadly limited on paper. There is no mechanism to monitor what sharks and rays are being exported.
Recently in Dhaka, the Ministry of Environment, Forest and Climate Change, with support from the Wildlife Conservation Society (WCS), hosted the fifth national seminar on strengthening compliance with the Convention on International Trade in Endangered Species (CITES) of Wild Fauna and Flora. Discussants raised concerns over unabated illegal trade of wildlife centering Bangladesh while placing several recommendations.
CITES is a legally binding agreement between governments that aims to ensure that international trade in wild animals and plants does not threaten their survival. Bangladesh has been a signatory to CITES since 1981. Implementation of CITES aligns with UN Sustainable Development Goals and several other international conventions.
Despite having fallen under marine aquafauna, marine species of Bangladesh are under the conservation umbrella of the Wildlife (Conservation and Security) Act 2012. Due to the increase in the export of sharks and rays, the Forest Department — the CITES enforcement authority in Bangladesh — has provisioned protection of eight genera and 23 shark and rays species by updating the Wildlife Act in 2021.
However, the new move set conditions, such as allowing sustainable export, consumption, and trade of one genus and 29 species of sharks and rays if their catch is found to be 'non-detrimental' to wild populations.
Furthermore, studies on population viability of threatened sharks and rays in Bangladesh waters are entirely missing — a key component that is often used to determine the safe level and sustainable magnitude of harvest and trade in wildlife.
Discussants at the seminar threw another basic question: who can distinguish the export-restricted and export-permitted items on the fish landing stations, when the fishermen are largely unaware of the laws and the regulatory bodies lack monitoring instruments?
In the case of export, the Protection and Conservation of Fish Act 1950 does not provide any protection for sharks and rays. Moreover, the customs officials cannot inspect the 'dry fish' when it is being exported. Usually, the labels of the exported 'dry fish' do not make it clear which species of sharks and rays are in the packs. Bangladesh is a global hotspot for sharks and rays.
As the CITES authority in Bangladesh, the Forest Department provides certification of tradable and non-tradable wildlife. Currently, only export of agarwood has the department's approval. The department is also liable to check the import of non-CITES wildlife. In this task, several law enforcement agencies including Bangladesh Navy, Border Guard Bangladesh, Bangladesh Customs and Bangladesh Police help the Forest Department.
During the seminar, one Forest Department official cited that identifying CITES-listed animals, detecting fake permits, and anomalous trades through the ports are the major challenges for the law enforcers at the grassroots level. Representatives from law enforcement agencies also said that bringing persons involved in illegal wildlife trade to the book seems challenging because such crimes often are not considered as cognisable.
Amir Hosain Chowdhury, Chief Conservator of Forests in Bangladesh, while saying that people involved in wildlife crime or illegal trade of wildlife easily get bail from the court and feel free to continue the crimes, emphasised necessary amendments of the laws.
"These crimes must be considered as cognisable. Otherwise, protecting wildlife from illegal transboundary trading will be tough," Amir said.
Environment Ministry's Additional Secretary Iqbal Abdullah Harun echoed Amir, saying that illegal wildlife trade needs to be recognised as a serious crime in our legislation.
"Because illegal wildlife trade poses a serious threat to national security and regional stability," Iqbal said.
To check illegal trade of shark, rays and other endangered marine life, a distinction between terrestrial and marine wildlife in the definitions of wildlife protective laws is crucial. Such a distinction would further warrant a specific conservation act for marine life.
Moreover, law enforcers need to be aware of the laws and have proper knowledge to identify non-tradable wildlife. Some participants in the discussion rightly said that wildlife conservation should be included in training modules for law enforcers.
At the event, WCS Global Shark and Ray Conservation Program Director Luke Warwick reiterated WCS's commitment to continue supporting Bangladesh in implementing CITES to enable population recoveries for threatened sharks and rays, managing fisheries and bycatch, and regulating trade.
Knowledge sharing is indeed important for the conservation of Bangladesh's wildlife. At the same time, inter-department or inter-agency collaboration is a must. If there are different definitions of tradable and non-tradable animals, illegal wildlife traders always enjoy those as loopholes.