Definition
Administrative action
An administrative action is a legal action concerning the conduct of a public administrative body.
Show MoreJBS, the world’s largest meat processor, and its financial enablers, have turned the deforestation of the Amazon for cattle-ranching expansion into a thriving business model – a business model that has been depriving Indigenous communities of their livelihoods and fueling the global climate and biodiversity crises for decades. The Transnational Legal Coalition (TLC), formed in 2024, launched coordinated legal actions in the Netherlands, Ireland, UK and Germany against JBS and 11 of its business service providers, including banks, investors, law- and accounting firms, concerning suspected money laundering offenses.
The complaints aim to push European regulatory authorities to investigate suspected money laundering linked to illegal deforestation, Indigenous- and human rights violations, and possible failures by JBS’s providers to comply with due diligence and reporting obligations deriving from existing anti-money-laundering laws (AML).
There is a vast body of evidence connecting the meat-processor JBS to decades of illegal deforestation and land grabbing of Indigenous territories in the Brazilian Amazon. Most of this deforestation is not only illegal, but also constitutes an environmental crime under Brazilian law – as it would be under the laws of most European states. Through its direct and indirect suppliers, JBS can be linked to 6.5 million hectares of deforested land, as new analyses from Aid Environment show. By late 2023, an estimated 60,000 cattle were being raised illegally on nearly 900 km² of pasture within Indigenous territories. Indigenous communities continue to pay the price for illegal deforestation: they are forced out of their own territories, while their homes, livelihoods and cultures are destroyed. In addition, their struggles to defend their rights and denounce these crimes contend with constant criminalization and violent suppression.
The TLC argues that under anti-money laundering (AML) laws, the cattle raised on criminally deforested land constitute proceeds of crime. This assessment remains unchanged by JBS’s usual business practice of moving cattle to compliant farms before they are slaughtered and processed at one of its 21 facilities in the area. The concept of money laundering applies to all physical and other new forms of handling of money or property derived from criminal activity – provided those handling it know of or have reason to suspect its criminal origin. The TLC claims that vast publicly available evidence raises serious questions about JBS’s knowledge of the origins of the cattle in its supply chain. This is why we have filed a complaint against JBS’s ultimate parent company, which was recently established in the Netherlands. We are asking the Dutch Public Prosecutor's Office to open an investigation into JBS N.V. and, ultimately, to bring charges against the company for money laundering – specifically, for handling the proceeds derived from illegally deforested land in the Amazon.
Given the size and volume of JBS’s business and its globe-spanning value chain, the risk of money laundering travels alongside the profits generated within global financial markets. Therefore, the TLC’s other 11 complaints target financial institutions that lend to or invest in JBS, as well as the company’s legal and accounting firms in the Netherlands. These complaints rely on AML legal frameworks common to all European states – as well as the UK. Essentially, this framework requires those operating in the “regulated sector” – including financial institutions, lawyers and accountants – to conduct enhanced due diligence for AML purposes on customers and transactions which carry a high risk of money laundering. It also requires them to report suspected money laundering to the relevant authorities. In fact, failing to report such suspicions can constitute a criminal offense, both for the company and its employees.
Environmental crime is one of the most lucrative crimes of all – globally, it generates more illicit revenue than human trafficking or counterfeiting. While the latter have long been punished accordingly, illegal mining, deforestation, and overfishing have so far faced hardly any criminal consequences in Europe. The price is paid by disenfranchised local, often Indigenous, traditional communities. Their livelihoods, land and territories are turned into commodities for the global markets and their human rights violated, often with little consequences for the perpetrators. Yet the biggest drivers and beneficiaries of such environmental crimes are right here in Europe: banks, financial service providers, and multinational corporations.
The Transnational Legal Coalition (TLC) aims to challenge the world’s biggest corporate and financial abusers. It was founded by ECCHR.
An administrative action is a legal action concerning the conduct of a public administrative body.
Show MoreAn administrative action is a legal action concerning the conduct of a public administrative body.
Show MoreEconomic activities in the Global South far too often disregard the plight of people and the environment. Looking at resource exploitation, we see that the responsibility for endangering human rights and the environment lies with those who profit most from these industries in the global economy. We work with those affected by such human rights violations to enforce their rights.
Show MoreEconomic activities in the Global South far too often disregard the plight of people and the environment. Looking at resource exploitation, we see that the responsibility for endangering human rights and the environment lies with those who profit most from these industries in the global economy. We work with those affected by such human rights violations to enforce their rights.
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