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Sabah, Malaysia | February 2026 | Illegal Wildlife Trade & Ecotourism Governance
Executive Summary
On 23 February 2026, Malaysian authorities raided a resort in Semporna, Sabah, discovering a live Sunda pangolin (Manis javanica) and multiple pots of cooked pangolin in herbal soup. The operation — designated Ops Khazanah — was conducted jointly by the Sabah Wildlife Department (SWD), the Royal Malaysia Police, and the General Operations Force. Three individuals were arrested under the Sabah Wildlife Conservation Enactment 1997.
This case is analytically significant for two interconnected reasons. First, it implicates the tourism sector as an active demand-side vector for wildlife crime, with the resort reportedly marketing pangolin dishes as an ‘exquisite’ experience for visitors. Second, it occurs within a broader regional trafficking ecosystem in which Singapore plays a structurally important role as a transit hub. This case study examines the incident in its local, national, and regional contexts, with particular attention to Singapore’s entanglement with the pangolin trade, its legislative responses, and the reputational and governance challenges the case presents for Southeast Asia’s ecotourism economies.
Category Detail
Date of Operation 23 February 2026
Location Semporna District, Sabah, Malaysian Borneo
Species Sunda pangolin (Manis javanica) — CITES Appendix I
Evidence Seized 1 live pangolin; multiple pots of cooked pangolin in herbal soup
Arrests 3 individuals
Legislation Invoked Sabah Wildlife Conservation Enactment 1997
Maximum Penalty RM 250,000 fine and/or 5 years imprisonment
Enforcement Body Sabah Wildlife Department (SWD), Royal Malaysia Police, PGA Sandakan
- Background: The Global Pangolin Crisis
1.1 Conservation Status
All eight pangolin species are classified as threatened under the IUCN Red List, with Asian species — including the Sunda pangolin (Manis javanica), Chinese pangolin (Manis pentadactyla), Indian pangolin (Manis crassicaudata), and Philippine pangolin (Manis culionensis) — listed as Critically Endangered or Endangered. The Sunda pangolin, native to Southeast Asia and found in Malaysia, Indonesia, and Singapore, has experienced a population decline exceeding 50% over the last fifteen years. All eight species were uplisted to CITES Appendix I in 2016, effectively banning commercial international trade.
Despite this protected status, a 2025 CITES report revealed that between 2016 and 2024, an estimated 553,042 pangolins were involved in seizures across 49 countries, representing 2,222 separate seizure incidents. Pangolins constitute the world’s most heavily trafficked wild mammals, driven by demand for their scales — used in Traditional Chinese Medicine — and their meat, which confers social status in certain culinary communities.
1.2 Drivers of Demand
Demand is concentrated primarily in China and Vietnam, which together represent the principal alleged destination countries in detected trafficking routes. The demand drivers are dual:
Pharmaceutical demand: Pangolin scales (composed of keratin) are used in traditional medicine formulations, primarily for purported lactation-stimulating, anti-inflammatory, and detoxification properties. Despite a lack of scientific evidence for these claims, their inclusion in traditional pharmacopoeia sustains commercial demand.
Status consumption: Pangolin meat is consumed as a luxury food item signalling wealth and social prestige in elite dining contexts across parts of East and Southeast Asia. The Semporna case exemplifies this dimension, with the resort positioning the dish as an ‘exquisite’ tourist experience.
KEY DATA Between 2017 and 2019, over 609 seizure incidents occurred in Asia alone, accounting for 244,600 kg of scales and 10,971 individual animals. TRAFFIC data indicates that 91% of total seizure volume in Asia since 2015 has been attributable to mainland China, Vietnam, Hong Kong SAR, Malaysia, and Singapore — underscoring the region’s centrality to the trade. (TRAFFIC, 2022; CITES, 2025)
- The Semporna Incident: Case Analysis
2.1 Operational Details
The Semporna district is situated in southeastern Sabah, adjacent to the Celebes Sea, and is internationally renowned as a gateway to some of the world’s most biodiverse marine ecosystems, including the coral reefs surrounding Sipadan Island. The area draws substantial international tourism traffic, particularly from Singapore, mainland China, and Europe, for diving and nature-based experiences.
The raid on 23 February 2026 followed intelligence received by the SWD that a local resort was keeping pangolins and listing them on its menu. The multi-agency task force — comprising SWD officers, Royal Malaysia Police, and PGA Sandakan — executed the operation under the designation Ops Khazanah. Officers discovered a live Sunda pangolin on the premises alongside multiple pots containing cooked pangolin meat in herbal soup, consistent with traditional Chinese medicinal or luxury culinary preparation.
Three individuals were arrested. SWD Director Soffian Abu Bakar confirmed that as a species protected under the Sabah Wildlife Conservation Enactment 1997, no person is permitted to possess, keep, sell, or serve the animal as food. Convictions carry fines between RM 50,000 and RM 250,000 and/or up to five years’ imprisonment.
2.2 The Tourism Dimension: A Demand-Side Analysis
What distinguishes this case analytically from conventional trafficking seizures is its situating within the hospitality and tourism sector. The resort was not merely a transit point for contraband; it was actively marketing a protected species as a premium tourism product. This represents a qualitatively distinct category of wildlife crime: demand generation through the tourism industry.
This commodification of wildlife within a tourism context creates a compounding threat dynamic. Visitors — potentially unaware of the legal prohibition or emboldened by perceived impunity — may seek similar experiences at other establishments. The commercialisation of illegal wildlife consumption as an ‘authentic’ or ‘exotic’ tourism experience can normalise demand among visitor populations who would otherwise lack access to such products in their countries of residence.
ANALYTICAL NOTE The framing of pangolin dishes as ‘exquisite’ tourist experiences is consistent with what scholars of wildlife crime have termed ‘aspirational consumption’ — the attribution of luxury status to the consumption of rare or prohibited species. This is analytically distinct from subsistence consumption, and warrants different regulatory and awareness-raising responses.
2.3 Governance and Institutional Response
The SWD Director’s public statement explicitly linked the incident to Sabah’s international tourism reputation. This is significant: the enforcement response was framed not merely in conservation terms but in terms of destination branding and the state’s obligations to Visit Malaysia 2026, Malaysia’s flagship tourism campaign. Between 2021 and 2024, Sabah welcomed approximately 7.85 million tourists generating over RM 16 billion in revenue; between January and August 2025 alone, over 2.4 million visitors arrived.
This framing reflects an understanding that the economic case for wildlife conservation and the economic logic of sustainable ecotourism are, in principle, aligned. Sabah has invested substantially in positioning itself as a responsible nature destination — the state’s ecotourism strategy explicitly commits to minimum negative socio-cultural and environmental impacts, and its wildlife facilities (the Sepilok Orangutan Rehabilitation Centre, the Bornean Sun Bear Conservation Centre) attract international recognition. The Semporna case therefore represents a direct threat to a carefully constructed national brand.
- Singapore: Structural Position and Regional Implications
3.1 Singapore as a Trafficking Transit Hub
Singapore’s significance to the regional pangolin trade derives primarily from its role as the world’s second-busiest port and a global free trade and logistics hub. Academic and enforcement literature consistently identifies Singapore as a critical transit node in trafficking supply chains connecting source regions — principally Central and West Africa — with destination markets in China and Vietnam.
The evidence base is substantial. In a single six-day period in April 2019, Singaporean authorities intercepted nearly 26 metric tonnes of pangolin scales — estimated at USD 77 million in black-market value — en route from Nigeria to Vietnam. This single interdiction, which comprised two separate seizures of 12.9 and 12.7 metric tonnes respectively, remains among the largest in recorded wildlife enforcement history.
SINGAPORE 2019 SEIZURE In April 2019, Singapore authorities seized approximately 25.6 metric tonnes of pangolin scales in two separate operations conducted within six days. These shipments, transiting Singapore’s port from Nigeria to Vietnam, represented an estimated 36,000 pangolins and had a black-market value of approximately USD 77 million. The seizures demonstrated both Singapore’s centrality to trafficking routes and the scale of industrial-level wildlife crime.
Singapore’s free trade zones are particularly vulnerable to transit exploitation. As noted in academic analysis published in the East Asia Forum, these zones are used as transit locations for illicit wildlife trafficking, with pangolin scales moving through global supply chains connecting supply regions like Nigeria with destination markets in China. Free trade zones can obscure the nature and origin of illegal wildlife products, limiting documentation requirements and customs scrutiny.
3.2 Singapore’s Legislative and Conservation Response
Singapore has progressively strengthened its legislative framework in response to its role in the global trade. In 2022, the Endangered Species (Import and Export) Act was amended to significantly increase penalties: traffickers now face fines of up to SGD 100,000 per specimen and up to six years’ imprisonment. This represents a substantial toughening of the deterrence framework.
In parallel, Singapore has invested in conservation science relevant to pangolin survival. The Mandai Wildlife Group, operating under Mandai Wildlife Reserve, operates a biobanking programme that has successfully extracted and stored genetic material from 38 Sunda pangolins. The initiative — begun approximately a decade ago — reflects the institution’s recognition that ex-situ genetic conservation may represent a critical safety net for species populations subject to severe poaching pressure.
Within Singapore’s urban environment, the Sunda pangolin’s primary threat is vehicle traffic rather than direct poaching. However, the island’s awareness of its complicity in global trafficking dynamics — through transit infrastructure — has informed a policy posture combining domestic conservation, regional intelligence-sharing, and graduated legislative deterrence.
3.3 Singapore-Malaysia Conservation Interdependencies
The Sabah incident has direct relevance for Singapore across multiple dimensions of wildlife governance and regional responsibility:
Supply Chain Disruption
The Semporna resort’s activities represent a demand-side node within a supply chain whose upstream and downstream segments may involve Singaporean infrastructure. While no direct evidence links this specific incident to Singaporean transit, the broader trafficking ecosystem in which it operates does. The Sunda pangolin is native to Malaysian Borneo; interdicting demand within Sabah disrupts potential flows that might otherwise transit Singaporean logistics networks.
Tourism Market Overlap
Singapore constitutes one of Sabah’s primary inbound tourism markets, given its geographic proximity (approximately a 2.5-hour flight to Kota Kinabalu) and the high proportion of Singaporean residents of Chinese descent who visit Malaysia for nature and culinary tourism. Singaporean tourists present at establishments offering illegal wildlife products face criminal liability under both Malaysian and Singaporean law. The Semporna incident provides an occasion for Singapore’s government and civil society to reinforce pre-departure awareness obligations.
Reputational and Bilateral Implications
Malaysia and Singapore share deep trade, investment, and people-movement ties. Incidents of wildlife crime within the Malaysian tourism sector carry reputational spillover risks for the broader Southeast Asian ecotourism brand in which Singapore participates, particularly given Visit Malaysia 2026’s targeting of international tourist markets that also visit Singapore. Singapore has a material interest in the governance integrity of its regional neighbours’ wildlife sectors.
- Analytical Framework: Wildlife Crime and Ecotourism Governance Failure
4.1 Typology of Wildlife Crime in the Tourism Sector
Wildlife crime within tourism contexts can be categorised along two axes: the role of the tourism operator (passive facilitator versus active vendor) and the nature of the product offered (live animal display, food product, souvenir, or experiential activity). The Semporna case falls into the most legally and ethically serious category: an active operator selling a prohibited species as a food product to paying tourists, with the species explicitly positioned as an attraction rather than a byproduct.
This typology matters because it informs appropriate policy responses. Passive facilitation — for instance, a resort tolerating the purchase of wildlife souvenirs by guests — calls for education and supply-chain intervention. Active vending by operators requires robust enforcement, licence revocation mechanisms, and deterrent sentencing to eliminate the business case for wildlife crime as a tourism revenue stream.
4.2 Governance Failures and Structural Vulnerabilities
The case illustrates several governance vulnerabilities that are not unique to Sabah but are shared across Southeast Asian ecotourism jurisdictions:
Regulatory monitoring gaps: Wildlife protection legislation exists (the Sabah Wildlife Conservation Enactment 1997 predates this incident by nearly three decades), yet resort operators were able to openly list pangolin on menus and maintain a live specimen on site. This suggests deficiencies in routine hospitality sector inspection by both wildlife and tourism regulatory bodies.
Inadequate deterrence: While the legislated penalties are substantial (up to RM 250,000 and five years’ imprisonment), historical prosecution rates and sentencing outcomes for wildlife offences in Malaysia have been insufficient to eliminate the trade’s profitability for operators.
Demand persistence: The sustained demand for pangolin meat as a luxury dining experience reflects insufficient progress on consumer-side behaviour change, particularly among tourist populations who may perceive local wildlife consumption as culturally authentic or legally ambiguous.
Tourism licensing gaps: Existing tourism operating licences in Malaysia do not systematically integrate wildlife compliance obligations. The incorporation of wildlife law attestations into hospitality licensing conditions could create additional accountability mechanisms.
4.3 Ecotourism Brand Risk
Sabah’s tourism economy is structurally dependent on its global reputation as a responsible nature destination. Kinabalu Park holds three UNESCO designations (World Heritage Site, Global Geopark, and Biosphere Reserve). The state’s tourism strategy is explicitly premised on the principle that tourism revenues fund conservation and that conservation integrity maintains tourism appeal. This virtuous cycle is vulnerable to incidents like Semporna, which signal to international visitors that wildlife protection within the tourism sector cannot be assumed.
For Singapore, this risk is compounded by the country’s own brand positioning as a green, sustainable city-state. Singaporean travel platforms, media, and educational institutions have a role to play in reinforcing the message that wildlife crime in tourism contexts — including in neighbouring Malaysia — is inconsistent with the values of responsible travel.
- Policy Implications and Recommendations
5.1 For Malaysian Authorities (National and State)
Integrate wildlife compliance checks into routine tourism licensing inspections, including unannounced audits of hospitality sector menus and food preparation facilities.
Accelerate the gazetting of Wildlife Crime as a scheduled offence under Malaysia’s Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act (AMLA), enabling asset recovery from operators profiting from protected species trade.
Establish a national Wildlife Crime Intelligence Unit with dedicated capacity for the tourism and hospitality sector, supported by tip-off mechanisms for industry insiders and tourists.
Implement mandatory wildlife awareness training as a condition of tourism operator licensing renewal, aligned with CITES obligations and Visit Malaysia 2026 sustainable tourism commitments.
5.2 For Singapore
Strengthen pre-departure travel advisories targeting wildlife crime exposure for Singaporeans travelling to Malaysian Borneo and other biodiversity-rich destinations, including explicit statements of liability under both Malaysian and Singaporean law.
Deepen Customs and enforcement intelligence-sharing with Malaysian authorities, particularly regarding trafficking routes transiting Singapore’s port that may originate in or pass through Sabah.
Leverage Singapore’s conservation science capacity — particularly Mandai Wildlife Group’s biobanking programme — to support Sunda pangolin ex-situ genetic conservation in partnership with Malaysian institutions.
Direct Singapore Tourism Board and wildlife NGOs to develop joint consumer-facing campaigns addressing demand reduction, targeting the dining choices of Singaporean tourists in the region.
5.3 For the Regional Ecotourism Sector
Develop a Southeast Asia Tourism Operators Wildlife Compact, under which hospitality businesses voluntarily commit to wildlife-free menus, staff training, and incident reporting mechanisms as a condition of inclusion in regional tourism promotion materials.
Engage ASEAN’s wildlife law enforcement network (ASEAN-WEN) to expand monitoring of tourism-sector wildlife crime, currently underrepresented in seizure statistics relative to trade and logistics channels.
Incorporate wildlife crime incident reporting into UNWTO sustainable tourism certification frameworks to create market incentives for compliance among hospitality operators seeking international accreditation. - Conclusion
The Semporna pangolin incident of February 2026 is a micro-level event with macro-level implications. At the local level, it represents a failure of regulatory oversight and a threat to Sabah’s hard-won reputation as Southeast Asia’s premier ecotourism destination. At the regional level, it illuminates the persistent demand-side dynamics that sustain the global pangolin trade — a trade in which Singapore’s role as a transit hub and consumer-sending country gives it both responsibility and leverage.
The enforcement response — swift, multi-agency, and publicly communicated — reflects a growing institutional understanding in Malaysia that wildlife crime within the tourism sector requires proactive rather than reactive governance. The SWD Director’s explicit linkage of the incident to Sabah’s tourism brand signals that conservation enforcement is increasingly understood as an economic as well as ethical imperative.
For Singapore, this case is a reminder that responsible engagement with regional biodiversity cannot be limited to domestic conservation efforts or port-level interdiction. It requires sustained attention to the demand-side drivers — culinary tourism, exotic consumption, and aspirational wildlife experiences — that are partly generated or transmitted by Singaporean travellers, markets, and logistics networks. The Sunda pangolin’s survival depends on coherent action across the full spectrum of governance actors in its range states and transit corridors alike.
References and Key Sources
CITES. (2025). Conservation Status, Trade and Enforcement Efforts for Pangolins. CITES Secretariat, Geneva.
East Asia Forum / Langdale, J.V. (2025, April). Singapore’s battle against illicit financial flows. Macquarie University.
Malaysian Investment Development Authority (MIDA). (2025). Tourism Development in Sabah: Unlocking the Potential of Eco-Tourism and Cultural Heritage.
Mongabay / St. Clair, P. (2025, April). Singapore biobank offers backup plan for pangolins. Mandai Wildlife Group.
Sabah Wildlife Department (SWD). (2026, February 24). Official Statement — Ops Khazanah, Semporna. Kota Kinabalu: SWD.
The Star / Asia News Network. (2026, February 24). Sabah resort in the soup for serving up pangolin dishes.
TRAFFIC. (2022). Asia’s Unceasing Pangolin Demand. TRAFFIC Southeast Asia Regional Office, Petaling Jaya.
Wildlife Justice Commission. (2025). Disruption and Disarray: An Analysis of Pangolin Scale and Ivory Trafficking, 2015–2024. WJC, The Hague.
CITES / Down to Earth. (2026, February). World Pangolin Day 2026: 500,000+ pangolins seized globally between 2016 and 2024.
Esri / Tinsman, J. et al. (2024). Map Reveals Supply Chain of Pangolin Trafficking. UCLA / US Fish and Wildlife Service.