The transnational chain of rhino horn smuggling
The transnational chain of rhino horn smuggling
China News Weekly reporter/Xu Dawei
Issued in the 1004th issue of China News Weekly on January 19, 2021.7
A fishing boat travels secretly in the waters at the junction of Fujian and Guangdong.
In the vast sea, this fishing boat with a length of only more than 70 meters is like a leaf of duckweed in the wind and waves.
However, this seemingly ordinary fishing boat is not ordinary at all. The boat is not full of catches, but rhino horns from Africa.
On the evening of June 17, 2019, the anti-smuggling department of China's customs had assembled a large number of troops in the waters and was waiting for the fishing boat.
On May 21 this year, Xiamen Customs notified the cracked case of this huge rhino horn smuggling case and seized 145 rhino horns with a total weight of 250 kilograms and a value of about 100 million yuan.
This case also set a record for the number of smuggled rhino horns uncovered by Chinese customs in recent years.
An official from the Xiamen Customs Anti-Smuggling Bureau told China News Weekly that out of the 145 pieces of rhino horns seized, 110 whole horns were taken directly from the rhinoceros, and the remaining 35 pieces were confirmed to be from different rhinos based on their size and appearance. It was cut from the horns, and it was judged that about 100 rhinos were brutally killed.
Rhino horn smuggling is as profitable as heroin. In order to curb the poaching frenzy, the first convention banning the international trade of rhino horn was implemented in 1975.
At present, all the five remaining rhino species in the world are listed in Appendix I of CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora), which prohibits international trade.
As China and other Asian countries continue to increase their crackdown on rhino horn smuggling crimes, it has become increasingly difficult to smuggle rhino horn.
The smuggling of rhino horns has now become a "black business."
From poaching and supply at the source to the end consumer, the participation of organized smuggling groups further integrates the supply of rhino horn from the source with the market demand of the consumer country, making the illegal rhino horn smuggling trade more concealed and complicated.
This shocking case of rhino horn smuggling has also revealed the tip of the iceberg of the black transcontinental rhino horn smuggling trade chain.
Sniping the "ghost ship" at sea
Sniping the "ghost ship" at sea
On January 28, 2019, which coincided with the Chinese Lunar New Year, an intelligence clue attracted the attention of the Xiamen Customs Anti-smuggling Bureau.
The clue said that Wang Yongming, a native of Wenzhou, Zhejiang, organized the supply of rhino horn and ivory in South Africa, and planned to smuggle them into the country through sea and air channels. The sea channel may be shipped to the domestic coastal areas by ocean ships in the near future.
There are many coastal ports in Fujian, and the carving industry in some areas is developed, which is conducive to the secondary processing and distribution of rhino horn and ivory.
The Xiamen Customs Anti-smuggling Bureau made an intelligence study and judged that "smuggled rhino horns are likely to land in Fujian waters."
At this time, Wang Yongming had returned to China from Mozambique. Intelligence information showed that he was going to Fujian to "receive the goods." The police investigation of the gang began immediately.
China and Africa are tens of thousands of miles away, and ordinary ships cannot handle ocean-going transportation.
"The original intelligence information is very vague." Bao Qi, deputy director of the Intelligence Division of the Xiamen Customs Anti-smuggling Bureau, told China News Weekly that at that time, it was judged that the smuggling and transportation were most likely to be carried out by ocean fishing vessels.
The customs anti-smuggling police began to investigate the ocean-going fishing vessels one by one. However, until after the Spring Festival, there was still no gain, which made Bao Qi, who led the intelligence check, puzzled.
"Intelligence is early warning information, and the real situation is likely to be'separation of people and goods.'" Bao Qi said.
On February 9, Wang Yongming arrived in Xiamen, Fujian.
The anti-smuggling police in charge of outside investigations received news. Someone informed Wang Yongming that the "cargo" was backlogged in a terminal in Fujian, and "the cargo may not be available for delivery in the near future."
In the early morning of February 11, Wang Yongming’s account suddenly generated a large amount of funds, which indicated that the transaction had been completed, but the number and location of the transaction were unknown.
Further investigation by the police found that once rhino horn entered the circulation market, it changed hands quickly.
"In fact, it is delivered in stages, and different cargo owners give different goods." Bao Qi explained, which brings no small challenge to tracking the flow of smuggled rhino horns.
Like hunters, the anti-smuggling police are waiting for the target's second transaction.
After a period of dormancy, the signal appeared-Wang Yongming sent the "Ma Tsai" to set off again.
On March 5, the smuggling vessel left the sea off Zhejiang and headed for Mozambique.
The 1,600-ton target ship "Sea Pioneer" entered the field of police investigation and control.
The registered nationality of the "Maritime Pioneer" was changed to Belize, a Central American country, and the crew was mainly Burmese. The purpose of this "operation" was to evade inspection and criminal punishment.
A thousand-ton ship sails on the ocean, and the customs anti-smuggling department wants to track the smuggled ships, which is nothing more than "finding a needle in a haystack."
After setting sail from the port of Mozambique on May 15, the smuggling ship shut down the ship’s AIS positioning system and kept the communication silent. It became a "ghost ship" at sea, which made detection and tracking more difficult.
"You don't know where the ship is going in the vast sea. We can only make research and judgments based on the limited information we have." Bao Qi told China News Weekly, using the scattered information of the ship passing by the monitoring sea area, through big data analysis, the anti-smuggling police were able to Find out the route, course, speed, and expected stop point of the smuggled ship.
In mid-June, according to the calculation of the shipping route, the smuggling ship entered the South China Sea through the Strait of Malacca. The Xiamen Customs Anti-smuggling Bureau, together with the Guangdong and Fujian Maritime Police Bureaus, connected the Nansha Islands, Paracel Islands, Fujian and Guangdong border waters, Xia Zhang waters, and Wenzhou waters. Cloth 5 "pockets", open the net to wait.
At about 14:00 on June 17th, the ship signal appeared in the waters at the junction of Fujian and Guangdong, which meant that the anti-smuggling police had less than 12 hours of arrest time left. Once the time passed, the smuggling ship was very likely to flee into Taiwan. Strait to evade investigation.
Zeng Xuefeng, deputy head of the Anti-smuggling Section of the Dongdu Sub-bureau of Xiamen Customs Anti-smuggling Bureau, has many years of anti-smuggling experience. He told China News Weekly that some large smuggling ships often stop on the open sea outside of China’s customs anti-smuggling enforcement area, and then use small boats to go. "Receive the goods" and wait for the opportunity to be shipped into mainland China.
The capture location was finally determined to be in the Fujian and Guangdong waters.
That night, 120 anti-smuggling police officers, 288 maritime police officers and soldiers, 8 ships, and 18 action teams were distributed in the sea area at the junction of Fujian and Guangdong, as well as in Fuzhou, Quanzhou, Wenzhou, Dalian and other places. The sea and land linkages simultaneously carried out centralized network collection operations.
"The opposite ship, stop the ship for inspection! Repeat! Stop the ship for inspection!" When the anti-smuggling police jumped on the smuggling ship that was swaying in the wind and waves, Liu Hequn, a member of the smuggling gang responsible for the escort, also "confidently" thought it was just a game. During routine inspections, the crew did not even "bring out" to the smuggling leader hiding behind the scenes.
In Xiamen, thousands of miles away, the Customs Operations Command is nervously awaiting the results of the investigation.
After some searches, the anti-smuggling police found that it was almost an empty ship, and the only four containers were empty, and nothing was found in the galley, cockpit, crew rest room, etc., which allowed the scene to participate in the anti-smuggling operation. The police are a little suspicious.
At this time, on the other end of the call, Bao Qi, deputy director of the Intelligence Division of Xiamen Customs Anti-smuggling Bureau, said confidently, “Don’t worry, there must be goods on board.” After repeated searches, the police finally found 14 in the auxiliary oil tank of the engine room of the ship. A black nylon duffel bag, filled with rhino horns of different lengths, counted 145 pieces and a total weight of 250 kilograms.
Good news came from the sea, and another big net on the land began to close.
Five suspects including Wang Yongming, commanded by remote control in Wenzhou, were simultaneously arrested, and more than 30 products including 1 ivory, 1 leopard skin, and ivory necklace were seized.
Smuggling path at any cost
Smuggling path at any cost
The smuggling of rhino horn by Wang Yongming’s group took three and a half months, passing through Madagascar, Maldives, and the Straits of Malacca along the way. After connecting with small offshore vessels near the Taiwan Strait, they waited for the opportunity to smuggle into China’s coastal areas without customs clearance.
In the entire smuggling route, there are no transit points and no other cargoes. The total round-trip mileage exceeds 20,000 nautical miles, and the cost of a single smuggling trip can reach millions of yuan.
In addition, normal ocean-going ships generally have a tonnage of more than 10,000 tons, while the cargo ship purchased by a smuggling gang has 1,600 tons. The ship is in poor condition and has poor wind and wave resistance. It is very prone to capsize in bad weather.
Behind such an adventure is driven by the huge profits of rhino horn smuggling.
The black market price of rhino horn in Asia is about 60,000 US dollars per kilogram (about 400,000 yuan).
Zeng Xuefeng told China News Weekly that rhino horn was smuggled and smuggled into the country, and the price was increased to terminal buyers. The price could be more than ten times higher than the original "received price".
An assessment report of the United Nations Office on Drugs and Crime (UNODC) shows that in the illegal trade of ivory and rhino horn, the most value-added link is the final retail link.
For example, only in this link from Asian wholesalers to retailers, the price of rhino horn has risen by 103%, and the price of ivory has soared by 529%.
A number of anti-smuggling police told reporters that the huge profit margins have made the rhino horn smuggling gangs extremely cautious and have strong anti-detection capabilities.
"The real smuggling is far more complicated than the plot of the film and television drama." Bao Qi said, rhino horn is expensive, and the smuggling gang invests in "real money". The smuggling route is planned carefully and thoughtfully.
"Generally, there is no such planning route for smuggling." Bao Qi told China News Weekly that smuggling gangs usually use container ships to conceal fake names of goods to illegally smuggle ivory and rhino horn through freight channels.
"Smuggling across continents by small ocean-going fishing boats is very rare," Bao Qi said.
Huang Hongxiang, the founder of Zhongnanwu and an undercover investigator of international rhino horn smuggling, told China News Weekly that the smuggling route of rhino horn is mainly Africa-Southeast Asia-Asia terminal markets.
Huang Hongxiang’s field investigation in Vietnam found that many rhino horn smuggling often choose to “transit” in Southeast Asian countries such as Myanmar and Vietnam because of the local loose law enforcement environment and easy access to end buyers.
The relevant analysis of the International Foundation for the Protection of Animals (IFAW) shows that in recent years, rhino horn smuggled into China mainly comes from South Africa and Vietnam, and both routes show a clear trend of organized crime.
As China Customs has stepped up its crackdown on smuggling of endangered species, criminal groups on both routes generally employ water passengers or cargo protection groups to reduce their own risks.
IFAW senior project officer Ma Chenyue told China News Weekly that rhino horns from Vietnam were mainly smuggled from Africa to Southeast Asian countries such as Vietnam by criminal gangs, and then hoarded at the borders of China, Vietnam, China and Laos, looking for opportunities to smuggle them into the country.
The methods of smuggling and entry chosen by criminal gangs mainly include hiring border residents to enter the country through the border crossings, and hiring security gangs to smuggle entry through non-customs clearance areas.
In recent years, there has also been a high incidence of cross-border parcel delivery and smuggling.
As an emerging market for rhino horn consumption, Vietnam has become one of the most important transit countries for rhino horn smuggling to China in addition to its own needs.
According to an unannounced visit by the EAL (Elephant Action Alliance) in 2016, Chinese traders stated that Vietnam is their main source of rhino horn, and sellers in Vietnam confirmed this, saying that 80% of buyers are Chinese.
From August 2016 to June 2017, EAL conducted an 11-month investigation into the illegal smuggling of rhino horn at the Chinese border.
EAL investigators learned that smugglers have four to five different land routes to and from a border city in China.
The shortest distance is only a three-minute walk.
The rhino horns from South Africa are mainly cross-border cargo-carrying personnel employed by criminal gangs. They smuggle the rhino horns in their luggage by means of "ant moving", and criminal gangs often choose to go through China. International flights connecting Hong Kong, Doha and Ho Chi Minh City.
Li Lishu, head of the China Project of the Beijing Representative Office of the International Wildlife Conservation Society (WCS), reminded us to focus on smuggling by air.
Li Lishu told China News Weekly that compared to ivory, rhino horn has a higher value and is more convenient to transport. It is usually smuggled through air-lifted suitcases.
After shipping rhino horns from Africa, smugglers will transit at airports in North Africa, Asia and other places, and Hong Kong is an important "passageway."
Judging from some cases of smuggling rhino horns by air, some smugglers will collude with airport staff to avoid scanning and inspections when entering customs.
Another noteworthy phenomenon is the increasingly updated sales channels.
"Rhino horns are no longer sold in stores as they used to be." Yu Chong, chief representative of Wild Rescue's Beijing representative office, told China News Weekly. In order to avoid the blow, most of the rhino horn sales were transferred to social media, especially WeChat.
Sellers and buyers can communicate and pay privately through WeChat. Sellers usually publish product information in Moments or customer groups, which makes law enforcement more difficult.
Ma Chenyue reminded that online transactions played an important role in the transactions of smuggled rhino horn products. Among the 15 criminal cases of illegal acquisition, transportation, and sale of rhino horn recorded by IFAW in 2019, 14 involved the Internet. Up.
"Online platforms are tools commonly used by criminals to publish advertisements, contact and communicate, and transfer payments. They need to be paid attention to."
"International" smuggling network
"International" smuggling network
With the arrest of the other two behind-the-scenes principals Chen Youren and domestic cargo owner Ruan Yucheng, the veil of the large transnational rhino horn smuggling criminal gang seized by Xiamen Customs was unveiled.
Behind overseas procurement, cross-border trafficking, smuggling entry, and rapid distribution, the interlocking and clear division of labor is behind a well-organized and highly professional smuggling group.
In terms of the division of labor, there are special members in the gang responsible for receiving and loading the goods on the ship in Africa; the transoceanic maritime transport is also escorted by the members of the special organization; the shareholders of the ocean-going vessels are responsible for the smuggling into the country.
The various links of smuggling are independent of each other, and the lines are clearly cut.
As an old anti-smuggling policeman, in Zeng Xuefeng's view, the difficulty in combating such smuggling crimes lies in how to spot the cargo owners who are hidden behind the scenes.
In the gang, Wang Yongming has multiple identities. He is both the owner of the goods and the organization of the supply of goods. He is a key role in maintaining the operation of the smuggling chain.
In fact, establishing a smuggling channel is not easy.
"Without the cooperation of the locals in Africa, you can't get the'goods'." Zeng Xuefeng pointed out that smugglers like Wang Yongming have complicated local networks in Africa.
Bao Qi told China News Weekly that Wang Yongming bought a local policeman to help transport the rhino horn to the smuggling boat.
Among the shareholders responsible for smuggling into the country, one is the president of a Portuguese chamber of commerce in Fujian, and Mozambique is a Portuguese-speaking country, which also shows the complex ecology of the rhino horn smuggling network.
The Wildlife Trade Research Organization began to pay attention to the "Asian role" in the "black business" of rhino horn more than ten years ago.
Data from earlier years showed that among the Asian suspects arrested in South Africa for rhino horn crimes, the most were Vietnamese nationals, followed by Chinese nationals and Thai nationals.
Susie Watt, an internationally renowned animal protection expert, said in a previous interview with the media that the Chinese rarely involve the front end of rhino horn crime, that is, actual poaching; in contrast, they often assume the middleman who buys rhino horn from poachers. Character.
Previously, South Africa’s anti-poaching special police introduced that the rhino horn smuggling interest chain generally consists of five layers: the lowest poachers are often poor blacks; the second layer is local small-scale acquisitions and transporters, known as “runners”. "; The third tier is national acquirers who are engaged in more professional and organized group crimes; the fourth tier is African acquirers and exporters, mostly Vietnamese, and some are Chinese; the fifth tier is The leader of the sales organization in Vietnam and China.
Huang Hongxiang once played the role of a Chinese buyer and became the undercover agent of South Africa's anti-poaching department.
He told China News Weekly that there is a big misunderstanding now that Chinese people involved in the illegal wildlife trade are gangsters or vicious smugglers, but in fact, most Chinese smugglers are ordinary businessmen.
The principal culprit of this huge rhino horn smuggling case uncovered by Xiamen Customs, Wang Yongming was a trader in Africa.
"Wang Yongming's trading company doesn't make money, it's just an empty shell, and usually helps people dump foreign exchange." Bao Qi introduced.
"Smuggling rhino horns does not mean that you will be able to settle local relations after one or two years in Africa." Huang Hongxiang pointed out that these Chinese who have lived in Africa for many years have a very rich local resource network.
"On the one hand, they have created a local market so that more locals can see that wild animal products can be sold for money, which objectively increases the motivation of locals to go poaching; on the other hand, they understand the local situation, and Know the sales channels on the Chinese side.” Most African countries lack strict supervision and market supervision systems, leaving these smugglers with loopholes.
Huang Hongxiang said that what drives these Chinese to engage in the illegal rhino horn trade is still the huge black interest behind it.
At present, the Asian region is still the main area for the consumption of rhino horn.
UNODC data shows that every year, about 5.6 tons of rhino horn enter the market.
Among them, 0.4 tons were seized in Africa, and the remaining 5.2 tons were smuggled outside Africa.
The vast majority (approximately 5.1 tons) entered East Asia and Southeast Asia, of which 0.5 tons were seized, and the remaining 4.6 tons entered the Asian terminal market.
According to a data provided by the International Wildlife Conservation Society (WCS), between 2016 and 2018, in the Asian end consumer market alone, the annual revenue from the illegal trade in rhino horn was as high as 170 million to 280 million U.S. dollars.
Yu Chong, chief representative of the Beijing Representative Office of Wild Rescue, told China News Weekly that the main demand for rhino horn in Asia in recent years has been medicine and investment products.
Traditional Chinese medicine believes that rhino horn has the functions of cooling blood, detoxifying and clearing away heat.
In Vietnam, many people regard rhino horn as an expensive health medicine.
"The superstition that rhino horn can treat cancer is probably related to the 150,000 cancer cases in Vietnam each year." Yu Chong said.
In China, Angong Niuhuang Pills were once widely praised for containing rhino horn ingredients.
After China completely banned rhino horn from being used as medicine in 1993, there are still many "Lao Angong Niuhuang Pills" and "Korea Angong Niuhuang Pills" that use rhino horn formulas in circulation on the black market.
Ma Chenyue introduced that in addition to being used as medicine, rhino horn products are also regarded as precious collections by many people.
Some people believe that as the number of rhino populations decreases, rhino horn products have the function of maintaining value and increasing value.
Many customs anti-smuggling police officers worry that "the more precious rhino horns are, the more fatal it will be for some buyers."
Poverty and corruption are catalysts for poaching
Poverty and corruption are catalysts for poaching
WCS recently submitted a risk alert to relevant Chinese authorities.
From December 2020 to February 2021, three consecutive rhino horn smuggling cases occurred in South Africa and Vietnam, with a large number of seizures. In each case, the amount of rhino horn seized was more than 60 kilograms, and all of them were smuggled by freight.
WCS predicts that this is the rhino horn smuggling criminal gang starting to ship the previously hoarded goods and adopting a more "optimized" freight smuggling method instead of the past personnel smuggling method. It is recommended that the Chinese customs authorities remain vigilant.
Due to the new crown epidemic, rhino poaching in Africa experienced a "quiet" year last year.
According to recent data released by the Ministry of Agriculture, Forestry and Fisheries of South Africa, rhino poaching has dropped significantly.
In 2019, a total of 594 rhinos were killed. In 2020, the number of poaching was 394, a decrease of 33%; the data of Kenya Wildlife Service (KWS) also showed a clear downward trend. In 2020, the number of rhino poaching in Kenya was zero. .
Some animal protection organizations are cautious about this. They believe that the decline in poaching is not only due to the impact of the epidemic, but also because the decline in the number of rhinos makes poaching more difficult, especially in the Kruger National Park in South Africa.
According to data released by CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora) at the CoP18 Conference in 2019, as of 2018, there were 23,562 rhinos in Africa, distributed in 14 countries including South Africa, Kenya, and Namibia.
The number of rhinos in South Africa accounts for about 80% of the entire Africa, mainly white rhinos.
In 2020, 245 rhinos were hunted in Kruger National Park, accounting for 62% of all poaching in South Africa.
Yu Chong told China News Weekly that the decline in data does not fully explain the reduction in rhino poaching attempts or actions. For example, in the Kruger National Park in South Africa, the number of recorded poaching attempts and actions in 2019 was as high as 2014. Fortunately, Most poaching attempts and operations were successfully intercepted.
Huang Hongxiang told China News Weekly that there are generally two types of poachers. One is well-equipped professional poaching gangs. They are usually equipped with advanced thermal binoculars, night vision devices, GPS systems, fully automatic rifles and even helicopters and military. Armored vehicles; the more one is the poor local villagers, "they carry old-fashioned rifles, bows and arrows and even poison."
Poverty is the catalyst for poaching. At the border between Mozambique and South Africa, some locals rely heavily on rhino horn poaching income.
“Because of poverty, after these villagers poached rhinos, they would sell rhino horns to the local consignees who bought rhino horns.” Huang Hongxiang introduced.
According to data from the United Nations Office on Drugs and Crime (UNODC), in poaching, the price of a unit of rhino horn is 55 times that of ivory. The price of an elephant’s ivory is US$1,000 and the price of a rhino’s rhino horn is US$24,000. .
Another set of data shows that even as a low-level member of a local rhino poaching gang, participating in a poaching activity can still have a profit of 2,500 to 5,000 U.S. dollars, while the income of local farmers or miners is only a few hundred U.S. dollars a year.
Some local animal protection organizations in Africa told Huang Hongxiang that, on the one hand, the epidemic has exacerbated local poverty and caused more people to take risks for their livelihoods; on the other hand, the epidemic has affected the financial income of local reserves, and anti-poaching patrols have been weakened.
The information provided by the Wild Rescue to China News Weekly shows that the new crown epidemic has plunged the tourism industry in Africa into a quagmire, and protected areas that rely heavily on tourism projects are on the verge of collapse.
When the economy is in trouble, protection work is ranked last in terms of funding and law enforcement investment priorities.
"There are good reasons to believe that South Africa is still the focus of rhino poaching." Ma Chenyue said.
In November 2020, local authorities in South Africa’s KwaZulu-Natal province confirmed that seven white rhino carcasses had been found in different areas of the Hluhluwe-iMfolozi Reserve. The authorities feared that large-scale poaching activities would continue.
South Africa’s Kruger National Park is home to the world’s largest rhino population. The reserve covers an area of 7,580 square miles, which results in the lack of sufficient supervisory manpower for Kruger Park. Effective supervision requires sufficient funding.
Lack of people, money, and equipment are the reality that African countries face in protecting rhinos.
South Africa’s KwaZulu-Natal Ministry of Economic Development, Tourism and Environmental Affairs spokesperson De Boer said that there are not enough rangers and anti-poachers in the area. As the provincial budget has been cut by at least R5 billion, the local government is unable to hire. More rangers.
In recent years, in order to protect rhinos, some countries in Africa have implanted chips in the horns of rhinos to establish a rhino identity system.
Among the batch of rhino horns seized by Xiamen Customs this time, 70 pieces contained chip information.
"This shows that these rhino horns have been seized and sold." Bao Qi said that the customs department has notified the relevant countries of the corruption in law enforcement in Africa found in the smuggling of extra-large rhino horns. .
Huang Hongxiang told China News Weekly that a large number of rhino horns are stored in warehouses in some African countries. “The price per kilogram of rhino horns can reach 40,000 to 60,000 US dollars, and the monthly salary of 200 US dollars for the warehouse staff is already sufficient. Limit." Huang Hongxiang believes that the extreme poverty, inefficient law enforcement environment and corruption in Africa make it difficult to ban rhino horn poaching and illegal smuggling.
"Although some poachers were caught, the leaders and middlemen in the criminal gangs were not punished." Yu Chong suggested that high-level sellers and buyers, as well as criminal gangs in South Africa and Mozambique, should be arrested, prosecuted and punished in accordance with existing laws. And core figures, while fighting corruption in national parks and reserves.
A number of animal protection experts interviewed believe that ending poaching does not depend on how many poachers are stopped, but requires more international cooperation in order to break up crime in the upper reaches of the illegal trade chain.
(Wang Yongming, Liu Hequn, Chen Youren, Ruan Yu became pseudonyms)
China News Weekly, Issue 26, 2021
Statement: The publication of the "China News Weekly" manuscript is authorized in writing
Statement: The publication of the "China News Weekly" manuscript is authorized in writing