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The illegal wildlife trade has direct relevance for zoo management, animal acquisition and disposition and it has no place in modern zoo management. Zoos must not only act within the law of the country in which it is based, but they should also follow the rules and intentions of international trade regulations and, where relevant, domestic laws of the animal’s country of origin. After its rediscovery in 2012, zoos in Asia and Europe started displaying Bornean earless monitor lizards (Lanthanotus borneensis), the ‘Holy Grail of Herpetology’. Earless monitor lizards have been legally protected in each of its three range countries for over four decades and, over this period, no specimen has ever been legally exported. However, the illicit trade in the species is thriving and individuals become more affordable. Using publicly available data, I present a timeline of how and from where a total of 16 zoos acquired their earless monitor lizards, including from private individuals and non-accredited zoos. Apart from one zoo in Japan (since 2012) and one zoo in the USA (since 2021), all non-range country zoos that currently display the species are based in Europe. Their absence prior to 2021 in US zoos (despite an increasing illegal trade) could be explained as the acquisition of earless monitor lizards would have been in violation of the Lacey Act (1900) that requires buyers to ensure that imported or purchased wildlife has not been taken in violation of any foreign law. While there is no evidence that any of the zoos, their directors or their staff have broken any laws – no-one in the zoo community has been convicted for illegally trading earless monitor lizards – with more zoos speaking out against the illegal wildlife trade, it is imperative that zoos behave in an exemplary manner and set high standards. At present, some zoos do not meet this standard.

The Convention on International Trade in Endangered Species of Wild Flora and Fauna (CITES) aims to ensure that the trade in wild fauna and flora does not threaten the survival of species. Increased protection and regulation, including a potential CITES listing, can unintentionally cause an increase in the value of some species amongst collectors, who rush to acquire specimens before they are subjected to regulation. The commercial value of rare species can lead to the Anthropogenic Allee Effect; causing disproportionate exploitation, resulting in it becoming rarer and, eventually, with little control mechanisms leads the species into an extinction vortex. Here we use the case of the earless monitor lizard to demonstrate why some species should be considered for a CITES Appendix III listing, as an immediate and interim solution, to prevent laundering of wild-caught specimens and illegal international commercial trade particularly in range-restricted species. The earless monitor went from unprotected under CITES to a proposed Appendix I listing. During the interim period, between publication of the proposal until the CITES decision came into effect, no control mechanisms were in place to combat smuggling, effectively placing a target on its back. Failure of the international community to protect this species between the moment the proposal was published and when the decision was enforceable resulted in increased smuggling, with little tools for law enforcement to prevent this. We propose a compulsory Appendix III listing for any species proposed for Appendix I, if they are not yet listed on CITES, to enable regulatory processes to prevent international illegal trade. This ensures that trade can be monitored and provides the law enforcement agencies with the tools necessary to act when illegal trade occurs. Keywords: CITES, Appendix III, Smuggling, Law enforcement