Modern Slavery and the nexus to Illegal Unreported & Unregulated Fishing (IUUF) by Steve Farrer

Fishing is one of the major industries around the world, employing hundreds of thousands, and as a key source of protein for over 3 billion people; even a small level of IUU fishing can generate billions of dollars in illicit profits.

With an estimated 90% of the world’s fisheries classified as fully exploited or overexploited, legal and sustainable fishing operations are critical to maintain the integrity of global fishery resources.

It is estimated that illegal and unreported fishing represents approximately 14 to 33 percent of the global marine capture value , equating to an estimated US$15.5 billion to US$36.4 billion annually, making IUU Fishing one of the top 10 crimes by proceeds across the globe, and a significant contributor to “Green” or “Environmental Crimes.”

The recent report by The Stimson Center into Distant Water Fishing (DWF) analysed automatic identification system (AIS) data to determine the top 10 DWF fleets and the top 20 countries where they operated from 2015 to 2017.

Of the top 5 DWF fleets, which account for nearly 90% of DWF efforts. China and Taiwan represented nearly 60% of all global DWF effort in other countries’ waters from 2015 to 2017, with Japan, South Korea, and Spain each representing a further 10%.

These vessels primarily fish in three regions:
• the Pacific,
• East Africa, and
• West Africa,

with Kiribati (Pacific), Seychelles (East Africa), and Guinea-Bissau (West Africa) receiving the highest numbers of DWF vessels in their exclusive economic zones (EEZ) within each region, respectively. 

The report is a wealth of information on DWF operations and highlights the need for greater transparency, traceability, accountability and management as current practices are unsustainable, with significant risks from transhipment, IUUF, and forced labour practices by those involved.

Allegations surrounding slavery in the fishing industry have swirled around for over 20 years – most notably in Asia, (see: Here, Here & Here) and fishing operations off West Africa, and Southern Africa, however the problem is much more widespread. There are reports of forced labour conditions for crew in British,  Scottish and Irish fleets, amongst a number of incidences and geographies.    

Forced labour, as defined by the International Labour Organization (ILO), highlights a set of eleven indicators covering the main elements of a forced labour situation; in the fishing industry it is largely driven by the need to reduce costs, in a low tech, labour-intensive and low profit industry.

Greenpeace’s “Misery at sea: human suffering in Taiwan’s distant water fishing fleets” provides an example of the nexus between DWF and human trafficking – documenting, in harrowing detail, serious human rights abuses, poor labour standards, dire working conditions, and the use of fishing techniques that harm our oceans and the life in them.

The more recent Greenpeace “Seabound: The Journey to Modern Slavery on the High Seas” report further highlights the plight of migrant fishers from Southeast Asia. Subjected to inhumane working conditions on board the vessels they work on, which are also reportedly using destructive, illegal, and unreported methods, which take a heavy toll on the health and viability of already fragile oceans.

In its 2018 Global Slavery Index, the Walk Free Foundation estimated 24.9 million men, women, boys, and girls trapped in forced labour; of which of this, some 16 million are trapped in industries associated with forced labour, including fishing.

Empirical estimates of the number of forced labour victims in the fishing industry vary significantly, however the Walk Free Foundation “Spotlight on Sectors” paper takes a different view on the problem by looking at the Top 20 fishing countries, which are responsible for 80% of the world’s fish catch, assessed against 6 key risk factors for modern slavery in fishing, namely:

1. Fishing outside of the vessel’s national waters (officially known as Exclusive Economic Zones or EEZs) where industry may be subject to fewer regulations.
2. A dependence on distant water fishing (DWF) in remote locations.
3. High levels of vessel and fuel subsidies provided by the national government.
4. Relatively low per capita GDP of the fishing country.
5. Low average value of a fishery’s catch per fisher.
6. Large scale unreported fishing by a country’s fishing fleets. Illegal fishing, a major component of unreported fishing, causes billions of dollars in losses to economies around the world each year, and poorly managed fisheries are lawless markets.

The Walk Free Foundation’s risk assessment of High / Medium / Low national fishing fleets – from these 20 countries using forced labour – is concisely outlined in a table within the report – and this will be of help to compliance professionals including risk from human trafficking in risk assessments.    

The Walk Free Foundation research further cites that:

• in a survey examining the experiences of Cambodian and Burmese fishers in Thailand between 2011 and 2016 – a significant 76% of migrant workers in the Thai fishing industry had been held in debt bondage (one of the indicators of forced labour); 38% had been trafficked,

• an analysis of seafood imports to Europe and the US suggests that imported fish are approximately 8.5 times more likely to have been caught or processed by modern slavery, compared with domestically caught fish

The risk indicators, even from this small selection of resources, are clear for compliance professionals to inculcate into risk assessments on different products, geographies and clients.

One vital resource, that compliance officers may find very helpful to better understand IUUF, is the Combined IUUF List maintained by Trygg Mat Tracking – a compilation of up to date information on all vessels that appear on the lists of IUU fishing vessels published by the 12 Regional Fisheries Management Organisations (RFMOs), and fishing vessels that have been subject to an INTERPOL Purple Notice.

Trygg Mat Tracking also provide a capability for reporting suspicious activity / information through their web portal – a possible avenue for compliance professionals to engage assistance.

The Seafood Slavery Risk Tool – jointly run by the Monterey Bay Aquarium Seafood Watch program, Liberty Asia, and the Sustainable Fisheries Partnership – is another potential resource for compliance professionals.

A powerful resource, should compliance professionals wish to understand IUUF further, is the Leonardo DiCaprio Foundation funded Global Fishing Watch – which provides maps to visualise, track and share data about global fishing activity in near real-time and for free.

Should compliance professionals want to investigate a specific vessel further – there are several vessel tracker resources that may be helpful – see the article highlighting top 8 ship tracking websites for recommendations.

The Global Initiative Against Transnational Organised Crime (GITOC), in releasing their IUU Fishing Index, a tool designed to provide a better understanding of illegal, unreported and unregulated (IUU) fishing worldwide, stated “IUU fishing is also often found to be associated with many other forms of transnational organised crime, such as human trafficking, drug trafficking and piracy, not to mention the exploitation of weak and corrupt elements of national management regimes”. A valuable source of risk information for compliance professionals.

Recognising the risk of human trafficking in commercial fishing, Interpol, the international police organisation, have issued two Interpol Purple Notices on the subject – Human trafficking and modern slavery in the fisheries sector (Feb 2017) and Human Trafficking and Forced Labour: The deceptive and coercive practices undertaken within the recruitment process to work on fishing vessels (March 2019). Both are valuable resources for compliance professionals.

The recent RUSI paper outlines new research into 5 jurisdictions in 2 regions suffering from IUUF on an organised scale – namely Indonesia, Thailand and Vietnam in Southeast Asia (SEA); and Tanzania and South Africa in the Western Indian Ocean (WIO). They conclude that there is evidence that the criminal networks involved are capable of running highly sophisticated operations to grave ecological, social and economic effect; this systematic, high-volume IUU fishing constitutes organised crime on a transnational scale.

Conclusion

Human Trafficking is one of the fastest growing crimes in the world and the use of forced or bonded labour on deep water fishing fleets, as well as onshore fish processing, one of the major industries using slave labour. Similarly, deep water fleets from certain jurisdictions are also engaging in IUUF on a commercially organized scale, depleting fish stocks in countries that lack the enforcement or marine management capabilities. This article has highlighted a number of indices and resources that the AML compliance professional would find very helpful in better managing risk on clients or client supply chains in the fight against these two crimes.

Mr. Farrer has been, for the past 5 years, actively involved in working with the financial services sector, under the anti money laundering (AML) framework, to help identify and mitigate the illicit proceeds from human trafficking (modern slavery). Previously the head of global Non Government Organization (NGO) team collating information on large-scale trafficking incidences, to proactively inform financial institutions of those individuals and entities that are either directly facilitating or indirectly financially benefiting from human (and other forms of) trafficking. In recognition of his knowledge and expertise, Mr Farrer has been involved in plenary sessions and working groups of the Financial Action TaskForce (FATF), the Egmont Group of Financial Intelligence Units (Egmont) and the AsiaPacific Group on Money Laundering (APGML), on the use of AML to combat the illicit proceeds from human trafficking and related criminal activities..

Prior to this, Mr. Farrer was the regional head of intelligence for a global financial institution, covering Greater China and North & East Asia, leading a world-class team, pioneering the use of open source intelligence & techniques to proactively identify & mitigate anti money laundering risk. With over 25 years of experience, he has enjoyed a number of senior management roles in both small specialist advisory firms and major multinational corporations, focusing on anti money laundering & fraud risk mitigation, through the innovative use of technological solutions and use of intelligence, in making risk-based decisions.

Institutions seeking to enhance their response to human trafficking can contact him on sf@corbanconsultinguk.co.uk

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melvinlzk@yahoo.com.sg
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melvinlzk@yahoo.com.sg

Good insights and thoughtful on human trafficking which quite common but still need together effort across countries with ensure action taken to say No on IUUF.