Intelligence Briefing – Illegal Unregulated & Unreported Fishing by FCN

Illegal Fishing represents one of the largest markets open to and exploited by organised criminal groups, but beyond overfishing and the environmental challenges this brings, other serious crimes are also involved, including drugs and human trafficking, corruption and tax evasion, particularly effecting developing Countries. its time Illegal fishing was considered as a major financial crime issue as well as an environmental one. For more read the Intelligence Briefing on IUU Fishing by FCN. 

To Read the Intelligence Briefing IB – Illegal Wildlife Trafficking – Final 9-9-19.

Fishing Facts

With fish and other aquatic animals an important part of many peoples diet, it’s estimated by the Food and Agriculture Organization (FAO) of the United Nations, that we catch approximately 171 million metric tons (likely more than 2 trillion fish) annually (2016) worth an estimated USD362 billion. Of this USD 232 billion is estimated to be from so called aquaculture production (i.e. farming), with the balance (i.e. USD130 billion) coming from commercial fishing in the high seas. Whilst domestic markets represent overall the largest markets, exports amount to USD152 billion, with 54 percent originating from developing countries, supplying 3 billion people who rely on fish for their primary source of protein. The FAO also estimates that out of approx 5,000 individual fish stocks, 60% of world fisheries are fully-fished meaning the potential for food has been realised without jeopardising the future abundance of the fish), but that 33% of fish stocks are over fished (over exploited jeopardising the future sustainability of these fish stocks). This is a deterioration from 10% in 1974 to 33% in 2015. As the size of these individual fish stocks vary, a recent estimate suggests that about 82% of consumed fish are sustainable while 18% come from unsustainable fisheries.

Many millions of people around the world find a source of income and livelihood in the fisheries and aquaculture sectors. According to the FAO almost 60 million people were engaged in the sector in 2016 with two thirds or approx 40 million in fishing, of which 85% were in Asia, followed by 10% in Africa, utilising over 4 million fishing vessels. The fleet in Asia was the largest, consisting of 3.5 million vessels, accounting for 75 percent of the global fleet.

Of the 5,000 plus fish species available, the most popular 5 catches make up almost 25% of total fish capture, being Mackerel, Anchovy, Tuna, Sardines and Pollock. The most popular fishing grounds are those of the Pacific North West which lands almost a quarter of the global catch, (22.4 million metric tons), followed by the Pacific West and Central (12.7 mmt), the Atlantic North East (8.3 mmt), the East Indian Ocean (6.4 mmt) and the West Indian Ocean (4.9mmt).

Endangered Fish Species

There are plenty of other fish in the sea, we are told but according. to the International Union for Conservation of Nature’s (IUCN) Red List of endangered species, 5 percent of the world’s known species, are at risk for extinction. While habitat loss and pollution are significant factors in the decline of these species, the greatest threat by far is overfishing. According to WWF, we are seeing “the precipitous decline of key fish stocks such as bluefin tuna and Grand Banks cod, as well as collateral impacts to other marine life. Hundreds of thousands of marine mammals, seabirds, and sea turtles are captured each year, alongside tens of millions of sharks. Many of these species are endangered and protected, while some such as the vaquita, Eastern Pacific leatherback turtle, and Maui dolphin are on the brink of extinction.”

Illegal Unreported and Unregulated (IUU) Fishing

IUU fishing is not only a major threat to ocean ecosystems worldwide, it is detrimental to the legal fishery trade and has been linked to organised crime. The depletion of fish stocks through IUU fishing threatens global food security, along with the livelihoods of those millions of people engaged in legitimate fishing. IUU fishing is also often found to be associated with many other forms of transnational organised crime, for example, according to the UNODC, Illegal fishing is “frequently transnational and organised in nature” and involves, “document fraud, drug trafficking, and money laundering.”  “Criminal activities in the fisheries sector are often regarded as synonymous with illegal fishing, which many States do not view or prosecute as criminal offences, but rather as a fisheries management concern, attracting low and usually administrative penalties. Organised criminal organisations thus engage in fisheries crime with relative impunity due both to low risk and high profits and uncoordinated, ineffective domestic and cross-border law enforcement efforts.” see the UNODC Factsheet on Fisheries Crime

Shark Fin:

According to the FAO, the trade in shark fin is causing catastrophic harm to the marine ecosystem. At least 73 million sharks are killed each year by finning, though some estimate that finning kills up to 100 million sharks each year. Estimates of the global value of the shark fin trade range from US$540 million to US$1.2 billion a year. 

Shark finning is the act of removing fins from sharks and discarding the rest of the shark. The sharks are often still alive when discarded, but without their fins. Unable to swim effectively, they sink to the bottom of the ocean and die of suffocation or are eaten by other predators. Shark finning at sea enables fishing vessels to increase profitability and increase the number of sharks harvested, as they only have to store and transport the fins, by far the most profitable part of the shark.

Shark finning increased since 1997 largely due to the increasing demand for shark fins for shark fin soup and traditional cures, particularly in China. The International Union for Conservation of Nature’s Shark Specialist Group say that shark finning is widespread, and that “the rapidly expanding and largely unregulated shark fin trade represents one of the most serious threats to shark populations worldwide.”


According to the International Labour Organisation (ILO), there are also “strong indicators that forced labour in the fisheries sector is frequently linked to other forms of transnational organised fisheries crime.” Trafficking for the purpose of forced labor “in furtherance of both sea-and shore-based operations” is frequent; it is a global problem, but West Africa and South and Southeast Asia are particular hotspots. Trafficking of children in the fishing industry is commonplace in these regions, as is physical abuse, forced labor, and debt bondage. The fishing industry is vulnerable to such human rights abuses because, unlike merchant vessels, there are no international regulations or port state control measures that govern on-board living and working conditions. With fishing stocks depleted in many parts of the world, fishing vessels must travel much further away from shore to fish and can remain there for long periods of time. Crews in these circumstances are more susceptible to abuse as they are isolated from aid and unable to escape.

At the country level, illegal fishing can also cost governments tax revenue. According to the OECD, the three primary ways that fishing operators commit tax fraud are by “disguising the origin of fish, under- declaring the size of a catch and incorrectly describing the species or products caught or sold.”  This defrauds consumers and deprives developing country governments of important tax revenue

Estimates of the size of IUU Fisheries Trade through research by FCN likely values the trade as between US$19-45 billion, based on 2016 data. This is an increase on previous estimates from Global Financial Integrity “GFI”). In a Report issued in 2017, called Transnational Crime in the Developing World, GFI estimated the value as between US$15.5 to US$36.4 billion (based on 2011-2014 fishing data, and based on a previous study published in 2009, itself based on fishing data from 2000-2003, which had valued the IUU Fisheries Trade at US$10-23.5 billion, which is the most often quoted number. The new 2016 number, simply updates the numbers with those now available which shows the increase to between US$19-45 billion.

The United Nations’ 2030 Agenda for Sustainable Development and its 17 Sustainable Development Goals (SDGs) include commitments on IUU fishing, for example to ‘end overfishing, illegal, unregulated and unreported fishing’ and “to eliminate state subsidies that contribute to these practices,” (targets 14.4 and 14.6). The only indicators against which progress is currently measured, however are the proportion of fish stocks within sustainable levels and states’ implementation of international instruments aiming to combat IUU fishing, which leaves a major evidence gap as to where interventions are most needed, and how states’ performance measures against others. In order to fill this evidence gap, the IUU Fishing Index, was created and first published in January 2019. The Index benchmarks countries’ vulnerability, prevalence and response to IUU fishing, based on a suite of 40 indicators.

IUU Fishing Index

The scores from the Index yield both expected and unexpected results. 

  • While Belgium came out with the most favourable score for all indicators combined (1.43, China fared worst, with an overall score of 3.93. (Scores: 1 = best-performing; 5 = worst-performing), and a Global Average of 2.92.Many developing countries in Africa, Asia and Oceania are highlighted as areas of concern, primarily because they lack state resources to fully respond to the threats posed by IUU fishing.
  • However, several industrialised countries also scored as vulnerable thanks to extensive fishing infrastructure requiring sophisticated regulatory capacity.
  • By region, Asia displays the poorest scores in terms of prevalence of IUU fishing; of the ocean basins, the East Indian Ocean has the worst score; and China, Taiwan Cambodia and vietnam all perform especially poorly. Countries from other regions and ocean basins scoring badly include Russia and Panama. Europe and North America score best on measures of response to IUU fishing, but Oceania also performs well, highlighting the high priority given to fisheries by countries and regional institutions.

Whilst China comes bottom of these ratings, it should be recognised that China stands out when it comes to Fishing, compared to any other Country. China has almost 15 million people engaged in Fisheries (9.4 million in Fishing / 5 million in Fish Farming), and controls 12% of the global market via its fleet of 220,000 motorised fishing vessels, of which 25,600 are at least least 100 ton ships.

Whilst Illegal fishing is a global phenomenon, however it is particularly concentrated in developing countries as they are responsible for 82.7 percent of the total international trade in fishery commodities. Illegal fishing operations regularly target port states with weak monitoring and enforcement because they can operate with relative impunity. Developing countries, which often lack the resources, rule of law, and/or political will to sufficiently monitor and enforce fishing regulations, bear the greatest burden, frequently economic, of illegal fishing due to their reliance on the fishing industry.

The prevalence of IUU fishing in the world is more concentrated in regional hotspots for IUU fishing which are in the Eastern Pacific, the Northwest Pacific, West Africa, Southeast Asia, and Pacific Islands.

The EU Carding System

The introduction of the carding system by the EU has seen 25 countries yellow carded, with six receiving red cards since 2010, when EU regulations were brought in to list third countries of concern. Countries such as Cambodia, Comoros & St Vincent & Grenadines remain red carded and are therefore banned from supplying EU markets. Countries that remain yellow carded are Vietnam, Taiwan, Kiribati, Liberia, Sierra Leone, Trinidad & Tobago & St Kitts & Nevis. Countries previously listed that have been delisted most recently include, Thailand that was deemed to have sufficiently addressed concerns and was delisted in January 2019. Calls have been made for the US and Japan to join such a system and jointly issue cards, which would make this system even more powerful and effective.

Areas of Concern and Potential Red Flags

In addition to material exposures to Countries of Concern (see above), Potential additional “Red Flags” may include: fishing for fish species with a high market value; taking Flags of Convenience, transparency Issues with vessel ownership and inadequate use of vessel tracking technology, involvement in Transhipment, use of Ports that are not signed up to international standards, and inclusion on relevant watchlists. Fish Species that are targeted for illegal fishing often have high market values. Examples include tuna, Patagonian toothfish, crab, shrimp, and abalone. Patagonian toothfish, more commonly known as Chilean sea bass, are so lucrative that they are nicknamed “white gold.” This species usually has a legal-market value of more than US$10,000 per ton, while other highly sought species like tunas and lobsters average US$2,320 and US$9,000 per ton, respectively.

Flags of Convenience (FOCs) are a maritime legal regime that allows a vessel to be registered outside the country of ownership. The flag state (i.e., the country in which the vessel is registered) has legal authority over the vessels under its flag and is responsible for enforcing national regulations. Countries that “specialise” in offering FOCs principally do so to collect revenues from fees, services, and taxes, though they routinely do not have the ability and/or desire to exercise adequate control over vessels flying their flag, particularly those operating in distant waters.. The International Transport Workers’ Federation, has declared 33 countries and territories as offering FOCs and of these, 23 are developing countries and 3 are landlocked.

Vessel Ownership & Registration – according to the Environmental Justice Foundation, the adoption of a global record “with consistent and validated vessel, company and owner information, underpinned by an International Maritime Organization (IMO) number as a unique vessel identifier (UVI), is a practical, feasible and cost-effective step to combat illegal, unreported and unregulated (IUU) fishing by driving transparency and traceability throughout the seafood supply chain.” Currently, only non-fishing commercial vessels are required by the IMO to be registered with the vessel numbering scheme. That said, whilst there are a variety of actors involved in IUU fishing, from individual operators and small enterprises to multinational companies and organised criminal syndicates, some of the most damaging illegal fishing is conducted by seemingly legitimate enterprises, often fleets of corporate trawlers, which engage in harmful and unlawful fishing practices in order to maximise profits and the veneer of legitimacy makes it difficult to detect the underlying illegal activity.

Vessel Tracking – tracking is not possible for most of the estimated 4 million fishing vessels in the world. Still, 200,000 larger vessels publicise their locations via the automated identification systems. Global Fishing Watch enables users with Internet access to monitor fishing activity globally, and to view “individual vessel tracks, exclusive economic zones, marine protected areas, and other features.” It is hoped that the initiative can help to reduce “global overfishing, illegal fishing and habitat destruction.” According to Global Fishing Watch, “We are revolutionising the ability to monitor the global commercial fishing fleet, offering near real-time tracking of fishing activity via a public map, for free, to track fishing boats and download data about their past and present activities.” Some vessels with trackers have been known to switch them off while they operate in “questionable locations” then switch them back on when they return to safer waters, which may itself be a potential red flag.

Vessel Watchlists  – watchlists are available identifying vessels that have been found to carry out or support IUU fishing and can be searched to identify and monitor the global fishing vessel fleet for illegal activities. 

Transhipment  – exchanging fish catch, crew or supplies between boats at sea is common, but it also creates the opportunity for illegal activity involving drugs and people, for example human rights abuses have been associated with transshipment. By allowing fishing vessels to remain at sea for months or even years captains can impose conditions on crew that amount to conditions of forced labour and modern slavery.

Ports of Landing – Ports with lax enforcement or limited inspections have traditionally been a weak point in the global fight against IUU fishing. With adoption of the Port States Measures Agreement (PSMA), and its entry into force in June 2016, (by 30 States – now up to 50 States) designed to prevent illegally caught fish from entering ports, Countries subject to PSMA have committed to exerting greater port controls on commercial foreign-flagged vessels. For foreign fishing vessels wishing to enter PSMA Ports, they must first request permission in advance, transmitting detailed information on their identities, activities, and the fish they have onboard, with landings only permitted at specially designated ports equipped for effective inspections. Ships suspected of being involved in illegal, unreported and unregulated (IUU) fishing can be denied entry into port outright – or permitted to enter for inspection purposes only and refused permission to offload fish, refuel, or resupply. Vessels that are allowed into ports may be subject to inspections conducted according to a common set of standards. They will be required to prove that they are licensed to fish by the country whose flag they fly, and that they have the necessary permissions from the countries in whose waters they operate. If not, or if inspections turn up evidence of IUU fishing activity, vessels will be denied any further use of ports and reported as violators. Once a ship is denied access or inspections reveal problems, parties must communicate that information to the country under whose flag the vessel is registered and inform other treaty participants as well as Ports in neighbouring countries.

What can you do to help?

For Financial Institutions, consider whether IUU Fishing is relevant for you, based on the risks posed and in particular whether you need to include combatting this within your financial crime programme. The potential Red Flags and materials above can be used for this purpose, particularly in awareness raising but also in designing and updating controls.

Beyond this FI’s should consider whether IIU Fishing should be included within their Corporate & Social Responsibility programmes, which may go further than IUU Fishing by also denying access to financial services from commercial activities that damage the oceans. For example by involvement in losing so called “ghost gear” which is a major contributor to all marine litter, (estimated to be as much as a tenth of all litter found in the ocean), or by using driftnet fishing, deep sea bottom trawling, or fishing with the use of explosives or cyanide. For an example of how to respond to IUU Fishing, by denying commercial operations any access to financial services see here from Standard Chartered Bank. 


Every time wild-caught fish is bought at a restaurant, store, or waterfront dock, there is a 1 in 5 chance that it was caught illegally. Illegal, unreported and unregulated fishing accounts for anything up to 27 million metric tons of fish annually, worth up to $45 billion. This equates to more than 800 Kgs of wild-caught fish stolen from the seas every second. With fish stocks under pressure and some species endangered, it is more critical than ever that steps be taken to address illegal, unreported, and unregulated (IUU) fishing.

According to a December 2018 Report by the OECD titled; “Combatting Illegal, Unreported and Unregulated Fishing: Where countries stand and where efforts should concentrate in the future” they identify six policy areas for government intervention in relation to IUU fishing. These relate to increased responsibility by flag states (regulating domestically flagged fishing vessels in the areas beyond their national jurisdiction and in foreign exclusive economic zones), by coastal states (regulating vessels in the domestic exclusive economic zone), by port states (applying port controls and regulating the flow of products to the market) and by market states (creating economic disincentives for IUU fishing and using market tools to detect illegal seafood moving along the supply chain). The final two relate to enforcement to improve the capacity of monitoring, control and surveillance schemes, national inter-agency co-operation practices, and the comprehensiveness of existing sanctioning systems, and finally international co-operation, to improve the scope of international co-operation against IUU fishing.

These actions are clear, and so are the choices. We will miss the UN Sustainable Development Goals for 2020 for Fishing, but we still have time and a responsibility to act to save life in our oceans. To ensure sustainable fish stocks a more robust response is needed not only to IUU Fishing as an environmental issue but as a criminal one too.

0 0 votes
Article Rating
Notify of

Inline Feedbacks
View all comments