Drifting among the ice fields of the Bering Sea, the poachers illegally harvested fur seals by the thousands. They were unconcerned about the long-term biological or cultural impact of their actions; short-term financial gains were all that mattered. So focused were they on the task at hand, they must have felt a heart-stopping panic when they saw a Revenue Cutter Service ship coming for them over the horizon.
Thousands of miles from the continental United States, cutters such as the Rush represented the federal government in the Alaskan territory in the 1870s. The phrase “Get there early to avoid the Rush” was coined in 1874 by seal poachers seeking to avoid being interdicted by the cutter.1 Even without today’s advanced navigation equipment and cold weather clothing, these cuttermen patrolled the waters off Alaska and established a reputation for protecting living marine resources that the modern Coast Guard endeavors to uphold.
The connection between stable fisheries and stable governance has long been understood. Many countries depend on fisheries for food security, cultural connections, and gross domestic product. Governments’ ability to protect their domestic fish stocks from external poaching is critical not only to their legitimacy, but also
to global stability.
The Somali piracy in the early 2000s, for example, is often cited as arising in part from illegal, unreported, and unregulated (IUU) fishing. At the end of the 20th century, distant-water fishing fleets of other countries encroached on Somali waters. Lacking a strong government to project authority in the maritime domain, Somali mariners sought to defend their fisheries—which included attacking and sometimes hijacking and holding foreign fishing vessels for small ransoms.This later transformed into oceangoing piracy.2
As a global leader in IUU enforcement, the U.S. Coast Guard has an opportunity to spearhead a more comprehensive response to IUU fishing. To do this, it must maintain focus on uncovering illegal fishing while going a step further along the bad actors’ food chain into the deep end of unreported fishing. As part of a whole-of-government approach and working with partner nations, it should target transshipment vessels that support state-sanctioned fish laundering.
The Deep End
IUU fishing generally is equated with illegal fishing, meaning catching fish contrary to national laws or international management measures. The Coast Guard is highly effective at countering illegal fishing through its law enforcement actions, such as detecting and seizing high-seas drift net vessels and preventing foreign fishing vessel incursions into an exclusive economic zone. In addition, detecting illegal fishing is aided by the expansion of satellite-based systems and Automatic Identification System (AIS) tracking by both nongovernmental and governmental organizations. Previously dark corners of the ocean are now bathed in light, but violators do not necessarily go away. They simply scatter to find new places to hide. A decrease in at-sea interdictions could just represent a shift in violators’ tactics.
To remain at the leading edge, the Coast Guard needs to expand its focus to include unreported as well as illegal fishing. Unreported fishing is similar to tax fraud; it is knowingly misreporting a catch for economic gain. International fisheries often are managed by setting a total allowable catch (TAC) per nation per year. By misreporting and manipulating catch data, a nation’s vessels can overfish while giving the appearance of lawful harvesting to law enforcement boarders or satellite surveillance. To make matters worse, the phony catch numbers often are the primary data source fisheries scientists use to set the following year’s TAC, further skewing the stock assessment modeling. Meanwhile, the ruse is virtually undetectable at the boarding team level.
The preferred mechanism for this unreported sleight-of-hand is transshipment vessels. Best thought of as floating refrigerated warehouses, transshipment vessels are large support ships that provide for the at-sea transfer of catches, allowing smaller catcher vessels to offload while still on the fishing grounds. They also supply catcher vessels with food, fuel, and personnel, allowing them to remain on the fishing grounds for longer periods.
Most transshipment is regulated by regional fisheries management organizations (RFMOs) and coastal states, but in areas in which regulatory control and oversight are inadequate, the risk of misreported catches increases.3 A 2018 study of China’s fishing fleet in the northwest Pacific analyzed the freezer hold capacity of Chinese catcher vessels and transshipment vessels operating in the chub mackerel fishery. Conservatively, the study estimated that China knowingly harvested more than double the catch reported to the North Pacific Fisheries Commission in 2016, noting that China “declares improbably low catches in its distant water fishing fisheries.”4 A separate 2022 study identified the northwest Pacific also as an AIS disabling hotspot, adding that disabling frequently occurs in areas with high transshipment activity.5
When catches from multiple vessels are mixed, it is incredibly difficult to distinguish fish that are illegally caught, mislabeled, or not accounted for from lawful catch. Illegal transshipment is akin to fish laundering.
Harness the SAFE Act
In 2019, Congress passed the Maritime Security and Fisheries Enforcement (SAFE) Act.It requires 21 agencies to coordinate to combat IUU fishing, with the aim of reducing stovepiping and providing a larger, cohesive federal response. The act establishes an interagency working group to facilitate coordination, with a Coast Guard flag officer sharing the rotating co-chair duties with NOAA and the Department of State.6
The Coast Guard should harness the collective power under the SAFE Act to counter high-seas unreported fishing being concealed by transshipment. The service has the capability, authority, and expertise to board transshipment vessels at sea; however, these boardings produce piles of paperwork for analysis. To avoid being overwhelmed by the multitude of transshipment vessels of various flag states working across different RFMOs, each with its own regulations, the Coast Guard initially should focus on one flag state—Panama.
A study funded by the Pew Charitable Trusts examined RFMO-related transshipments between 2015 and 2020 and found that a small number of carrier vessels accounted for the majority of events. Of the at-sea transshipment events studied, the largest number were between Chinese-flagged fishing vessels and Panamanian-flagged transshipment vessels.7
The five-year strategy prepared by the SAFE Act’s working group identifies Panama as a priority flag state with which to pursue additional projects and initiatives to counter IUU fishing—in part because of the country’s willingness to take action against IUU fishing activities associated with its vessels.8 The Coast Guard’s own IUU implementation plan calls for strengthening multilateral coalitions and expanding existing bilateral agreements to include counter-IUU language, as well as “reinforcing expectations that all fishing nations exercise responsible flag state control over their vessels.”9
The Coast Guard excels at supporting partner nations, conducting joint patrols, and upholding the governance of the RFMOs, but it has an opportunity to lean further into the fight. In concert with its SAFE Act partners and allied nations, it should work to identify and expose transshipment vessels laundering fish for economic and potentially political gains. Getting this information into the court of public opinion would build momentum for, at minimum, tighter oversight and regulation, if not an international ban on high-seas transshipment. Requiring fishing vessels to transit to port for offloading would provide greater catch accountability while also helping to address the human rights abuses that stem from the forced labor associated with IUU fishing.
To not fully engage on the unreported aspect of IUU fishing is tantamount to handing over fisheries management to countries that are either indifferent to fish stock collapse or, worse, actively supporting it for their own advantage. Bolstering the Coast Guard’s efforts against unreported fishing would protect fish stocks, level the playing field for law-abiding fishermen and seafood producers, and incentivize lawful fishing practices on a global scale. It would let the world’s IUU networks know the Coast Guard is coming for them, no matter how fast they move or how slick their tactics. For when the service and its partners focus their efforts on all aspects of IUU fishing, those bad actors attempting to beat the system will find that, today, they cannot avoid the Rush.
1. U.S. Coast Guard, Timeline 1700s to 1800s, www.history.uscg.mil/Complete-Time-Line/Time-Line-1700-1800/.
2. Ghassan Schbley and William Rosenau, Piracy, Illegal Fishing, and Maritime Insecurity in Somalia, Kenya, and Tanzania (Washington, DC: CNA, September 2013); and James Kraska and Brian Wilson, “The Co-Operative Strategy and the Pirates of the Gulf of Aden,” RUSI Journal 154, no. 2 (April 2009): 74–81.
3. The Pew Charitable Trusts, “Most Global At-Sea Transshipment Involves a Small Group of Key Carriers,” PewTrusts.org, 19 April 2023.
4. Yoshioki Oozeki et al.,“Reliable Estimation of IUU Fishing Catch Amounts in the Northwestern Pacific Adjacent to the Japanese EEZ: Potential for Usage of Satellite Remote Sensing Images,” Marine Policy 88 (February 2018): 64–74.
5. Heather Welch et al., “Hotspots of Unseen Fishing Vessels,” Science Advances 8, no. 44 (November 2022).
6. Office of Marine Conservation, U.S. Department of State, “Illegal, Unreported and Unregulated Fishing,” www.state.gov/key-topics-office-of-marine-conservation/illegal-unreported-and-unregulated-fishing/.
7. Pew, “Most Global At-Sea Transshipment.”
8. U.S. Interagency Working Group on IUU Fishing, National Strategy for Combating Illegal, Unreported and Unregulated Fishing 2022–2026 (Washington, DC: Department of Commerce, 2022).
9. U.S. Coast Guard, Illegal, Unreported, and Unregulated Fishing Strategic Outlook Implementation Plan (Washington, DC: Headquarters, U.S. Coast Guard, July 2021).