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This document was developed by an Expert Review Group based on outcomes from three Virtual
Expert Workshops on Best Practices in Compliance in RFMOs, convened by The Pew Charitable Trusts,
in collaboration with the International Seafood Sustainability Foundation (ISSF), with the support of a
Steering Committee. The document examines the compliance processes of the RFMOs and makes several recommendations for their strengthening.

A group of Chinese-linked distant-water squid fishing vessels have been identified regularly transmitting over MMSIs in the 150 series (not assigned to any country) and engaging in complex behaviour involving regular name changes over AIS, sharing of names and MMSIs between vessels and transmission of multiple MMSIs from individual vessels. Whilst this behaviour alone does not constitute IUU, it does make it extremely challenging to monitor the number of individual vessels and the activities of these vessels using AIS and confirm their identities - a matter of concern for RFMOs, coastal States and port States that the vessels interact with during their operations. The Joint Analytical Cell (JAC) consulted with China on the issues identified in the report and the results of this informative dialogue are captured in the final report.

The 2009 Port State Measures Agreement (PSMA) was the first legally binding international instrument to
empower port States to deny foreign vessels suspected of having engaged in illegal, unreported and unregulated (IUU) fishing from using their ports and to land catches. This paper builds upon previous work analyzing 2020 AIS data to rank fishing ports globally and assessing evolving port State risk and port States performance in PSMA implementation.

The assessment of the implementation of, and compliance with, agreed obligations is a key component of the internationally accepted fisheries governance regime. To fulfill the objectives of the tuna RFMOs, participants must implement and comply with a range of RFMO obligations. All the tuna RFMOs have recognized a need for a structured process to assess the implementation of, and compliance with, obligations and have adopted compliance assessment processes. Compliance assessment processes provide a framework to assess implementation and compliance in a structured and consistent way and may identify trends in compliance over time. Compliance assessment processes seek to improve the performance of an RFMO and to support participants to better meet their obligations.

Following the FAO's in-depth study "Transshipment: A closer look," this report captures contributions from the ground that aim to provide voluntary guidelines for the regulation, monitoring, and control of transshipment that are in fact robust, future-proof, and operationally achievable. The study recommends looking at seven key areas that would enable relevant authorities to minimize the risk of IUU-caught seafood entering the market and to ensure compliance with national and regional legal frameworks.

The Committee on Fisheries (COFI) of the Food and Agriculture Organization of the United Nations (FAO) requested an in-depth study of transshipment to develop international guidelines based on best practices. The FAO fisheries operations and technology branch took up the assignment and began its work in 2019. The team conducted a global study to shed light on current regulations, practices, and control of transshipment to assess the status quo. The study was finalized in 2020 and provides the most comprehensive foundation (based on a risk-based approach) for the development of international guidelines on transshipment, highlighting areas of persistent and emerging concern.

This report analyzed the movements of carrier vessels operating in the Western and Central Pacific Fisheries Commission (WCPFC) Convention area in 2016. Through analysis of AIS data, the report identified carrier vessel voyage patterns and quantity, carrier vessels' flag state patterns, the spatial distribution of potential transshipment on the high seas, and the port visit locations by carrier and flag states. The report also found that many carrier vessels did not transponder on AIS, leading to significant gaps in data on unreported transshipment events. Ultimately, the WCPFC’s management of transshipment in its Convention area is compromised by a lack of reported information on transshipment, coupled with non-compliance with reporting requirements and non-standardized reporting responses by CCMs on carrier vessels and their activities.

With six of the seven main tuna species already fully fished or overfished, this study aims to find a correlation between tuna distribution and spawning grounds with reefer activity. Tuna is a highly sought-after fish species and reefers provide increased fishing activity while their use in transshipment can also aid in IUU fishing that mainly targets tuna sub-species. On a global scale, the study was unable to find any correlation between reefer activity and tuna distribution or habitat.

This report reviews the transshipment measures of the five tuna RFMOs plus SEAFO and CCAMLR. Although each tuna RFMO generally prohibits at-sea transshipment except for large-scale longline fishing vessels with 100% observer coverage on the carrier vessels, their relationship, the report finds, with other MCS measures leaves multiple gaps and shortfalls. Through the analysis of non-tuna RFMO transshipment measures in critical comparison to the many shortfalls found with existing measures in tuna RFMOs, the report gives detailed recommendations to improve and strengthen tuna RFMO transshipment regulations.

The Environmental Justice Foundation (EJF) has found that many Western coastal countries in Africa have been unable to control and monitor transshipment at sea. These coastal countries have insufficient resources to inspect vessels before transshipment and instead rely on onboard observers monitoring for illegal activity, who have multiple shortcomings. With 37% of West African catch coming from IUU fishing, this activity puts marine management at risk and poses severe threats to the livelihoods of coastal countries' citizens. The EJF proposes banning transshipment at sea for these coastal countries, requiring them to work with the international community and improve their monitoring and control systems.

Port State Measurement Agreements (PMSA) aim to combat IUU fishing by bringing international parties to enact legislation and regulation on foreign vessels entering port. Parties to the PMSA, Port-States, are responsible for monitoring whether a vessel has engaged in IUU fishing. Reefers (because of their role in transshipment) pose a serious problem in effectively tracking and monitoring IUU fishing, leading to harmful marine biodiversity activity and human rights abuses such as seafood slavery. However, reefers are readily equipped with Automatic Identification System (AIS) Technology which, this paper shows, has proven to be an effective tool in MCS that PMSA parties can continue to use.

The international community has sought to limit or ban-transshipment at sea due to the difficulty it poses in monitoring IUU fishing and controlling its effects. The WCPFC has banned purse seine vessels operating within the WCPFC Convention Area; however, for longliners and other vessels, the WCPFC merely encourages them to conduct transshipment at sea to the extent practicable. Despite proper infrastructure at port, a precedent of other vessels conducting transshipment at port, and insignificant costs, CCMs have used the "impracticability" test to continue transshipping at sea. This paper proposes replacing the "impracticability" test with bright-line rules to put an end to CCMs' patterns of transshipment at sea.

In this research study, Global Fishing Watch uses AIS information to identify where transshipment can be happening and who is doing it. About 42 percent of potential rendezvous (what is identified through AIS data to track transshipments) occur on the high seas, with the rest happening within the EEZs of different nations–especially Russia. It is concerning, however, that those areas with higher levels of reported IUU fishing correlate with areas of high potential rendezvous. With such a high level of transshipments occurring on high seas, the global community could not only benefit from using AIS data to identify illegal transshipments but must also cooperate to address lax oversight and control. This revised report improves on the methodology of the earlier finding in February 2017.

In a study commissioned by the Pacific Islands Foreign Fisheries Agency (FFA), transshipment and purse seine vessels are analyzed concerning the benefits accrued to Pacific Island Countries (PICs). The study finds that transshipment at port has not brought increased revenue in the past 18 years (as of the time of writing.) As gross revenues have not increased, neither have transshipment fees; PICs could benefit from standardizing fees not only to increase revenues but also because these fees help support monitoring and fisheries management efforts. High seas longline transshipment is there to stay for PICs, it makes financial viability possible for the fishing industry, but PICs must continuously monitor where transshipment is happening, and what benefits are accrued.

This report builds on the literature that the ISSF has conducted on analyzing tuna RFMOs transshipment regulations(See 2014-2018 reports). This report reviews the transshipment measures of the five tuna RFMOs plus SEAFO and CCAMLR. Although each tuna RFMO generally prohibits at-sea transshipment except for large-scale longline fishing vessels with 100% observer coverage on the carrier vessels, their relationship, the report finds, with other MCS measures leaves multiple gaps and shortfalls. Through the analysis of non-tuna RFMO transshipment measures in critical comparison to the many shortfalls found with existing measures in tuna RFMOs, the report gives detailed recommendations to improve and strengthen tuna RFMO transshipment regulations.

The Committee on Fisheries (COFI) undertook a global report on transshipment activities including the state of transshipment regulations and practices, guidance on specific control mechanisms for transshipment, and the state of independent monitoring and control over transshipment. The COFI held a workshop to overlook their report and the Global Stakeholder Survey responses they received from 91 States. The workshop concluded, among various other findings, that transshipment threatens the marine environment and human rights abuses without effective monitoring and control. However, the practice is an important cost-effective fishing operation and does not in itself pose a threat to what was previously discussed–further research must be done to see the extent of illicit transshipment operations.

RFMOs have the role of managing fisheries on the high seas. However, they have been under scrutiny before in their conservation of fish and monitoring and enforcing legislation. With transshipment at high seas becoming an increasingly salient issue, strong RFMO enforcement is ever more needed. This study examined all RFMOs' regulations and gave them a score on stringency. While RFMOs have not become less stringent since the late 1990s, the study concludes that a moratorium on transshipment at sea is needed to alleviate the lack of comprehensive monitoring, control, and surveillance.

The Western and Central Pacific Fisheries Commission (WCPFC) manages fishing activity in the Western and Central Pacific Oceans, one of the largest areas in the world and one of the most valuable fisheries in the world. However, their ability to enforce transshipment rules to prevent IUU fishing is severely lacking due to insufficient funds and resources, specifically when it comes to onboard observers. The observers have failed at monitoring the activities of both the fishing vessel and carrier vessel during transshipment and reporting that information for independent verification. By adopting rules already in use by other t-RFMOs, the WCPF can significantly improve its current transshipment regime.

Using Global Fishing Watch data, Oceana identified where the hotspots for transshipment events worldwide. Many of the hotspots for transshipment were in areas where transshipment may be under less scrutiny. The Sea of Okhotsk has a long history of IUU fishing, but the Russian and Japanese EEZ zones account for more than 50 percent of the total likely transshipment events globally. Or the waters of Guinea-Bissau, a country unable to enforce strict transshipment regulation compliance, was another hotspot. The report shows how transshipment activity patterns arise based on the location, facilitating additional research into the nature of transshipments in these areas.

Transshipment at high seas is very difficult to monitor, allowing the possibility of illegally caught fish to enter the legitimate seafood market, or enabling human rights abuses. This paper uses AIS data to track global transshipment behavior. They find that a majority of transshipment occurs at high seas outside of EEZ boundaries–areas that may lack national jurisdiction or where regulations are difficult to enforce. Additionally, possible transshipment encounters are happening with vessels flying flags of convenience. Together, these findings paint a scene of large transparency issues in global transshipment behaviors that will need to be addressed by governing bodies.