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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.

Through examination of Ghana's Fisheries Act of 2002 and Fisheries Regulation of 2010, the TaylorCrabbe Initiative seeks to answer what the legal status of Transshipment in Ghana is and if the Minister for Fisheries and Aquaculture Development can allow transshipment at sea from industrial trawlers to canoes. Under their legal reasoning, they find that no act has allowed the transshipment of fish from local trawlers to canoes. The Fisheries Commission or Council can authorize forms of transshipment, but not the Minister. Unless the transshipment has been approved and properly supervised, transshipment in Ghana is illegal.

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.

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 study uses AIS data to identify when and where transshipment occurs, which fisheries and fleets are most involved in the practice, and what proportion of the high-seas catch is transshipped versus landed directly, altogether giving a detailed account of global seafood supply chains. Among many other findings, the study finds that fishing in EEZs was mainly landed directly, but on high seas, transshipment largely predominated. Fleet usage also differed with trawlers mainly used in EEZs and longline fishing dominated at high seas. The study ultimately shows how the type of catch and its location shape the infrastructure of the supply food chain involved (i.e. a history of poor monitoring, low compliance, and weak enforcement correlates with a large number of transshipments in Russian waters.) The findings of this study can aid in identifying where illicit activity can be happening and what warrants more monitoring, control, and surveillance.

This study begins by identifying the trends in usage of flags of convenience (FOC). Using the Lloyd's Register database, they compile a list of fourteen countries that consistently top lists of FOC countries or are of particular concern to IUU fishing. Despite the adoption of enforcement pieces like the UN FAO IPOA, registration to these fourteen countries has only slightly declined and new vessel constructions are largely registering with FOC countries. Next, the database helps determine the role and character of the at-sea transshipment, refueling, and resupply fleets in supporting the operations of high-value tuna longline fleets and other fishing fleets on the high seas. Many of these vessels engage in a combination of participating in IUU transshipment as well as legal vessels fishing for tuna.

Greenpeace undertook a research project to understand the extent of misuse of AIS by the global reefer industry. Greenpeace identified and studied 416 reefers that make up the majority of vessels that have transshipped at sea in the period 2017-2019. From these vessels, Greenpeace found multiple instances of violations of AIS, with proof in adopting 'flags of convenience' (most commonly, Panama), the behavior of vessel interactions with 'encounter' and 'loitering,' and transshipment in areas that are unregulated or pose a threat to marine habitats. The continued violations of AIS by reefers, according to Greenpeace, calls for a robust Global Ocean Treaty that will stop these harmful activities and protect our oceans.

Without a Worldwide Unique Vessel Identifier (WUVI) database, the International community has largely relied on data in self-created combined vessel lists for spatiotemporal mappings of fishing presence, effort, and footprint. Projects match fishing vessel registration identifiers to their alleged AIS MMSI numbers using these vessel lists. This study aims to prove that this method has yielded a large number of erroneous ship identification references. Global Fishing Watch, one of the largest vessel identification projects, is crosschecked with the vessel data that the study gathered and found that it suffers from major flaws and biases. Such errors put at risk both the creditability of the GFW and private/independent fisheries monitoring control & surveillance (MCS) initiatives. Not only should projects use more scientific responsibility, but a worldwide database could also help end the data-gathering methods that brought these mistakes about.

Agreed on by leading NGOs engaged in global tuna sustainability, the best practices outlined ensure that at-sea transshipment is well-managed and transparent. The best practices come in three facets: management best practices, data reporting best practices, and monitoring best practices. The policies include 100 percent observer coverage either human or electronic for all at-sea transshipment events, require information on all at-sea transshipment events to be shared with the relevant RFMO, prohibit vessels from acting as both a fishing vessel and carrier vessel on the same trip and a multitude of other policies that fisheries can work towards implementing.

To combat IUU fishing facilitated by at-sea transshipment, the Indonesian government banned the activity in 2014. Enforcing the ban, however, has been difficult due to the challenges of detecting and monitoring transshipment activities at sea. This study provides a suite of indicators for longline and purse seine fisheries in Indonesian waters as a useful tool to underpin monitoring, control, and surveillance activities to reduce IUU fishing. Through this analysis, the extent of increased enforcement and legislation managing transshipment puts Indonesia at the forefront of nations addressing IUU fishing.

The inadequate regulatory control and monitoring of transshipment, especially at sea, create gaps that enable illicit activity. Recognizing this inadequacy and its consequences, the Pew Charitable Trusts calls for a ban on transshipment until best practices are implemented. They outline multiple best practices across three categories, reporting, monitoring, and data-sharing. By implementing these practices, all parties can be assured that adequate guidelines are in place to make transshipment a more effective and safe practice, not contributing to IUU fishing.