Illegal, Unreported, and Unregulated Fishing

Environmental Crimes No Comments

Introduction

Illegal, Unreported, and Unregulated (IUU) fishing encompasses a broad array of practices. These generally centre on the evasion of global and domestic fisheries management arrangements and legislation, as well as conservation regulations within and beyond national jurisdiction. It threatens maritime security by causing loss of economic revenue, environmental damage, and damaging livelihoods of coastal communities.

A large ship in the water Description automatically generated

Yu Feng, a Taiwanese-flagged fishing vessel suspected of illegal fishing activity – USN

The term IUU fishing was officially adopted in the Food and Agriculture Organization of the United Nations (FAO) 2001 International Plan of Action to Prevent IUU, though the practices themselves preceded this.1. The FAO plan was the first major international initiative to deter and eliminate IUU fishing, and has been recognised by various institutions such as the World Summit on Sustainable Development (WSSD), G8, WWF,2 and the United Nations General Assembly (UNGA).3 Due to the significant impact of the issue, the UN Secretary General identified IUU fishing as one of the seven main threats to maritime security.3

Regional organisations followed suit. These include the African Union,4 who identified IUU fishing as a significant issue within their 2050 Integrated Maritime strategy, the European Union through their Regulation to prevent, deter and eliminate IUU fishing,5 and ASEAN, who have recently established the ASEAN Network for combatting IUU fishing.6 The ‘Quad’ (USA, Japan, India and Australia) in the Indo-Pacific has also centred IUU Fishing in its activities.7

IUU fishing has been recognised as a key priority by most individual coastal states too (see for example the US,8 the UK9, and Australia10). There has also being a burgeoning academic interest in IUU fishing.11

Illegal, Unreported, and Unregulated (IUU) fishing encompasses a broad array of practices centred on the evasion and avoidance of global and domestic fisheries management arrangements and legislation, as well as conservation regulations within and beyond national jurisdiction. Following the definition of the FAO:

  • Illegal fishing is fishing that is: conducted by national or foreign vessels in waters under the jurisdiction of a State, without the permission of that State, or in contravention of its laws and regulations;
  • conducted by vessels flying the flag of States that are parties to a relevant regional fisheries management organisation but operate in contravention of the conservation and management measures adopted by that organisation and by which the States are bound, or relevant provisions of the applicable international law; or
  • in violation of national laws or international obligations, including those undertaken by cooperating States to a relevant regional fisheries management organization.

Unreported fishing comprises activities: 

  • which have not been reported, or have been misreported, to the relevant national authority, in contravention of national laws and regulations; or
  • are undertaken in the area of competence of a relevant regional fisheries management organisation which have not been reported or have been misreported, in contravention of the reporting procedures of that organisation.

Unregulated fishing takes place: 

  • in the area of application of a relevant regional fisheries management organization that are conducted by vessels without nationality, or by those flying the flag of a State not party to that organization, or by a fishing entity, in a manner that is not consistent with or contravenes the conservation and management measures of that organization; or

  • in areas or for fish stocks in relation to which there are no applicable conservation or management measures and where such fishing activities are conducted in a manner inconsistent with State responsibilities for the conservation of living marine resources under international law.

Common IUU fishing practices include: fishing in a country’s Exclusive Economic Zone (EEZ) without a license; vessels with dual flags; vessels circumventing regulations through Flags of Convenience; fishing non-permitted species; unlicensed border hopping; fishing above quota; fishing in prohibited areas (such as Marine Protected Areas); vessels with false flags; fishing in RFMO without license; fishing with illegal gear or using illegal means; transhipment without authorization; fishing out of season; misreporting catches; not reporting catches; the dumping of fish and retaining only of ‘high grading’ fish; and failure to operate Vessel Monitoring System.12

Characteristics

Much work has been conducted on the causes of IUU fishing. Explanations relating to an assumption of economic self-interest are prevalent.13 These include economic incentives arising from the abundance of a valuable commercial species in a particular place or at a particular time, or a lack of expected sanctions.14 As the Marine Resources Assessment Group highlights, legal and illegal fishers may sell to the same markets, but legal operators face the burden of increased costs of meeting regulations (such as minimizing long-line vessel lines to reduce by-catch), while illegal fishers face fewer overhead costs (as well as potentially evading tax).15

Economic hardship can also be an important ‘push’ factor towards illegal practices, particularly in small fishing communities.16 If a community is generally impoverished, it has been shown to contribute to IUU fishing as a result of a ‘scarcity mindset’, whereby short-term needs legitimise (in the mind of the perpetrator) illicit activities that may cause long-term impacts. One example offered is the poaching of trochus in Australian waters by impoverished Indonesian fishers.

Economic self-interest explanations have been criticised for not recognising the facilitating political and social context in which IUU fishing takes place.17 Battista et al., for example, argue that the moral, societal, and cultural factors affecting IUU fishing behaviour are also importance – especially for smaller scale activities by local community actors. 18 They argue that IUU can be driven not only by self-interest, but also feelings of entitlement over the resource, a desire to retain a sense of identity or tradition, protests against the existing rules (perceived as illegitimate or oppressive)19 or enforcers (perceived as corrupt),20 coercive enrolment, a lack of information and beliefs it is victimless, and consequent moral norms of acceptance within fishing communities. Legitimacy and trust in regulations may also be undermined when violations occur often, weakening a sense of obligation to continue following such measures.21 As Osterblom et al. argues, governments can create market vacuums, the state may not be perceived as legitimate, and crime offer a solution for those who cannot depend on alternative livelihoods. 22

IUU fishing includes both serious and minor offences, with perpetrators ranging from organized criminal groups to otherwise legitimate commercial vessels or artisanal fishers.23

As Vrancken et al. argue, IUU is commonly considered as a fisheries management issue as much as a criminal one.24 IUU violations are often treated as administrative contraventions or occurring as a result of regulatory gaps, weak and uneven governance in the management of fisheries (or in areas without fisheries management), and insufficient levels of sanctions (such as fines). Subsidy provision leading to over-capacity of fleet or quotas in the face of increasing demand and falling stocks have also been highlighted as management issues.25Rather than being explicitly criminal, IUU in this sense is seen as comprising relatively minor opportunistic infractions by individuals, artisanal fishers, or otherwise legitimate fishing businesses in areas with poor fisheries management or problems of legitimacy perception, made on the above bases of economic calculation and social context.26 

However, evidence of the organised and purposive nature of many IUU fishing activities has increasingly led to its treatment as a form of transnational organised crime at sea.27 The United Nations Office on Drugs and Crime (UNODC) argue that organised crime in the fisheries sector is likely to become more prevalent as fish become more scarce and so more valuable.28 This is in line with evidence showing that illegal fishing activities have increased significantly in recent years, and that much of this activity is highly organised and explicitly profit-driven, perpetrated by organisations with strong links to other forms of serious crime such as drugs trafficking and forced labour.29 IUU fishing has also been linked to notions of ‘green crime’; that is crimes that cause significant environmental harm, even if not technically illegal.30

IUU fishing is recognised as a criminal activity by multiple international organisations and agencies. These including the UN General Assembly,3 the FAO, 31 the UNODC (who brand it a ‘marine living resources crime’),32 and Interpol.33 NGOs such as WWF also refer to IUU in their efforts to improve and universalise enforcement over criminal harm to marine living resources.2

IUU fishing is increasingly characterised as a security issue within academia,34 as well as by various international, regional, and non-governmental organisations,35 and by many states. IUU fishing can have significant impacts socio-economic effects on populations who depend on fish for their livelihoods and sustenance.36 It can also cause further insecurity through linked crimes. Glaser et al. argue, for example, IUU fishing in Somalia resulted in some former local fishers turning to piracy, including – initially at least – targeting IUU fishing vessels that they considered to be legitimate targets 37 DeSombre argues that IUU fishing, through depletion and eco-system damage, may intensify disputes over island territories in order to ensure access to fishery resources.36 IUU fishers have been used by states to attempt to secure access to greater fishery resources. China for example has been accused of pursuing this strategy in the South China Sea.

Scope

While there is general agreement that IUU fishing is increasing,38 there are various estimates on the scope of the issue. Assessments are complicated by the use of different measures, as well as the broad array of activities – many of them clandestine – that constitute IUU fishing practices. As such, data on the frequency and degree of the problem remains limited or is based on best guess estimates. 39

One measure of the overall impact of IUU has been to estimate catch sizes. The US National Intelligence Council, for example, suggest that IUU accounts for one third of the total global catch, based on data extrapolated from well-documented fisheries.8 The Environmental Justice Foundation argue that at least 15% – 11 to 26 million tons annually – of the global catch is taken through IUU fishing.40 In Europe, 40-60% of seafood catch is linked to IUU activity. 41 Other studies suggest that a quarter of the global landed value of fish is taken through IUU activities.42

A second measure through which to assess the scope of IUU fishing is the financial cost it incurs through losses to legitimate actors such as states. Agnew et al., in a much-cited paper, estimate the annual cost to the legitimate global economy is between USD 10 and 24 billion. 43 In the Eastern Central Atlantic, this loss has been assessed at between USD 828 million and 1.6 billion annually.44 Liddick suggests that USD 2 to 5 billion dollars are lost by developing nations every year as a result of IUU fishing. 23

Case studies demonstrate that IUU fishing is prevalent in all regions in the world, including in coastal areas, the Exclusive Economic Areas (EEZs) of states and on the High Seas. While there is significant variation in both the level and trend of IUU catches across regions, it is clear that IUU is global in scope.43 These claims are supported by the Global Initiative’s IUU Fishing Index.45

These difficulties of measurement have resulted in some novel alternative approaches. Platforms such as Spyglass, Global Fishing Watch, and Project Eyes on the Sea for example, rely partly on shared information in order to track illegal vessels and their activities. 46

Other measurements focus not on the vessels themselves, but focus instead on ‘hubs’ such as transhipment or bunker vessels which are easier to track. 47 This is because some fishing vessels may not have Automatic Identification Systems (AIS), or may have switched them off, making them more difficult to monitor them at sea.48. Transhipment or bunker vessels, on the other hand, are required to use AIS and are generally monitored to a greater degree.49 By tracking these vessels, on which fishing vessels rely for refrigeration, fuel, and supply provision, patterns emerge whereby they either meet up with known fishing vessels or idle long enough for a rendezvous to occur with vessels that are not being tracked.49

Transhipment at sea by the Fisheries Committee for the West Central Gulf of Guinea

Even using these methods, monitoring IUU fishing is difficult. Vessels often operate clandestinely and may be engaged in legitimate activities alongside IUU practices. For example, Intchama et al. found that 20 per cent of vessels with licenses in Guinea Bissau also had records for criminal activities in the past, ranging from using an illegal mesh size, to fishing in a prohibited area, to labour abuse.50

Impact

IUU fishing has multiple impacts, including on vulnerable (often coastal) communities, states (particularly in the Global South), and the environment.  The UN Environment Programme (UNEP) and INTERPOL ‘Environmental Crime Crises’ report describes illegal fishing as comprising a ‘rapidly rising threat to the environment, to revenues from natural resources, to state security, and to sustainable development.’ 51

The depletion of fish stocks through unsustainable IUU fishing practices has been shown to damage coastal communities by undermining legitimate fishing economies, threatening livelihoods and creating food insecurity.52 Chapsos et al. have analysed the impact of IUU fishing on fishing communities in Indonesia, for example. They demonstrate that such activities resulted in a severe depletion of fish stocks, which in turn pushed local artisanal fishers to turn to IUU practices themselves in order to survive.53 Multiple studies have shown similar results in other countries.54 Violent confrontations between IUU fishers and local communities can also take place .55

IUU fishing has been linked to piracy.56 Local fishers who have lost their source of income as a result of foreign IUU fishing fleets have sometimes turned piracy as an alternative source of income, as was the case in Somalia.57 Here, IUU fishing vessels not only competed with local artisanal fishers, but often did so using unsustainable methods ways such as bottom trawling, and in some cases clashed directly with Somali fishers or destroyed their fishing gear.58 In the absence of government protection and enforcement, such activities provided a moral narrative for piracy against fishing vessels, which in the Somali case quickly escalated to more organised forms of criminality such as kidnap and ransom attacks against cargo vessels.

IUU fishing has also been linked to human trafficking, slavery, and poor working conditions for local fishers and those trafficked to work on fishing vessels, and to generally poor compliance with environmental or labour regulations.60

IUU fishing can impact on states as well as smaller communities. The most direct form this takes is loss in the value of the national catch, because a proportion is lost to IUU activities. Additional costs to the State can emerge when levies, landing fees, and taxes are reduced due to legitimate operators landing less as a result of such activities.61 Loss of livelihoods in affected coastal communities is another indirect economic factor for the state, 62 as is a weakening fishery sector due to reduced landings, meaning the losses of port dues and bunkering. A further strain can be placed on national budgets by the costs of trying to enforce sanctions against IUU fishers, particularly when these activities are conducted by sophisticated and well-resourced criminal organisations or are widespread amongst artisanal fisheries in coastal communities.

IUU fishing can play a role in exacerbating international tensions and conflict. DeSombre argues that IUU fishing, through depletion and eco-system damage, may intensify disputes over island territories in order to ensure access to fishery resources.36 IUU fishers have also been used by states to attempt to secure access to greater fishery resources in contested areas.

US Coast Guard inspects a suspected IUU vessel in Ghana by the US Navy

Finally, IUU fishing has important environmental impacts. Perhaps as much as 90% of the world’s fish stocks are either depleted or overexploited, with the observable collapse and near collapse of some fish species.63 Many of these species are protected in some form, but are targeted by IUU fishers due to their high market value. There is evidence of this for species such as tuna, redfish, orange roughy, squid, toothfish, sturgeon, and sharks for example.64 These impacts can be intensified by the use of indiscriminate fishing methods such as bottom trawling or the use of driftnets, which can result in high levels of bycatch. 65 Bycatches are also associated with discards because non-target species are often dumped in the ocean where they can decompose and contribute to oxygen deprived “dead zones”. 66 Because of these issues, IUU fishing can precipitate a reduction in biodiversity and ecosystem resilience.

Certain types of illegal fishing practices, such the use of explosives or poisons such as cyanide can also cause significant environmental damage, and often kill more fish than can be harvested.67

Linkages and Synergies

Evidence shows that IUU fishing is commonly linked to other forms of maritime crime. The UN Office on Drugs and Crime (UNODC) suggest that extensive criminal activities run parallel with IUU fishing and fisheries crimes.32 An important reason for this is that IUU fishing often takes place in areas of low enforcement capability, creating opportunities for other criminal activities too.68

IUU fishing has been linked to trafficking and smuggling for example.69. Vessels have also been linked to people smuggling, the trafficking of weapons or wildlife, and the smuggling of goods such as cigarettes for the purposes of tax evasion.70. There are also links between IUU fishing and human trafficking, with significant evidence of the use of forced labour on some vessels.71

Responses

Responses to IUU fishing vary greatly due to the diverse practices that constitute IUU fishing, and because the actors involved have varying degrees of capacity and legitimacy through which to tackle the issue. Responses have been international and national in nature. They can be distinguished between those approaches that tackle IUU a primarily a fisheries management issue and those that approach it as a form of transnational organised crime.

Within the fisheries management paradigm, there have been efforts to order to dis-incentivise opportunistic IUU fishing and address the unequal nature of laws governing waters and seas (such as the vast range of regulations pertaining to protected species, quotas, permissible tackle, catch documentation schemes, monitoring and control systems, tax laws, and port controls). This has occurred primarily under the auspices of the UN Food and Agriculture Organization (FAO), including through the 2009 FAO Agreement on Port State Measures to Prevent, Deter, and Eliminate IUU Fishing designed to close off the opportunities for IUU fishing vessels to land catches and obtain supplies 72

The United Nations drew up laws and regulations in the 1990s to combat IUU fishing, and in 2001, 110 nations endorsed the FAO’s International Plan of Action to Prevent, Deter, and Eliminate IUU fishing (IPOA-IUU)—the principal international instrument aimed at addressing the problem. Under the IPOA-IUU, signatory states were expected to develop Plans of Action by 2004, but only six nations met the deadline, and significant implementation challenges remain.

The Round Table of Sustainable Development at the Organization for Economic Cooperation and Development (OECD) established a High Seas Task Force in 2003, and the Rome Declaration on IUU fishing (2005) called on developed nations to provide financial and technical assistance to third world countries to help them develop Monitoring, Control and Surveillance programmes 73 All of these initiatives have contributed to harmonization and regulatory cooperation in the fight against IUU fishing.74

Regional Fisheries Management Organisations (RFMOs) have also been established to provide stronger international frameworks of regulations specific to certain areas, alongside attempts to improve joint-surveillance, detection likelihood, and technical information-sharing.74 RFMOs can play advisory or legally binding managerial roles. RFMOs integrate management across a number of countries, and are thus advantageous for managing highly mobile species, because their agreements and actions apply to all member states.74 For example, the Sub-Regional Fisheries Commission in West Africa was formed to coordinate surveillance and information sharing across the region, and in 2001, an international MCS network was established that included the EU, the U.S. and Japan, along with forty other members. The West African initiative has enjoyed some success, including the apprehension of several IUU fishing vessels, but the network is voluntary, informal, lacks resources, and has no full-time staff.

Similar initiatives are visible at national levels. These tend to focus on making IUU more expensive through reduced revenue and increased operating costs, as well as ensuring a strong regulatory structure.75. Total Allowable Catch (TAC) limits and Marine Protected Areas have been established by some states.76. Increasing fines may serve to dis-incentivise IUU fishers and also make such activities economically untenable 77. There is some evidence to suggest that such measures have been successful where implemented. Even so, it is also recognised that in many cases sentences and fines are not particularly severe for IUU fishing because courts are hesitant to impose sanctions that may seem excessive in comparison to other serious crimes.18. At the same time, fisheries enforcement agencies often struggle from a lack of funding and resources 73

De Coning & Witbooi argue that the fisheries management approach ‘misdiagnoses’ the problem and means that policy has been hampered as a result.78 Others have suggested that fisheries management is best considered less as an issue of regulation (and the gaps in this), but more as a problem of weak governance more generally, comprising issues of fisheries management, governmental policy and law enforcement.26 Measures targeting fishing subsidies, marine insurance, oil bunkering activities, flag-hopping and connections with organized crime in related sectors offer potential solutions.79

Treating IUU fishing as a form of transnational organised crime opens up other responses aligned towards criminal investigation and law enforcement. 80 However, such an approach creates new demands centred on coordination and criminal intelligence gathering. 53 Enforcement requires effective monitoring, control and surveillance of maritime spaces in order to gain sufficient information on the scale and patterns criminal activities on which to act upon.74 These can be particular challenges for countries in the Global South, which may lack resources for high levels of surveillance and effective systems for analysis, interdiction and imposing penalties81 Some have suggested that technologies such as drones or satellite imagery may help address these gaps,82 though such methods make capacity demands of their own. Expanding fisheries enforcement powers beyond fisheries authorities to (often better-funded) law enforcement institutions such as customs, immigration, police forces and the navy is also a way of increasing capacity in these areas.83

Ghanaian Navy boarding team departs the Ghanaian Navy vessel, GNS Blika, during an illegal fishing scenario by United States of Navy

Law enforcement approaches expand the repertoire of anti-IUU fishing measures. They create the possibility of investigations rather than simply inspections, as well as joint intelligence gathering activities between agencies. 84 They can realign the focus of such work from the management of vessels to actively targeting the individuals and organisations who are the most persistent offenders.78 They provide greater opportunities to tackle linked and facilitating crimes such as corruption, and offer the potential for increased international cooperation, information sharing and intelligence analysis between agencies who may already have experience of working together to combat other forms of maritime crime. The FAO has called for supplementing fisheries management approaches with more robust law enforcement strategies. 85

A final national measure, utilised in cases where IUU fishing takes place in specific locales and at smaller scales, is to engage local communities through participatory responses.86 Participatory responses can take the form of customary marine tenure, rights-based management, and co-management, as well as information campaigns, which aim to bring local communities into the IUU response and given them a stake in its outcomes.87.

Non-governmental organisations (NGOs) can also play a role in responding to IUU fishing. NGOs such as Greenpeace for example assist in monitoring, control and surveillance in countries where the government is unable to fulfil this role fully. Other organisations collect and analyse data on IUU fishing. NGOs have also been prevalent in awareness campaigns in local communities, as well as involved in capacity-building.

List of References

  1. FAO 2001; FAO 2002
  2. Rose & Tsamenyi 2013
  3. UNGA 2008
  4. African Union 2018
  5. EU 2008
  6. ASEAN & SEAFDEC 2021
  7. Financial Times 2022
  8. US National Intelligence Council 2016
  9. Her Majesty’s Government 2014
  10. Australian Government 2005
  11. DeSombre 2019; Chapsos & Hamilton 2019; de Coning & Witbooi 2015; Liddick 2014
  12. US National Intelligence Council 2016; Chapsos & Hamilton; Liddick 2014
  13. Battista et al. 2018; Le Gallic & Cox 2006; OECD 2005; Charles et al. 1999; Becker 1968; Schmidt 2005
  14. Chapsos & Hamilton 2019; Liddick 2014; Le Gallic & Cox 2006; Schmidt 2005; Marine Resources Assesment Group 2005
  15. Marine Resources Assesment Group 2005; See also: Liddick 2014; Agnew and Barnes 2004; Agnew et al. 2009; Upton & Vitalis 2003
  16. Chapsos & Hamilton 2019; Agnew and Barnes 2004
  17. Battista et al. 2018; Osterblom 2011
  18. Battista et al. 2018
  19. See, for example: Nielsen & Mathiesen 2003; Hauck 2007; 2008; 2011
  20. See, for example: OECD 2005; Liddick 2014; Environmental Justice Foundation 2005; Petrossian 2015
  21. Battista et al. 2018; Hatcher et al. 2000
  22. Osterblom 2011
  23. Liddick 2014
  24. Vrancken et al. 2019
  25. Cisneros-Montemayor et al. 2022
  26. Okafor-Yarwood et al. 2022; Song et al. 2020
  27. Chapsos & Hamilton 2019; Agnew and Barnes 2004; de Coning & Witbooi 2015; Liddick 2014; Haenlein 2017; Belhabib & Le Billon 2020
  28. UNODC 2011
  29. Chapsos & Hamilton 2019; UNODC 2011; Agnew and Barnes 2004; de Coning & Witbooi 2015; Liddick 2014; Hauck & Sweijd 1999; NAFIG & Interpol 2017
  30. Hauck 2007
  31. FAO n.d.
  32. UNODC 2011; UNODC n.d.; UNODC n.d.
  33. Interpol 2018
  34. Chapsos & Hamilton 2019; Osterblom 2011; Pomeroy et al. 2016; Muawanah et al. 2012; Bueger et al. 2015; Beseng & Malcolm 2021; DeSombre 2019
  35. Nellemann et al. 2014
  36. DeSombre 2019
  37. Glaser et al. 2019
  38. UNODC 2011; FAO 2014
  39. Bergseth et al. 2015
  40. Environmental Justice Foundation 2005
  41. Pew n.d.
  42. Pauly & Zeller 2016; Belhabib & Le Billon 2020
  43. Agnew et al. 2009
  44. Agnew et al. 2009; Environmental Justice Foundation 2012
  45. Global Initiative 2019
  46. Spyglass n.d.; Global Fishing Watch n.d.; Pew 2015
  47. Dunn et al. 2018; Boerder et al. 2018; Galaz et al. 2018; Ford et al. 2018
  48. Dunn et al. 2018; Le Gallic & Cox 2006; Griggs & Lugten 2007
  49. Ford et al. 2018
  50. Intchama et al. 2018
  51. UNEP 2014
  52. Glaser et al. 2019; Chapsos & Hamilton 2019; Worm et al. 2009
  53. Chapsos & Hamilton 2019
  54. Intchama et al. 2018; Okafor-Yarwood et al. 2022; Okafor-Yarwood 2020
  55. Glaser et al. 2019; Okafor-Yarwood 2020
  56. de Montclos 2018; Denton& Harris 2018;Okafor-Yarwood 2020
  57. Glaser et al. 2019; Sumaila & Bawumia 2014
  58. Glaser et al. 2019; Sumaila & Bawumia 2014; Okafor-Yarwood 2020; Lehr & Lehmann 2006
  60. ILO n.d.; Mackay 2020; Selig et al. 2022; IOM 2016[/ef_note] Individuals can also be harmed because the equipment or methods used may be unsafe.59Katikiro & Mahenge 2016; Guard & Masaiganah 1997
  61. Konar et al. 2019; Liddick 2014
  62. Daniels et al. 2016
  63. Kituyi & Thomson 2018
  64. Polacheck 2012; Ye & Valbo-Jorgensen 2012; Davidson et al. 2015
  65. Jennings & Lock 1996; Hiddink et al. 2020; Althaus et al. 2009; Lewison et al. 2004; Yatsu et al. 2002; Davies et al. 2009
  66. Altieri et al. 2017
  67. Katikiro & Mahenge 2016; Guard & Masaiganah 1997; Mak et al. 2005; Fox & Caldwell 2006
  68. Sumaila & Keith 2006;Doumbouya et al. 2017
  69. Mackay et al. 2020; Belhabib et al. 2020
  70. Bondaroff 2015; Somiah 2021; Warchol & Harrington 2016
  71. ILO n.d.; Mackay 2020; Selig et al. 2022; IOM 2016[/ef_note] In contexts such as the Somali example discussed above, fishers can be well placed to turn to other criminal activities such as piracy, because they have access to vessels from which to stage attacks and experience of local waters.

    Finally, IUU fishers commonly rely with other illegal practices to facilitate their activities, including corruption, document fraud, transhipment, bunkering and money laundering.59Tsamenyi & Hanich 2012; Martini 2013; Telesetsky 2014; Standing 2008

  72. FAO 2009
  73. Palma et al. 2010
  74. Arias & Pressey 2016
  75. High Seas Task Force 2006; Sumaila et al. 2006
  76. Grimm et al. 2012; Jennings 2009
  77. van As & Snijman 2019
  78. de Coning & Witbooi 2015
  79. Cisneros-Montemayor et al. 2022; Miller et al. 2016; Ford et al. 2018; Miller & Sumaila 2014
  80. High Seas Task Force 2006; Sumaila et al. 2006; Hauck 2008
  81. Hauck & Kroese 2006; Sumaila & Keith 2006;Doumbouya et al. 2017
  82. Miller 2010; Toonen & Bush 2020; Longepe et al. 2018
  83. Cabral et al. 2018
  84. Vrancken et al. 2019; van As & Snijman 2019
  85. FAO 2014
  86. Lestari et al. 2019
  87. Pita et al. 2010; Mikalsen & Jentoft 2001; Symes & Philippson 2009