How Illegal Fish Becomes Legal Fish

By Gareth Johnstone and Duncan Copeland

Every day, consumers around the world buy seafood believing it was legally caught and responsibly sourced.

In many cases, that confidence is justified. Governments, seafood companies, certification schemes and civil society organisations have invested heavily in traceability systems designed to improve transparency and accountability across seafood supply chains.

Yet, when an estimated 1 in every 5 fish is caught illegally, there is a question that receives far less attention than it deserves. How does an illegally caught fish become a legal fish in the market? The answer is often surprisingly simple: it is laundered.

Much like money laundering disguises the origin of illicit funds, fish laundering disguises the origin of illegally caught fish. Through a combination of mixing catches, transshipment, vessel identity fraud, mislabelling and falsified documentation, illegal fish can enter legitimate supply chains and eventually reach consumers, often without detection.

What makes this challenge particularly difficult is that much of the laundering takes place before the fish ever reaches port. By the time seafood enters a traceability system, the information it contains may already have been compromised.

This uncomfortable reality highlights an important limitation in current discussions about seafood traceability. Traceability systems are exceptionally useful for tracking products through supply chains. However, they cannot independently verify whether the information entered into those systems was accurate in the first place.

If illegal fish has already been mixed with legal catch at sea, transferred between vessels, relabelled, or supported by fraudulent documentation, even sophisticated traceability systems may simply be tracing bad information.

The challenge is not that traceability has failed. The challenge is that traceability alone cannot solve the problem.

The fight against illegal, unreported and unregulated (IUU) fishing therefore starts much earlier than many people realise. It starts on the water, where fishing activity takes place, where catches are transferred, where vessels interact, and where decisions are made about what information will follow seafood through the rest of the supply chain.

One of the most striking examples is the growing fishmeal industry.

Around the world, millions of tonnes of fish are reduced into fishmeal and fish oil each year. These products are important ingredients in aquaculture feeds and play a significant role in supporting global seafood production. Yet once fish are processed into fishmeal, species identity and catch origin become extremely difficult to verify.

If illegally caught fish enters this process, it can become almost impossible to determine its origin. The fish does not disappear. Instead, it re-enters global food systems in another form.

This raises an important question for all of us.

If we care about the sustainability and legality of the seafood we eat, should we not also care about the legality and sustainability of the fish used to feed it?

This question is particularly relevant for countries such as Norway.

Norway has established itself as a global leader in ocean governance, sustainable seafood production and responsible aquaculture. Norwegian salmon is exported around the world and increasingly scrutinised by consumers, retailers and regulators who want confidence in the environmental and social credentials of seafood products.

Yet the credibility of seafood supply chains does not begin at the processing plant or supermarket shelf. It begins much earlier, with the fish that enters those supply chains and, in some cases, with the fish used to produce aquaculture feed.

As governments and companies strengthen due diligence requirements, sustainability reporting and supply chain transparency obligations, greater attention will need to be paid to where and how legality is established.

The solution is not less traceability. The solution is better verification. This means stronger vessel monitoring systems, wider adoption of electronic monitoring, improved document verification, risk-based port inspections, more effective use of intelligence, and stronger cooperation between flag States, coastal States, port States and market States.

It also means recognising that fish laundering is fundamentally a transnational problem.

Illegal operators exploit the gaps between jurisdictions. Fish may be caught in one country's waters, transferred at sea, landed in another country, processed elsewhere and consumed in a completely different market. No single authority sees the whole picture. That is why regional cooperation is becoming increasingly important.

Across Africa, regional fisheries organisations and monitoring, control and surveillance centres are working together to share intelligence, coordinate responses and close the gaps that illegal operators exploit. By connecting enforcement systems across jurisdictions, countries can make it far harder for vessels involved in illegal fishing and fish laundering to move undetected between regions.

The objective is straightforward: ensure that vessels denied access in one jurisdiction cannot simply reappear somewhere else under a different identity, a different licence or a different set of documents.

This World Ocean's Day, it is worth reflecting on how much progress has been made in improving seafood traceability over the past decade.

But it is also worth recognising that traceability is only one part of the solution.

We need to know not only where fish has travelled. We need confidence that it was legally caught in the first place.

Because the journey from sea to plate begins long before fish reaches a port, and if we want truly transparent seafood supply chains, that is where our attention must start.

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This article accompanies the release of TMT's Spotlight report, "Laundering Illegally Caught Fish at Sea". The publication is dedicated to the memory of Alistair McDonnell, whose commitment to fisheries monitoring, control and surveillance helped shine a light on many of the issues discussed here.

Photo credits:

Top image, Tracey Jennings / Ocean Image Bank,

Second image, Duncan Copeland, TMT