APG Issues Paper - Illicit financial flows generated from illegal fishing - November 2023

28 November 2023

In October 2021, the APG commenced a project on illicit financial flows arising from illegal, unreported and unregulated (IUU) fishing.  This Issues Paper is the final output from that project, and it sets out factors that may be undermining an effective Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) response to proceeds from illegal fishing. The project also produced a focus chapter on illicit proceeds related to IUU Fishing in the 2022 APG Yearly Typologies Report.

The paper notes that illegal fishing is increasingly conducted by transnational crime groups, and is valued at an estimated USD 10-23.5 billion per year, undermining the legitimate fishing industry and posing a threat to national and regional security.  Adding concern and complexity to this picture, illegal fishing intersects with multiple other crime types such as corruption, fraud, trade-based money laundering, human and drug trafficking, slavery and labour exploitation, arms trafficking, tax evasion, document and customs fraud, and wildlife crime.

Commonly characterised as a regulatory or ‘fisheries’ issue, the financial dimensions of illegal fishing pose a complex challenge for law enforcement due to a number of factors including: 1) a lack of understanding of the transnational nature of this crime; 2) weak international coordination on illicit proceeds of illegal fishing; and 3) absence of parallel financial investigations.  Preliminary research reveals that jurisdictions generate a limited amount of financial intelligence and information on the nature and dynamics of illicit financial flows associated with illegal fishing.  This begins with low levels of understanding across governments on ML/TF risks posed by illegal fishing.  Opportunities exist to build knowledge, expertise and understanding of the typologies unique to illegal fishing in order to effectively conduct relevant financial investigations. Re-characterising illegal fishing as a predicate crime for money laundering could more effectively trigger effective AML/CFT responses to tackling this complex transnational threat.