What is the connection between IUU fishing and forced labor?

IUU fishing and forced labor are closely linked because both thrive in the same conditions: low oversight, remote locations, and weak enforcement. Vessels that operate outside legal frameworks often rely on forced or trafficked labor to cut costs and avoid accountability. For seafood companies, this means the two risks rarely travel alone. This article walks through how the connection works, where the risks are highest, and what you can do to address both at once.

Why do IUU fishing operations rely on forced labor?

IUU fishing operations often rely on forced labor because it dramatically reduces operating costs while keeping workers in conditions where they cannot report abuse or illegal activity. When a vessel is already operating outside the law, the barriers to exploiting crew members are much lower. Forced labor and IUU fishing reinforce each other: one enables the other to persist.

Legal fishing operations carry significant costs. Vessels must comply with quotas, maintain certifications, pay fair wages, and submit to inspections. IUU operators skip most of these expenses. To stay competitive, some of these operators use trafficked or coerced workers who have no realistic way to leave the vessel or report their situation. Workers may be recruited through deceptive job offers, have their documents confiscated at sea, or face debt bondage arrangements that make it nearly impossible to walk away.

There is also a silencing effect. Crew members on vessels engaged in illegal fishing may witness unreported catches, falsified logbooks, or unlicensed gear. Keeping workers isolated and dependent makes it far less likely that any of this is reported to authorities. The result is a system where labor exploitation and illegal fishing protect each other from scrutiny.

What are the warning signs of forced labor on fishing vessels?

Warning signs of forced labor on fishing vessels include irregular vessel movements, crew members who cannot communicate freely, missing or withheld identity documents, and vessels that avoid port inspections or spend unusually long periods at sea. These indicators often appear in combination, and no single factor is conclusive on its own.

Some of the most commonly identified risk indicators include:

Vessels that conduct frequent at-sea transshipments, transferring fish and crew between vessels without returning to port
Crew members who are unable to speak with inspectors privately or who appear coached in their responses
Workers whose wages are withheld, paid to a third party, or subject to unexplained deductions
Recruitment through intermediaries in high-risk labor-sending countries with little documented contract information
Vessels that disable or manipulate their AIS transponders to avoid detection
Extremely long fishing trips with no documented port calls

Satellite tracking data can reveal behavioral patterns that flag potential problems before any physical inspection takes place. A vessel that regularly goes dark on AIS, drifts in remote areas for extended periods, or meets other vessels in the open ocean without documented transshipment authorization may warrant closer scrutiny.

How does IUU catch enter legitimate supply chains?

IUU catch enters legitimate supply chains primarily through transshipment at sea, falsified documentation, and mixing with legally caught fish at processing facilities. Once IUU fish is blended into a larger batch and assigned valid paperwork, it becomes very difficult to distinguish it from compliant product downstream.

The process often starts at sea. A vessel fishing illegally may transfer its catch to a refrigerated carrier vessel, which then delivers it to a port where it enters the processing chain with documentation that does not accurately reflect its origin. In some cases, catch certificates are forged or obtained fraudulently. In others, processing facilities may knowingly or unknowingly accept mixed loads without verifying the source of every component.

From there, the fish moves through the same channels as any other product: processors, traders, importers, and eventually retailers. By the time it reaches a brand or retailer, the original origin is buried under layers of documentation that appear legitimate on the surface. This is why post-processing traceability systems often fail to catch the problem. If first-mile data is not captured at the point of catch, the window for detecting IUU entry closes very quickly.

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Which regions and fisheries are most at risk?

The regions and fisheries most at risk for both IUU fishing and forced labor include the Western and Central Pacific Ocean, the Indian Ocean, Southeast Asian fishing fleets, and distant-water fishing operations flagged by nations with limited monitoring capacity. These areas combine high fishing pressure, limited enforcement infrastructure, and documented labor recruitment vulnerabilities.

The Western and Central Pacific is the world’s largest tuna fishery by volume, and while it has robust RFMO oversight through the WCPFC, its sheer scale and the involvement of diverse flag states create enforcement gaps. The Indian Ocean and parts of the South Atlantic also present elevated risk, particularly for longline vessels targeting tuna and swordfish in areas far from port.

Southeast Asian supply chains, particularly those originating in Thailand, Indonesia, and the Philippines, have faced documented scrutiny over labor recruitment practices and the use of broker networks that may expose workers to debt bondage. Distant-water fleets operating under flags of convenience, where the flag state has limited capacity or motivation to enforce labor laws, carry some of the highest combined IUU and forced labor risk.

Small-scale and artisanal fisheries in certain coastal regions may also carry risk, particularly where catch is aggregated informally before entering export supply chains without batch-level documentation.

What regulations require companies to address IUU and labor risks?

Several major regulatory frameworks now require seafood companies to identify and address both IUU fishing and forced labor risks. These include the EU’s IUU Regulation and its CATCH certificate system, the US Seafood Import Monitoring Program (SIMP), the EU Corporate Sustainability Due Diligence Directive (CSDDD), and US import restrictions under the Tariff Act that prohibit goods made with forced labor.

In the EU, the IUU Regulation has been in force since 2010 and requires catch certificates for all imported seafood, validated by the flag state. The EU is also advancing the Corporate Sustainability Due Diligence Directive, which in 2026 is placing due diligence obligations on large companies that require them to identify and address human rights risks, including forced labor, throughout their supply chains.

In the US, SIMP requires importers of certain seafood species, including tuna, to report harvest and chain of custody data at the point of entry. Separately, Section 307 of the Tariff Act of 1930 prohibits the importation of goods produced with forced labor, and US Customs and Border Protection has issued Withhold Release Orders against specific seafood suppliers based on forced labor findings.

Some jurisdictions, such as the UK and Australia, have also introduced modern slavery reporting requirements that apply to large companies and their supply chains. The regulatory direction across these frameworks is consistent: companies are expected to know where their seafood comes from and to have documented evidence that it was produced legally and ethically.

How can seafood companies detect and prevent both risks simultaneously?

Seafood companies can detect and prevent both IUU fishing and forced labor risks simultaneously by implementing first-mile traceability systems that capture vessel activity data from the point of catch, cross-reference it against regulatory and certification databases, and integrate social compliance evidence directly into each batch record. Addressing both risks together is more effective than treating them as separate compliance problems.

The most practical starting point is vessel-level data. Satellite VMS and AIS tracking can reveal behavioral patterns associated with both illegal fishing and labor risk, such as AIS disabling, unusual transshipment activity, or extended time at sea without port calls. When this data is captured in real time and linked to specific catch batches, it creates an auditable record that supports both regulatory compliance and labor due diligence.

From there, companies can layer in social compliance evidence. Certifications such as the FISH Standard for Crews, SMETA/SEDEX audits, and Fair Trade USA assessments provide documented evidence of labor conditions. When these are linked to specific Raw Material IDs rather than stored separately, they become part of the verifiable product record rather than a parallel paper trail.

Automated checks against IUU blacklists, RFMO vessel registries, and port state measures databases help flag vessels with compliance issues before their catch enters the supply chain. The key is integration: when vessel tracking, catch documentation, labor certifications, and regulatory checks all feed into a single batch record, companies can respond to risk signals quickly and produce audit-ready evidence without manual assembly.

SmarTuna’s digital traceability platform is built around exactly this approach, combining satellite tracking, automated database verification, and social compliance integration to help seafood companies address IUU and forced labor risk from the first mile forward.

Frequently Asked Questions

How do I get started with first-mile traceability if my supply chain already has multiple intermediaries in place?

Start by mapping your supply chain back to the vessel level, even if you currently rely on processors or traders as your first point of contact. Request vessel identification data (IMO numbers, flag state, and fishing licenses) from your suppliers and cross-reference these against publicly available RFMO vessel registries and IUU blacklists. From there, you can identify which vessels or origins carry the highest combined IUU and labor risk and prioritize those for deeper traceability investment. A phased approach — starting with your highest-volume or highest-risk species — is more realistic than trying to overhaul the entire supply chain at once.

What's the difference between AIS and VMS data, and which one should seafood companies be using?

AIS (Automatic Identification System) is a publicly broadcast signal that any vessel over a certain size is required to transmit, making it accessible through commercial maritime data providers. VMS (Vessel Monitoring System) is a government-mandated, closed system used by fisheries authorities to track licensed fishing vessels, and access is typically restricted to regulators. For seafood companies, AIS data is the more practical tool for supply chain monitoring since it is commercially available and can be analyzed for risk indicators such as AIS disabling, unusual transshipment patterns, and extended time at sea. VMS data, where accessible through regulatory partnerships or certification bodies, provides an additional layer of verification.

Can a vessel hold a valid fishing certification and still be involved in forced labor?

Yes, and this is one of the most important misconceptions to address. Fishery certifications such as MSC focus primarily on stock sustainability and environmental practices, not labor conditions. A vessel can be certified as sustainably fishing while still having serious labor rights violations on board. This is why social compliance certifications — such as the FISH Standard for Crews or SMETA audits — need to be evaluated separately and linked to specific vessel records rather than assumed to be covered by fishery-level sustainability credentials. No single certification covers both dimensions comprehensively.

What should a seafood company do if a supplier cannot provide vessel-level documentation?

Treat the absence of vessel-level documentation as a risk signal in itself, not simply a paperwork gap. Start by formally requesting the information in writing and giving the supplier a defined timeframe to respond — this creates an auditable record of your due diligence effort. If documentation cannot be provided, consider whether the volume or origin justifies sourcing from an alternative supplier who can meet traceability requirements. Under frameworks like the EU CSDDD and US SIMP, demonstrating that you actively sought and acted on supply chain information is part of what constitutes adequate due diligence.

Are small and mid-sized seafood importers subject to the same forced labor and IUU regulations as large companies?

For IUU regulations, size generally does not determine compliance obligations — US SIMP and EU catch certificate requirements apply to importers regardless of company size, as long as they are importing covered species. For human rights due diligence frameworks like the EU CSDDD, current thresholds focus on large companies, but smaller suppliers in those companies’ chains are increasingly expected to provide compliance evidence upstream. Proactively building traceability and labor documentation now positions smaller importers competitively as customer requirements tighten, and it reduces the risk of supply chain disruption from Withhold Release Orders or customs holds.

How often should seafood companies audit their vessel data and labor compliance records?

Static, point-in-time audits are increasingly insufficient given how quickly vessel ownership, flag state, and crew composition can change. Best practice is to combine periodic formal audits — typically annual for social compliance certifications — with continuous or near-real-time monitoring of vessel tracking data throughout the year. Automated alerts against updated IUU blacklists and RFMO registry changes are particularly valuable because a vessel’s compliance status can change between audit cycles. The goal is a living record that reflects current conditions, not a snapshot that may be outdated by the time it is reviewed.

What evidence should companies be able to produce if questioned by regulators or customers about their IUU and forced labor due diligence?

Companies should be able to produce a documented chain of custody from vessel to point of import, including vessel identifiers, flag state licenses, catch certificates, and any applicable RFMO authorization. On the labor side, evidence should include social compliance audit reports or certifications linked to specific vessels or processing facilities, records of any corrective actions taken, and documentation of how recruitment practices were assessed for debt bondage or deceptive contracting risks. Critically, this evidence should be organized by batch or Raw Material ID so it can be retrieved quickly and linked to specific product — not stored as a general folder of supplier documents that cannot be tied to individual shipments.

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