Illegal, unreported, and unregulated fishing (IUU) represents a significant threat to ecosystem conservation, and equally to a State’s sovereign ability to protect its territory. This paper compares the responses to IUU fishing in West Africa, and Indonesia. Though far apart and governed very differently, Indonesia and the West African region face similar obstacles in addressing IUU fishing, including the influence of powerful developed States, a lack of accountability in transshipments, corruption and limited transparency, and challenges in financing for Monitoring, Control, and Surveillance (MCS) systems. They can equally benefit from common solutions including market-based mechanisms like tariffs on countries exploiting flags of convenience, and better labelling practices on catch. IUU is not only a manifestation of profit-driven interests but also a derivative of weak governance systems. Thus, curtailing it will also require more robust standards on market access and restrictions on transshipments, sufficient funding for capacity building, and a strong political will to create effective regulatory bodies.
Illegal, Unreported, and Unregulated (IUU) fishing represents a significant challenge to fisheries’ resiliency, biodiversity, food security, and economic development. This problem persists because there is high economic incentive for operators to compete, and there is insufficient regulation to stop it. It poses a serious threat to ecosystem conservation and challenges the sovereign ability of States to control their own territories.
The myriad of fisheries exploitation practices are covered under the umbrella term ‘IUU’, but more specifically include: ‘illegal fishing’, when commercial boats operate in violation of fishery laws, such as without a license or in a manner inconsistent with the license they have; ‘unreported fishing’, where operators inaccurately or altogether fail to report their catches to national or regional authorities; and, ‘unregulated fishing’, which is conducted by either vessels with no nationality or those using a ‘Flag of Convenience’ not part of a regional organization, or where there is a lack of sufficient information about the resource being fished.1
From a policy and diplomacy standpoint, this issue is particularly difficult to manage because there is no supranational or regional authority with the mandate to ensure universal application and adequate enforcement of fishing standards. Under the United Nations Convention on the Law of the Sea (UNCLOS), all States enjoy freedom of movement within Exclusive Economic Zones (EEZs), but only the coastal State can exercise sovereign rights over the exploitation and conservation of the resources below the surface of the water. 2 They are responsible for resources in their own EEZs and can also participate in Regional Fisheries Management Organizations (RFMOs) to ensure the sustainable use and conservation of species on the High Seas. Ultimately, while UNCLOS manages maritime behavior and transactions between States, fisheries regulation happens at the State and regional levels. Thus, practical management of IUU fishing falls to a combination of RFMOs, other regional governance organizations, and domestic fisheries and law enforcement departments.
This global problem is particularly acute for developing countries where local communities are more directly reliant on subsistence fishing and there is less financing for Monitoring, Control, and Surveillance (MCS) systems. This is complicated by the fact that developing States with particularly biodiverse coastlines are most at risk for IUU. A country’s risk of IUU fishing is “positively related to the number of commercially significant species found within its territorial waters...”.3 It is thus unsurprising that IUU fishing remains a significant challenge to many coastal developing States (and regions).
This paper compares the impacts, governance challenges, and responses to IUU fishing in Indonesia and West Africa. This State and region, respectively, face similar management challenges but contrasting governance circumstances. They have extensive coastlines, exceptionally high amounts of IUU fishing, very productive ecosystems, and to some extent the political will to resolve the issue. However, they also lack the means to do so alone. Geographically, both have large maritime areas to patrol, but Indonesia is one State with a massive array of over 17,000 islands, while West Africa is a collection of independent States which share one very large, continuous coastline and maritime economic zone. Though Indonesia’s territory is diffuse, it operates as one unified State under a central government (working with subnational authorities). In contrast, West Africa has a more continuous territory to patrol, but faces sovereignty challenges when trying to collectively operate. By examining these cases together and comparing the challenges they face, it is possible to identify operational solutions which are more universally applicable.
IUU is a particularly visible challenge in West Africa. West African countries lose over $1.3 billion in total revenues every year from IUU fishing.4 One half to one third of the total regional catch is obtained through IUU.5 While regional in scope, the problem is particularly acute in Senegal, Ghana, Sierra Leone, Liberia and Mauritania.6 The main problematic IUU practices in West Africa involve activity of unlicensed foreign vessels, fishing in prohibited areas –i.e. too close to shore– or with illegal methods –such as illegal nets.7
In West Africa, transshipments and Flags of Convenience (FOCs) enable IUU fishing. Transshipments involve the use of large refrigerated commercial ‘reefer’ vessels which receive, process, and freeze fish directly at sea before bringing them to port. Though legal, the practice is frequently manipulated for IUU fishing. Reefers are used for 16% of West African exports, and of the 35 operating off the coast in 2013, most operated under FOCs from Vanuatu, where restrictions are low, and punition is weak.8 IUU vessels can use reefers to bring their illegal catch for processing at sea. There, fish are mixed with legal catch from other vessels before arriving at port, making it nearly impossible to separate out legal from illegal catch.9 Use of these vessels enables operators to evade port State inspection measures, as a loophole in EU law exempts refrigerated container ships from inspections at EU ports.10 In practice, this means that IUU fishermen can load their illegal catch at sea and it is then transported directly to Europe without entering West African ports for inspection. There are a few hubs for transshipment off the coast of West Africa, including near Guinea and Guinea Bissau, as well as in the Gulf of Guinea near Ghana, Togo and Benin.11 This is an issue for neighboring States, as transshipment leads to a significant loss of revenue for receiving ports along the West African coast.
FOCs are also used to circumvent restrictions. In many cases registration for these flags is cheap and easy to obtain. Flag states with low regulations ignore international law obligations or fail to enforce local regulations on vessels under their jurisdiction operating in foreign territories. This practice weakens the rule of law and challenges the enforcement power of local authorities.
These practices cause severe impacts on local populations. In West Africa, the fisheries industry accounts for 20% of primary sector employment; the industry provides revenue to communities which might otherwise be reliant on subsistence fishing, enabling them to also purchase more expensive food goods. Decreased intake in port cities impacts the overall GDP, regional development, and individual economic resiliency.12 While most artisanal fishermen are men, the vast majority of workers in processing plants are women. Not only is their livelihood tied to the level of intake in port cities, but also criminal activities associated with IUU fishing often target women and other vulnerable populations. In West Africa –and Southeast Asia– de facto slavery and forced labor including exploitation of women and children on boats and at the ports is a serious issue.13 The region also struggles with human trafficking associated with these activities.
II. Governance Challenges
The only RFMO present in West Africa is the International Commission for the Conservation of Atlantic Tunas (ICCAT), which monitors tuna stocks, as well as over 30 different species of concern in the region. As such, national governments are the main mechanisms for control of IUU fishing in the region. These structures are only as effective as the State’s capacity to monitor activities in their territory. In West Africa, implementation capacity is often weak, and many States struggle with government corruption, a lack of transparency, and low enforcement including limited revenues for patrolling and follow-through on punishments. But these States are also limited by size. Fishing agreements between States can be negotiated at the bilateral or multilateral level; between a host government and an intergovernmental organization like the EU, between individual States, a host country and a flag State government, or a company and a host State. Yet when individual West African States negotiate these agreements with larger entities like the EU or China, they operate from a much weaker position. As individuals, their EEZs are limited and if they compete with one another, the parties they negotiate with can play them off one another or threaten to move their business elsewhere. There is very little transparency in these negotiations, which complicates enforcement and limits accountability.14
This individual versus collective approach has enforcement consequences as well. Without a global register of high seas vessels, there is little information on deep sea catches entering their ports. Even if States establish effective monitoring of vessels in their EEZ, if they fail to share information about illegally operating vessels it is relatively easy for operators to relocate to the next EEZ. Some States have tried to resolve this problem by passing similar laws. Senegal and Cote d’Ivoire joined forces to ban transshipments in their territory.15 But without a contiguous restriction zone (there are four other countries with EEZs between them) and greater cooperation from their neighbors, reefers can reestablish in nearby EEZs (as they have in the Gulf of Guinea for example).
Internal politics also plays a significant role in facilitating IUU fishing. Corruption is a major problem in the fisheries sector worldwide, and especially in this region. In Senegal, for example, high level government figures have been prosecuted for selling illegal permits to foreign operators for their personal gain.16 Some of these countries themselves also issue FOCs without monitoring the practices of their operators. In 2014, the EU issued a warning to Ghana for IUU fishing by vessels operating under their FOC.17 Ships with West African FOCs also are found to conduct IUU fishing elsewhere. Many ships use Liberian FOCs or commercial registries are registered to the country because it is known to not enforce regulations on ships bearing its FOC.18
Even when monitoring does exist, there is little agency towards enforcement. Though many West African States require observers onboard fishing vessels, they are paid by the operators themselves. Thus, there is little incentive to discover corruption on these boats.19 Equally, when exposed, fines are insufficient to disincentivize repeated behavior.2
The greatest IUU fishing threats in West Africa come from China and the EU. From 2000 to 2010, the EU only reported 29% of its total catch from West Africa, while China reported only 8%.21 The impacts of this underreporting are significant, as for instance West Africa provides 25% of Europe’s fish supply.22
The relationship between West African countries and China and the EU highlights the magnifying role that fisheries agreements and FOCs play in IUU fishing. In recent years, China has begun using ‘second generation agreements’, including vessel charters and transfer of fishing vessels to the FOC of a third country (in some cases another West African one).23 This means that Chinese IUU reports do not reflect the volume produced by these vessels under secondary agreements.
Inequalities in political and economic bargaining power have also enabled China and the EU to dominate domestic fleets in some West African countries via these secondary agreements. For instance, most of the Mauritanian industrial fleet are Chinese and Mauritanian joint ventures.24 Additionally, a large share of Senegal’s fishing fleet are reflagged EU vessels.25 Through this practice, IUU fishing is attributed to these ships rather than Chinese or EU enterprises. Additionally, these fleets pay domestic port and licensing fees rather than foreign ones, leading to lower revenues for the receiving country than if they were registered as foreign fleets.26
Foreign overfishing decreases food security and inhibits local poverty reduction. It leads to increased competition between West African fishermen, inhibiting cooperation and motivating IUU fishing from artisanal fishermen; in Senegal for instance, artisanal pirogues fish illegally in Mauritanian waters.27
A number of West African States have adopted robust Monitoring, Control, and Surveillance systems (MCS), but deploying these systems at the individual level does not always lead to impactful reductions in IUU fishing. Current MCS measures in the region only recovered $13 million out of $2.3 billion total losses in revenues.28 Funding for these systems is limited and effectiveness is tied directly to corruption levels. Research demonstrates that domestic crises can inhibit MCS enforcement. For example, the countries hit hardest by the Ebola crisis, Guinea and Sierra Leone, experienced the highest rates of IUU fishing in the region during that time period.29 However, Sierra Leone is consistently rated as having one of the strongest MCS systems in the region.30 This correlation is partially based on the fact that these States catch the most offenders and enforce the strongest charges for these crimes. In contrast, Senegal’s stricter legislation in 2015 has failed to produce expected reductions in IUU.31 Together, these outcomes point to the need for adequate funding and implementation structures. To produce real results from MCS measures to combat IUU fishing in West Africa it is imperative that these efforts are sufficiently funded, with adequate transparency measures to ensure follow-through.
Enforcement of MCS is most effective via a regional approach. However, ICCAT is the only regionally operating instrument on fisheries in the area. Both the majority of West African States, and foreign States with the highest rate of fishing in the region (including the EU and China) are ‘Contracting Parties’ to ICCAT.32 These States must follow the guidelines and restrictions established by the RFMO, including regional observer programs, and the policy that ICCAT species must be transferred for processing from transshipments to port.33 Yet ICCAT has limited capacity to curtail overall IUU fishing in West Africa. The RFMO only protects around 30 species, and its jurisdiction is limited to the high seas. While the organization can influence IUU fishing of these critical species on the coast via the ports in Contracting Parties, it has no control over practices within States’ EEZs.
To resolve this dearth of regional cooperation, States in the region have formed the West African Sub- Regional Fisheries Commission to coordinate surveillance and information sharing.34 They developed the ‘Surveillance Operations Coordinating Unit’ to coordinate joint patrols by air and sea, as well as protocols for when patrols in pursuit cross into another State’s territorial waters.35 Though this Commission successfully apprehended some IUU vessels, it was significantly underfunded and in practice began to represent an informal network based around rhetoric.36 Largely supported by international funding, it was forced to disband when its original financial backers including the World Bank ended their support, resulting in a significant increase in IUU after the program ended in 2013.37 Despite some cases of corruption, there is broad political will for renewed regional cooperation. Yet an absence of funding and limited data sharing remains a serious impediment.38
Indonesia experiences significant levels of IUU activity. Over 30% of IUU comes just from Indonesia, and the country loses over $2 billion per year in profits as a result.39 Foreign boats from across Asia, including Japan, Taiwan, South Korea, China and the Philippines come to Indonesia to fish there, and operators from these countries, as well as from Indonesia, also engage in significant levels of IUU fishing. The problem is most acute in the Straits of Malacca near Northern Sumatra, where illegal commercial trawlers intrude upon the 3-mile zone reserved for artisanal fishermen.40 IUU fishing in the region impedes conservation programs in this important, biodiverse zone, and makes it difficult to establish enforceable, necessary quotas for high value species such as tuna.
IUU fishing is a significant challenge for Indonesia as in West Africa, because a large portion of the population is heavily reliant on fish as a subsistence food source. IUU fishing impacts the economy of the region, the sustainability of local fisheries and individual species, and also challenges Indonesian sovereignty. Violent conflicts have erupted between commercial trawlers and local fishermen, and over the past 15 years over 200 people have died from these encounters.41 Beyond frequent incursions into areas reserved for traditional fishermen, the other main manifestation of IUU in Indonesia involves the incursion of foreign vessels into State territory without bilateral agreements between Indonesia and their flag state.42 Finally, transshipments resulting in unreported catch, and use of illegal fishing gear are also pervasive within Indonesia’s maritime territory.43
Indonesia also faces non-compliance within its own fleet, both domestically and abroad.44 Like many West African States, Indonesia is under international political pressure because of illegal fishing activities of its operators in other areas.45 However, while oftentimes vessels operating under a West African State flag do not actually originate from there (and as discussed above, e.g. from China, the EU or elsewhere), Indonesian vessels themselves have been found operating in RFMOs.46
II. Governance Challenges
Though Indonesia experiences significant issues with IUU fishing both in its EEZ from foreign vessels and abroad by its own fishing fleet, recent political developments demonstrate the impactful manifestations of a strong will towards enforcement. In contrast to West Africa, Indonesia avoids challenges associated with regional interstate collaboration because it is one State managing a diffuse territory. But this is no small feat; Indonesia has 4.8 million square kilometers of ocean territory spread across its 17,000 islands.47 Thus, even with political leadership dedicated to aggressive action, financing and implementation remain challenging. For example, commercial trawling has remained illegal in Indonesia since it was banned by presidential degree in 1980, but the law remains unenforced.48 In fact, recent anecdotal evidence from artisanal fisherman suggests trawling may be on the rise again.49 It is likely that this increase is related to connected to corruption of officials.50
Though Indonesia has ratified a number of international agreements important in combatting IUU such as UNCLOS, the UN Fish Stocks Agreement, and the 2001 FAO International Plan of Action for IUU (IPOA-IUU), its implementation efforts fall short of these standards.51 Indonesia is party to both the Indian Ocean Tuna Commission (IOTC) and the Western & Central Pacific Fisheries Committee (WCPFC). These RFMOs, which border the country’s EEZs on both sides, manage ‘tuna and tuna-like species’ and ‘highly migratory fish stocks’, respectively.52 53 The commissions have both MCS schemes and port-state measures to ensure compliance in party States. While these groups closely monitor IUU fishing of tuna and large migratory species on the high seas (and at the ports), their jurisdiction is restricted to enforcement of species protection in these areas. Thus, as in West African States, Indonesia’s membership in these RFMOs does not minimize IUU in their EEZ.
Domestic momentum towards MCS implementation shifted dramatically in 2014 when President Joko Widodo (‘Jokowi’) was elected. Hailed as a new democratic force, President Jokowi expressed a commitment to ‘protect Indonesian Sovereignty’ and crack down on IUU fishing.54 He appointed former entrepreneur Susi Pudjiastuti as fisheries minister.55 The popular minister has taken aggressive action to ensure follow-thru, by blowing up confiscated foreign vessels caught committing IUU fishing. Since October 2014, the ministry has blown up 317 ships, from Vietnam, the Philippines, Malaysia, and China.56 These ships are largely caught by a special maritime task force established by the fisheries ministry known as ‘Satgas 115’.57 This strategy is hugely popular in Indonesia, but volatile abroad.58
In addition to this more demonstrative enforcement measure, the Indonesian fisheries ministry relies heavily on surveillance to support these actions. The government has committed significant resources to ensure all Indonesian vessels are equipped with Vessel Monitoring Systems (VMS), in compliance with Article 18 of the UN Fish Stocks Agreement, and the requirements of the IPOA-IUU.59 The ministry also requires that all large commercial foreign-flagged vessels operating in Indonesian waters must have a transmitter as a condition of holding a fishing license.60 These systems enable monitoring of all vessels within Indonesia’s territorial waters and can be used to identify vessels acting in violation and bring IUU catch to port.61
In 2018, the fisheries minister began a partnership with Google to use Vessel Detection Systems (VDS) satellite data –known as Automatic Identification Systems (AIS)– to more effectively monitor IUU activity.62 This new strategy attempts to address VMS tampering, which is an inherent flaw in this system; because VMS are onboard their ships, operators can turn these systems off or use them to falsify their location in certain instances.63 VDS and VMS systems together enables the ministry to both externally detect vessels engaging in IUU fishing early on and continue to monitor their activities to ensure they are reprimanded. This system seems promising for improved enforcement, but as with other MCS measures requires funding and coordination to ensure effective execution.
At the international level, IUU activity perpetrated by operators using Indonesian or West African flags is difficult to address without direct action by national governments, or the existence of a high seas agreement to regulate their behavior. Until such an agreement is negotiated, IUU action outside of State jurisdiction is limited only by RFMOs.
When it comes to fighting IUU within their own territories, both Indonesia and West African States are guided by the FAO’s IPOA-IUU, which is the main international agreement addressing this problem. In 2009 the FAO passed the Agreement on Port State Measures to Prevent, Deter and Eliminate Illegal, Unreported and Unregulated Fishing (PSMA), which entered into force in 2016. This agreement is the main mechanism managing this problem at the local level and creates binding obligations for inspection of foreign vessels trying to enter another States port.64 It also allows for blocking of ships suspected of IUU fishing, and includes measures like trade restrictions, catch documentation, and vessel registration and licensing systems to ensure accountability.65 While port inspections are already standardized, problems arise due to a lack of universal information sharing, and enforcement to ensure vessels do not just move to another port in a neighboring State.66
The PSMA can provide an important shared framework for policy implementation moving forward, as Indonesia and a number of West African States including Senegal, Gambia, Ghana, Cabo Verde, Guinea, Mauritania, and Gabon are all party to it.67 These States may be across the world from one another, but they share key challenges when it comes to IUU: influence of powerful developed States, lack of accountability in transshipments, corruption and limited transparency, and challenges of financing for MCS mechanisms.
Because of these shared challenges with controlling IUU, as well as mutual cultural and economic value for ocean protection, certain solutions may be universally beneficial despite their differing political circumstances. Past impacts and efforts towards developing strong MCS indicate that West African States could benefit from the joint VMS-VDS approach similar to the one Indonesia is implementing. However, this remains inhibited by inadequate financing, and a need for coordination to ensure effective implementation. Renewed efforts towards collaboration must be supported by sufficient funding, as the West Africa’s prior regional project ended not due to lack of interest in collaboration but because of the end of funding for the project. EU policy actually requires allocation of funding for MCS in all of their bilateral fishing agreements, yet they often fail to follow through with this financial support. The OECD’s Rome Declaration on IUU fishing called on developed countries specifically to provide funding for MCS measures. Better EU financial support could ensure VMS measures are successfully implemented.
Market-based mechanisms can also provide effective monitoring in both case studies, including tariffs on countries exploiting flags of convenience, and better labelling practices on catch.68 Universal standards on market access, including a global record of fishing vessels or shared use of ‘blacklists’ beyond the sub-regional level could increase cooperation and support among developing States. Finally, restrictions on refrigerated transport and container vessels not only while at sea, but also in the ports of developed countries could help close the legal loophole that makes transshipment a hub of IUU activity.
Ultimately, IUU fishing is not a question of individual actors subverting the system, but of complex power dynamics. The States discussed in this paper are both victims of IUU fishing and perpetrators of it both at home and abroad. They are both taking aggressive action to put a stop to it and subverting this action via corruption and underhanded dealings. Yet on the other hand, powerful developed States often lament the pervasiveness of IUU in diplomatic fora and produce legislation to stop it, yet support long- distance fleets using the FOC system to perpetrate IUU abroad.
At the international level, commitments to support capacity building to implement global policing of commercial fisheries are imperative. Support from developed States, in both funding for MCS and in improving their own accountability can ensure that Indonesia, and the countries in West Africa have the means to implement and enforce their own policies. These States in turn can benefit from greater implementation of new MCS technologies, accountability within their own government structures, and follow-through on policy action to ensure enforcement measures come to fruition.
Fundamentally, IUU is not only a manifestation of profit-driven interests but also a derivative of weak governance systems. Because of this, curtailing it depends on promoting sustainable fishing, producing the political will to create effective regulatory bodies, and ensuring adequate funding to implement policies.
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Belhabib D, Sumaila UR, Lam VWY, Zeller D, Le Billon P, Abou Kane E, et al. (2015) Euros vs. Yuan: Comparing European and Chinese Fishing Access in West Africa. PLoS ONE 10(3).
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1 Liddick, D. (2014) The dimensions of a transnational crime problem: the case of IUU fishing Trends in Organized Crime 17 (4): 290-312.
2 Under the United Nations Convention on the Law of the Sea (UNCLOS), coastal States have both a territorial sea of 3 nautical miles and can declare an extended Exclusive Economic Zone of up to 200 nautical miles off their coastline (UNCLOS 1982).
3 Petrossian, G.A. (2015) Preventing illegal, unreported and unregulated (IUU) fishing: a situational approach, Biological Conservation, 189, 39–48, pg. 39.
4 Africa Progress Panel (2014) Grain, fish, money: financing Africa’s green and blue revolutions. Africa Progress Report 2014.
6 Daniels, A., Gutierrez, M., Fanjul, G., Guerena, A., Matheson, I. & Watkins, K. (2016) Western Africa's missing fish: The impacts of illegal, unreported and unregulated fishing and under-reporting catches by foreign fleets. 203 Blackfriars Road, London SE1 8NJ, Overseas Development Institute.
7 MRAG (2010) Estimation of the cost of illegal fishing in West Africa. Final Report. London: Marine Resources Assessment Group.
8 Daniels et al 2016.
12 African Progress Panel 2014.
13 Daniels et al 2016.
14 Pettrosian 2015.
15 Daniels et al 2016.
18 Liddick 2014.
20 Fessy, T. (2014) ‘The unequal battle over West Africa’s rich fish stocks’. Dakar: BBC News, 9 January 2014.
21 Belhabib D, Sumaila UR, Lam VWY, Zeller D, Le Billon P, Abou Kane E, et al. (2015) Euros vs. Yuan: Comparing European and Chinese Fishing Access in West Africa. PLoS ONE 10(3).
22 Petrossian 2015.
25 Belhabib 2015.
27 Doumbouya A, Camara OT, Mamie J, Intchama JF, Jarra A, Ceesay S, Guèye A, Ndiaye D, Beibou E, Padilla A and Belhabib D (2017) Assessing the Effectiveness of Monitoring Control and Surveillance of Illegal Fishing: The Case of West Africa, Frontiers in Marine Science, 4:50.
32 ICCAT 2018.
34 Liddick 2014.
38 Belhabib et al 2015.
39 Liddick 2014.
40 Petrossian 2015.
42 Sodik, D. M. (2009) Analysis of IUU Fishing in Indonesia and the Indonesian Legal Framework Reform for Monitoring, Control and Surveillance of Fishing Vessels. The International Journal of Marine and Coastal Law. 24 (1), 67-100.
47 Liddick 2014
51 Sodik 2009.
52 IOTC 2018.
53 WCPFC 2018.
54 Chan, F. (2017) ‘Indonesia blows up and sinks another 81 fishing boats for poaching’. The Straits Times.
55 Munthe, B. C. & Kapoor, K. (2018) ‘Indonesian minister urged to stop destroying illegal fishing boats’. Reuters. 10 January 2018.
56 Chan 2017.
57 Chan 2017.
58 Munthe, B. C. & Kapoor, K. (2018) ‘Indonesian minister urged to stop destroying illegal fishing boats’. Reuters. 10 January 2018.
59 Sodik 2009.
62 Salna, K. (2018) ‘Google Is Indonesia's New Weapon in War on Illegal Fishing’. Bloomberg.com. 19 April 2018.
63 Sodik 2009.
64 FAO (2001) International plan of action to prevent, deter and eliminate illegal, unreported and unregulated fishing. Rome: FAO.
66 Liddick 2014.
67 FAO 2001.
68 Liddick 2014.