Plenary Session: Who Can You Trust?

Criteria of Seafood Supply Chain Trustworthiness for

Regulators and Businesses

Moderator: David Schorr Speakers: Katrina Nakamura Alistair McDonnell Nigel Edwards

Tuesday, 2 February 2016

Trust but Verify: Defining, Finding, and Using Reliable Evidence of the Legality of Seafood Origins

Morning Plenary Session Tuesday, 2 February 2016

Alistair McDonnell INTERPOL

Risk management of imports under IUU reg

The operating environment at UK Border Inspection Posts (BIPs):

• 35,000 seafood consignments into UK per year

• 19 BIPs, staffed with approx 42 health inspectors on the front line, 365 days a year

• 80 % of fish trade imported through five ports

• 100% documentary checks

• 100% physical checks on each consignment

• £1.7 - £2 billion per annum

Risk management of imports under IUU reg

Goals: 1. Compliant trade should flow w/ minimum of interruption

2. A manageable system for classifying shipments by risk

(and reducing that risk by dialogue with business)

3. Transparency and accountability to civil society, management and the European Commission.

4. Training of officers in fulfilment of regulatory obligations

5. Allocation of resources (60/30/10 split H/M/L)

6. Interception of highest risk consignments

A risk-based approach

Built on 20 benchmarks from the IUU Reg + National Benchmarks (e.g. corruption indices).

20 benchmarks 6 categories of information

(suits of cards analogy)

IUU Risk Criteria

- Risk criteria can be used to assess an import - Allocate a score 1, 3 or 9, Low, Medium, High - Red trump – all to high, Green trump – all to low

- Information can be Open Source, CinC, Restricted - Fulfilled, Partially fulfilled, or Unfulfilled

Risk factors associated with Business

Relates to importer,

exporter, cargo owner

High Score

• Previous non-compliance

• Community alert/ MA request

Med Score

• New/ unknown trader

Low Score

• regular supply chain

• established traceability

• Third party audits

Intelligence

• Own records/ knowledge

• EU Alerts/ Mutual Assistance

requests

• Investigation papers

• NGO data e.g. SIF EJF

High Score

• EU DG highlighted risks

• Outstanding MA requests

• Evidence flaws control

system

Med Score

• Poor reputation as Flag state,

processing, transit/

transhipment country

Low Score

• Signed up to RFMO (and

compliant)

• Bi-lateral agreement

• History of compliance

Risk factors associated with Country

Intelligence

• Results of own findings

• EU Alerts/ Mutual Assistance

requests

• Investigation papers

• NGO data e.g. SIF EJF

High Score

• History fraudulent catch /

health certificates

• History errors

• Information inconsistent with

other documents

Med Score

• Processing statement with

copy catch documents

• Prior notification late/ docs

incomplete

Low score

• Info available to cross-check

e.g. signatories

• Electronic scheme (Enables

verification/ eliminates

tampering)

Risk factors associated with Documents

Intelligence • Own checks • Information from EU DG • Information from MMO

Risk factors associated with Species

High Score

• CITES

• UK Priority e.g. Dissostichus

spp. (toothfish) or bluefin tuna

Med Score

• High value/ kg

• IUCN red list

• RFMO managed

Low Score

• all other species

Intelligence

• EU Alerts/ Mutual Assistance

requests

• Investigation papers

• NGO data e.g. SIF EJF

High Score

• Unjustified economically

• Known IUU Issues

Med Score

• Fluctuations pattern

• Inconsistent with countries

activity

• New product/ species

Low Score

• Regular trade no previous

issues

Risk factors associated with Trade

Intelligence

• Local knowledge of imports

• Comparison with UK historic

data

• Global Intel analysis e.g. IMCS

and NOAA

• Investigation papers

• NGO data e.g. SIF EJF

Risk factors associated with Vessel

High Score

• EU DG highlighted risks/ MA

requests/ community alert

• IUU list (not permitted)

Med Score

• Registered with Flag state –

reputation as flag

convenience

• IUU related nationals,

beneficial owners and legal

entities connected to vessel

Low Score

• Approved RFMO list

Intelligence

• EU Alerts/ Mutual Assistance

requests

• Investigation papers

• NGO data e.g. SIF EJF

Verification tools

IUU EU approach _peer to peer verification between authorities with competencies as specified in the IUU regulation & notified to EU by approved countries. (90?)

INTERPOL - IUU + transnational organized Fisheries Crime approach– peer to peer.

Police, Customs, Tax, Port Health, border control, nationals, Port authorities, shipping and fishing vessel registries, Maritime Security, anti-corruption commissions, Fisheries administration, (190 Member countries).

Practical challenges

Consider three very different cases:

- tuna - Pacific cod & pollock langoustines

Key verifications

• Cross checks between Vessel Monitoring System/Logbooks/ Areas of operation and licenses?

• Is the flag administered in the territory of the country or overseas?

• Transparent licensing system (& whose bank account was paid?)

• Does the flag state cooperate with the coastal state, port state, market state or state of nationals?

• Does the company cooperate on mitigating risk?

• Mutual Co-operation and assistance between states

* intelligence-based vs. “regulatory” info

* formal vs. informal info

* risk vs. uncertainty

“looking where the light is already shining” vs. where problems may be hidden

INTERPOL For official use only

16

Thank You

Plenary Session: Who Can You Trust?

Criteria of Seafood Supply Chain Trustworthiness for

Regulators and Businesses

Moderator: David Schorr Speakers: Katrina Nakamura Alistair McDonnell Nigel Edwards

Tuesday, 2 February 2016