A new tool to peer into fishing networks: Q&A with Austin Brush of C4ADS

One in five fish sold globally is caught illegally, according to C4ADS, a Washington, D.C.-based think tank that tracks illicit trade networks. That’s between 11 million and 26 million metric tons of fish annually.

C4ADS plans to launch Triton, a web-based analysis tool to examine ownership within the global fishing fleet, by the end of 2022. The plan is for the tool to enable government monitors, fishery certification bodies, journalists and researchers to better track fishing fleets and seafood source companies to understand who profits from sales of fish, and who is responsible for labor and environmental practices aboard fishing vessels. With this increased transparency and oversight, the aim is ultimately to reduce illegal, unreported and unregulated fishing, known by the acronym IUU.

Mongabay interviewed Austin Brush, the IUU portfolio manager at C4ADS, about Triton.

Mongabay: First off, how would you describe Triton?

Austin Brush: Triton is a transparency portal that we are developing at C4ADS. It consists of two primary components: the vessel and company database, which has ownership information, key identifying information for vessels and companies, and then there are the analytical products, which includes risk alerts and dossiers on fishing vessels in general.

The vessel and company database we are developing is for industrial fishing vessels. Currently it is focused on longline and reefer vessels. Triton users will be able to explore those relationships graphically, see the different kinds of networks between company and vessel, track that relationship through officers, directors, shareholders. For each entity, there will be a corporate entity number, address, phone number — all important information for how a company might be operating, whom it might be related to, and ultimately who actually controls that company.

Mongabay: We don’t generally think of corporate structure or beneficial ownership when we think of IUU fishing. For example, other groups who look at IUU fishing, like Global Fishing Watch, look at where these vessels are fishing. Why is Triton focused on ownership?

Austin Brush: I believe that in thinking about IUU fishing, it is important to think of the vessel at large. Where it is at sea and what is it doing at sea are all critical components of the vessel’s daily operations. At C4ADS, we have been focusing on … who really owns, operates and manages these fishing vessels; and who ultimately profits from what is caught at sea and what is traded and sold.

Fully understanding who owns these vessels is a critical next step in following the money, and taking it from not just the activity at sea but then identifying those key actors who are shaping the way a vessel behaves, and the way that fishing activity occurs at sea.

Mongabay: Could you give an example of one instance of IUU fishing where beneficial ownership shows how the owner shaped that behavior?

Austin Brush: Yeah, I think we can see that many cases of IUU fishing are tethered to their registered owner. The registered owner gets the license for the vessel. They retrieve the flag of convenience. They manage the paperwork. They play a role in recruitment and the hiring of labor on board the vessel. They can at times deal with the transport and management of people from one location to another to board the vessel. The beneficial owner is ultimately the entity that controls and profits from the later distribution of that seafood.

One example we could possibly point to is the “Somali Seven” fleet off the coast of Somalia. It was pretty notorious and widely reported on in 2017 that these vessels had retrieved licenses to fish in Somali waters. They had gone through multiple levels of ownership change. Originally, they had Thai owners, [then] owners based in Djibouti, but these companies in Djibouti, whilst incorporated there, were linked back to some of the same shareholders and directorship based in Thailand. [The fleet] had been implicated in illegal fishing and other labor abuses, and then changed identity and changed where it operated and shifted ownership. We can see that the ultimate shareholders and officers of those companies never really shifted, which indicates that the beneficial ownership never really changed either.

Mongabay: I see. So Triton is not yet a functioning public data portal. I have not looked at the website. But what I understand is that it will be populated with data from C4ADS reports over the past five years: “Net Worth,” “Strings Attached,” “Something Smells Fishy.” In the methodology for these briefs, you talk about how the data used is public — from regional fisheries management organizations (RFMOs), national vessel registries. Why are these vessels so hard to track if there is so much public data on them?

Austin Brush: Exactly. So one of the primary methodologies that C4ADS relies on is using publicly available data. But one of the challenges that we see is that this data is held across a variety of different databases across a variety of different jurisdictions, sometimes it’s not particularly easily discoverable, or easy to identify information and bring together all these disparate data sets together. Another challenge we see is that there’s variance in data quality and data reporting. In certain jurisdictions, the information reported on a vessel is more limited or not publicly available at all. We see that sometimes there’s conflicting ownership reporting across data sources. Those are probably the key challenges we see with the vessel data itself.

When taking that to the next level, looking at the corporate registries of different countries is another additional challenge. Some of those aren’t immediately publicly available without being present in the country. Some records we have to pay for. Others are in different languages, and need to be assessed, structured and analyzed. Sometimes the actual data format is really hard to decipher and access. So all these are challenges of the data itself. We’re working towards not only collecting that data, but then analyzing, structuring, cleaning, and kind of conducting that more focused network analysis, to see how those relationships relate back to a vessel.

Additionally, we’re doing open-source research on those companies to identify further links, or look at potential derogatory reporting, or just better understand who these companies are, and where they might have a footprint within the seafood sector.

Mongabay: The New York Times published a report about China’s distant-water fleet at the end of September. It portrays China as a dominant player, fishing up to countries’ borders, having questionable labor practices on board. Would you concur with that assessment, given your research? Are there other players of concern? Is all the fish collected by distant-water fishing countries being consumed solely within those countries, as the media suggest? Or does the catch show up in the tuna cans and fish balls on supermarket and restaurant shelves of the global market?

Austin Brush: I guess a clarifying point I do want to raise here about Triton is that the portal isn’t focused on just illegal fishing or illicit activity. What we’re ultimately focused on is improving access to beneficial ownership for all vessels, licit and illicit, to create better, more transparent access to data and prove that it is reasonable and necessary to collect data on how vessels need to register and get flags, etc. So Triton is just trying to improve transparency at large.

Really, in relation to The New York Times piece, I mean, China is certainly one of the biggest actors in the fishing sector. They operate the largest distant-water fishing fleet. They have a particularly global presence. So I think by the very nature of the sheer scale of their fishing fleet, we do see more instances of illegal fishing or labor abuse on board those vessels, because of just the sheer number of them. But we also do see, in certain cases, exploitative fishing arrangements, focusing on unregulated fisheries, like the squid fisheries off the coast of Argentina, or the Indian Ocean, which does not have the kind of oversight or regulatory bodies closely managing those species. So we do see targeting of specific fisheries that are more vulnerable and exploitable.

And I think, based off of recent research, we definitely do see a lot of the seafood being consumed domestically in China. I think there is a growing demand for seafood products within the country itself. But there was a relatively interesting article in the journal Science not so long ago that did this more detailed assessment of how the seafood that does enter China for processing is then reexported outwards. So, I mean, there certainly is a real export market from China to other countries. Consumption isn’t necessarily just domestic. There are global seafood market implications based off of the seafood that’s caught by some of these distant-water fishing fleets.

Read more: How Mitsubishi vacuumed up tuna from a rogue Chinese fishing fleet

Mongabay: You said Triton’s focus was not just on illicit fisheries, but on transparency at large. Maybe you could speak to that. At least Triton’s initial reports were made for the International Seafood Sustainability Foundation (ISSF), which as an entity is focused on tuna and tuna markets. Could you talk about the data in general, how much of it was made for specific clients? For a researcher or a journalist approaching the database, what is Triton particularly good for?

Austin Brush: I think there are a few emphases as of now. There is certainly an emphasis on industrial fishing vessels. We’re focused on that primarily: vessels registered with the IMO [International Maritime Organization] that are fishing abroad. The other kind of gear types that we’ve collected quite a bit of data on are longline vessels, purse seiners, squid fishing vessels, as well as the reefer fleet. So those are the key vessel types we focused on. And then within longliners, we’ve focused on five key flag states: China, Taiwan, South Korea, Spain, and Japan, which account for most fishing in terms of hours spent on the high seas.

By vessel type, there is probably a little bit more of a lean towards tuna and bass species and vessels focused on tuna. As we continue to roll out Triton, we hope to be continuously expanding the kind of key vessel and ownership data we’re collecting, beyond the initial batch of vessels.

Mongabay: Since you uncovered how these entities operate through shell companies, how do you know your data will stay valid? Might these “bad actors” change their tactics since you revealed them?

Austin Brush: That’s a really important question. Part of the solution will be creating a data refresh, so this data won’t be static. It will constantly be updated to ensure that the vessel data is up to date, and vessel ownership … they need to submit reports on an annual basis, there will show change over time. We’ll be continuously checking in and refreshing data based on that information as well.
And there will always be challenges in identifying some of this information. Shell corporations, privacy, secrecy jurisdictions, these will always be challenges, especially when looking at bad actors, not just within the fishing space, but kind of writ large. So we’ll be continuously working on different methodologies to layer on open-source data, other data provided from partners, and what we can find, to try and overcome some of those data access and data quality issues that we see with shell corporations and companies.

Mongabay: In Triton’s FAQ, you talk about how it will be a tool “to ensure the key stakeholders in the seafood industry could turn information into action.” Who are the key stakeholders you are referring to?

Austin Brush: I think there are a few groups. One of those includes law enforcement. We believe that government agencies that are responsible for monitoring and preventing IUU fishing can use the data available in Triton to expedite their own investigative capabilities, identify ownership or connected ownership of specific vessels.

We also see some key components being regulatory bodies, regional fishery management organizations, groups like the ISSF, who are responsible for regulating and overseeing specific vessel types. The ISSF can use this ownership data to better manage capacity levels, or understand what companies are part of a broader organization, how much they actually catch, or what kind of vessels they actually own.

Other key groups we see are seafood industry actors, those companies that are committed to sustainability and future efforts to ensure not using, harvesting or sourcing catch that might be linked to IUU fishing or human trafficking and forced labor. And [seafood industry actors] using beneficial ownership data, to better understand their own supply chains and who might actually own the vessels from which they’re sourcing seafood.

Read more: Worked to death: How a Chinese tuna juggernaut crushed its Indonesian workers

And then the other ways are layering this beneficial ownership data on top of existing regulatory initiatives like the Port States Measures authority, tools to better understand who might be entering a port, or trying to gain access, and using this beneficial ownership data to conduct due diligence prior to vessels’ entry. I think the final group that I’d like to highlight is probably the private sector. Specifically, the financial and insurance sectors, which might be able to use this beneficial ownership data as another tool for due diligence on a vessel or company.

Mongabay: When do you expect Triton to be released? Will it be publicly accessible? Or only available to certain people?

Austin Brush: So we’re hoping to have a more public, full launch later this year, probably closer to November, December. There are always things to improve so I want to be wary of promising a public launch. There is a component of Triton that is publicly available, not the entire database but a few levels of ownership. Triton will also be available to close partners, civil society, NGOs, journalists, based off of a pro bono relationship.

We are hoping to grant access to key stakeholders that might not have institutional support. There will also be a paid subscription service that will include more in-depth analytical support, which includes investigative support, updates of information upon request, access to underlying documentation like the corporate registry documentation that is available, and connecting vessel owners in any associated companies to public trade records.

Mongabay: What are the levels that will be available free to the public?

Austin Brush: The free level will be restricted to about two levels of ownership. Additionally, there will be available analytical products highlighting potential risk of a fleet, vessel or company.

Mongabay: What is one unexpected finding, outcome or realization you had from this research?

Austin Brush: I think something that constantly surprised me is the complexity through which some of these vessels are owned. A vessel that’s flagged to one country may be owned by a company in another country, managed by a third company in another country, and then owned by a beneficial owner that’s incorporated in a fourth or fifth country.

I would say it’s impossible to underestimate the complexity through which some of these vessels are owned.

Mongabay: So what is the most number of levels you found to find the beneficial owner?

Austin Brush: Eight? Nine? Ten? It can be pretty significant in terms of the number of companies involved, especially for larger conglomerates.

There is a pretty wide variance. In some cases, we see that a vessel is owned by one individual or company and that’s about it. So it’s just one or two levels. That’s a simple structure. There are also ones where you have maybe five, six or seven intermediary companies to link back to the beneficial ownership.

Banner image of sharks swimming off the coast of the Galapagos Islands in Ecuador. Image by Rhett A. Butler/Mongabay.

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