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Home
Why Starboard?
Product overview

Global maritime domain awareness and vessel analysis

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Learn about our latest improvements

Starboard for
Biosecurity Fisheries monitoring and surveillance Satellite surveillance VMS fishing fleet management
Latest case study
Investigating the Lu Rong Yuan Yu 606

Arming research analysts with hidden clues to their maritime domain

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Meet the team
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After Sun Flower 7: Analysing fishing activity of South Korean-owned carriers in the Western Central Pacific

Case Study · 24 July 2024 · 20 minute read

Combining historical vessel behaviours, company networks, fishing effort, and conservation and management measures (CMMs) for comprehensive fisheries risk and compliance analysis.

This article was written with support and contributions from friends and customers of Starboard, including Francisco Blaha, Damian Johnson, New Zealand Ministry for Primary Industries, and Amentum. The purpose of the article is to bring together the ideas of experts and interested parties on a topic of common interest, and to highlight where further work and collaboration can be achieved.

Over the last two years, carrier fishing activity in the Western and Central Pacific Fisheries Commission (WCPFC) has been a topic of discussion regarding the violation of fish aggregating device (FAD) use during closure periods, and more broadly whether carriers should be allowed to deploy FADs at all. In this article, we analyse the historic case study of the Sun Flower 7, the activity that led to prosecution, where else that activity has been occurring, and a deep dive into the surrounding policy structure and implications for unmonitored marine pollution from this type of activity in the region.

On 5 June 2023, the Korean Ministry of Oceans and Fisheries disclosed that an administrative fine of $150,000 USD had been handed down to Ji Sung Shipping Co Ltd, 1 the owner of South Korean-flagged fish carrier Sun Flower 7. 2 This fine related to the vessel’s activity in November 2022 during South Korea’s additional FAD closure period. 3

The track of the Sun Flower 7 exhibited behaviours which experts described as likely deploying drifting FADs in the northern part of Kiribati’s exclusive economic zone (EEZ) and the adjacent high seas. Such activity was in contravention of WCPFC CMMs during the FAD closure periods of that year. Once the vessel indicated it would arrive in Bangkok, Thailand’s Port State Measures (PSM) regulatory framework was enabled. This allowed an investigation by Thai authorities and was supported by the Kiribati Ministry of Fisheries and Marine Resources Development. As a consequence, the vessel was denied port entry, escorted out of Thailand’s waters and reported to the Korean Ministry of Oceans and Fisheries in South Korea for investigation. In addition to the subsequent fine imposed by the flag-state, the enactment of PSM regulatory framework in this manner set a precedent and proof of concept for collaborative work against IUU fishing between port states and flag states under the WCPFC and Port States Measures Agreement (PSMA). 4 The financial implications of being denied port entry under the PSMA may also serve as a deterrent going forward, for large fishing companies that rely on a regular pattern of operations and port use, and whether they continue to allow their vessels to act in contravention of WCPFC conservation and management measures for increased profits.

Unusual vessel movements of the Sun Flower 7 during November 2022, in the northern part of Kiribati’s EEZ and the adjacent high seas resulting in prosecution for FAD setting during a closure period. Technically this would be classed as IUU fishing, but the vessel was never IUU listed. Tools such as Starboard that provide long track histories, analysis of vessel behaviour, and the capability to share analysis facilitate international collaboration. In this case Francisco Blaha and the Environmental Justice Foundation used Starboard to analyse the same unusual ship tracks.



While the Sun Flower 7 was under investigation, the same type of FAD setting behaviour was also noted of a fish carrier named Volta Victory 5 in May and October 2022. Volta Victory is Panama-flagged but owned by Singapore-based company Galaxy International Maritime, possibly a shell company, as this is the only vessel it seems to operate as a chartering company.

Volta Victory’s activity in May and October 2022 was outside of the standard FAD closure periods for WCPFC that year, as outlined in the conservation and management measure in force at the time. According to CMM 2021-01 6 the FAD closure periods for 2022–2023 were July to September between 20°N and 20°S, although each flag state must also stipulate two additional months (either April–May or November–December) that their fleets will be restricted from setting FADs. Panama’s Cooperating Non-Member (CNM) participatory agreement in the WCPFC 7 doesn’t allow them to operate fishing vessels (although carriers are classed as fishing vessels under the Convention text), so they assess this obligation as non-applicable, and don’t implement the additional ban period for their vessels. This highlighted to analysts that the practice might be more widespread and more complex than previously realised, and required further investigation and collaboration.

Likely FAD setting activity by the Volta Victory, during May 2022 in the Kiribati’s EEZ and the adjacent high seas. The owner is Singapore-based company Galaxy International Maritime, but uses Panama for the vessel flag, which is a cooperating non-member of the WCPFC.



Since June 2023, when the fine was handed down to the owner of Sun Flower 7, Starboard and other analysts have been monitoring the activity of carriers in the Ji Sung Shipping fleet, as well as conducting network analysis on the relationship between similar South Korean fishing companies operating in the WCPFC–to determine whether they were also setting FADs during the annual closure periods, and how to detect and monitor this activity in future.

Of note is that since the Sun Flower 7 resolution in June 2023, carriers have resumed FAD setting activity, but are now exclusively conducting that activity on the high seas adjacent to Kiribati (no longer inside the Kiribati EEZ), which could indicate that Kiribati have prohibited this activity from occurring inside their EEZ. Correspondence with relevant flag and port states would be required to confirm the reason for this observed change in activity.

FAD setting activity in a survey or search and rescue style pattern during December 2023, in the same high seas area as the illegal FAD setting from November 2022.



An additional consideration that has previously been raised by fisheries experts such as Francisco Blaha, 8 is that there is currently no binding regulation under the WCPFC on the material, quantity, or tracking of FADs released on the high seas. Instead, CMM 2023-01 9 asks the respective flag-states to “encourage” their fleets to track, manage, retrieve and report lost FADs, but does not mandate it, meaning it cannot be strictly enforced (but can still be reported to the flag-state for investigation where necessary). Considering the sheer quantity and regularity of FADs being set by the carriers outlined in this article alone, there is concern that these larger carrier-borne FADs are being released into the ocean in significant quantities without observer monitoring or intent of retrieval–and no ramifications for it. This would cause a concerning amount of marine pollution, including when they eventually wash ashore in nearby Pacific islands.

Based on these initial observations, it becomes evident that WCPFC conservation and management measures relating to FAD setting, carrier classification and regulation, and marine pollution are not being consistently interpreted and applied by parties under the WCPFC. This is likely due to the complexity and inconsistency of wording between the relevant conservation and management measures, flag and coastal state legislation, and international law.

How does the WCPFC Convention text classify fish carriers?

As outlined in the overarching WCPFC Convention text on the Conservation and Management of Highly Migratory Fish Stocks in the Western and Central Pacific Ocean, fishing includes (among other things) “placing, searching for or recovering fish aggregating devices or associated electronic equipment such as radio beacons”. 10 The same document also classifies a “fishing vessel” as “any vessel used or intended for use for the purpose of fishing, including support ships, carrier vessels and any other vessel directly involved in such fishing operations”. This means that carrier vessels are characterised as fishing vessels, which can engage in FAD setting activities under the WCPFC Convention text, but are also subject to any additional relevant legislation of flag and coastal states–further confusing the matter from a compliance perspective. The wording of the WCPFC Cooperating Non Member (CNM) Request for 2024 7 for Panama states that “The participatory rights of Panama in the WCPO are limited to the provision of carrier and bunker vessels. Panama’s participatory rights also apply to vessels that supply food, water and spare parts to carrier vessels that engage in transhipment activities, provided that these vessels do not engage in activities supporting fishing vessels, including providing and/or servicing FADs.” While this makes it seem like Panama’s vessels cannot conduct fishing activity (consisting of only carrier, bunker, and logistical support vessels), the wording established under the WCPFC convention text classifies carriers as fishing vessels, meaning it could be within their right (under the WCPFC) to conduct fishing activity, and it would be up to the flag or coastal state to legislate otherwise. This highlights that the classification of carriers and their regulated activities should be reviewed as a point of contradiction between WCPFC documents and flag-state legislation.

How do the WCPFC CMMs treat the setting and retrieving of FADs by fish carriers?

Ancillary to the overarching WCPFC Convention text, conservation and management measures (CMMs) are individual documents under the WCPFC Convention which describe and categorise binding decisions relating to specific topics, such as catch reporting, bycatch regulations, and gear requirements (among many other topics). Such decisions are classified by the year of adoption and are then sequentially numbered. The WCPFC also release Resolutions, which are non-binding recommendations on topics which have not yet been agreed to come into force as full CMMs (The 2018-01 Resolution on labour standards is a good example of this. 11)

When analysing the different interpretations on FAD setting regulations, there are dozens of CMM’s to search through for relevance and nuance. From these, a few key documents emerge as most relevant to our analysis.

CMM 2009-02 on the application of high seas FAD closures and catch retention 12 states the definition of a FAD, as in footnote 1 to CMM 2008-01 13 (superseded by 2023-01, 9) shall be interpreted as including: “any object or group of objects, of any size, that has or has not been deployed, that is living or non-living, including but not limited to buoys, floats, netting, webbing, plastics, bamboo, logs and whale sharks floating on or near the surface of the water that fish may associate with”.

CMM 2023-01 Conservation and Management Measure for Bigeye, Yellowfin and Skipjack Tuna in the Western and Central Pacific Ocean 9 regulates the use of FADs where relevant to closure areas and timeframes, and has now superseded CMM 2021-01 6 of the same title. The primary difference between these two CMM’s with relation to FADs is that CMM 2021-01 instituted an annual FAD closure period between 20°N and 20°S of July–September, with an additional two months (either April–May or November–December) at flag-state discretion. This additional closure period is communicated by the flag state to the WCPFC, but is not made publicly available except where WCPFC-registered enforcement agencies request the data for an investigation or relevant operation. With effect from February 2024, CMM 2023-01 only mandates a FAD closure period of 1 July–15 August each year, with one additional month (April, May, November, or December) at the discretion of respective flag states. Effectively a 50% reduction in the WCPFC FAD closure periods under the new CMM.

While CMM 2023-01 and CMM 2009-02 both talk to the restriction of setting FADs during closure periods, it is noted that there are provisions made in those CMMs for fishing vessels retrieving FADs during the closure period which are lost or wish to be used when the closure period ends. Due to this nuance, gear retrieval was the justification used by the master of Sun Flower 7 for the large geometric patterns observed of his vessel in November 2022. This explanation was not accepted by authorities (and indicates that the masters may have known they were acting illegally), as the analysed AIS activity had been at higher speeds and more consistent patterns than would be expected for a vessel locating, hooking, and hauling objects from the water (FADs in particular can sometimes weigh up to 200kg) on board. Fisheries expert Francisco Blaha discusses this in more depth in his original blog post on the Sunflower 7, based on his extensive experience in the field.

CMM 2023-01 also stipulates that “A flag CCM 14 shall ensure that each of its purse seine vessels shall have deployed at sea, at any one time, no more than 350 drifting Fish Aggregating Devices (FADs) with activated instrumented buoys" although it is unclear whether this guideline also applies to carrier vessels deploying FADs, as the flag-state is only required to track deployments of its “purse seine vessels”. Under this CMM, vessels must also comply with coastal-state regulations when setting FADs inside EEZs, in accordance with the relevant FAD Management Plan. 15 Of note, for Kiribati, it states that “The vessel master must not engage in any FADs deployment work without prior authorisation from the Director of Fisheries”. Based on the case of the Sun Flower 7, with the master’s explanation of gear retrieval, it is likely that he did not seek prior authorisation of FAD deployment from the Kiribati Director of Fisheries, and was in contravention of coastal state legislation, as well as WCPFC CMMs.

How do the CMMs handle the potential marine pollution impact from FADs?

Exploring the issue of marine pollution, CMM 2017-04 Conservation and Management Measure on Marine Pollution 16 specifically restricts the discharge of plastics into the ocean, but allows for fishing gear to be discarded as an exception to the rule. Through this wording, this conservation and management measure allows for the deployment of FADs (as fishing gear) without any limit or intent to recover them after use. This appears to be in contravention to CMM 2023-01 which states that purse seine vessels shall have no more than 350 drifting FADs with activated instrument buoys deployed at any one time. Together, this could be interpreted as fishing vessels being allowed to ‘lose’ any number of instrumented FADs in excess of 350, or deploy and abandon any number of non-instrumented FADs on the high seas, without contravening any CMMs. In another of his blog posts, 17 Francisco Blaha summarises a paper published by Robin Churchill in 2021 18 which asks whether FADs would contravene international marine pollution law over and above WCPFC CMMs.

Examples of FAD pollution that wash ashore, as discussed by Francisco Blaha, and posted on Instagram by debrisresearch.



Some interesting discussion points emerge from this article:

  • “Over the past few years, tropical tuna RFMOs have adopted a number of measures designed to alleviate some of the environmental problems caused by lost or abandoned FADs. All four RFMOs prohibit the use of entangling material suspended beneath FADs in order to prevent sharks, turtles, and other non-target species from becoming entrapped, and “encourage,” but do not (yet) require, FADs to be constructed of biodegradable materials apart from the satellite buoy.”
  • In addition to this, noting that FAD retrieval is classed as a fishing activity under the WCPFC convention text, any FAD that drifts into an EEZ of a country where the vessel is not licenced to fish (and where the national legislation classes the activity as illegal) means its retrieval becomes illegal (unlicenced) fishing. This poses an interesting policy implication for the responsible management of drifting FADs, as it makes potential retrieval more difficult in areas bordering EEZs.
  • International law under The London Convention, London Protocol, and UNCLOS could potentially be used in an attempt to apply some form of external regulation against the intentional release of excessive amounts of FADs where it’s apparent that their recovery is not possible, such as in the case of large carriers releasing dozens of large, non-biodegradable FADs in a short period of time.
  • The implications of using international law to regulate marine pollution in the WCPFC is that flag-states must be party to those laws to be subject to them. For example the list of parties which have ratified UNCLOS include South Korea, but does not include the United States (although an argument could be made that conventions such as UNCLOS 19 are now so widely implemented and accepted by non-signatories that it is considered binding customary law). The burden of proof also lies with the investigating party, as to whether the loss of FADs is intentional or accidental. In the case of the South Korean fish carriers, it could be argued that the release of numerous large FADs without any observed attempt at subsequent retrieval, could be classed as intentional dumping under international law. 18

It’s worth noting here that there has already been a great deal of work done in the Pacific on the extent of marine pollution caused by purse seine (and other) fishing gear, 20 and that WCPFC, Parties to the Nauru Agreement (PNA), and other bodies are currently reviewing the materials and quantities of FADs being deployed–such as moving toward biodegradable materials. 21 There is also concern that despite 100% observer coverage on purse seine fishing vessels in the WCPFC, the issue of marine waste as a result of FADs is not considered an actionable outcome of those reports. 22 In fact, in the Table of Regional Observer Program (ROP) minimum standard data fields, under the section on “abandon any gear?”, it states “FADs not included”. 23 This results in around 64,000 drifting FADs being released each year in the WCPFC (as of 2019, with a likely increase in numbers each year), under the justification that profitable purse seine fishing is becoming unviable without their use. 18 This poses a separate problem of how catch limits for tuna are often being assessed and set based on fisheries catch data (rather than effort), but also highlights the importance of considering international law in the prosecution of marine pollution for the intentional deployment of FADs without intent for recovery, while new policies are being written and implemented to address the matter long term. 24

For carriers, under CMM 2009-06 - Conservation and Management Measure on the Regulation of Transhipment, 25 observers are only required to be carried where the vessel is transshipping catch, meaning it’s possible that the South Korean FAD setting carriers outlined in this article do not have observers on board (as they do not transship at sea), leaving no record of their fishing activity. Estimated numbers of FADs being deployed each year in the WCPFC are often based on purse seine observer reports, 26 meaning it’s possible that those numbers are much higher than anticipated as a result of carriers deploying additional FADs without oversight.

Analysing South Korean-owned fish carrier behaviour in the WCPFC over three years

Based on WCPFC CMM analysis, it becomes apparent that the focus of analysis should be around the FAD closure periods of July–September until the end of 2023, and 1 July–15 August from 2024. During the FAD closure periods, increased scrutiny will be taken on the AIS tracks of carriers while in known purse seine fishing grounds. In addition, there should be consideration for the frequency of FAD setting both inside and outside of FAD closure periods, when contemplating potential marine pollution breaches under international law.

To address this, behavioural analysis was conducted in Starboard from 2021–2024 to determine:

  • Where is the FAD setting primarily occurring in the WCPFC?
  • Who is perpetrating the activity, and under which companies?
  • What is the relationship between the companies, carriers, and purse seine vessels?
  • Is any potential FAD setting activity identified while inside the closure periods and locations?
  • Where are the primary fishing grounds for the relevant South Korean fishing fleets?
  • What are AIS reporting levels of purse seine fleets, and where do they operate?
  • What are the characteristics of ideal purse seine fishing grounds for the fleets of interest?
  • What sort of AIS activity characterises FAD setting activity?
  • What other insights can be gathered from the resulting analysis?

Company structure and carrier behaviour analysis to uncover networks

The relationship between carriers, fishing vessels, and companies in the region is important to consider when identifying activity of interest relating to FAD setting during closure periods. By taking the owners listed under the IMO Company and Registered Owner Scheme of the 2 carriers of concern identified so far (Sun Flower 7 and Volta Victory), we can then search for additional information and relationships that might expose additional carriers of interest.

This work was conducted through multiple platforms and sources, in order to expand the scope and depth of analysis:

  • The Starboard company Search function was used to visualise the fleets of Ji Sung Shipping and Galaxy International Maritime on AIS, to determine where there were overlaps in fishing grounds, ports, and potential interactions with other companies. This revealed a company named Sein Shipping Co Ltd which operates fish carrier vessels out of the same ports as Ji Sung Shipping and Galaxy International Maritime.
  • From here, some more in-depth historic ownership analysis was conducted through S&P’s Maritime Intelligence Risk Suite (alternately this could be completed through free and open source resources such as Equasis, Triton, or IMO’s Global Integrated Shipping Information System, where a relationship between Volta Victory and another carrier named Volta Glory was discovered under the historic ownership of South Korean company Silla Co Ltd.
  • When this relationship was cross referenced in open source research, it was found that these vessels were caught conducting illegal transshipment activity in Liberia in 2013, while flagged to Ghana and owned by Silla Co Ltd. 27 This led to the sale of Volta Victory to what appears to be a Singapore-based charter company for the purpose of operating Volta Victory under the flag of Panama while in the WCPFC, supporting South Korean-owned purse seine vessels. The Singapore company, Galaxy International Maritime, is also owned by the previously identified company Sein Shipping Co Ltd.
  • Noting the historic IUU transshipment activity under Silla Co Ltd, and established ties between major South Korean companies in the seafood supply chain (indicating a degree of vertical integration) 28, the risk of further IUU fishing activity is elevated under this ownership network.
  • When combining all of these sources of information, a network diagram was created to help visualise the analysis.

Identified relationships between 4 major companies operating South Korean (including those flagged to other countries such as Panama and Kiribati) fish carriers, purse seine support carriers, purse seine fishing vessels, and other fishing vessels. Ji Sung Shipping, Sein Shipping, and Silla Co Ltd are all South Korean companies, while Galaxy International is registered to Singapore

Based on this network analysis, it appears that there is a relationship between at least three of the most prominent South Korean shipping/fishing companies (and their subsidiary companies) in the region. This relationship extends to purse seine support carriers ferrying catch between Pacific, South East Asian, and East Asian ports, as well as setting FADs for purse seine vessels operating in the WCPFC. This information can be used to focus our attention on specific areas, vessels, and companies of interest that have a heightened residual risk of FAD setting activities during the closure periods.

AIS and environmental analysis of purse seine and carrier vessel activity

All of the vessels which were identified through network analysis were then grouped together and downloaded as a CSV from Triton (a C4ADS-developed research tool), which automatically includes metadata such as the respective MMSIs. The CSV was dropped into Starboard, which automatically populates and selects those vessels on the map for analysis.

Looking at their track history back to 2021 revealed that the highest concentration and overlap of fishing activity with carrier FAD setting activity (as characterised by the large uneconomic geographic patterns and high speed turns) was on the high seas in and adjacent to the Kiribati EEZs. The historic fishing activity associated with South Korean fishing vessels was downloaded from Starboard and turned into a heatmap, which was then re-uploaded as a geojson layer. This highlighted areas of concentrated fishing efforts, which was then overlaid with the relevant fish carrier track histories. Underpinning this analysis, both sea surface temperature (SST) and chlorophyll-a (CHL) were compared against the AIS history in Starboard to determine key fishing grounds for purse seine vessels, and corresponding operating areas for the carriers of interest.

Carrier AIS track history including FAD setting activity across the Kiribati and Tuvalu EEZs over 2 years, coinciding with favourable tuna fishing grounds. While SST can be used as an indicator for estimating the location of upwellings, downwellings, and fronts associated with potential fishing grounds, chlorophyll-a is an indicator of the level of the fertility and productivity of marine waters. 29 This figure has a chlorophyll-a environmental layer applied through the Starboard map layers, showing higher concentrations of chlorophyll-a in darker shades of green.



Of note in this analysis was the lack of AIS data available for fishing vessels within the Kiribati and surrounding EEZs. Considering the number of South Korean purse seine vessels that are either flagged or chartered to Kiribati (as registered in the WCPFC record of fishing vessels), 30 it can be presumed that carrier activity inside the Kiribati EEZ is indicative of high density purse seine fishing grounds. While VMS data for this region would provide more detailed information on true purse seine fishing efforts, this data is not available for public use.

The limited AIS use observed for purse seine vessels over 300GT while on international voyage is of a separate concern in itself, as the IMO requires AIS to be fitted aboard all ships of 300 gross tonnage and upwards engaged on international voyages, and that ships fitted with AIS shall maintain AIS in operation at all times except where international agreements, rules or standards provide for the protection of navigational information. 31

The highest concentration of South Korean purse seine activity (as derived from AIS locations and inferred from carriers’ FAD setting locations) is observed near the equator, where sea surface temperature consistently remains around ~28C and surface chlorophyll-a density is high. Due to these factors, this area was designated as our ‘area of interest’ for further analysis.

The area of interest for this article is marked by a yellow box. The heat mapping data constitutes South Korean fishing activity from 2021–2023. Bright yellow indicates higher density, with darker purple the lower density AIS areas. The Kiribati and Tuvalu EEZs are darkened in colour and labelled, and the WCPFC high seas areas are darkened further again.

In addition to analysing the historic fishing grounds, environmental conditions, and AIS tracking, it appears that FAD setting activity may sometimes be identifiable in self-reported draught changes (if we remember Francisco’s comments on the considerable weight of larger FADs). For example, the below figure shows Volta Victory’s journey between July 2022 and August 2023. By filtering the track history to only show their draught changes during this time, it’s noted that the vessel updates its draught after every port call (reflecting transshipment of catch), and on one instance they also updated their draught from 6 to 5.8 after conducting zig zag activity consistent with FAD setting in the Kiribati EEZ and high seas during October 2022.

Volta Victory conducted likely FAD setting activity in October 2022, as shown inside the blue box, which was followed by a draught change from 6 to 5.8 (highlighted in the track history panel), indicating an at-sea discharge of weight.

Through analysing all of these factors in incremental time frames from 2021–2024, the following samples of South Korean FAD setting activities were extracted for carriers in the area of interest. The activity is overlaid against heat maps of South Korean fishing efforts (both longline and purse seine) from 2021–2023, to highlight the correlation of activities.

Jan–Jun 2021
Vessels: Lake Aurora and Lake Win
Owner: Ji Sung Shipping
Flag state: South Korea

Activity: FAD setting activity outside of the annual closure period, which is consistent with the regulations of WCPFC and relevant CMMs.

Both sets of FAD setting activity were followed by draught changes.

Jul–Aug 2021
Vessel: Salt Lake
Owner: Ji Sung Shipping
Flag state: South Korea

Activity: FAD setting activity during the annual WCPFC FAD closure period for 2021 (Jul–Sep). 6 A draught change of 5.9 to 5.4 was noted at the completion of this activity.

This activity was at the time prohibited under CMM 2021-01.

Oct 2021
Vessels: Lake Aurora and Volta Victory
Owner: Ji Sung Shipping and Galaxy International Maritime
Flag state: South Korea and Panama

Activity: Likely FAD setting activity outside of the annual WCPFC FAD closure periods on the high seas and within Kiribati EEZ. A correlated draught change was noted for Lake Aurora but not for Volta Victory.

Panama does not licence fishing vessels, meaning the FAD-setting activity of Volta Victory was potentially in contravention of its CNM participatory rights.

Mar–May 2022
Vessels: Lake Win and Volta Victory
Owner: Ji Sung Shipping and Galaxy International Maritime
Flag state: South Korea and Panama

Activity: Likely FAD setting activity outside of the annual closure period.

Panama does not licence fishing vessels, meaning the FAD-setting activity of Volta Victory was potentially in contravention of its CNM participatory rights.

Jul–Sep 2022
Vessels: Lake Dream
Owner: Ji Sung Shipping
Flag state: South Korea

Activity: FAD setting activity during the annual WCPFC FAD closure period for 2022 (Jul–Sep). 6

This activity was at the time prohibited under CMM 2021-01.

Oct–Dec 2022
Vessels: Sun Flower 7 and Volta Victory
Owner: Ji Sung Shipping and Galaxy International Maritime
Flag state: South Korea and Panama

Activity: FAD setting activity for which Sun Flower 7 was fined during the November 2022 flag-specified FAD closure period.

Volta Victory was also likely to be in contravention of Kiribati’s local legislation on FAD setting, and CNM participatory rights on the high seas.

Jan–Jun 2023
Vessels: 12 from Ji Sung Shipping Fleet + Volta Victory
Owner: Ji Sung Shipping and Galaxy International Maritime
Flag state: South Korea and Panama

Activity: There is a noticeable absence of carrier FAD setting activity, and a general reduction in AIS use by South Korean fishing vessels over the next 6 months while the Sun Flower 7 investigation was underway. There are minor uneconomic course deviations observed of some carriers while transiting the purse seine fishing grounds, which could warrant further investigation.

Dec 2023
Vessels: Sun Flower 7
Owner: Ji Sung Shipping
Flag state: South Korea

Activity: Sun Flower 7 resumes FAD setting activity outside of the annual closure period, but only on the high seas and no longer inside the Kiribati EEZ.

FAD-setting activity under this company changes to a survey or search and rescue style pattern, rather than zig zags.

Nov 2023–May 2024
Vessels: Lake Aurora
Owner: Ji Sung Shipping
Flag state: South Korea

Activity: Lake Aurora resumes FAD setting on the high seas adjacent to Kiribati EEZ. A draught change from 5.4 to 4.7 was noted at the completion of this activity.

CMM 2023-01 9 comes into force, whereby the new FAD closure period applies to 1 Jul–15 Aug each year, plus one additional month at the discretion of the flag-state.

May 2024
Vessels: Oceanus
Owner: Dongwon Industries
Flag state: South Korea

Activity: Likely FAD setting activity before the annual closure period, as characterised by high speed uneconomic course deviations in purse seine fishing grounds. Oceanus is owned by another large South Korean fishing company (Dongwon Industries), indicating that the FAD setting practice is wide-spread. This vessel transships at sea and may have observer reports available to confirm or deny this sample of activity as FAD setting.

Jun 2024
Vessels: Lake Win
Owner: Ji Sung Shipping
Flag state: South Korea

Activity: FAD setting activity continues right up until 2130 UTC on 30 June 2024, hours before the July closure period came into force.

Summary of findings and future monitoring and compliance analysis

As outlined in the WCPFC convention text and relevant CMMs, FAD setting is classified as ‘fishing’ activity, and carriers are classed as ‘fishing vessels’. Based on this distinction alone, carrier vessels operating under the WCPFC and CNM Participatory Rights (in this case Panama) are technically allowed to set and collect FADs outside of the annual closure period. It is unknown whether the flag states (in this case South Korea and Panama) impose any additional restrictions on carrier vessels conducting ‘fishing activity’ on the high seas of the WCPFC, but based on the observed FAD setting activity, it is presumed that no such restriction existed during the analysed period of time (or at least was not monitored or enforced). In addition to this, FAD-specific measures sometimes only specify the regulation of purse seine fishing vessels, rather than fishing vessels more broadly. This leaves a loophole for carrier vessels to exploit and highlights the need for regulation as their own vessel type, or to include them specifically under FAD-related measures (rather than incorporating them as fishing vessels).

Relationships were identified between three major South Korean (and subsidiary) companies which operate purse seine, longline, and fish carrier vessels. This relationship implies a degree of vertical integration, whereby fish carriers support purse seine fishing vessels through FAD setting and in-port transshipment (among other things). Vertical integration naturally raises the risk of IUU fishing activity, as the supply chain is internalised. This is evident when looking at the history of Silla Co Ltd, where its vessels (including Volta Victory) were caught illegally transhipping in the Liberia EEZ in 2013.

Analysis of FAD setting activity for fish carriers prior to July 2023 found that on multiple occasions, the FAD setting was in contravention of CMM 2021-01 closure period. The observed FAD setting activity was characterised by large, uneconomic, geometric movements, with high speed turns in predictable zig zag and repeating rectangular patterns (similar to survey or search and rescue patterns) in known purse seine fishing grounds, sometimes followed by a reduction in self reported draught while at sea.

From July 2023–June 2024 (since the resolution of the Sun Flower 7 investigation) there has not been any large-scale FAD setting activity observed from South Korean-owned carriers during the FAD closure periods, or within the Kiribati EEZ. There was however, a return to large scale FAD setting on the high seas beginning December 2023, which is outside of the annual closure period. Volta Victory, under the CNM of Panama, has not been observed conducting large scale FAD setting activity since the resolution of Sun Flower 7, indicating that there may have been some separate investigations occuring by that flag-state as well.

There was some activity observed from carriers during the 2023 FAD closure periods which consisted of smaller high speed turns and uneconomic deviations to course while transiting the purse seine fishing grounds. This could indicate attempts by carriers to continue FAD setting during closure periods without bringing too much attention to their activity, scaling down on the more obvious geometric patterns–although this requires further investigation to confirm the true nature of the activity, if not innocent transit. For carriers which transship at sea, observer reports may be available for further analysis (through flag-state request).

Example of five South Korean and Panama flagged (South Korean-owned) fish carriers conducting uneconomic transit activity through known purse seine fishing grounds during the 2023 FAD closure period in the area of interest (Kiribati EEZ and adjacent high seas).



The sheer number of FAD setting activities undertaken by these carriers over long periods of time, and in large areas of ocean, is a concern for marine pollution and is further enabled under WCPFC conservation and management measures which allows for the mass abandonment of FADs, and is not a reportable event for observers. While considering marine pollution during the AIS analysis of South Korean fish carriers, any attempted FAD recovery was expected to be characterised by slow speed manoeuvres and loitering activity while in and around purse seine fishing grounds. This type of activity was not observed during the analysed period, and indicates that FAD recovery was not routinely being conducted by these particular vessels.

Based on these findings, it becomes evident that there is a continued requirement for monitoring, analysis, and collaboration regarding the regulation of carrier vessels setting FADs in the WCPFC. This includes further discussion and improvements of WCPFC CMMs, information sharing processes, and international collaboration. The following observations have been compiled as a result of this analysis, for further consideration:

  • Carrier vessels should be closely monitored during the current closure period of 1 July–15 August 2024, in particular for more subtle manoeuvres that could indicate FAD setting.
  • Requests to flag-states or the WCPFC Secretariat for their additional FAD closure months (or CNM restrictions on carrier FAD setting in general) can be made by authorised enforcement agencies during relevant operations to analyse and report on any potential FAD setting activity.
  • Consideration for the additional flag-specified closure periods being made public for more effective monitoring and compliance efforts.
  • Consideration for further analysis outside of closure periods on the amount of FADs potentially being released and not recovered by carrier vessels, and whether this constitutes illegal dumping under international law.
  • Whether the role and classification of carriers as fishing vessels under the WCPFC Convention Text and ancillary CMMs should be reviewed, to determine whether fishing activities such as FAD setting should be allowed for carrier vessels (and if so, whether it should be monitored by observers).
  • Improved information sharing between flag-states and port-states for effective collaboration and implementation of PSM controls to enable the denial of port entry for more IUU vessels and overarching companies.


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References

  1. Ministry of Oceans and Fisheries. (2023, June 5). Subject: Thailand notification of a denial of port entry.
  2. WCPFC. (15 Jun 24). Record of fishing vessels (16 Jun 2022) [Dataset]. https://vessels.wcpfc.int/vessel/8847
  3. CMM 2021-01 - Conservation and Management Measure for Bigeye, Yellowfin and Skipjack Tuna in the Western and Central Pacific Ocean, WCPFC (2021). https://cmm.wcpfc.int/measure/cmm-2021-01 where relevant to South Korean flagged fishing vessels “it shall be prohibited to deploy, service or set on FADs in the high seas for one additional month of the year. Each CCM shall decide which one month (either April, May, November or December) shall be closed to setting on FADs by their fleets in the high seas for 2024, 2025, 2026 and notify the Secretariat of that decision by March 1, each year.”
  4. FAO. (2016, December). Agreement on Port State Measures to Prevent, Deter and Eliminate Illegal, Unreported and Unregulated Fishing. https://www.fao.org/3/i5469t/I5469T.pdf
  5. WCPFC. (15 Jun 24). Record of fishing vessels: Volta Victory VID 9215 (05 Nov 23) [Dataset]. https://vessels.wcpfc.int/vessel/9215
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  14. The Convention establishes a governing body known as the Commission which is comprised of representatives from members, cooperating non-members and participating territories (collectively, CCMs).
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  19. List of parties to the United Nations Convention on the Law of the Sea. (2023). In Wikipedia. https://en.wikipedia.org/w/index.php?title=List_of_parties_to_the_United_Nations_Convention_on_the_Law_of_the_Sea&oldid=1181375262#List_of_parties
  20. An assessment of plastic waste generation from FV in the WCP, and potential measures to improve onboard management. (2021, June 5). Francisco Blaha. http://www.franciscoblaha.info/blog/2021/6/3/an-assessment-of-plastic-waste-generation-from-fv-in-the-wcp-and-potential-measures-to-improve-onboard-management
  21. Progress of FADMO-IWG Priority Tasks for 2023. (2024, August 24). WCPFC. https://meetings.wcpfc.int/file/13017/download.
  22. Kelsey Richardson. (2015). Marine pollution originating from purse seine and longline fishing vessel operations in the Western and Central Pacific Ocean, 2003-2015. https://pacific-data.sprep.org/data-dashboard/marine-waste-pacific
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  25. CMM 2009-06 - Conservation and Management Measure on the Regulation of Transhipment, WCPFC (2009). https://cmm.wcpfc.int/measure/cmm-2009-06
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