The Fighting Foreign Illegal Seafood Harvests (FISH) Act of 2025 directs the Department of Commerce (through NOAA) to create and publish an IUU (illegal, unreported, and unregulated) vessel list of foreign vessels, fleets, and beneficial owners the United States determines are involved in IUU fishing or fishing associated with forced labor. Vessels placed on the list face port‑access and servicing bans in U.S. waters and their seafood products are barred from U.S. import channels; NOAA must issue implementing regulations within 12 months and the bill provides targeted appropriations.
The measure pairs trade prohibitions with a Treasury sanctions authority that can block property and revoke visas for listed actors, expands interagency information sharing and Coast Guard high seas boarding priorities, and funds studies, data‑sharing strategies, and international capacity building to reduce IUU fishing at source. For compliance officers, importers, maritime service providers, and diplomacy teams, the bill changes how U.S. authorities will target foreign fleets and supply chains rather than relying solely on downstream import enforcement.
At a Glance
What It Does
The bill requires NOAA (Secretary of Commerce) to develop and publish an IUU vessel list, with criteria for inclusion (including RFMO lists, evidence of forced labor, transshipment support, and sanctions designations). Listed vessels are barred from U.S. ports and services and seafood from those vessels is prohibited from importation; the Treasury Secretary can impose blocking sanctions and visa restrictions on persons or vessels tied to IUU activity.
Who It Affects
Foreign distant‑water fleets, their beneficial owners, transshipment and support vessels, U.S. seafood importers and processors, maritime service providers, the U.S. Coast Guard, CBP, and NOAA enforcement and data units, plus regional fisheries management organizations (RFMOs) and partner nations where capacity building is targeted.
Why It Matters
The bill shifts U.S. strategy from primarily downstream import controls to combining a public blacklist, trade and port denials, and extraterritorial sanctions—linking supply‑chain enforcement with maritime interdiction and international capacity‑building, which could materially change how seafood risk is managed in commerce and diplomacy.
More articles like this one.
A weekly email with all the latest developments on this topic.
What This Bill Actually Does
At its core the FISH Act directs NOAA, working with State, CBP, and Labor, to operate a public IUU vessel list that identifies foreign vessels, fleets, and beneficial owners the United States concludes are engaged in IUU fishing or supporting it. The statute sets multiple bases for inclusion: being listed by an RFMO, undermining RFMO measures (for example exceeding catch limits or violating allocation rules), being reported by U.S. authorities where the flag state fails to act, evidence of forced labor or related enforcement actions (including CBP withhold‑release orders or Treasury sanctions), and providing services like transshipment to IUU‑listed vessels.
The agency must publish identifying information where available (IMO or other unique vessel identifiers, MMSI/call sign, owner addresses) and explain the basis for each listing.
The bill builds procedural guardrails: nominations may come from executive agencies, certain partner countries, or civil organizations with data agreements; NOAA must notify a vessel’s beneficial owner and allow up to 90 days to provide information before adding a vessel; and the Secretary must publish removal and addition procedures. Listings are generally permanent, but the statute creates narrow removal pathways—automatic removal where a prior CBP withhold‑release order is revoked, removal if an RFMO delists the vessel, or removal on application where the owner proves no IUU/forced‑labor involvement for five years and demonstrates corrective actions.Consequences are operational and trade‑facing.
A listed vessel is prohibited from using U.S. ports and services (except for inspection, enforcement, or force majeure) and U.S. vessels may not service them except for safety or enforcement. Seafood caught, processed, or transported by listed vessels is barred from U.S. import and subject to seizure and forfeiture under customs law, with a statutory exception protecting importers who paid for cargo and lacked reason to know it derived from IUU fishing.
Separately, the Treasury Secretary may impose IEEPA‑style blocking sanctions and visa bans on persons and vessels involved in IUU or trade in endangered species, with statutory waiver and humanitarian exceptions.Implementation and capability building are prominent. The bill requires NOAA to issue regulations within 12 months, authorizes $20 million per year (FY2025–2030) for Commerce to run the program, tasks the Interagency Working Group on IUU Fishing to improve data collection and sharing and to incorporate forced‑labour and trafficking risk indicators, directs CBP to develop strategies to catch seafood tied to forced labor, and strengthens Coast Guard boarding priorities, reporting, and international capacity‑building efforts.
It also funds studies on technology, geopolitical supply‑chain links (including China–Russia interactions), and a National Academies study to quantify economic and enforcement impacts.
The Five Things You Need to Know
NOAA must base IUU inclusions on a 'clear and convincing' evidence standard and may rely on RFMO lists, CBP enforcement actions (including withhold‑release orders), Treasury sanctions, and U.S. investigations.
Before NOAA can add a vessel, the agency must notify the beneficial owner and allow up to 90 days for the owner to submit information for review.
Entries generally remain on the list permanently; removal requires either an RFMO delisting, revocation of a CBP withhold‑release order, or a successful owner application showing no IUU or forced‑labor involvement for the prior five years and demonstrable remediation.
Seafood from listed vessels is barred from U.S. import and subject to seizure and forfeiture, but the cargo is exempted if an importer can show it paid and did not know, and had no reason to know, the seafood was from IUU fishing.
The Treasury Secretary may impose blocking sanctions and revoke visas for persons or vessels tied to IUU or trade in endangered species, but the President may waive sanctions in the national interest and statute includes humanitarian, intelligence, and treaty‑compliance exceptions.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Establishes the IUU vessel list and criteria for listing
This section creates the statutory authority for NOAA to develop, maintain, and publish a public IUU vessel list. It enumerates multiple, alternate bases for inclusion—from RFMO listings to evidence of forced labor to vessels that provide services (transshipment, refueling) to IUU vessels. Practically, this gives NOAA a broad menu of triggers to name not only fishing vessels but also support ships and beneficial owners, expanding the scope of actors that can be targeted beyond the vessel seen at sea.
Operational consequences for listed vessels
The bill imposes immediate operational penalties: U.S. ports and services are off‑limits to listed vessels (except inspection/enforcement or force majeure), U.S. vessels may not service them except for safety or enforcement, and listed vessels cannot travel U.S. territorial seas except in innocent passage. The statute also explicitly prohibits imports of seafood linked to those vessels and ties enforcement to existing customs seizure and forfeiture procedures, creating an integrated port‑and‑trade response.
Enforcement mechanics, exceptions, and removal rules
The statute makes listed vessels and their cargo subject to seizure and forfeiture, but protects importers who can credibly show lack of knowledge about IUU provenance. Listings are effectively permanent unless specific removal triggers occur: RFMO delisting, revocation of a CBP withhold‑release order, or a successful owner application showing five years free of IUU/forced‑labor issues and corrective action. NOAA must publish procedures for additions/removals and update the public list continuously and in the Federal Register annually.
Treasury sanctions and immigration consequences
This section authorizes the Treasury Secretary to use IEEPA authorities to block property and interests of foreign persons, vessels, or entities involved in IUU or trade in endangered species, and to bar their access to U.S. visas and admission. It also spells out penalties for violations, national‑interest waivers, and exceptions for humanitarian, intelligence, and treaty obligations—giving the executive branch a powerful extra‑territorial enforcement tool tied to the list and independently applicable.
Enforcement posture, data strategies, and import screening
The bill instructs the Coast Guard to prioritize high‑seas boarding and inspection of suspected IUU vessels and to report back to Congress on resultant actions; it charges the Interagency Working Group with mapping data streams, identifying sharing barriers, and proposing an IUU information‑sharing center. CBP is tasked to develop a strategy specifically to identify seafood imports tied to forced labor, and the Working Group must propose automated risk‑targeting improvements to trade systems—linking maritime observation with import screening.
Capacity building, studies, and funding
The bill encourages State, USAID, MCC, and multilateral engagement to strengthen fisheries management in priority regions and asks the Working Group to inventory U.S. capacity‑building assets. It mandates technology and geopolitical studies (including a Russia‑China seafood supply analysis), commissions a National Academies economic and incidence study, and boosts Sea Grant appropriations—providing both research and program funding to support the enforcement and prevention agenda.
This bill is one of many.
Codify tracks hundreds of bills on Foreign Affairs across all five countries.
Explore Foreign Affairs in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- U.S. coastal and commercial fishing sectors: The bill aims to reduce competition from illegally caught seafood entering U.S. markets, which may preserve prices and resource sustainability for compliant U.S. fleets and processors.
- Labor and human‑rights advocates: By explicitly linking forced‑labor evidence to IUU listings and directed CBP strategies, the law creates new legal levers and visibility for labor‑abuse claims in seafood supply chains.
- NOAA, CBP, and Coast Guard enforcement units: The legislation provides clear mandates, information‑sharing duties, and appropriations to support a coordinated enforcement posture and new investigative tools.
- Responsible importers and traceability vendors: Companies that invest in vessel‑level traceability and due diligence stand to differentiate products and reduce seizure risk, creating a market advantage.
- Regional fisheries management organizations (RFMO) partners and capacity recipients: Targeted capacity building and diplomatic encouragement aim to strengthen RFMO measures and partner nations’ enforcement capabilities, improving regional fisheries governance.
Who Bears the Cost
- Foreign distant‑water fleets and beneficial owners (particularly flags of convenience): They face operational restrictions, reputational harm from public listing, denial of port services, and potential asset blocks and visa bans.
- U.S. seafood importers and processors: Firms will face higher compliance, documentation, and due‑diligence costs to prove seafood provenance and may experience shipment delays or seizures tied to listed vessels.
- Maritime service providers and insurers: Companies providing fuel, supplies, transshipment, or insurance to listed vessels risk losing access to U.S. business or being subject to sanctions and reputational risk.
- U.S. agencies required to implement the program: NOAA, CBP, and the Coast Guard must scale identification, legal review, and enforcement capacity; the statutory tasks may outstrip appropriations and create operational strain without sustained funding.
- Diplomatic relations with flag states: The unilateral list and sanctions authority create potential diplomatic friction and increased demand on State Department resources to defend listings and manage bilateral consequences.
Key Issues
The Core Tension
The central dilemma is speed versus legitimacy: the United States needs tools to shut down IUU fishing and related forced‑labor abuses quickly, but creating a fast, unilateral blacklist and attaching trade and sanction penalties risks misidentifying actors, undermining multilateral RFMO processes, and imposing heavy costs on legitimate trade—so the bill trades decisiveness and extraterritorial reach for stricter procedural and evidentiary burdens and a heavy implementation burden on agencies and trade actors.
The bill packs a lot of authority into a single program and that creates practical and legal tensions. First, the evidentiary and procedural design: NOAA may list based on a 'clear and convincing' standard, but it must also rely on intelligence and foreign‑sourced evidence that may be classified or contested.
The 90‑day owner notification gives a narrow window for a rebuttal; because listings are generally permanent absent narrow removal paths, a mistaken or politically motivated designation could be costly and difficult to reverse. The statute attempts to balance zeal with safeguards—allowing owner applications for removal and recognizing RFMO delistings—but the removal thresholds (including a five‑year clean period) are high and will prolong commercial disruption.
Second, operationalizing import and port‑access bans depends on connecting maritime observations, RFMO outputs, customs forensic capacity, and trade‑data risk targeting. CBP’s innocence exception for importers protects downstream actors who lacked reason to know, but it also creates a defense that may be hard to adjudicate quickly.
The interplay with customary international law and RFMO processes matters: the bill encourages RFMO harmonization but grants the U.S. independent listing authority, which can be effective but risks duplication or conflict with multilateral processes. Finally, the Treasury’s use of IEEPA and visa blocks is powerful but extraterritorial; aggressive application could trigger diplomatic pushback or legal challenges from affected states or companies.
All of this rests on adequate funding, interagency coordination, and the technical capacity to link vessel identity to supply chains reliably.
Try it yourself.
Ask a question in plain English, or pick a topic below. Results in seconds.