FISH Act of 2025
- Sponsor
- Rep. Crenshaw, Dan [R-TX-2]
- Committees
- Natural Resources Committee (primary)
- Last action
- Apr 21, 2026
Bottom line
The FISH Act of 2025 creates a robust framework for the U.S. to unilaterally and multilaterally combat IUU fishing and forced labor in the seafood supply chain through blacklisting, sanctions, and enhanced enforcement.
What it actually does
This bill significantly strengthens the United States' efforts to combat illegal, unreported, and unregulated (IUU) fishing and associated forced labor globally. It establishes a mandatory public blacklist of foreign vessels and beneficial owners engaged in IUU fishing or forced labor, imposing severe consequences such as port access bans and import prohibitions. The bill also authorizes the Treasury Department to impose economic sanctions on entities involved in IUU fishing or endangered species trade, and enhances interagency coordination, data sharing, and international engagement to prevent these activities at their source.
Proponents argue
Supporters argue that this bill is crucial for protecting marine ecosystems from overexploitation, ensuring fair competition for the U.S. fishing industry, and upholding human rights by combating forced labor. They contend that IUU fishing undermines global food security, distorts markets, and often involves transnational criminal activity, making a comprehensive and aggressive U.S. response essential for national security and economic interests.
Opponents contend
Critics may contend that the bill's broad blacklisting and sanctioning powers could lead to diplomatic friction with foreign nations, potentially disrupt legitimate seafood supply chains, and impose significant compliance burdens on U.S. importers. Concerns might also be raised about the potential for overreach or the difficulty of accurately identifying beneficial owners and enforcing these measures globally without unintended consequences for innocent parties.
The bill is moderately complex due to its amendments to existing law and detailed definitions, requiring a careful read to grasp its full implications.
Section 4, amending Section 608 of the High Seas Driftnet Fishing Moratorium Protection Act
Establishment of a Black List (IUU Vessel List)
This provision mandates the Secretary of Commerce, in coordination with other agencies, to create and maintain a public list of foreign vessels, fleets, and their beneficial owners engaged in IUU fishing or fishing-related activities that support it, including those linked to forced labor. Vessels are added based on clear and convincing evidence, including being listed by international organizations, undermining conservation measures, or using forced labor. Once listed, vessels face prohibitions on U.S. port access, services, and their seafood products are banned from import.
Supporters argue
Proponents argue that a public, comprehensive blacklist with clear consequences is a powerful deterrent against IUU fishing and forced labor, providing transparency and enabling targeted enforcement. They assert it will protect marine resources, level the playing field for legitimate fishers, and uphold human rights.
Critics contend
Opponents might argue that the broad criteria for inclusion and the severity of consequences could lead to disputes with foreign governments, potentially impacting legitimate trade. Concerns could also be raised about the administrative burden and the potential for misidentification or insufficient due process for listed entities.
Tradeoffs
The provision balances the need for aggressive enforcement against IUU fishing and forced labor with the complexities of international maritime law, trade relations, and ensuring fair process for affected entities.
Section 5
Imposition of Sanctions
This section authorizes the Secretary of the Treasury to impose economic sanctions on foreign persons or vessels involved in IUU fishing, trade of endangered fish species, or providing material support to such activities. Sanctions include blocking property and interests in property within U.S. jurisdiction, and rendering individuals ineligible for U.S. visas or admission. The President retains authority for national interest waivers and humanitarian exceptions.
Section 7
Enhanced Enforcement Provisions
This section encourages the Commandant of the Coast Guard to increase high seas boardings of vessels suspected of IUU fishing and requires regular coordination with regional fisheries management organizations (RFMOs) to track corrective measures taken by countries whose vessels were boarded. It also mandates a report to Congress on Coast Guard counter-IUU patrols, incidents, and follow-up actions, including details on bilateral agreements and enforcement outcomes.
Section 8, amending Section 3551(c) of the Maritime SAFE Act
Improved Management at Regional Fisheries Management Organizations (RFMOs)
This section expands the responsibilities of the Interagency Working Group on IUU Fishing to include developing strategies for leveraging enforcement capacity against IUU fishing, particularly focusing on nations identified under existing law. It also mandates strategies for combating associated abuses like forced labor, utilizing resources from various U.S. government reports and enforcement actions related to forced labor and human trafficking.
Section 9, amending Section 3552 of the Maritime SAFE Act
Strategies to Optimize Data Collection, Sharing, and Analysis
This provision requires the Interagency Working Group on IUU Fishing to identify information and resources to prevent IUU and forced labor seafood from entering U.S. commerce. It mandates a report within three years detailing relevant data streams, barriers to sharing, recommendations for joint enforcement protocols, forensic resource development, enhanced field investigations, improved automated risk-targeting of seafood imports, and the establishment of an IUU fishing information sharing center.
Section 11
Preventing Importation of Seafood and Seafood Products from Foreign Vessels Using Forced Labor
This section directs the Commissioner of U.S. Customs and Border Protection (CBP), in coordination with the Secretary of Commerce, to develop a strategy for identifying and preventing imports of seafood harvested on foreign vessels using forced labor. CBP is also required to publish information regarding this strategy on its website.
Section 12
Reports and Studies on IUU Fishing and Related Issues
This section mandates several studies and reports: one by the Secretary of Homeland Security on the impact of new technology on IUU fishing and associated crimes; another by the Secretary of State on the influence of Russian and Chinese fishing industries and seafood reprocessing in China; and a multifaceted study by the National Academies of Sciences, Engineering, and Medicine on the occurrence, economic costs, and effectiveness of response strategies for IUU fishing and forced labor, with an authorization of $4,000,000 for this study.
A foreign vessel can be added to the IUU vessel list if it has the same beneficial owner as another foreign vessel already on the list at the time of an infraction.
Section 4(c)(2)(G)
Why it matters:This is standard legislative practice for defining the scope of a new authority, but its impact on expanding the reach of the blacklist to entire ownership structures is substantial and could be easily overlooked.
Case for: Proponents argue this is critical to prevent bad actors from simply re-flagging or re-registering vessels under the same ownership to evade blacklisting. It targets the ultimate beneficiaries of IUU fishing.
Case against: Critics might argue this could lead to overreach, potentially blacklisting legitimate vessels under the same beneficial owner due to infractions by a single vessel, especially if ownership structures are complex or opaque.
Estimated impact: Significantly expands the potential number of vessels subject to blacklisting and sanctions by targeting ownership networks rather than just individual vessels.
The import of seafood or seafood products caught, processed, or transported by foreign vessels on the IUU vessel list is prohibited.
Section 4(d)(3)
Why it matters:This is a key enforcement mechanism, but its full scope (covering processing and transport, not just catching) might not be immediately apparent without careful reading. It's standard for enforcement details to be in such subsections.
Case for: Proponents argue this comprehensive import ban is essential to close loopholes, preventing IUU-caught fish from entering the U.S. market even if processed or transported by a different vessel in the supply chain. It targets the entire illicit supply chain.
Case against: Critics might argue that tracing seafood through processing and transport stages can be extremely complex, potentially leading to legitimate products being caught in the ban or imposing significant burdens on importers to verify every step of the supply chain.
Estimated impact: Creates a broad import barrier for any seafood linked to blacklisted vessels, regardless of where or by whom it was processed or transported after being caught.
The Secretary of the Treasury may impose sanctions on any foreign person or vessel that has participated in the sale, supply, purchase, or transfer of a fish species that is an endangered species, as defined in the Endangered Species Act of 1973.
Section 5(a)(1)(A)
Why it matters:It's a specific detail within a broader list of sanctionable activities. While related to marine conservation, it expands the Treasury's sanctioning authority beyond just IUU fishing to illegal wildlife trade in fish. This is standard for defining the scope of authority.
Case for: Proponents argue that combating illegal trade in endangered fish species is a critical conservation priority, and leveraging Treasury's sanctioning power provides a potent tool to disrupt these illicit networks, complementing existing wildlife protection laws.
Case against: No specific opposition is typically raised against combating illegal trade in endangered species, though concerns about the practicalities of identification and enforcement in global markets could be discussed.
Estimated impact: Expands the scope of Treasury's sanctioning authority to include illegal trade in endangered fish species, providing a new enforcement avenue for wildlife conservation.
The cargo of seafood from a blacklisted foreign vessel shall not be subject to seizure and forfeiture if the importer has paid for the cargo and did not know, or did not have any reason to know, that the seafood was the product of IUU fishing.
Section 4(e)(2)
Why it matters:This is a standard carve-out to protect innocent parties, often placed in enforcement sections. It's important for due diligence but can be missed in a quick read.
Case for: Proponents argue this exception protects legitimate U.S. businesses that unknowingly import IUU seafood, placing the burden on bad actors while encouraging importers to conduct due diligence. It prevents unfair punishment for those acting in good faith.
Case against: Critics might argue that the 'did not know, or did not have any reason to know' standard could be difficult to prove or disprove, potentially creating a loophole for some importers to avoid accountability if due diligence is not rigorously defined and enforced.
Estimated impact: Provides a defense for legitimate importers, but also implicitly creates an incentive for robust supply chain verification to demonstrate lack of knowledge.