A fundamental restructuring of the bill. v3 significantly narrows the scope of sanctions and enforcement mechanisms related to illegal, unreported, and unregulated (IUU) fishing and forced labor, removing direct import prohibitions and asset blocking. It also introduces new procedural safeguards for vessel owners and reduces authorized appropriations for key programs.
Fighting Foreign Illegal Seafood Harvests Act of 2025
- Sponsor
- Sen. Sullivan, Dan [R-AK]
- Committees
- Commerce, Science, and Transportation Committee (primary)
- Last action
- Mar 24, 2026
Bottom line
The FISH Act of 2025 enhances U.S. and international tools to deter IUU fishing and forced labor in the seafood industry through targeted sanctions, increased enforcement, and improved data and collaboration.
What it actually does
This bill, known as the FISH Act of 2025, significantly strengthens U.S. efforts to combat illegal, unreported, and unregulated (IUU) fishing and associated forced labor globally. It establishes a public list of foreign vessels and beneficial owners engaged in IUU fishing, imposes visa sanctions on these owners, and mandates increased Coast Guard enforcement and international cooperation. The bill also enhances interagency coordination, data sharing, and technical assistance to foreign nations, while requiring several studies on the impacts of IUU fishing and new technologies.
Proponents argue
Supporters argue that this bill is crucial for protecting marine ecosystems, ensuring fair competition for the U.S. fishing industry, safeguarding national security interests, and combating severe human rights abuses like forced labor. They contend that IUU fishing undermines sustainable fisheries, distorts global markets, and often funds criminal enterprises, making a comprehensive and aggressive approach necessary.
Opponents contend
Critics, if any, might raise concerns about the potential for diplomatic friction with foreign nations due to unilateral sanctions and increased enforcement actions. They might also argue that the bill's focus on enforcement could disproportionately affect legitimate fishing operations or that it does not sufficiently address the underlying economic and governance issues that drive IUU fishing and forced labor.
The bill is moderately complex due to its technical nature and amendments to existing law, requiring a focused read to grasp its full implications.
Section 4
Establishment of an IUU Vessel List
This section amends existing law to require the Secretary of Commerce, in coordination with other agencies, to develop and maintain a public list of foreign vessels, fleets, and their beneficial owners engaged in IUU fishing or supporting such activities. It specifies criteria for inclusion on this list, including being listed by an international fishery management organization, undermining conservation measures, or providing services to listed vessels. The bill outlines procedures for adding and removing entities from the list, including notification and a hearing process, and requires the publication of detailed vessel information.
Supporters argue
Supporters argue that a public, comprehensive IUU vessel list provides a powerful deterrent against illicit fishing activities by increasing transparency and enabling targeted enforcement. It offers a clear mechanism for identifying bad actors and holding beneficial owners accountable, thereby protecting marine resources and legitimate fishing operations.
Critics contend
Some may contend that the criteria for inclusion, particularly regarding 'partial information' or 'reason to believe,' could lead to arbitrary listings or diplomatic disputes. Concerns might also be raised about the due process for beneficial owners and the potential for misidentification, which could harm legitimate businesses.
Tradeoffs
The provision balances the need for aggressive enforcement against the potential for diplomatic friction and the administrative burden of maintaining a robust, accurate, and legally defensible list. It also navigates the tension between transparency and the protection of sensitive intelligence used to identify IUU activities.
Section 5
Visa Sanctions for Foreign Persons
This section makes foreign persons who are beneficial owners of vessels on the newly established IUU vessel list inadmissible to the United States and ineligible for visas or other entry documentation. Any existing visas for such individuals would be revoked. The President is granted authority to waive these sanctions in the national interest, and specific exceptions are provided for authorized intelligence activities, compliance with international agreements, safety of vessels and crew, and cases where ownership was established through force or fraud.
Section 6
International Agreements and Transparency
This section encourages the President to consider the impacts on IUU fishing and forced labor when negotiating international agreements, ensuring such agreements strengthen efforts to combat these issues without compromising higher national interests. It also urges the Federal Government to encourage other nations to ratify relevant treaties like the High Seas Fishing Compliance Agreement and the Port State Measures Agreement, and to pursue multilateral initiatives to raise international ambition. Furthermore, it mandates that any non-binding instruments concluded under this section be subject to specific reporting requirements to Congress, enhancing transparency.
Section 7
Enhanced Enforcement by the Coast Guard
This section directs the Commandant of the Coast Guard to strive to increase observation and boarding of vessels suspected of IUU fishing on the high seas to the greatest extent practicable. It also requires the Administrator of NOAA, in consultation with the Coast Guard and State Department, to regularly coordinate with regional fisheries management organizations (RFMOs) to track corrective measures taken by countries whose vessels have been boarded. A report to Congress is mandated within three years, detailing bilateral agreements, IUU incidents, actions taken, and potential future enforcement strategies.
Section 8
Improved Management at Regional Fisheries Management Organizations (RFMOs)
This section amends the Maritime SAFE Act to expand the duties of the Interagency Working Group on IUU Fishing. The Working Group is now tasked with developing strategies to leverage enforcement capacity against IUU fishing and associated abuses like forced labor, utilizing resources such as the List of Goods Produced by Child Labor or Forced Labor and the Trafficking in Persons Report. Additionally, the Secretary of State, in coordination with the Coast Guard and NOAA, must identify RFMOs lacking high seas boarding and inspection programs, assess obstacles, and take appropriate action to increase their implementation.
Section 9
Strategies to Optimize Data Collection, Sharing, and Analysis
This section amends the Maritime SAFE Act to require the Interagency Working Group on IUU Fishing to develop strategies within three years to optimize data collection, sharing, and analysis. The goal is to prevent fish and fish products from IUU fishing and forced labor from negatively affecting U.S. commerce, without burdening legitimate seafood. The strategy must identify relevant data streams, barriers to sharing, and provide recommendations for joint enforcement protocols, forensic resources, field investigations, automated risk-targeting, and information dissemination, including establishing an IUU fishing information sharing center. It also requires an analysis of other countries' IUU policies.
Section 10
Investment and Technical Assistance in Fisheries Sector
This section encourages the Secretaries of State and Commerce, in consultation with other relevant agencies, to increase support for programs that provide technical assistance, institutional capacity building, and investment to foreign nations' fisheries sectors. The goal is to help these nations achieve sustainable fisheries management and combat IUU fishing and fishing involving forced labor. The focus of this support is encouraged to be on priority regions and flag states identified under existing law. The Interagency Working Group on IUU Fishing is also tasked with analyzing U.S. capacity-building expertise and resources, including potential avenues for public-private and multilateral collaboration.
Section 11
Strategy to Identify Seafood from Forced Labor
This section requires the Secretary of Commerce, in coordination with other relevant agencies, to develop and publish a strategy for utilizing relevant United States Government data to identify seafood harvested on foreign vessels using forced labor. The information regarding this strategy must be made publicly accessible on a website.
Section 12
Mandated Studies and Reports
This section mandates several studies and reports: (a) The Secretary of Homeland Security, with NOAA support, must study the impact of new technology (e.g., drones, satellite Wi-Fi) on IUU fishing and associated crimes within one year. (b) The Secretary of State, with Commerce support, must study the collaboration between Russian and Chinese fishing industries and China's role in global seafood reprocessing, including classified and unclassified portions, within two years. (c) NOAA must arrange for the National Academies of Sciences, Engineering, and Medicine to conduct a multifaceted study quantifying IUU fishing, evaluating its costs to the U.S. and global economies, and assessing response strategies, with $2,000,000 authorized for this purpose. A report on the National Academies' findings and recommendations is due to Congress within 24 months.
This subsection clarifies that the Secretary may continue to take enforcement actions described in the High Seas Driftnet Fishing Moratorium Protection Act (16 U.S.C. 1826i(c)(2)) as it existed *before* the enactment of the FISH Act of 2025, against vessels, owners, and operators on the new IUU vessel list.
Section 4(d)
Why it matters:This is standard legislative practice to ensure continuity of existing enforcement authorities when amending a statute. It prevents a gap in enforcement powers during the transition to the new IUU vessel list framework.
Case for: Supporters would argue that preserving existing enforcement tools ensures that the U.S. government does not lose any capabilities in its fight against IUU fishing while the new, expanded framework is implemented. It provides a stable legal basis for continued action.
Case against: No specific case against this technical continuity provision is typically made. However, if the prior enforcement actions were controversial, critics might argue that they should have been re-evaluated or explicitly re-authorized rather than implicitly carried forward.
Estimated impact: Maintains the full scope of existing enforcement powers, which include potential port restrictions and other measures, against vessels newly identified under the expanded IUU list criteria.
This subsection designates any memorandum of understanding or other non-binding instrument concluded to further the objectives of Section 6 (international agreements) as a 'qualifying non-binding instrument' for purposes of section 112b of title 1, United States Code. This means such instruments are subject to specific reporting requirements to Congress.
Section 6(c)
Why it matters:This is a transparency and oversight measure, ensuring that executive branch agreements, even non-binding ones, related to this Act's objectives are reported to Congress. It's a standard mechanism for congressional oversight of foreign policy.
Case for: Proponents would argue that this provision enhances congressional oversight of the executive branch's international engagements, ensuring transparency and accountability for agreements made under the Act's authority, even if they are not formal treaties.
Case against: No specific case against this transparency measure is typically made. However, some in the executive branch might privately prefer more flexibility in international diplomacy without additional reporting burdens.
Estimated impact: Increases transparency and congressional oversight of non-binding international agreements related to combating IUU fishing and forced labor.
This section explicitly states that the authorities and requirements provided in this Act, and the amendments made by this Act, shall not include any authority or requirement to impose sanctions on the importation of goods or related to sanctions on the importation of goods.
Section 14
Why it matters:This provision likely represents a compromise to limit the bill's economic impact, avoid potential trade disputes or World Trade Organization (WTO) challenges, and focus enforcement efforts at the source rather than at the point of import. It could also be a concession to industries concerned about supply chain disruptions.
Case for: Supporters would argue that this limitation prevents the bill from becoming a trade barrier, allowing the U.S. to focus its efforts on combating IUU fishing and forced labor at their sources without disrupting global commerce or inviting retaliatory tariffs.
Case against: Critics might argue that by explicitly excluding import sanctions, the bill removes a powerful tool for preventing illicit seafood from entering the U.S. market. They might contend that without the ability to block imports, the U.S. is less able to protect its domestic industry and consumers from products linked to IUU fishing and forced labor.
Estimated impact: Significantly narrows the scope of potential economic sanctions under the Act, focusing enforcement on vessels and individuals rather than the goods themselves.