IMO/INTERPORTPOLICE Symposium

The illegal wildlife trade is estimated to be worth US$20 billion a year and, with more than 80% of global trade transported by sea, the audience heard how shipping offers criminals an attractive method by which to move their illicit goods around the world.  

The symposium was opened by Dr Heike Deggim, Director of IMO’s Maritime Safety Division. She outlined the measures IMO has taken to tackle maritime-related wildlife crime as well as corruption and fraud and invited law enforcement and border control agencies to take part in future sessions of the FAL Committee, describing it as the best forum for improving the facilitation of maritime transport. She called on governments, police and border control agencies, and the ports and shipping sector to work closer together to promote the facilitation of international maritime traffic.  

In his opening remarks, Jay Grant, Secretary-General of INTERPORTPOLICE, saluted the FAL Committee’s actions to improve cooperation and communication through enhanced use of electronic data exchange and single window systems, and expressed support for IMO’s guidance on countering illegal activities.  

Mr Grant said it was important for the industry to take – and be seen to take – action to deter and detect such activities. He described one of the aims of INTERPORTPOLICE as helping to “dovetail law enforcement and security measures put in place by port and airport police departments, border control agencies and security service providers with those of the maritime industry”, and he challenged the law enforcement community, governments and the maritime and port sectors to engage more with each other.  

The Buckingham Palace Declaration 

One of the day’s key moments was the signing of the Buckingham Palace Declaration by Jay Grant on behalf of INTERPORTPOLICE. The Declaration is a landmark agreement which commits signatories to take real steps to shut down routes exploited by wildlife traffickers. IMO was one of its original signatories in 2016. 

Lord Hague of Richmond, Chair of The Royal Foundation of the Prince and Princess of Wales, the driving force behind the Declaration, welcomed INTERPORTPOLICE to the network of organizations working to strengthen defences against wildlife trafficking.  

“The criminals behind it cannot be allowed to act with impunity”, he said, adding, “We must all do what we can to rid the world of this awful trade”. 

He hailed the IMO Facilitation Committee’s approval in 2022 of guidelines on the prevention and suppression of the illicit international trade in wildlife on ships. See FAL.5/Circ.50. 

Describing the maritime trade as “the backbone of the UK’s economy”, Lord Hague said the country was a leader in both the maritime industry and maritime technology. But he warned, too, that the sector plays an “unwitting but significant” role in wildlife smuggling.  

Lord Hague outlined how criminals’ unlawful trade in wildlife is now converging with that of narcotics and human trafficking, illustrating the sophistication of these networks which also have links to piracy and terrorism. He explained how The Royal Foundation’s United for Wildlife programme develops partnerships to combat and eradicate the illegal wildlife trade. Its work has contributed, he said, to several hundred arrests worldwide.  

Speaking after the Declaration was signed, John Dodsworth of WWF UK characterised illegal wildlife crime as more than just a conservation problem. It is, he said, a global security, economic and public health issue, and one that for the perpetrators is low-risk but high-reward. Tackling it is no small task, he said, but progress is being made.  

Maritime corruption: “It takes two to tango” 

Cecilia Müller Torbrand, CEO of the Maritime Anti-Corruption Network (MACN), opened a  
round-table discussion with a presentation on the issue of maritime corruption. She explained how being spread across many jurisdictions creates a complex environment for the shipping industry which, alongside the contribution it makes to countries’ economic development, exposes the sector to the risk of corruption.  

Her organization, which covers more than 180 members and represents more than 50% of world tonnage, has recorded 50,000 incidents of corruption in the 10 years it has existed, but she described this as the tip of the iceberg, given the number of port calls made by ships.  

Ms Müller Torbrand welcomed progress made at IMO level, for instance guidance approved by the FAL Committee to combat maritime corruption in 2022, but she called for more collective action to fight the problem noting, “It takes two to tango”.  

MACN is working with ship managers, ship owners, port agents and flag registries, she said, but cautioned her audience: “This is global. We all need to work together to combat this at port level”. 

She was asked what seafarers should do if demands for cash were made of them.  

“I never recommend they pay cash,” she responded. “If payments are made and they say it’s not valid, pay electronically so it can be challenged afterwards. And it takes the pressure off the captain.” 

Rob Lomas, of International Registries (UK) Ltd, said corruption is affecting the profitability of the shipping industry - but sounded an optimistic note: “I foresee a time when we start to turn the tide...It’s only through engagement that we can make progress. I am amazed at progress made in the last year or two. It indicates governments realise something has to be done about corruption.” 

Captain Himanshu Chopra of the global provider of ship management services, Anglo Eastern, described corruption in the maritime sector as an unnecessary burden on seafarers.  

“They’re trained to run ships and vessel operations; they shouldn’t have to deal with corrupt officials in port,” he stated.  

Asked what he thought could reduce the risk, he responded, “Most issues encountered can be related to the inward port clearance process or clearing quarantine. If we can digitalise the process before a vessel comes into port, this reduces risks,” he said. 

Mandatory Maritime Single Window deadline 

Rhona Macdonald from the International Association of Ports and Harbors (IAPH) gave a presentation on “FAL in context: Key outputs from the Symposium, Maritime Single Window 2024 – A window of opportunities”. Organised jointly by IMO, IAPH and BIMCO, with the support of the International Port Community Systems Association (IPCSA), and held at IMO in January 2023, it marked one year to go until the compulsory introduction of Maritime Single Windows (MSWs) for the electronic exchange of information required on ships’ arrival at a port, during their stay and on departure.  

She ran through the main topics the event covered: Why MSWs are important and the opportunities they bring; barriers to their implementation; different types of MSW structures; the benefits of interoperability and harmonisation of systems; the need for a good governance structure; and the necessity to build in safeguards against cyber risks.  

Read more about the symposium, "Maritime Single Window 2024 – A window of opportunities" here.  

Addressing criminal activity in the supply chain 

Captain Cyrus Mody, of ICC International Maritime Bureau (IMB), delivered a presentation on how his organization confronts incidents of maritime crime and malpractice. The IMB, established in 1981, is a non-profit making membership organization which describes its main task as protecting the integrity of international trade by identifying and investigating frauds, spotting new criminal methods and trends, and highlighting other threats to trade.   

His presentation covered the different types of criminal practises IMB sees: drugs, illegal fishing, illegal migration, piracy, dumping, cyber-crime, but also white-collar crimes such as fraud, which are harder to detect. 

Captain Mody said there is currently no system in place whereby financial institutions targeted by fraudsters can easily share information, and, because detecting these sorts of crimes is so challenging, banks can find themselves being hit time after time.  

The most required document in the maritime business is the Bill of Lading, which accords ownership of goods. It is, Captain Mody said, the only point at which a shipment of goods is connected to the financing of that shipment.  

He explained that bank staff are not required to make checks on information on the Bill of Lading. One technique that fraudsters’ try, therefore, is using a container ship’s name on the Bill of Lading when the actual ship is carrying oil and therefore must be an oil tanker. Another is documenting a heavier weight of cargo on the Bill of Lading than its actual weight - as a way of leveraging more finance from a bank. 

Sanctions evasion is another problem. Captain Mody said a typical method used by sanctions evaders is the use of convoluted shipping routes with cargos being discharged and reloaded at several ports and onto different vessels, information which doesn’t match that on the Bill of Lading. And he highlighted an increase in instances of ships “going dark” for a few weeks near particular ports which, whilst hard to prove the reason, looks suspicious.  

As an aside, Captain Mody said that more than 95% of false Bills of Lading identified by his organization are issued by non-vessel owning cargo carriers (NVOCCs) and encouraged all NVOCCs to register with IMB, thus signing up to a code of conduct on the issuing on Bills of Lading.  

Whilst there are fewer incidents now of so-called phantom ships, Captain Mody said, IMB is seeing an increase in the creation of false ship registries and cases of ships going dark or switching off automatic identification systems (AIS), both of which are difficult to identify and investigate.  

Another type of crime that Captain Mody spoke about was that of counterfeiting. IMB operates the world’s only hologram image register which safeguards hologram copyright and enables authentication. They do so on behalf of the International Hologram Manufacturers Association which designs and makes holograms that appear on banknotes or event tickets, for example, all of which must be registered.   

Falsifying of holograms, along with the illegitimate use of a company’s letterhead and logos is seen in cases of high yield investment frauds where, for instance, fake personas are created to open bank accounts.  

Protect, prevent, prepare 

Chris Trelawny joined INTERPORTPOLICE as its Deputy Secretary General from IMO. Addressing the symposium, he explained it is a non-profit organization that links those involved in policing and security to enable the sharing of expertise. Its main areas of work cover air and sea ports, transportation, critical national infrastructures and borders. The organization does not have an operational enforcement role, but it works with police, security authorities and international organizations to help identify risks and reduce vulnerability.  

Through the dissemination of the INTERPORTPOLICE Community Security Best Practices, including protective security management systems and the SeeSayAct programme, the development of international standards, the sharing of learning from after-action reviews, and operational training, INTERPORTPOLICE aims to build resilience against the threat of trans-national terrorism, criminality and sabotage.  

Mr Trelawny said that, using a strategy of “protect, prevent, prepare”, INTERPORTPOLICE works to address and mitigate threats by supporting members to learn from previous incidents, support effective communication systems and strategies, and address emerging challenges.  

The symposium was closed by Julian Abril Garcia, Head of the Facilitation Section at IMO. He noted that the FAL Committee was expected the following day to adopt a resolution on amendments to the FAL Convention urging contracting governments to put in place new measures in the national maritime transport facilitation programmes to include the need to combat illicit activities.  

Mr Abril Garcia called on police, border control and other agencies, as well as port and shipping communities, to work alongside national delegations to the FAL Committee or through their representative bodies who hold consultative status with IMO, including INTERPORTPOLICE, IAPH, WWF and ICC IMB.  

“Today's symposium has looked at ways [illicit activities] can be oppressed”, he said, adding, “It is one step in an ongoing process to identify existing and emerging challenges to the smooth running of international maritime traffic and to develop practical solutions to address them”. 

Read more about the symposium on maritime law enforcement here, including presentations.   

Photos of the event can be found here.