New FISH Act Creates Global Blacklist, Bans Foreign Vessels Linked to Illegal Fishing and Forced Labor from US Ports

The Fighting Foreign Illegal Seafood Harvests Act of 2025, or the FISH Act, is a major regulatory overhaul designed to clean up the global seafood supply chain. The bill’s core function is establishing a public “black list” of foreign vessels and their owners that engage in illegal, unreported, or unregulated (IUU) fishing or use forced labor. If a vessel or its owner lands on this list, they face severe consequences: they are banned from U.S. ports, cannot receive services within U.S. jurisdiction, and any seafood they catch, process, or transport is prohibited from being imported into the U.S. market.

The Global Blacklist: Why Your Tuna Might Get More Expensive

Section 4 of the FISH Act hands the National Oceanic and Atmospheric Administration (NOAA) the power to create and maintain this IUU vessel list, working closely with Customs and Border Protection (CBP) and the State Department. Getting on the list is easy if you’re already flagged by an international organization, but the bill expands the criteria significantly. A vessel can be listed if it’s caught undermining international fishing rules, if U.S. authorities report it for IUU fishing, or if it’s linked to forced labor—specifically referencing CBP enforcement actions and Treasury sanctions under the Global Magnitsky Act. Even vessels that simply refuel or resupply a listed vessel can be added, effectively cutting off support networks for illegal operations.

This is where the rubber meets the road for consumers and legitimate businesses. By banning imports from blacklisted vessels, the U.S. is signaling a zero-tolerance policy for unethical seafood. For the average person, this means the supply chain gets safer, but it also puts pressure on importers to prove their products are clean. The bill does offer one small shield for importers: seafood cargo won't be seized if the importer “genuinely didn't know” it came from an IUU source. However, in an age of increased supply chain scrutiny, relying on ignorance might become a high-risk strategy.

Hitting Them Where It Hurts: Financial Sanctions and Asset Freezes

Beyond just banning boats, Section 5 gives the Treasury Department serious financial teeth. The Secretary of the Treasury gains the power to impose sanctions on foreign persons or entities involved in IUU fishing or the illegal trade of endangered fish. If targeted, all property and assets belonging to that foreign person that are in the U.S. or under U.S. control can be frozen, similar to actions taken under the International Emergency Economic Powers Act (IEEPA). Furthermore, sanctioned individuals face travel bans—they become inadmissible to the U.S. and any existing visas are immediately revoked.

This is a massive step up from trade restrictions alone. Imagine a scenario where a foreign fleet owner, who has never set foot in the U.S., suddenly finds their U.S.-based assets—say, bank accounts or investments—frozen because one of their ships was caught using forced labor. The bill targets the “beneficial owner” (anyone with 50% ownership or substantial control), making it much harder for bad actors to hide behind shell corporations. While the President can waive these sanctions if it’s deemed in the “national interest,” the default position is severe financial punishment.

The Hidden Costs: Data, Enforcement, and Global Strategy

Implementation of the FISH Act is a heavy lift, requiring significant interagency coordination. Section 9 mandates a comprehensive strategy within three years to optimize data sharing and analysis across federal agencies like NOAA, CBP, and the Coast Guard. The goal is to use existing systems to automatically flag high-risk seafood imports without slowing down the trade of legal products. This push for better data means more sophisticated targeting of illegal activity, which is good news for legitimate businesses tired of competing with cheap, illegally sourced seafood.

Finally, the bill requires several deep-dive studies that lay the groundwork for future action. Section 12 mandates a study on the influence of Russian and Chinese fishing industries on global markets and U.S. consumers, acknowledging the geopolitical angle of the seafood trade. Another study, funded by $4 million, will quantify the true economic cost of IUU fishing and forced labor globally. The U.S. is not just banning bad actors; it’s spending $20 million annually (authorized through 2030) to build a global strategy to fight illegal fishing at its source, including boosting Coast Guard patrols and technical assistance to developing nations (Section 7 and 10).