Dr. Ian Ralby, Dr. David Soud, and Sophie Podrog
On 7 July 2021, Jovenel Moïse, the President of Haiti, was assassinated in his own bedroom, sending Haiti into a constitutional crisis from which it has not recovered. While there remain conflicting reports around the circumstances of his murder, one credible consideration was that he may have been killed to prevent him from exposing individuals involved in criminal enterprise. While drugs and arms are the main illicit commodities associated not only with Haitian organized crime but with the Caribbean region more broadly, they may not have been the only illicitly traded goods with which Moïse was concerned – his other major interest was in criminality surrounding the trade in eels.
The Imperative For Vigilance
As little-known and seemingly bizarre commodities begin to fetch higher and higher values in global illicit markets, law enforcement officers must become more vigilant in identifying and responding to new trends. This need is becoming particularly acute in the maritime domain, as the out-of-sight nature of marine life makes the illegal trade in living marine resources particularly attractive to criminal actors. High value marine species are ideal commodities for pursuing illicit profits and laundering money at the same time. The general lack of familiarity with aquatic life reduces the likelihood of being caught either on paper or in person, and the inability to trace the origin of these commodities can make accountability an even more elusive challenge.
Why Eels?
Indeed, the eel trade is an excellent example of this growing problem for law enforcement officials in the Caribbean and beyond: the illegal movement of “invisible commodities” that no one recognizes as the instruments of crime. Eels may not seem to go together with guns and drugs, but they can be as profitable as cocaine with hardly any of the risk. While terrestrial commodities – including gold, timber, fuel and wildlife – have been part of this phenomenon for a while, the dynamic becomes more extreme when it involves marine species that are typically so unfamiliar to most people as to go unnoticed. This aspect of fisheries crime and exploitation of the maritime domain demands closer attention. Its implications are not only environmental and economic, but closely tied to both the rule of law and the ability to govern, as Moïse’s death painfully illustrates.
While eels are by no means the only invisible commodity in the Caribbean, they present a revealing case study. The world’s eel population originates entirely from the Sargasso Sea in the North Atlantic Ocean near Bermuda. Eels begin their lives as leaf-like larvae that drift in different directions from their spawning site in the Sargasso Sea towards estuaries and rivers. Within 55 days of their arrival to estuaries, they turn into glass eels- small, transparent organisms whose value soars while they are in this clear state. As they progress through estuaries, rivers, and ecosystems, they eat what is available to them. What they consume literally colors them as they grow into elvers. Elvers are still adolescent eels, but their color signifies their loss of value. The elvers continue to grow before transforming into adult yellow eels within a year. These adult eels remain in the yellow eel phase for several years, before European and American eels mature into their final phase, silver eels. Towards the end of their life, silver eels will return to the Sargasso Sea to spawn before their death.
Staggering Value
Regardless of how eels may or may not appeal to palates in different parts of the world, the economics around the marketplace are telling. At source, glass eels from the Caribbean fetch around $4,000 per kilo, making them four times more valuable than a kilo of marijuana at origin and roughly the same as cocaine at first point of sale. While the glass eels do increase in value across the supply chain, they reach a maximum figure of about $8,000 per kilo in transit and $12,000-$15,000 at destination. That does not keep pace with the supply chain of drugs, as cocaine reaches a range of about $28,000 to $70,000 at destination. The thing about living organisms, however, is that they grow. A patient purchaser of glass eels can raise those eels to full adulthood, at which point their value can hit as much as $35,000 per kilo, putting them back in the same range as cocaine. At scale, as in the case of the vast eel farms in parts of Asia, this “bio-arbitrage” can generate profits into the billions of dollars. There is nothing intrinsically illegal about this process – unless the eels were sourced or shipped illegally or used as a means of turning criminal cash, used to buy glass eels, into legitimate profits on the global seafood market. Those forms of illegality have become big business, and led to eels being officially declared endangered. In the EU, the export of eels has been banned outright since 2010, but illegal trade persists, and eel fisheries have been almost completely depleted to the point of being “critically endangered.” The Caribbean, where eels flourish but no such restriction exists, is already being exploited and is exposed to grave risk.
Whether it is eels, sea cucumbers, turtles, lobster or other sea creatures, maritime commodities are attracting more criminal actors. With their advantages of high values, bio-arbitrage, and limited interdiction risk, they present an appealing alternative to trafficking drugs, weapons, humans, or other contraband that features on the radars of law enforcement and customs agencies. And the informal and cash-intensive upstream markets for eels are an ideal venue for money laundering. What this means is that there is a need for increased vigilance.
Turning the Tide on Invisible Criminal Commodities
Disrupting the harvesting and sale of these invisible commodities requires three main approaches. First, there needs to be rigor in identifying the commodity trends. To accomplish this, both governmental and non-governmental actors need to work together. Various entities outside of government – from fishers to civil society organizations to businesses – are likely to see some of the initial trends in new maritime commodity harvesting and trading, which will leave traces in market activity and trade data. There needs to be a relationship between them and the governmental actors to then be able to make sense of what is going on and what can be done about it. Within governments, the challenge is of interagency cooperation. Too often, one ministry or agency will have some insight but not share it, and thus constrict what can actually be done. In this case, for example, it may be that the fisheries agencies spot the activity, but if that is not shared with the police, coast guard and customs, there may be little means of effectively interdicting it.
Second, coast guards and other maritime law enforcement agencies need not only to know what is going on, but also what they should be looking for and what they can do about it. Without training, it is not easy to even make sense of eels being trafficked, and with each of the maritime commodities, different means of transport require different training for law enforcement. And even when the eels or other commodities are identified, understanding the legal basis for what action may or may not be taken is critical. This is where regional organizations – the Caribbean Regional Fisheries Mechanism (CRFM), the Caribbean Community’s Implementation Agency for Crime and Security (CARICOM IMPACS) and the Regional Security System (RSS) – can all play a vital role both supporting information flow and ensuring standardized training across the region. Any jurisdiction that has a blind spot may become a magnet for the criminal activity.
Finally, prosecutors and judges must be clear on what can be done to stop those who engage in the illegal harvesting and trafficking of maritime commodities. If the law is not fit for purpose, legal professionals must also have a role in working with law enforcement to encourage a legislative or regulatory enhancement to address that state of affairs. In addition to having the right laws, the prosecutors and judges must be comfortable with them and willing to use them. So ensuring training in how to prosecute such cases is also a critical element that can be supported by regional organizations.
What Next?
Criminals will always seek illicit profit with the highest reward and the lowest risk. Maritime commodities have become increasingly popular on account of their relative invisibility. Eels may be the Caribbean’s “flavor of the month,” but something else will come to take their place in the future. That means that the region – replete with sophisticated criminal organizations – needs to build collective resilience against this phenomenon by working together. First, to make invisible criminal commodities visible, and thereafter, to make the risk of getting caught outweigh the potential rewards of the crime.
Dr. Ian Ralby is President of Auxilium Worldwide, a charitable non-profit committed to global harmony. He is a globally recognized expert in maritime law and security and works around the world to help states and regional organizations identify and address maritime crime. Auxilium Worldwide has been working extensively with the Caribbean Community’s Implementation Agency for Crime and Security (CARICOM IMPACS) to uncover and counter overlooked illicit maritime activities, particularly in the fisheries sector.
Dr. David Soud is Head of Resource Responsibility at Auxilium Worldwide. He specializes in tracking illicit flows, with particular expertise in the criminal exploitation of natural resources.
Sophie Podrog is an undergraduate at Yale University, majoring in Global Affairs with a certificate in Human Rights. While working for Auxilium Worldwide, she has specialized in researching eel trafficking along with other maritime crimes.
Featured Image: An apprehended vessels along with small skiffs used by fishermen which were apprehended on November 22, 2017. (Royal Bahamas Defense Force photo)

