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On the remote high seas of the western and central Pacific, longliners meet with refrigerated carrier vessels to offload their catch. These rendezvous, called transshipments, play an integral role in global fisheries. It’s how fish, like sushi-grade yellowfin tuna, reach market quickly and efficiently. Transshipments let commercial fishers stay at sea without expending extra time or fuel returning to port. But according to a recent report by the Pew Charitable Trusts, as many as a third of these transshipments may have gone unreported in 2016. These off-the-books transfers open the door for unscrupulous fishers to funnel illegal, unreported, or unregulated (IUU) seafood into the legal marketplace.

In 2016, 25 carrier ships reported 956 transshipments to the Western and Central Pacific Fisheries Commission (WCPFC), the organization responsible for managing that region’s fish stocks. But based on analyses of ships’ automatic identification system (AIS) transponders, which use satellites to track vessel movements, Pew scientists calculated that as many as 1,500 transshipments likely occurred. The discrepancy suggests carriers are not reporting every transshipment to the WCPFC and that many more carriers are operating in the area.

Mark Young, a coauthor of the report who spent 10 years in fisheries enforcement before he started at Pew, says the finding comes with a caveat: although satellite data can pinpoint two vessels coming together at sea, it can’t actually indicate what the ships are doing.

“You can’t infer illicit activity from AIS data,” echoes Jessica Ford, a senior research statistician at Australia’s Commonwealth Scientific and Industrial Research Organisation whose own research has examined IUU fishing with the help of AIS. But, she emphasizes, “you can infer a risk or a suspicion.”

Nate Miller, a senior data scientist with Global Fishing Watch who was not involved with the Pew report, points out that there are legitimate reasons why transshipments may go unreported. He says it’s common for fishing and carrier vessels to exchange more than just fish—food, medical supplies, and ice all need to be periodically resupplied to longliners. And ships sometimes meet to relieve and replace crew members who have been at sea for extended periods of time. A carrier might not report this kind of activity as a transshipment, Miller says, if it did not involve the transfer of fish.

But there’s good reason to suspect the undocumented transfers are part of illegal activity. A 2016 study found that each year more than US $142-million of IUU fish seeps into the legal market through covert transshipments. What’s interesting about that figure, Young notes, is that it comes from licensed vessels misreporting, or failing to report, their catch. That’s concerning, he says, because not only is this type of activity difficult to detect, it also takes money out of the pockets of local fishers and the economies of small Pacific Island countries, like Palau, Samoa, and Tonga, which are the source for more than 55 percent of the world’s tuna catch.

Of the suspected undocumented transshipments in the report, many were undertaken by carriers flying the Panamanian flag. Panama is infamous for offering a so-called flag of convenience—whereby a foreign operator registers their ship in Panama in order to fly that country’s flag and thus benefit from its lax fishing regulations. Young says all countries associated with the WCPFC, including Panama, must be held to account for lapses in reporting and encouraged to do better.

In recent years, many countries have adopted stricter regulations to combat illegal fishing, such as the 2016 Agreement on Port State Measures, which bars ships operating outside of the law from entering port. This leaves transshipment as one of the last frontiers for IUU fish to penetrate the market, says Miller. It’s an opportunity where “you could put your fish onto a carrier vessel, potentially mix it with legally caught fish, and then have that vessel bring it into port for you.” He says it’s also the channel through which other illegal activities—such as the trafficking of drugs, weapons, and people—can transpire.

Miller, Ford, and Young all agree that to curtail illegal transshipments, monitoring by both fisheries observers and electronic systems must be improved. Pew also recommends that all carrier vessels report transshipments to the appropriate overseeing body—as they’re required to do—and that the WCPFC and other regional fishing bodies whose jurisdictions overlap exchange data to better assess fish stocks and keep tabs on illegal players.

Young asserts that by instituting these recommendations, IUU fishing and other illicit activities can be deterred.

“The key about transparency is … it breeds self-correcting behavior,” Young says. “You put something out in the open and shine a light on it—invariably, people gravitate toward doing something that is legal and upfront.”