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Through the cracks: How gaps in the Seafood Import Monitoring Program allow illegal seafood into the U.S.

SIMP's partial species coverage leaves the U.S. market vulnerable to illegal imports. Drawing on research by Simeone Consulting, LLC, this policy brief examines how gaps in SIMP's coverage allow importers to swap SIMP-covered seafood for visually similar "close substitutes"—enabling illegally sourced products to enter the market without triggering any reporting requirements—and offers concrete recommendations for closing them.

Public Comment & Letters:

Letter to Senate Appropriations Subcommittee on Labor, Health and Human Services, Education, and Related Agencies: Support for FY27 ILAB Funding – April 2026
Letter to House Appropriations Subcommittee on Labor, Health and Human Services, Education, and Related Agencies: Support for FY27 ILAB Funding – March 2026
Letter to President of the Maldives: Criminal Charges Against Trade Unionists – March 2026
Notice response to NOAA Fisheries: Executive Order 14276 – October 2025
Letter to USTR: Enhancing Labor and Human Rights Protections in U.S. Seafood Supply Chains Through Trade Policy – October 2025
Joint statement: Strengthening Collective Efforts to combat IUU Fishing and Labor Rights Abuse – June 5, 2024

Reports & Publications:

Policy brief: Through the Cracks: How Gaps in the Seafood Import Monitoring Program Allow Illegal Seafood into the U.S. – May 2026
Report: U.S. Imports of Fish and Seafood: An Evaluation of Coverage Under the Seafood Import Monitoring Program (by John C. Simeone of Simeone Consulting, LLC) — May 2026
Fact sheet: A Shared Crisis at Sea – May 2026
Report: The Fisheries Import Control Scheme Handbook (with EU IUU Fishing Coalition and IUU Forum Japan) – November 2025
Fact sheet: Forced Labor in Seafood Supply Chains – October 2025
Fact sheet: Illegal, Unreported, and Unregulated Fishing – October 2025
Fact sheet: Manifest Modernization Act – October 2025
Fact sheet: International Trafficking Victims Protection Reauthorization Act – October 2025

Press Releases:

"New Analysis Reveals Major Gaps in U.S. Seafood Import Monitoring Program, Leaving Billions in Imports Unchecked" – May 14, 2026
"International Coalitions Release Recommendations to Fight IUU Fishing Globally" – November 21, 2025
"Advocacy Groups Demand Government Action at 10th Our Ocean Conference" – April 28, 2025
"Three Coalitions Urge the EU, Japan, and U.S. Governments to Strengthen Cooperation to Fight Illegal Fishing and Labor Abuses in Seafood Supply Chains" – June 5, 2024

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