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International

Fighting FOCs at home and abroad

20 November 2025

Nautilus head of international relations Danny McGowan review’s the Union’s involvement in a United States investigation into Flags of Convenience and the national security risks, poor labour standards, and seafarer abuse that they cause

During 2025, the USA’s Federal Maritime Commission called for submissions to an investigation into the use of Flags of Convenience (FOCs). I was pleased to be able to respond on behalf of the Union, alongside Nautilus Federation affiliates based in America.

I drew the Commission’s attention to the report commissioned by Nautilus and the International Organization of Masters, Mates and Pilots, detailing the impacts of the FOC system on domestic resilience and preparedness, urging the Commission to consider the recommendations made in the report as a ‘key concern’ relation to national security.

I also suggested that the Commission should examine (among other matters):

  • labour standards and seafarer abuse
  • safety deficiencies
  • the increasing threat of ‘dark fleet’ operations enabled by FOC registries
  • the growing crisis of seafarer abandonment

Currently, the investigation is paused due to the USA government shutdown. As such, there is no timescale for the release of the report. As soon as the Federal Maritime Commission’s report is released, I will be certain to share the details with our members.

In the meantime, Nautilus and our international partners will continue to highlight issues with the FOC system wherever possible, and to pursue the enforcement of the genuine link required under the United Nations Convention on the Law of the Sea (UNCLOS).


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