The trade in IUU toothfish continues two years after the adoption by CCAMLR of a Catch Documentation Scheme (CDS) for toothfish. Accurate and verifiable data is necessary for the CDS to successfully track the trade in toothfish, gather scientific data on the fishery, and close ports to IUU fish. ASOC is concerned that the CDS lacks a verification procedure, explicit actions to be taken upon discovery of IUU fish, timeframes for submission of documents and data to and from the Flag States and Secretariat, and an enforcement protocol to monitor compliance with CCAMLR’s Conservation Measures. CCAMLR must take action at its 20th meeting to verify the information in Catch Documents by VMS and independent observers, to provide specific direction for removing IUU fish from the market and to impose sanctions against offenders, to establish timeframes for submitting information, to require VMS verification for toothfish taken outside the CCAMLR Area, to prevent Members from registering known IUU vessels, and adopt an enforcement protocol.

Twenty years after its adoption, the Convention on the Conservation of Antarctic Marine Living Resources (CCAMLR) remains unique among fisheries agreements in its declared commitment to considering the impact of existing or proposed fisheries on the entire ecosystem, rather than on just the harvested species. However, the recent picture of fisheries activities within the Convention area suggests a substantial – and perhaps widening - gap between theory and practice. The fishery that has most clearly proved beyond CCAMLR’s capacity, and which has posed the most significant environmental damage on the Antarctic environment in modern times, is that for Patagonian Toothfish, Dissostichus eleginoides. That fishery is discussed below, but the roots of that problem (and the structural problems that have contributed to CCAMLR’s inability to deal with the toothfish challenge) threaten to be repeated in the second-generation krill fishery that is rapidly developing Antarctic waters. The authors provide suggestions for structural and procedural changes within CCAMLR to permit it to effectively manage the marine living resources of the Southern Ocean.