INTRODUCTION
The global production and demand for illicit drugs continues to rise, leading to increased smuggling attempts by criminal organisations using commercial vessels as ‘drug mules.’ Even when the master and crew are unaware, the consequences can be severe. This Risk Bulletin examines the threats posed by maritime drug smuggling and outlines ISPS Code measures and additional security strategies to safeguard vessels and crew.
BACKGROUND
Illicit drugs being smuggled by sea include cocaine, heroin, methamphetamines and other narcotic substances, all as described in the United Nations Office on Drugs and Crime (UNODC) ‘World Drug Report 2024’. This detailed report includes the most recent analysis of drug trends, trafficking routes, seizure results and other related information. The report’s outlook points to an urgent need for heightened ship security and crew awareness at all port calls located in ‘high risk’ drug production, export, transit and reception area countries.
THE ISPS CODE AND IMO RES. MSC. 228(82)
Members will be aware that the ISPS Code – as a part of and as mandated by SOLAS – provides the obligations and recommendations to be implemented by both ships and ports to meet three prescribed levels of security threats. At all levels, the Code includes the requirement to prevent unauthorised access to both ships and port facilities at all ports as well as when ships are underway.
Importantly, the ISPS Code is supplemented by specific counter smuggling security advice contained in the IMO’s Revised Guidelines for the Prevention of Smuggling of Drugs, Res. MSC. 228(82) (adopted 7 Dec 2006). This version, extending to 57 detailed pages, remains valid and in force. Content main headings are as noted below:
- Competent Authority Procedures
- Possibility of Illicit Loading onto Ships
- Company Role in Ship Security
- Measures and Procedures for Overall Ship Security
- Detection of Concealed Drugs
- Detection of Drugs and Tell-Tale Signs
- Action When Drugs Are Found
- Medical Substances Permitted on Board
The IMO’s Revised Guidelines are of critical importance to the prevention of unauthorised access to shipboard spaces and the concealment of drugs. As such, they should already be implemented – under the direction of the appointed Ship Security Officer (SSO) – by way of a specially incorporated section in each vessel’s flag state approved ISPS Code Ship Security Plan (SSP).
OTHER SOURCES OF DRUG SMUGGLING COUNTER MEASURES ADVICE
The latest edition of the ICS publication, Drug Trafficking and Drug Abuse On Board Ship – Guidelines for Owners and Masters on Preparation, Prevention, Protection and Response (2025-2026 Ed.) has just been released. This 250-page Guide provides comprehensive advice on the application of the ISPS Code and the IMO Guidelines for Prevention of Drug Smuggling. It includes security checklists and warning posters for downloading, printing and use on board.
The ICS webpage, which describes and assists purchasing the ICS Guidelines, provides the following content summary:
- Drug trafficking trends and patterns, as well as high-profile seizures and incidents
- Physical security measures, both in port and on-board ship
- Training and education, including suggested training at both ship and corporate levels.
- Search procedures, including methods of searching and common concealment methods.
- Actions to be taken when drugs are found on board, including incident response reports and customs information.
The cost of the Guide at GBP 225.00 is not cheap but should be considered by all Members as a sound investment in crew training and awareness and avoidance of the costs associated with potential vessel detention, reputational damage and crew arrests.
Members are also referred to the publications available online and free of charge from the UN Office on Drugs and Crime (UNODC) website. An example is provided by the UNODC Statistics webpage which includes maps showing the global flow of drugs and the main source, transit and recipient countries involved. The quantities of drugs reported, and the criminal organisation activities of the traffickers involved sound a clear warning to Members and their shipmasters of the danger of their ships being targeted and used by criminal gangs for drug trafficking purposes.
PRACTICAL DRUG SMUGGLING/TRAFFICKING COUNTER MEASURES
A summary of the drug smuggling and trafficking counter measures detailed in the ICS Guidelines is provided below.
Prevention and Training:
- Voyage specific drug smuggling risk assessment should be conducted by the Master and SSO at voyage planning stage.
- If high-risk load and/or discharge ports and/or area transits are identified, the Master is to alert the Company Security Officer (CSO), obtaining the latest port security status from agents.
- The Master, SSO and CSO should assess the situation and arrange shore-based security services as required.
- Full crew briefings required prior to port arrival and debriefings after departure.
- Ship Security Plans should not be disclosed without company permission.
- Crew on vessels trading in high-risk areas should be rotated to reduce coercion risks.
- Records of security drills, inspections, and security measures are to be maintained.
- Background checks on crew and third-party contractor should be conducted.
- The company drug policy should be displayed onboard and the crew educated on risks.
- Conduct pre-joining and unannounced drug tests for crew members.
- A confidential hotline for reporting threats and coercion should be established.
- The crew are to be trained on cyber security threats such as phishing and fraud.
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At a Port or Anchorage:
- Access to be controlled through a single-entry point guarded by a 24/7 crew watchkeeper.
- All persons attending on board are to provide photo ID, the reason for boarding and submit to a bag check. The names and times of boarding/departure should be logged.
- Install CCTV at single-entry point and other security risk areas.
- Subject risk assessment, engage shore-based security guards.
- The Master, Chief Engineer and SSO to conduct regular but randomly timed security checks with times and results to be logged.
- Engage with only industry approved ship services, stores and equipment providers.
- Maintain a close watch and conduct random patrols of areas where stevedores, repairers or other service providers are working.
- Keep the entire vessel, including decks, overside and cargo holds well-lit at night.
- Maintain a close watch for unauthorised divers and small boats alongside.
- Alert the crew to avoid accepting parcels or packages from outsiders.
- Stay alert to suspicious activities such as unauthorised data collection.
- Stay alert to ship structural modifications that could conceal drugs.
- Note and conduct regular searches of potential drug concealment.
- Monitor crew behaviour for signs of drug use or trafficking involvement.
NOTE: A major concern is often that a port facility’s security – which should also be regulated by the ISPS Code and a Port Facility Security Officer (PFSO) – may not be operated to required ISPS Code standards. If so, then the port area control barrier to unauthorised shipboard access may be of little or no value. Masters and SSOs should therefore communicate with PFSOs on arrival to confirm a port’s ISPS Code Security Level and make independent enquiries (e.g. through local agents) to assess the efficacy of its application.
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Prior to Vessel Departure from a Port or Anchorage, or High-Risk Area:
- Conduct an intensified ‘stowaway’ search of all storage, accommodation, engine room and cargo spaces for both stowaways and concealed drugs.
- Conduct thorough and ‘permit to work’ controlled searches of void spaces, ballast tanks, chain lockers, ventilation trunks, and similar areas.
- Inspect external and exposed vessel structures such as the rudder trunk area.
- Subject risk assessment, engage diver/underwater hull inspection services.
- Subject risk assessment, engage anti-narcotics team/ sniffer dog services.
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If Drugs Are Located:
- The crew must not touch or move drugs. Seal off the area immediately.
- There should be full documentation of the drug discovery with photo and video evidence.
- Report the findings immediately to the SSO, CSO, DPA, and Port Authorities.
- Cooperate fully and transparently with authorities.
CONCLUSION AND TAKEAWAY
The consequences of being found with drugs on board are severe. They include crew arrests and potentially long jail sentences, vessel detention, exceptionally large fines and – in some countries – seizure or confiscation and court ordered sale of the ship itself.
UN reports and other studies agree that the global drug smuggling and trafficking problem will continue to increase. It can therefore be expected that the number of commercial ship drug discoveries will also increase unless shipowners and their crews become more assertive and successful in preventing their ships from being used to transport illicit drugs.
MMIA recommends that Members review their current ISPS Code SSPs and supporting procedures – together with their masters, SSOs, CSOs, DPAs and ship managers – to ensure that they specifically incorporate the IMO’s Revised Guidelines for the Prevention of Smuggling of Drugs, Res. MSC. 228(82). Further, that these Guidelines are fully implemented and audited in accordance with flag state ISPS Code requirements.
Members are also encouraged to purchase and provide their fleet with the above noted ICS publication, Drug Trafficking and Drug Abuse On Board Ship – Guidelines for Owners and Masters on Preparation, Prevention, Protection and Response (2025-2026 Ed.). MMIA consider the cost of this publication to be a prudent Member investment in master and crew drug smuggling threat awareness, counter measure training and critical loss prevention.
Regarding Club cover, Members are respectfully reminded that for entered vessels found with drugs on board and which are then exposed to liabilities, losses and expenses and/or fines or other penalties, the MMIA Rules of associated application are as follows:
General Rule 25 – Imprudent or Improper Trades, provides that there will be no cover for, “…any liabilities, losses or expenses arising out of or consequent upon an entered ship carrying contraband, blockade running, being employed in unlawful trade or performing any voyage or being employed in any trade if the Managers having regard to all the circumstances consider, in their discretion, that the carriage, trade or voyage was imprudent, unsafe, unduly hazardous or improper”.
Class 1, P&I, Rule 23 – Fines, provides that cover for fines, or any other penalties imposed on an entered ship is only available, “…where the Member has satisfied the Directors [of MMIA] that he took all such steps as appear to the Directors to be reasonable to avoid the event giving rise to the fine or penalty” but “…there shall be no recovery … if the Managers consider in their discretion that the Member knew or should reasonably have known that he would become liable or if the Managers in their discretion consider that such fines or penalties arise out of default of the Member, his managers, superintendents or onshore management”.
Members will note that the above Rules provide discretionary constraints on P&I cover in ‘drugs discovered on board’ situations. Members are advised that their full compliance with the IMO’s Revised Guidelines for the Prevention of Smuggling of Drugs, Res. MSC. 228(82) – as supplemented and explained by the ICS publication referred to above – will assist MMIA’s Managers and Directors in exercising their discretion in a positive manner.
Finally, if Members have any questions or concerns regarding the potential constraints on cover referred to, they should confer with their P&I insurance brokers to arrange any separate and supplementary cover considered necessary. MMIA will of course be pleased to assist and advise as appropriate.
