This reporting project was supported by the Pulitzer Center.
In Uganda, Chinese demand for the Nile perch swim bladder, termed “fish maw,” is driving over-fishing and cross-border smuggling. In the second part of our ‘Gutted Trade’ series, we documented how Uganda’s new tax on maw exports has increased the country’s earnings from maw exports, but also driven many traders to shift their maw processing operations from Uganda to sister companies in Tanzania and Kenya. Tax and pricing differences have also reversed the route of smugglers, who now often move maws sourced in Uganda to Tanzania for export. But official data is lacking and often contradictory, and our sources also highlighted labeling issues that permit exporters to conceal or underreport consignments.
In this final installment, we explore who is behind the lucrative maw trade, from Ugandan and Asian companies to elites and cartels. We also investigate official arrests and prosecutions related to fish maw in Uganda, which are few in comparison to the rampant illegalities reported with the trade. Finally, we assess the bureaucracy involved in securing maw licenses and the existing regulations among the countries that share the lake – finding a need for much greater cross-border coordination for this valuable trade to more fairly benefit East African countries and their peoples, while keeping alive the lake ecosystem.
In 2020, the Uganda and China governments initiated a memorandum of understanding to allow Uganda to directly export maws to China, bypassing Hong Kong.
The new requirements included various quality assurance standards and licenses. However, by 2021, the MoU had not been signed by the Ministry of Finance. UN Comtrade data tracks negligible imports of fish maws to China from Uganda through 2022, the last year data is available, while Uganda’s exports to Hong Kong have persisted.
“Even the Chinese market, there was a lag; dragging of the foot to open the Chinese market for fisheries products like maws,” said Nyeko of the Uganda Fish Processors and Exporters Association (UFPEA). “Maw was left to be exported to Hong Kong, where there is a cartel that controls it, with price fixing, under invoicing, general loss in tax revenue.”
Hong Kong established a group of trusted suppliers from Uganda “years ago,” but TRAFFIC was unable to determine the names of these exporting companies in its investigation, said the researcher Louw.
“They’re very hush about names. It’s very difficult… That’s the one thing I find very interesting about the maw trade, is that it is not illegal… But the supply chain is so secretive, and I think it’s because it’s going to those same markets as shark fin and abalone so there is this secrecy around the trade, and because of the value of it,” she said. “But yeah, I think it’s a different case in Uganda and Lake Victoria, because there is so much illegality associated with the fishing itself.”
Wing Fat Company, a small medicinal Chinese medicine store in New York. In March, this store was selling fish maws from the Nile perch fish species, which are majorly caught in East Africa.
According to Richard Matovu, the trade’s original initiator in Uganda, local businesses used to export directly to Hong Kong, but Chinese companies took over the trade around the turn of the century when some local suppliers disappeared with advance payments.
Morgans Junior, the former maw trader from Kasensero, traveled to three cities in China in 2013 looking for a direct link to buyers who could procure his supply. But in Guangzhou, Shanghai and Shenzhen, “they said ‘no way,’” he said. “Some said they weren’t aware of it. Some said, ‘you have to go back in your country, because there is some client we send there.’ They knew that once [Ugandans] started to take it [to China], they wouldn’t be able to control the profit.”
After establishing a direct link to destination markets failed, Junior started supplying maw from the landing site to Chinese-controlled companies in Kampala, which he said bought them cheaply.
There are three main avenues sustaining the Uganda maw supply chain: one, fish factories- majorly Indian owned, which buy whole fish from traders and sell the maw to Chinese processors and exporters; two, local processors, who gut the fish and sell the carcasses locally; and three, illegal collectors who “hire rooms and wait” for paid suppliers to bring maw, according to Godfrey Ssenyonga Kambugu of the Association of Fishers and Lake Users of Uganda.
In Lambu, “there are big agents here, but we also have some boys who go and sell in Masaka but hiding,” one source said, who requested anonymity. In Kananansi, the maws of small Nile perch that local people retain for domestic consumption are sold to local traders for about $2.6 – 4 each, collected from homesteads.
A shop owner weighing fish maws at a small shop in Chinatown, New York in March. These maws were priced at $168 a kilogram.
But these are fringe, mostly secretive industries. The majority of maws in Uganda are extracted and processed by people working for Nile perch and fish maw processing companies that are owned by foreigners and powerful Ugandans.
In 2018, the Lake Victoria Fisheries Organization estimated that the lake sustained a total of 1,473 maw businesses employing 4,124 people. Thirty-three companies were involved in maw processing and exporting: 14 in Uganda, 12 in Tanzania and five in Kenya.
The regional body has not further updated this list since production of the GIZ-funded report, and a current list of exporting companies from Uganda was not provided by the Uganda Revenue Authority or the Bank of Uganda by the time of publication of this story.
However, we compiled a list of 35 possible companies involved in the trade in Uganda from a GIZ/LVFO report along with limited information provided freely on export/import databases Export Genius, Volza and Global Suppliers Online.
Of these companies, 18 were still registered on the Uganda Registration Services Bureau, while 14 had been struck off, and three had no records. At least nine companies had Chinese names. For others, such as Lusango Real Uganda Limited, we were able to determine links to Chinese ownership.
Of the 16 companies that provided their registration dates, half were registered in the last 10 years, while the first half were established more slowly in the 20 years from 1994 to 2014, indicating the recent acceleration in the business.
Some of the main companies, which also appear in data from the Uganda Revenue Authority, include Lake Bounty Limited, Fresh Perch Limited and E.A. Fish Bladder Processing Uganda.
“The Chinese factory operators have financial partnerships based on trust with the local maw suppliers. This has led to the Chinese maw processing factories contracting several maw agents to supply them with maws,” reported a GIZ-funded analysis of the Nile perch fish maws value chain in East Africa that was published in August 2018 by the Lake Victoria Fisheries Organization.
Several sources consulted for this story, including fishermen, current and former members of the army and police, researchers and government officials – many of whom feared to be identified- pointed to highly connected “mafias” controlling the supply of maw to Asian markets.
“What you may get officially, may not reflect what is on ground. There are some on ground who do not exist in the national database. Those in the national database… you will not be able to trace the exact owners. The way in which the policies were fast tracked indicated something highly political,” said the researcher (who requested anonymity) who recently conducted a partial study into the fish maw trade.
Powerful business people, including many from China and India, also control the majority of activities at landing sites, including the fishing intended for maw markets. Four of the seven members of the 2024 Uganda Fish Processors and Exporters Association executive committee, including the chairman, vice chairman and treasurer, appear to be Indian or Indian-Ugandan.
At Lambu, around 10 companies used to buy tilapia and Nile perch from local fishermen around the year 2000, but now, the landing site only supplies to one company, fishermen said.
Mandates set by the Ministry of Agriculture, Animal Industry and Fisheries in 2018 benefited factory owners while hurting the fishermen and local suppliers, TRAFFIC assessed. The first mandate required suppliers to sell the whole fish, including its swim bladder, exclusively to fish factories and traders.
Another mandate prohibited the gutting of fish at landing sites, which was previously sustaining local industries of smoking fish. At Kananansi, resident Nakibugwe Sylvia said prior to 2021, she had a stall for fish smoking that was provided by the government, where she would sell both the fish meat and its maw to local buyers. Her business was booming, enabling her to educate six of her children, buy two plots of land and construct a house.
But since fish smoking was prohibited, Nakibugwe now has to supplement the small income she gets rearing goats with support from her children.
“The implementation of these mandates has caused conflict between the majority of African suppliers, the [Ministry of Agriculture, Animal Industry and Fisheries], and the majority of Asian factory owners. The mandates severely cut the profits of the suppliers, who are unable to sell the high-value swim bladders to private traders, while the factory owners benefitted greatly,” TRAFFIC reported.
The Lake Victoria Basin Organization noted that these rules had restricted the benefits from the high-value maw trade to reach mainstream actors in the fish supply chain, including fishing crews, boat owners, fish suppliers and factory agents.
“Most fish suppliers still complain of stagnating or ever-reducing prices offered by fish factories despite the ever increasing prices of maw in the artisanal maw supply chain. This has led to suspicion among operators in the upstream side of fish chain of existence of conspiracy and curtail among fish factory processors and relevant government officials to reap from their (fisheries chain actors) effort,” the 2018 report noted.
Although the government had since agreed to re-install gutting areas licensed with a fisheries officer at every landing site, this has not yet been implemented due to a lack of funds, according to Nyeko.
On Buvuma Island, many women who used to sell fish locally are now engaged in brew making from island palms. “What they get now [in income] is worse than what they used to get when smoking fish,” a local trader said.
Further down the supply chain, many Ugandans are employed at maw processing plants located near Busia, on the Kenyan border. But pay, health and safety standards are wanting, according to one researcher who visited several of these sites. Issues of child labor and trafficking of other wildlife items were also linked to the maw trade. Ivory was found concealed in some fish maws that Malaysia imported from somewhere in Africa, said Dr. Rukuunya.
The licensing bottleneck
Restricted access to licenses also curtails local people from entering the lucrative maw trade. A license to buy and trade fish maw costs just 500,000 UGX (USD $133), but traders complained that only the applications of “big men” are actually considered. So local fishermen end up working for these few powerful owners, sent out with copies of the “big man”s license – although this is not permitted under Uganda’s new fish act. At Lambu, only about five people have licenses to transport fish outside of the site, according to local industry players.
According to Uganda’s 2022 Fisheries and Aquaculture Act, a new law managing the fisheries sector, the Chief Fisheries Officer must inform unsuccessful license applicants the reasons for the refusal within 30 days of their application.
Richard Matovu of the fish maw traders’ association complained that the number and cost of licenses required to enter the maw trade are exorbitant and end up shutting out most Ugandans. Up to eight different certificates can be required, he said, including the trading license, export permit, KCC license, vehicle movement permit, sanitation permit, and export levies, which depend on the quantities shipped.
“All that means money. To involve yourself in this business, you must be having millions. It is not simple money,” he said.
Dr. Rukuunya of the Lake Victoria Fisheries Organization said there is a need to reduce the stringent approval requirements for maw traders.
“You have to have a fish permit from the local government, you have to have a quality assurance certificate from the directorates responsible for fisheries, you have to go to URA and pay the taxes… The tax regime, I think, leads to the distorted nature of the fish maw trade, and there’s need for streamlining,” he said.
According to the new law, the licensing Chief Fisheries Officer “determine[s] the maximum allowed fishing effort in each district, based on available scientific data and where there is no data- a precautionary approach shall be applied.”
Fisheries minister Hellen Adoa said in 2022 that several members of Parliament’s claims that only foreign companies were being issued licenses was not true. She said that so many individuals had applied for fish maw licenses, and the trade was already driving depletion of the fish, so the government had decided to “go slow” in issuing permits.
Under the new fisheries act, contraveners to maw license rules should be fined 100 million shillings or sentenced to prison for up to three years, or both. But despite the widespread impression of illegality in the maw trade, our review of more than 1,500 fishing-related court cases over six years did not find significant evidence of prosecutions related to fish maw.
The only two maw cases in this data were registered at Lukaya court in Kalungu district in 2019, before the new law was passed. In these cases, prosecutors fined individuals UGX 100,000 ($27) for moving maws without a permit, in default one and two months in prison.
Although Uganda’s islands are a center of the maw trade, Koome Island court dismissed three quarters of its cases in the last six years. Out of 305 fishing-related cases that were completed- most related to the use of illegal gears- the court dismissed 201 cases in 2022 and 2023 alone, while just 18 resulted in convictions. About 15 percent of the dismissed cases were attributed to a lack of prosecution.
Of the major fish-related crimes, perpetrators fishing or moving fish without a license were least likely to be sentenced to prison – just 13 percent of cases were given prison sentences – compared to people caught using illegal nets or fishing immature fish. People fishing without a license also received the smallest fines (about USD $30) compared to people using illegal nets and gears, which on average were tacked with more than double this fine.
This analysis encompassed less than half of the country’s total fishing cases in the period, according to aggregate statistics. Despite several official requests for information over one year, specific case data was not provided by Kalangala court and the Standards, Wildlife and Utilities Chief Magistrate Court by the time of publishing.
The FY 2023 Value for Money Audit to Assess the Effectiveness of the Directorate of Fisheries Resources in Regulating the Fishing Effort in Uganda by the Office of the Auditor General found that about 76 percent of vessels and fishers in the 13 districts on Lake Victoria were unlicensed despite the Fisheries Protection Unit mandate to enforce regulations.
“Despite some gains such as impoundment of some illegal fishing gear, concerns remain about recurrence of the aforementioned crime, the fact that less than half of Lake Victoria’s fishermen are registered, and other illegal practices, which point to weaknesses in regulation,” the audit found.
Fishers are required to apply for licenses from the District Fisheries Officer and print them from e-licensing systems. Issues identified by this assessment included a lack of mobile licensing or sensitization of fishers to use this system; frequent systems breakdowns resulting in some fishers not receiving licenses they had paid for; irregular issuing of vessel plates, and a lack of recording of the actual fishers who operate boats registered only with owners’ names.
“Because of the laxity to manage and control these fishers by the boat owners, offenders are often not identified and thus keep recycling to other boats around the lake,” the audit found.
The audit recommended fast-tracking the completion of a new licensing system by the National Information Technology Authority and ensuring that it could be used by people in remote areas; setting timelines for license applications, approvals, and vessel plate delivery; and finding more efficient ways to dispatch vessel plates to fishers.
Development of a centralized data management system and coordination mechanism for all key regulatory stakeholders was also important, the audit concluded.
‘A new layer of cartels’
Fishermen claimed that some business owners work in collusion with the army, sometimes purchasing them engines and fuel to maintain influence over their enforcement activities and encourage them to turn a blind eye to illegal fishing. At Lambu, some fishermen estimated that “90 percent” of the lake had been destroyed due to overfishing from illegal fishing nets.
In Kananansi, a trader alleged that since the army came on the lake, military officials who catch local people holding fish maw also go and sell it elsewhere. Information collected for a 2023 study for the International Organization for Migration also found evidence of the army and local beach managers collecting bribes to allow illegal fishing of maw, according to Institute for Security Studies researcher Willis Okumu.
“In one way or another [fish maw] has created a new layer of cartels that basically are just interested in depriving the state of the fisheries resources. One layer is the FPU, another is the guys that manage the beaches, and therefore the state is still losing because all this money is going to private hands,” Okumu said.
“If you look at Lake Victoria as a regional corridor, we are establishing that we have a level of extortion linked to FPU – fishermen in Kenya and Tanzania paying protection fees to fish in Ugandan waters, paid per week or month,” he added.
According to the Lake Victoria Basin Organization, “ambiguity in interpreting the existing fishery products laws” has led to “arbitrary application by enforcement bodies which has promoted corruption, smuggling, and other underworld illegal trading activities.”
“Such a scenario tends to make maw trading, especially to small players who cannot afford bribes and enticements demanded by law enforcement, as though it is an illegal and cumbersome business in which they opt not to participate,” the LVBO maw guidelines report noted. “This gives opportunity to only those with resources, connections and good knowledge about the market and working of the processes involved to reach final buyers to dictate the prices offered to small players such as extractors, collectors and small-scale traders.”
Some of the more expensive fish maws sold at Wing Fat Company, a medicinal Chinese medicine store in Chinatown, New York in March.
In wildlife crime cases from Uganda, Kenya, Tanzania and Zambia analysed in 2018 by the Organisation for Economic Cooperation and Development (OECD), as cited in the 2020 United Nations Office on Drugs and Crime World Wildlife Crime Report, officials involved in law enforcement, including members of the police, military, and customs, were most involved in corrupt practices, along with some administrative officials.
However, the Fisheries Protection Unit public relations officer, Lt. Lauben Ndifula, presented the fishers’ allegations against the army as false claims by people conducting illegal activities.
“There is a lot of politics on the lakes. When I impound your nets, that person will not say anything positive about you. Sometimes you will hear that allegation that the lake is owned by a few people, but any Ugandan is allowed on the lake,” he said.
The Fisheries Protection Unit also has a department of intelligence that is mandated to investigate allegations of internal corruption, Ndifula said.
Some officials expressed optimism in the new Fisheries Protection Unit commander to reduce corruption. Mercy Adah Tukahirwa was appointed in Nov. 2023 to replace Dick Kaija, who the UGBulletin reported was “complacent on illegal fishers, most of whom are senior army officers.”
Fishers at Lambu landing site said Tukahirwa has a stricter approach to fighting corruption and illegality, citing the recent seizure of illegal Nile perch in Kalungu and the “fear” of locals who are engaged in illegal fishing.
“There is hope. For me, I know how women operate. They are better. For us men, you can go into corruption for so many [reasons] – bars, women… but women, they are not. They are focused,” one local source said.
Water, wealth, waragi and women
Uganda’s landing sites are not affluent communities, characterized mainly by temporary structures where fishermen and their families stay and hustle for the day’s income.
As the country’s population has swelled from just six million people in the 1950s to almost 50 million today, fishing sites have far exceeded their ideal capacity, according to Bwambale Mbilingi, a socio economist at the National Fisheries Resources Research Institute.
Twenty years ago, “I remember when I was in the islands – we would be about 50 people. Today that landing site has 2,000 people,” Mbilingi said.
As a socioeconomic group, fishermen are plagued by what Mbilingi termed “the four Ws” – “water, wealth, waragi [the name for Uganda’s local brew] and women.” Fishermen have more expendable cash from daily catches compared to farmers who must wait for the season’s harvest to reap profit, so much of fishers’ daily earnings are often spent pursuing sex or alcohol. Because of this, fisherfolk are one of the country’s most vulnerable groups for HIV/AIDS, with an estimated disease prevalence of three times the national level.
One root cause of the lake’s degradation is the lack of ownership by these local communities. Because the lake is seen as a common or government-owned resource, each individual maximizes their personal reapings instead of guarding the lake as their own: a classic ‘tragedy of the commons’ in economic theory that causes depletion of public resources.
Museveni disbanded the former system of local management under so-called Beach Management Units (BMUs) in 2015 due to widespread corruption. Since then, local management has not been standardized – conducted mainly by the army alongside “de facto management committees with people who have been locally appointed, usually a long time back,” Mbilingi said.
The 2023 audit report found that the Directorate of Fisheries Resources did not have an effective local or national coordination mechanism among key stakeholders including the Fisheries Protection Unit, Uganda Revenue Authority and local governments.
There is hope of developing a new system of local management under the new fisheries act, which requires the Chief Fisheries Officer to: “plan, set up and coordinate co-management structures for the effective involvement of fishing communities, traders, processors and exporters in the management and development of the fisheries.”
This approach should prioritize user rights, where fisherfolk hold legal custodianship of their landing sites, Mbilingi urged. He said NaFIRRI is developing a national plan of action to guide establishment of these systems.
“There’s a way you manage your garden jealousy. Because these fishers don’t look at the lake as their own, they don’t guard it jealously. It is looked at an individual level,” he said. “If you have that custodianship, when you see one of your colleagues engaging in illegal fishing, you are the one to stop him – you report to the chair and the whole community should be stopped from fishing.”
The Directorate of Fisheries Resources did not respond to our repeated requests for interviews and additional information over one year.
Dr. Rukuunya said the Lake Victoria Fisheries Organization council of ministers was consulting its scientific committees about establishing user rights management regimes to control entry into the fisheries and help fish stocks recover. “Once we have all the aspects together, then we shall change the management regime,” he said.
In March, responding to concerns of corruption and brutality linked to the army’s presence on the lake, President Museveni also proclaimed that he would meet fishing community elders to hand over management.
According to the FPU spokesperson Lt. Lauben Ndifula, Tukahirwa has spearheaded a strategy of changing mindsets among the fishing communities, visiting landing sites across the country to conduct sensitization campaigns.
“We call the fishermen to every landing site. We inform local leaders and they inform all the fishermen; we gather and teach them; we allow them to ask the questions, you know their challenges and their weaknesses,” Ndifula said. “We have pushed [sensitizations] to another level. [Fishers] said, ‘it is our first time to see commander on ground.’”
Despite the challenges, the thriving Asian market for fish maws still presents Uganda major opportunities for increased employment and income. Registering and licensing all maw businesses and enforcing regulations for maw extractors, traders, processors and exports will help create transparency, strengthen business relationships and weed out speculators who distort pricing information, the Lake Victoria Basin Organisation advised.
“These speculators operate through connivance with enforcement and security organs to create the impression that dealing in maw is an illegal undertaking. This is normally done in order to arouse unnecessary competition which ends up promoting corruption, trading in illegal sized maw and smuggling of maw across regional borders which increase the cost of transactions that subsequently affect the income and revenue of maw suppliers,” the guidelines report noted.
Sector leaders also urged for harmonization of laws and regulations among the three countries that share the lake to curb smuggling and disjointed standards and enforcement.
The fish maw guidelines document published in 2021 by the Lake Victoria Basin Organization is currently the only regionally approved document specific to the maw trade, which member states commit to use in developing regulations, but is not binding. Some stakeholders are pressing the East African legislative assembly to pass a regional enforcement framework to help partner states jointly manage fisheries, Rukuunya said.
This regional body also recommended various reforms that would benefit Ugandans involved in the upstream supply chain of fish maw, who have so far been marginalized.
These include establishing a pricing scale for licenses that caters for everyone from artisanal workers to large-scale traders and supporting small-scale collectors to form associations where they can sell their maw collectively. The association also urged mandating all maw buyers to have measurement tools that standardize prices, and licensing local maw extraction facilities where members of fishing communities can legally extract, clean and package their maw.
The organization further encouraged developing policies that would require maw processors and exporters, which are owned largely by foreigners, to cede some shares to local businesses.
On taxes, the government should consider reducing the export levy, and companies should be eligible for tax credits based on factors such as their tax compliance and the economic benefits they are bringing to the country and domestic workers, Robert Ssuuna, the tax expert, advised. Since taxation is handled under a separate ministry than fisheries, these experts pushed for cross-cutting efforts even on a national level.
And all this must be done in line with scientific estimates of the maximum number of Nile perch that can be sustained and caught within a healthy lake ecosystem, said fisheries research scientist Dr. Vianny Natugonza.
Although the government purposed to triple capture fisheries production to 700,000 metric tons between fiscal years 2020/2021 and 2024/2025, Natugonza said that these goals were not feasible, insisting that Nile perch was already a fully developed fishery, with an average annual catch of around 70,000-80,000 tons.
One Nile perch of 100 centimeters in length can produce up to 16 million eggs. Nowadays, these big Nile perch are aggressively hunted in Uganda for their higher values of meat and maw. But Natugonza encouraged changing strategy and protecting these big fish, which he said would help the overfished population recover.
“[The government] is saying that we should focus fishing on the big Nile perch. Allow the small Nile perch to grow. And for me I think otherwise. That instead we should jealously protect the big Nile perch, because once we have those big Nile perch, then we are assured of the small Nile perch,” he said.
Even with the hardships, some in Ugandan fishing communities are still dreaming of the long-promised riches from maw, the prospect of eager buyers from the other side of the world providing an irresistible allure. In the islands, one local maw trader said he has been arrested “several times,” but he stays in the trade with “much hope” of future profitability.
Leaders, too, have hope. Sixty-seven year old Ssenyonga, who represents the civil society organization of fishers, grew up by the lakeside in Entebbe, exploring the water from when he was just four years old. Trained as a teacher, he said he found his “calling” back in the lake when “the water spirits called me again.”
Since he started fishing in 1990, Ssenyonga has seen the economy grow from subsistence fishing to a large-scale industry that has supported fishers to invest and take their children to school. Despite the current struggles, this longtime fisherman hasn’t given up yet.
“I really love the lake, but I’ve seen it die,” he said. “I’m happy that I’ve been a change agent. But I’ve not yet delivered the fisherman to where I want him to be.”
