After a Brief Hiatus, Kenya Once Again Has Universal Jurisdiction Over Pirates

October 24, 2012 by Leave a comment

Jon Bellish is a Project Officer at the Oceans Beyond Piracy project just outside Denver, Colorado, though the views expressed are solely those of the author. You can follow him on Twitter.

On October 18, the Kenyan Court of Appeal in Nairobi handed down a pivotal decision in In re Mohamud Mohammed Hashi, et al. It held that Kenya has jurisdiction to try piracy suspects whose alleged acts occurred beyond the country’s territorial waters. Due to Kenya’s central role in the emerging global network of piracy prosecutions, the Court’s ruling in Hashi will have positive implications both within and outside of Kenya.

The Honorable Mr. Justice David K. Maraga (photo: Kenya Law Reports)

The Court of Appeal decision overturns a ruling from the High Court of Mombasa that concluded, as noted by Roger on this blog, that “[Kenyan] Courts can only deal with offences or criminal incidents that take place within the territorial jurisdiction of Kenya.” Rather than summarizing the lower court’s opinion, I will simply direct readers to Roger’s excellent analysis of that case.

On appeal, Justice David Maraga stated that the High Court erred by, 1) “subordinating Section 69 of the Penal Code to Section 5”; 2) misinterpreting Sections 369 and 371 of the Merchant Shipping Act of 2009, and; 3) “fail[ing] to appreciate the applicability of the doctrine of universal jurisdiction.”

With regards to the first ground of error, the Court Appeals took issue with the High Court’s interpretation of Section 5 of the Penal Code and its relationship to Section 69. Section 5 states that “The jurisdiction of the courts of Kenya…extends to every place within Kenya, including territorial waters.” The High Court characterized Section 5 as the “defining” Kenyan jurisdictional provision and concluded that Section 69, criminalizing piracy on the high seas, was “void, ab inicio.”

Justice Maraga differed with the High Court’s position and held that “there is no conflict or gradation between [Sections 5 and 69].” He noted that Section 5 is part of Chapter 3 of the penal code, entitled “Territorial Application of the Code,” while Section 69 is contained in Chapter 8, “Offences affecting Relations with Foreign States and External Tranquility.” In short, Section 5 concerns itself with the territorial jurisdiction of Kenyan Courts and Section 69 deals with extraterritorial offenses. If anything, concluded Justice Maraga:

“on the established principle of statutory interpretation that in event of inconsistency in statutory provisions the “later in time” prevails, it is Section 69 [passed in 1967] which should supersede Section 5 [passed in 1930] but there is no warrant for that as there is no conflict between the two sections.”

MV Courier, the pirated ship at issue in Hashi (photo: ShipSpotting.com)

The second basis for overturning the High Court’s ruling arises out of the 2009 repeal of Section 69 of the Penal Code and its replacement with Section 369 of the Merchant Shipping Act. Below, the High Court suggested that repealing Section 69 took the crime of piracy jure gentium off the books. However, Section 369 Merchant Shipping Act, the article replacing Section 69, closely tracks UNCLOS article 101’s definition of piracy under international law. Accordingly, although the Merchant Shipping Act does not include the Latin phrase “jure gentium,” the crime of piracy under international law, according to the Court of Appeal, survived the statutory change.

In the alternative, Justice Maraga pointed to Section 23(3) of the Interpretation and General Provisions Act, which states that in the case of a law being repealed mid-proceeding, that proceeding shall move forward “as if the repealing written law had not been made.” Because the act in question was allegedly committed on March 3, 2009 and Section 69 was not repealed until September 1, 2009, the above-mentioned interpretive provision would apply in this case.

The final issue under consideration was the broader question of whether Kenya was authorized under international law to try piracy cases where the act in question was committed outside Kenya’s territorial jurisdiction by perpetrators and against victims who are not Kenyan nationals.

Justice Maraga responded by noting that piracy was a crime of universal jurisdiction and recounting Kenya’s participation in and adoption of UNSCR 1918 in April, 2012. This resolution “Calls on all States, including States in the region, to criminalize piracy under their domestic law and favourably consider the prosecution of suspected…pirates apprehended off the coast of Somalia…” Ultimately, Justice Maraga concluded that:

the offence of piracy on the coast of Somalia, which we are dealing with in this appeal, is of great concern to the international community as it has affected the economic activities and thus the economic well being of many countries including Kenya. All States, not necessarily those affected by it, have therefore a right to exercise universal jurisdiction to punish the offence.

This decision should be welcomed by the international community, especially those involved in the prosecution and detention of suspected pirates. Most immediately, Hashi allows for five separate piracy cases brought under Section 69 of the Kenyan Penal Code to move forward, clearing up a two-year backlog. More importantly, however, the Court of Appeal’s unequivocal acceptance of the principle of universal jurisdiction, its applicability to piracy jure gentium, and its incorporation in Kenyan municipal law ensures that Kenya can continue to play a central role in the regional prosecutions of piracy suspects.

Filed under Somalia Tagged with , , , , , ,

Child pirates: A key issue for respecting child’s rights and halting piracy

October 23, 2012 by Leave a comment

This guest post is by Sonia Messaoudi who is a trainee-lawyer at Paris Bar School with an LLM in international law and human rights. She has interned at Amnesty International and the United Nations Assistance to the Khmer Rouge Trials

Two Somali youth accused of piracy returned home to their parents on 13 August 2012 after a Seychelles court determined they were too young to sentence after an eight-month detention. [Hassan Muse Hussein/Sabahi]

In August 2012, two Somali youth who had been accused of piracy returned home after a Seychelles court determined that they were too young to be sentenced. The children were brought to Garowe on a private plane paid for by the United Nations Office on Drugs and Crime. This is the modern and dark version of piracy books for children. Indeed, this is not an isolated case off the Horn of Africa as about one-third of Somali pirates are children. While eliminating piracy became a worldwide issue, it has to be approached without forgetting the protection of children who are involved in such criminal activities. As noted on the 23 November 2010 for the first time in a piracy resolution, the Security Councilexpressed concern about the involvement of children off the coast of Somalia.

According to international law, children should not be prosecuted by the same means as adults. The United Nations Convention on the Rights of Child states a child (i.e. anyone under 18 years old) should be handled differently than adults when charged with serious crimes, and “be treated in a manner consistent with the promotion of the child’s sense of dignity and worth.”  However, many Somali youth linked to piracy are held in foreign jails, causing great worry for their parents.

As the use of child soldiers is denounced, there is an increasing international mobilization against the use of children for criminal purposes. When dealing with child pirates, there are two possibilities: arrest them in accordance with a juvenile crime, or release them which means they must be put back into one of the worst forms of child labour.

In some countries, children are prosecuted, while in others children are protected. In the countries where children are prosecuted, the State must ensure it does so in accordance with international juvenile justice standards. Over the last twenty-five years, child-specific instruments, such as the UNCRC and general human rights treaties, have played a crucial role in setting out states’ obligations towards young offenders. The UNCRC has four general principles – (i) the right to life, survival and development, (ii) the right not to be discriminated against, (iii) the requirement that the best interests of the child be a primary consideration in all actions concerning children and finally (iv) the right of the child to be heard in all decisions that affect him/her. It requires a dedicated juvenile justice system, a minimum age of criminal responsibility and the adoption of measures to deal with children without resorting to judicial proceedings, provided that human rights and legal safeguards are fully respected. The UNCRC prohibits the imposition of the death penalty and life imprisonment on children, and requires that imprisonment be imposed only as a last resort and for the shortest appropriate period of time. It also prohibits arbitrary deprivation of liberty and provides for the right to prompt legal assistance and the right to challenge the legality of the detention.

As Radhika Coomaraswamy, the Special Representative of the Secretary-General for Children and Armed Conflict stated, if an international criminal tribunal is convened to deal with the perpetrators of acts of piracy, no child should be tried in the same court as adults but rehabilitated and integrated back into their communities. However, if a prosecuting state decides not to prosecute them, the concrete consequence is to put children back into a situation where they may be forced to perpetrate further acts of piracy. Therefore, solutions should be found in order to reintegrate them into the society as required by Article 7 of The 1999 ILO Convention on the Elimination of the Worst Forms of Child Labour, and article 40 the Convention of the Rights of the Child.

Potential solutions may be drawn from the situation of child soldiers. Roméo Dallaire has noted there is no major difference between a child soldier and a child pirate: “they are children being used by adults for criminal or political purposes, and they are extremely vulnerable, and there are a lot of them.” As for child soldiers, a program called “Prevention, Demobilization and Reintegration” created in 1990’s for helping child soldiers helped more than 100 000 since 1998. Prevention consists essentially in advocacy and supporting civil society by raising awareness of child rights through a variety of media, and using local and international human rights reporting mechanisms. Centers have been created in this purpose, assisted by local or international non-governmental organizations, UNICEF, and UN. Furthermore since piracy business is currently costing and estimated $12 billion to the world economy, prevention seems to be a good investment while finding a solution for child pirates and in order to prevent them from engaging in such criminal activities.

However, prevention and reintegration of children is not enough to eradicate piracy. We must attack the roots. Indeed, the employment of children in criminal activities such as piracy is forbidden by the Labour Organization Convention. The UNCRC states the State parties recognizing the right to child to be protected from exploitation shall provide for appropriate penalties or other sanctions to ensure an effective enforcement. In countries where  pirates originate, such as Somalia, governments often do not respect international standards of human rights. However in order to prosecute pirates who are using or recruiting children, some recommendations were made. Indeed, encouraging government to enforce national legislation to ensure there is no impunity against those accused of perpetrating these violations against children, and increasing pressure on persistent perpetrators through greater interaction between the Council and the Secretariat of UN, national courts and the ICC are one of them, as Resolution 1918 requested it off the coast of Somalia. In case of armed conflicts, some resolutions recommend sanctions, such as arms embargos. We could think about these kinds of solutions for piracy too.

However, the issue is now to know whether or not the use or recruitment of children for criminal activities such as piracy can be prosecuted. In some domestic law, as France and in some states in United States of America for instance, there are specific statutes criminalizing encouraging, using or recruiting children for criminal activities. However, where such is not criminalized especially for recruiting children, it may be possible to prosecute for causing, encouraging, soliciting, or recruiting criminal gang members. Furthermore, Article 101(c) on UNCLOS provides another way to prosecute them stating the recruitment can be as an act of incitement.

At the international level, convictions by International Courts of Thomas Lubanga Dyilo and Charles Taylor have helped raised awareness of the criminal nature of the recruitment and use of children in armed conflict. Furthermore, the International Criminal Court disallows the recruitment or conscription of child soldier (under the age of 15 years) into military which is defined as war crimes.

In order to draw a parallel between child soldiers and child pirates, the question is whether child pirates may be considered to be child soldiers. According to the international definition, a child soldier is any child under 18 years of age, who is part of any kind of regular or irregular armed force or armed group in any capacity including but not limited to: cooks, porters, messengers, and anyone accompanying such a group other than family members. Therefore, the question is whether or not pirates who are using or recruiting children are regular or irregular armed force or armed group. An International armed conflict exist whenever there is resort to armed force between two or more States, while Non-international armed conflicts are protracted armed confrontations occurring between governmental armed forces and the forces of one or more armed groups, or between such groups arising on the territory of a State [party to the Geneva Conventions]. The armed confrontation must reach a minimum level of intensity and the parties involved in the conflict must show a minimum of organization. There are two options then. First, it is an non-international armed conflict and we have to determine if the pirates groups can be seen as armed group or irregular armed force, and secondly, it is an international armed conflict and the question is whether or not piracy as international conflict. But pirates group are not well identified.  Both of the two options are not legally convincing. So it seems in most of the case, international humanitarian law cannot apply to child pirates in Somalia, as it applies for child soldiers.

Therefore, in order to impede children piracy and respecting children’s human rights, we should deal with child pirates but also with persons using or recruiting children for such a criminal activities. Where the first ones should not be prosecuted but reintegrated into the civil society, the second ones should be.

What is sure is that we have all, from the local communities to the States and international institutions, the responsibility to make sure the only pirate children should know is Captain HooK.

Filed under Somalia, Worldwide Tagged with , , ,

Long road to justice – The German piracy trial

October 21, 2012 by 2 Comments

 

 

 

This post comes from Tim René Salomon. He is a Rechtsreferendar (articled clerk) in Hamburg and currently assigned to the Landgericht Hamburg. The opinions expressed in this article are solely his own.

After 105 days of trial and a duration of almost 2 years, Judge Dr. Steinmetz announced the verdict and penalties on Friday, the 19th of October 2012 for the Third Grand Penal Chamber of the Landgericht Hamburg. The ten accused were found guilty of two crimes, attack on maritime traffic (§ 316c German Criminal Code – StGB) and abduction for the purpose of blackmail (§ 239a StGB). The adults were sentenced to six to seven years, while the juveniles and accused which were under 21 years of age at the time of perpetration were handed a two year penalty and will walk free after having served their time already during the extended period of pre-trial detention. It may be of even greater surprise, although the author finds this aspect to be one of the great success stories of the trial, that the three young accused behaved exemplary in pre-trial detention during which they went to school and have, after their early release, continued going to school with one of the accused even delivering his last word in the proceeding partially in German.

In the four hours of Steinmetz‘s announcement, he stressed numerous aspects of the trial, the acts committed and the political backgrounds and took the time to deliver his personal perception of what he termed an “absolutely exceptional proceeding”. This exceptionality is clear to observers everywhere. It was Germany’s first piracy trial in about 400 years, it was exceptional in the sense that so far no other trials in Germany are on the horizon on the subject matter, but it was also exceptional or better put notorious for its duration. The fact that it took two years is indeed remarkable, when looking at the rather simple case at hand:

The MV Taipan was headed from Haifa, Israel to Mombasa, Kenya and avoided the vicinity of Somalia in order to be relatively safe from pirate attacks. 500 nm from the Somali coast in the middle of the Indian Ocean on the April, 5 2010 they sighted the dhow Hud Hud, a kidnapped vessel, which was first deemed harmless and the threat it posed became apparent only when it sent two skiffs towards the container vessel Taipan. The crew of the Taipan, which now travelled full speed, was sent to the safe room and the master and two crew-members remained on the bridge. When the skiffs closed in and machine gun fire hit the Taipan, the master ordered everyone in the ship’s citadel. The pirates on the skiffs tried to climb on board, observed by a German maritime surveillance aircraft, and eventually succeeded. The individual role of each accused could not be ascertained with the necessary certainty, but it is documented that the pirates changed the vessel’s course to Somalia and destroyed the GPS antenna to complicate the tracking of the Taipan. After the Taipan’s master Eggers noticed this, he blacked out the vessel from the citadel to stop its travel, knowing that the Netherlands Navy frigate HNLMS Tromp was near, although the attack took place outside of the area under the EU ATALANTA mandate. During the following four hours the pirates unsuccessfully searched for the safe room until soldiers from the Netherlands Navy boarded the Taipan and apprehended ten suspects after a brief previous exchange of fire between the Tromp and the pirates. The suspects were then taken to Djibouti, flown to the Netherlands and were eventually extradited to Germany, where the prosecution was conducted.

What seems to be a rather clear cut case ended up to be a very challenging and long-lasting endeavor for the Hamburg court, which has led the trial with meticulous care. The applicability of German criminal law was more or less uncomplicated, since it derives from the German flag of the Taipan (§ 4 StGB), the passive personality principle as two victims, the master Eggers and merchant seaman Preuß, were German nationals (§ 7 (2) StGB) and the universality principle, which German law applies to attacks on maritime traffic (§ 6 Nr. 3 StGB). The court could have mentioned § 3 StGB, the territoriality principle, as the blackmail was directed against a German-based company, which means that the result of the crime arguably should have occurred in Germany according to the intention of the offenders (§ 9 StGB). Also the Hamburg court is locally competent because of the Taipan‘s home port, Hamburg (§ 10 German Criminal Procedure Code – StPO), with the Grand Penal Chamber of the Landgericht being the proper instance because of the expected penalty above four years imprisonment.

At the start of the proceeding every accused was granted two lawyers to prepare and conduct their defense. The issues started early in the trial. Seeing that people under the age of fourteen cannot be held criminally liable in Germany, the court first had to conduct medical exams to verify the claims of some of the accused that they were below this threshold or were at least under 18 or 21 respectively, rendering the juvenile code applicable. Two expert witnesses were heard until this issue was resolved with the necessary certainty. Moreover, during the trial, witnesses were heard e.g. on the situation in Somalia and the causes of piracy, the responsible captain of the Netherlands Navy testified and the master of the Taipan as well as his second officer also gave evidence. Some of the accused chose to make statements themselves during various stages of the trial, some admitting their participation in the act, while incriminating others, some claiming that they were forced to partake in the attack or at least deceived into participation. While the court was unable to bring to the light how exactly the pirate group conducted the attack, the declarations by the accused led to some insights into the act, although any allegations of force or deceit were held to have been unconvincing, since sufficient evidence pointed to the fact that all of the accused participated voluntarily. Consequently, the court saw an attack on maritime traffic and the abduction for purposes of blackmail as given in this case. The fact that the victims were in the safe room did not prevent the abduction from being successful in a legal sense, since the victims were in fact under the control of the pirates, who controlled the entire vessel.

This led the court to a possible penalty of 5-15 years imprisonment for the adults. In weighing the facts and background of the case to find a just penalty, the court stressed especially the danger of the act, the heavy weaponry used, the damage dealt to the vessel and the high criminal energy, but also the situation in Somalia under which the accused grew up, the fact that the accused were only small fish in a criminal network, the long pre-trial detention periods, the fact that there were no complaints against the accused during this detention and the short duration of the abduction. In doing so, it arrived at substantially shorter penalties than the state attorneys requested in this case.

In its concluding remarks, the court stressed that the trial was surely not able to prevent piracy or deter future perpetrators, but it also underlined that the trial was necessary with regard to the individual perpetrators and in order to communicate to the victims that the crime committed against them was punished. The duration of the trial was certainly longer than necessary. It was criticized by the court that the defense attorneys delayed the trial substantially, which is probably true. Although they merely used the means given to them by German criminal procedural law, some of their requests seemed far-fetched, e.g. the proposal for the court to travel to Somalia to see what life is like there, the proposition, the court should pay bribes in order to obtain witness statements from Somalia, a challenge against the court for bias, because the proceedings started one hour later than originally announced one day, or even the request to lock the captain of the Netherlands Navy, the person responsible for freeing the Taipan, in coercive detention, because he did not give evidence with regard to classified matters.

What remains for the international community? Surely, piracy trials need not last two years to be fair, but this trial shows that granting an effective defense also means trials tend to last longer. Against this backdrop, the ongoing trials in Kenya and the Seychelles, which last only much shorter and which, in case of the Seychelles, have featured one defense attorney for up to 14 accused show what happens when no effective defense is guaranteed. A similarly dramatic contrast is to be found in the way the issue of age was handled in the German trial versus how it is handled in e.g. the Seychelles. While the court in Hamburg went to great lengths to estimate as precise as possible the age of the accused, in the Seychelles, age has up to now not even been a criterion which lead the courts to distinguish between adults and juveniles with regard to the applicable penalties. Expecting the same diligence, which was used in the German proceeding everywhere in the world, would probably be a rule-of-law-overkill, but to some extent the German trial has thrown into sharp relief the conduct of trials elsewhere in the world.

Filed under Somalia, Worldwide Tagged with , ,

United States Supreme Court Gets its Chance

October 19, 2012 by Leave a comment

Abdi Wali Dire, left, arrives at the the federal courthouse in Norfolk, Va. on Tuesday, Nov. 9, 2010

As I previously mentioned here, the US Supreme Court may soon take up the issue of piracy in US courts. This could have importance not only for the piracy prosecutions taking place in the US but for the development of customary international law applicable in other municipal (i.e. domestic) jurisdictions as the US piracy statute directly incorporates customary international law.

The petitions for writs of certiorari in U.S. v. Dire and U.S. v. Said  (available here and here) raise compelling arguments that interplay with Alien Tort Statute litigation. They ask whether piracy as defined by the law of nations incorporates modern developments in international law. The answer will hinge on the limits of a federal court’s authority to ascertain a narrow set of violations of international law construed as federal common law.

The place of federal common law in US courts has been a matter of debate amongst the Justices of the US Supreme Court in two recent cases addressing the Alien Tort Statute which, like the US piracy statute, is defined by reference to “the law of nations.” In Sosa v. Alvarez-Machain, the majority opinion (written by Justice Souter) held:

[T]his Court has thought it was in order to create federal common law rules in interstitial areas of particular federal interest.[…] [There remain] limited enclaves in which federal courts may derive some substantive law in a common law way. For two centuries we have affirmed that the domestic law of the United States recognizes the law of nations. […] It would take some explaining to say now that federal courts must avert their gaze entirely from any international norm intended to protect individuals.

This led the US Supreme Court to determine that the Alien Tort Statute claims “must be gauged against the current state of international law, looking to those sources we have long, albeit cautiously, recognized.” These include treaties, custom, and the works of eminent jurists.

Justice Scalia was even more categorical in a partially concurring opinion that there exists only “a specifically federal common law (in the sense of judicially pronounced law) for a few and restricted ”areas in which a federal rule of decision is necessary to protect uniquely federal interests, and those in which Congress has given the courts the power to develop substantive law. […] [But] [C]ourts cannot possibly be thought to have been given, and should not be thought to possess, federal common-law-making powers with regard to the creation of private federal causes of action for violations of customary international law.”

“[T]he question to me is who are today’s pirates. And if Hitler isn’t a pirate, who is? And if, in fact, an equivalent torturer or dictator who wants to destroy an entire race in his own country is not the equivalent of today’s pirate, who is?” So asked Justice Breyer during the Kiobel v. Royal Dutch Shell oral argument on 1 October 2012

The Office of the Federal Public Defender takes up the federal common law debate in its petition, urging that although modern developments in international law might inform the existence of a civil cause of action, the same cannot inform the definition of a crime. It asserts,

Federal criminal law, unlike tort law, most decidedly is not an area in which judges are permitted to derive “substantive law in a common law way.” Sosa, 542 U.S. at 729. The elements of a federal criminal offense, in particular, must be defined by Congress alone. See, e.g., Liparota, 471 U.S. at 424. Elements of federal criminal offenses are not created by courts engaged in the uncertain enterprise of discerning the state of customary international law, unguided by an authority of last (or even first) resort.

Herein lies the crux of the issue. Must the law of nations as used as a definitional base in US statutes have a fixed meaning pertaining to crimes, when such is not required for civil causes of action? Given the central role piracy played in the recent oral argument in Kiobel v. Royal Dutch Shell, the Court may decide now is an opportune time to take up communis hostis omnium.

Filed under Somalia, Worldwide Tagged with , , , ,

Weekly Piracy Review

October 19, 2012 by Leave a comment

Somalis on Trial for Piracy in Rotterdam

Kenya’s Court of Appeals overturned a 2010 ruling (as we have noted here and here), which had mandated that Kenyan courts only try cases in which the offense occurred within its territorial waters. This impaired Kenya’s ability to assist in the international effort to punish those carrying out acts of piracy on the high seas. Judge David Maraga read the opinion of the court concluding that “piracy has negative effects on the country’s economy and any state, even if not directly affected by piracy must try and punish the offenders.” Though it appears some piracy prosecutions were continuing in Kenya despite the 2010 ruling, the international community will be relieved to know that the law in Kenya is now settled and that no obstacles remain to such prosecutions.

A Dutch court convicted nine Somali pirates to four-and-a-half years imprisonment. These individuals were arrested on-board an Iranian fishing boat they had taken in April. Though they were convicted of piracy, the men were acquitted on charges of attempted murder, as it could not be determined which of the men actually fired at the Dutch marines who arrested them.

Last Friday the Greek-owned carrier ship, the MV Free Goddess, was finally released by the Somali pirates who held it since Feb. 7, 2012. All 21 members of the crew who were on board at the time the ship was attacked over eight months ago were also released and appear to be well. The pirates responsible initially sought a $9 million ransom, yet they finally settled for $2.3 million last week-though the figure has also been reported as $5.7 million. This figure was stated by a Somali pirate and has not been confirmed by the company owning the ship, Free Bulkers SA. The ransom was air-dropped onto the Free Goddess, which then headed toward Oman to refuel, get fresh water and change out the crew members. During the time the ship was held hostage it was apparently being held at Gara’ad, a haven in Puntland, Somalia often used by pirates in the area.

Suspected Nigerian pirates boarded a Panamax tanker in the Gulf of Guinea off the Ivory Coast during the night on Saturday, October 6. Fourteen pirates, armed with knives and AK-47s hijacked the ship and re-directed it to Nigerian waters. They held the ship for three days while siphoning off oil, and then released the ship as well as all crew members on October 9. This attack was particularly alarming as it is the first of its’ kind to be reported in these waters, and shows that the Nigerian pirates are becoming both more sophisticated and bold. The attack occurred further west and away from Nigerian waters than any other reported attack, in an area which until now was believed to be safe for anchoring and performing fairly time-consuming operations. These Nigerian pirates took advantage of the fact that this particular ship was only midway through a ship-to-ship operation at the time of the attack. Tanker operators may now have to reassess their practice of carrying out these operations in the waters of the Ivory Coast.

Filed under Somalia, West Africa, Worldwide Tagged with , , , , ,

← Older posts

Newer posts →