The association would like to alert Members to two recent incidents involving Member ships registered in the Bahamas and visiting Brazilian ports. The ships received substantial fines by Brazilian immigration authorities for invalid crew documents because crewmembers had Bahamian Seaman's Record Books.

The Brazilian authorities can, in their discretion, accept or reject the documents provided by crewmembers carrying Bahamian Seaman's Record Books, because the Bahamas is not a signatory to the ILO Convention 108 on travel documents. Bahamian regulations describe the Seaman's Record Book as a record of discharge/sea-time only and is specifically not to be used as an identity card.

Because Brazilian authorities are allowed to exercise discretion in the case in which the flag country is not a signatory to the ILO convention, Members' ability to challenge these fines at the administrative and/or court level is uncertain. In one case currently being handled by the Club, the fine is in excess of US$ 400,000.

Because the Brazilian authorities are within their rights to reject the Bahamian Seaman's Record Books, they can insist that crew have relevant visas to work on ships calling in Brazilian ports. Members are advised to provide visas for all crew of ships visiting Brazilian ports, or ensure crews obtain valid seamen's identity cards from their home country.

Source of information:

Pat Bush

Thomas Miller (Americas) Inc.

New Jersey, USA

+1 201 557 7300

Newjersey.ukclub@thomasmiller.com