The Dept. of Treasury recently released data revealing U.S. votes on development projects at multilateral development institutions to which the U.S. is a dues-paying member. This update records votes on projects taken between January and August 2025, including the historic “No” vote reported recently by SSA against funding for a major overseas shrimp exporter, Thai Union. The release of this data ended a record-breaking 13-month drought in reporting from Treasury. The longest previous delay that the Southern Shrimp Alliance is aware of was eight months.
Between February and April 2025, Treasury did not participate in roughly 95 percent of all MDI project votes. Its stated reason for not participating in most of these votes was that “due to the lack of an Acting U.S. Executive Director, the United States was not able to enter a vote.” When the U.S. abstains, funding decisions may be made without its input. For example, at the International Finance Corporation (“IFC”), which has provided millions of dollars in funding to the Ecuadorian shrimp aquaculture industry, project funding decisions are made based on a majority of the votes cast on that project. (IFC Articles of Incorporation § 3(b) (2020)). As the year progressed, Treasury participated in more and more funding decisions, and by July appeared to be back to participating normally in votes.
Treasury has also added a new code to its available list, code “83”, described as “Neutral Posture”, which it used almost exclusively with an “Abstain” position. Historically, Treasury has taken an Abstain position in around eight percent of votes, but in July and August, the two months which appear to be unaffected by the U.S. having no Executive Directors earlier in the year, Treasury recorded a neutral abstention for 28 projects, which represented over 14 percent of project decisions. This may represent a new normal for Treasury, taking a less assertively pro-funding posture in general, but risks more projects being funded without U.S. input. As the steward of American taxpayers’ dollars, Treasury has an obligation to participate in every funding vote possible.
Treasury, however, seems to have shown a special interest in preventing MDIs from funneling money into the foreign shrimp industry in 2025. Despite having no Acting Executive Director, Treasury specifically voted “No” in April on an IFC loan to Thai Union that would help the company expand shrimp production in Thailand. Treasury did not cite 22 U.S.C. § 262h, also known as the “Surplus Commodities Rule,” in its decision. This law obligates Treasury to vote against projects at MDIs which support increases in availability of commodities already in surplus on the global market and increased availability of which would cause injury to U.S. producers. SSA has previously explained to Treasury through formal correspondence the negative impact on the U.S. domestic wild-caught shrimp industry of MDIs providing funding for overseas shrimp aquaculture and how that funding has led to oversupply and depressed prices.
Treasury is aware of its obligation to follow this law, as it is vote code “2” on its “Key to Voting Record of the U.S. Executive Directors to the International Financial Institutions.” However, it did cite “trade policy and reputational concerns” in its decision. It is a positive development for the U.S. domestic shrimp industry if Treasury begins to treat overseas shrimp production as a significant trade issue and pushes to cut funding going forward. It will take time to know if the spotlight that SSA has helped shine on Treasury’s voting behavior has made lasting change in their treatment of the shrimp industry, but SSA applauds this first step by Treasury.
SSA identified no further shrimp aquaculture projects in the eight months of published data. This continues a slowdown in MDI funding for aquaculture projects that began in 2024. Between 2016 and 2020, shrimp and aquaculture projects averaged around five per year. This number increased to an average of almost eight per year from 2021 to 2023. In 2024 and 2025, however, SSA has identified only two shrimp or aquaculture projects. It’s unclear why MDI funding for aquaculture projects seems to have slowed, and both deliberations and vote-taking at these institutions is not made public.
Access the updated U.S. Treasury Votes database current through December 2025 here: https://shrimpalliance.com/issues/fighting-for-fair-trade/mdi-funding-of-shrimp-aquaculture/
Review the U.S. Treasury Department’s “Key to Voting Record of the U.S. Executive Directors to the International Financial Institutions” here: https://home.treasury.gov/system/files/206/Voting-records.pdf