The Border Violence Monitoring Network welcomes the call for evidence for the 2014 European Union Maritime Security Strategy (EUMSS) and its revised Action Plan (2018) as a possibility to contribute to the safety at sea through pointing at current lacks in compliance with UN, EU and national law and offering recommendations for the implementation of such within the newly formulated strategy.

With this submission, BVMN aims to contribute to the Maritime Security Strategy, drawing particular attention to severe violations of international law concerning people in distress at sea. BVMN will especially focus on the mounting securitization efforts through the increasing employment of the European Border and Coast Guard Agency (Frontex), as well as a strengthening of border surveillance strategies to the detriment of Search and Rescue. Finally, we are formulating recommendations on how the significant gap between international Human Rights legislation and its implementation through national and European actors can be reduced and the compliance with international law at Europe’s external border assured within the updated Maritime Security Strategy. Even though the expertise of BVMN lays on pushback incidents in the Aegean Sea, the following submission will also cover some developments in the Mediterranean Sea. Through that, we aim to point to the overall importance of a comprehensive and reliable implementation of international law at sea within renewed Maritime Security frameworks.