Coalter Lathrop returns ten months after Episode 21, and the DSHMRA application story has grown significantly messier. Five applications are now public on NOAA’s site — four companies, two of which are subsidiaries of American Metal Incorporated, an entity that didn’t exist until January 2025, with one applicant incorporating as recently as August 2025. His read on the motivation ranges from holding licenses as a future bargaining chip if the US eventually joins UNCLOS, to outright stock pumping by finance-world actors betting on a land-rush narrative. The more consequential development is the first genuine spatial conflict in the Clarion-Clipperton Zone between two separate corporate interests — SeaX, an American Metal subsidiary, filing over areas already reserved for Impossible Metals Bahrain under the ISA. That’s a different problem than TMC’s intra-subsidiary overlap, and it puts Article 139’s obligation-to-ensure clause directly in the spotlight. Coalter has mapped at least 17 states parties — including Canada, the Netherlands, Switzerland, the UK, Belgium, Nauru, and Tonga — whose nationals appear in these five DSHMRA applications as applicants, contractors, or named technical partners. With the UK already having enacted domestic legislation tying unlawful seabed activity to money laundering law, and parliamentarians in the Netherlands and Switzerland actively raising the issue, Coalter argues the question is shifting from whether these states have an obligation to act — to which one moves first. Follow Coalter LinkedIn: https://www.linkedin.com/in/coalter-g-lathrop-7372bb6/ Chapters * 00:00:47 — Coalter’s Work Over the Past 10 Months * 00:08:02 — The New DSHMRA Applications: Who Is Applying and Why? * 00:17:13 — The First Direct Corporate Conflict: SeaX and Impossible Metals Bahrain * 00:30:38 — The Original Purpose of the ISA * 00:31:33 — The 171 Countries and the Obligation to Ensure * 00:38:51 — 17 Countries With Nationals in the DSHMRA Applications * 00:44:44 — How the UK Has Approached Its Treaty Obligations * 00:45:01 — The Need For Subcontractors and Legal Exposure * 00:51:55 — NORI and TOML Bring Cases Against the ISA * 00:57:46 — Dispute Settlement Gets Its First Test Drive * 01:05:08 — What a Realistic Path Forward Could Look Like * 01:08:28 — Kingston Roundtable, July 20th Legal/Regulatory References: * NOAA DSHMRA Applications comments: https://www.regulations.gov/document/NOAA-NOS-2026-0035-0001/comment * UNCLOS Article 139 — Obligation to Ensure: un.org/depts/los/convention_agreements * Seabed Disputes Chamber 2011 Advisory Opinion: https://www.itlos.org/fileadmin/itlos/documents/cases/case_no_17/17_adv_op_010211_en.pdf Event: * Coalter’s ISA Kingston Roundtable — Monday, July 20th, ISA Council Week 2, Kingston, Jamaica (targeting state delegations; topic: Article 139 obligation to ensure) Previous Appearance: #21: Coalter Lathrop on Risks to International Stability This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit tradingoff.substack.com/subscribe