ALSA 2025 meeting

Unresolved maritime boundaries—commonly referred to as “grey areas”—pose persistent legal and strategic challenges for Indonesia, particularly in zones like Tanjung Datu, where maritime claims overlap with Malaysia under the 1982 United Nations Convention on the Law of the Sea (UNCLOS). This paper introduces the GRIHAM-LAW (Grey Area Integrated Maritime and Homeland Law Enforcement and Watch) model as a conceptual and operational framework to address these challenges. Using doctrinal and normative legal analysis, the study explores the structural ambiguity in Indonesia’s maritime border governance, focusing on legal inconsistencies, unclear baselines, and divergent interpretations of entitlements under international law. These complexities have created jurisdictional vacuums that hinder effective law enforcement, open space for illegal activities such as unauthorized fishing and smuggling, and exacerbate tensions in bilateral relations. The GRIHAM-LAW model emphasizes integrated maritime and homeland surveillance, provisional enforcement arrangements, and joint monitoring mechanisms to mitigate risks while promoting legal certainty. Drawing on comparative regional practices and Indonesia’s own multi-agency maritime governance experience, the paper offers policy recommendations aimed at strengthening enforcement coordination, building trust, and protecting national interests without violating international obligations. Ultimately, this model advocates a pragmatic, law-based approach to grey area management that bridges the gap between sovereignty assertion and cooperative regional order.