Guidance

Operating vessel-based armouries

Export licensing requirements for storing firearms on a vessel-based armoury (VBA) in the high-risk area (HRA) of the Indian Ocean.

From:
Export Control Joint Unit, Department for International Trade, and Department for Business and Trade
Published
25 July 2022

This guidance is for operators of vessel-based armouries. It applies when the VBA stores weapons for use by UK private maritime security companies (PMSCs) in the HRA.

It explains how to:

  • get the relevant export licences
  • meet the extra licence conditions for a VBA

VBA licensing for UK companies

UK VBA operators must hold 2 separate open individual trade control licences (OITCLs) to run a VBA. They operate as a pair. One is a mirror of the other.

You must apply for an ‘inward’ OITCL from one of the 15 countries around the HRA to the VBA in international waters. The other is ‘outward’ in the other direction.

You must also supply documents to support your OITCL applications and meet OITCL licence conditions.

Applying for a licence

Apply for OITCLs using SPIRE, the online export licensing system.

See guidance on using SPIRE to get an export licence.

VBA licensing for non-UK companies

Non-UK VBA operators must get approval from Export Control Joint Unit (ECJU) for a UK PMSC to use their VBA. ECJU administers the UK’s export licensing system.

You must submit the same documentation as UK VBA companies to eco.antipiracy@trade.gov.uk.

When you meet the documentation requirements, ECJU will send a letter approving use of the VBA by UK PMSCs. The letter will contain terms and conditions almost identical to those on the UK company’s paired OITCLs.

Supporting documents

All VBA operators storing weapons for UK PMSCs must complete a maritime anti-piracy vessel-based armouries form and send it to eco.antipiracy@trade.gov.uk.

You must also supply:

  • details of all insurance specific to the operation of the armoury, including:
    • Shipowners’ Protection and Indemnity (P&I) insurance
    • public and employers’ liability (copies of certificates)
    • Hull and Machinery (H&M) insurance
  • copies of your ISO 28007 and ISO 28000 approval certificates; evidence the certification has been produced by an internationally accredited certification body, and the date of your last audit
  • flag state and class reports
  • a copy of your standard operating procedures
  • a copy of your rules of engagement / use of force
  • your policy on the storage and disposal of firearms, including what you would do with damaged or surplus weapons
  • your policy regarding zero tolerance of drugs and alcohol
  • the date of establishment of the VBA and how long it has been operational
  • evidence of compliance with principles in the International Code of Conduct for Private Security Providers (ICoC) with one of the following applying:
    • evidence of being a signatory
    • signed confirmation on your company letterhead that you have read and agreed to abide by the ICoC principles and would have become a signatory if you could have done so

OITCL licence conditions

After OITCL licence approval we issue the mirror licences with additional conditions:

All the following conditions apply:

  • the licences are subject to retrospective compliance inspection by ECJU, including all transactions of PMSC goods moved on and off the VBA
  • any approved VBA activity is limited to vessels which are registered to a flag state
  • due diligence must be undertaken on the controlled equipment which PMSCs place under the control of the VBA
  • the VBA must ensure that each PMSC has the relevant authorisation from their own state or country licensing authority to store weapons or goods in their specific VBA
  • PMSCs must not store more than 400 firearms at any one time
  • UK-authorised PMSC clients must provide the VBA with a copy of:
    • their most recent approval letter authorising use of the open general trade control licence (maritime anti-piracy) (OGTCL MA-P)
    • the appendix to the letter showing which land-based and vessel-based armouries they are authorised to use
  • PMSCs can only use VBAs specifically listed on their own OGTCL MA-P approval letter
  • a VBA must maintain a registry of the weapons placed under their control to enable potential future audit by UK licensing compliance inspectors
  • a VBA must not accept into their control any controlled goods that have been used for any unauthorised activities
  • VBA records should detail all movements of controlled goods into and out of each VBA including:
    • reception and removal
    • the country or state of the port of embarkation or disembarkation
    • the intended country or state of the pot of destination
  • controlled goods and equipment stored in the VBA must remain under the VBA’s control at all times, whether in use, in transit or in secure storage
  • the VBA agrees to inform ECJU in writing if any UK-licensed PMSC attempts to use their armouries or any other vessel or land-based armouries without prior authorisation (the terms of the OGTCL MA-P licence strictly prohibit this activity)
  • controlled goods and equipment stored on the VBA:
    • must be protected against unauthorised re-transfers, loss, theft or diversion
    • should not be re-sold, nor donated or loaned to any other entity other than the PMSC that places it under the control of the VBA
  • disposal of equipment stored in a VBA to an unidentified third party requires:
    • a trade licence if you are a UK PMSC
    • approval from their own state or country licensing authority for non-UK PMSCs

VBA: definition

A VBA is generally defined as a small to medium commercial vessel:

  • sized between 800 to 2,000 tons
  • operated from a moored position in international waters, in or around the Indian Ocean HRA
  • providing secure storage for military or dual-use controlled goods belonging to PMSCs, when these goods are not in use on an armed protection transit of the HRA

HRA: definition

The HRA is a United Kingdom Marine Trade Operations (UKMTO) designated voluntary reporting area (VRA). It sets out where there is a higher risk of piracy and within which you may need self-protection measures.

See a maritime security chart defining the HRA.

Countries around the HRA

The 15 countries bordering the HRA are:

  • Comoros
  • Djibouti
  • Kenya
  • Madagascar
  • Malaysia
  • Maldives
  • Mauritius
  • Mozambique
  • Oman
  • Seychelles
  • Singapore
  • South Africa
  • Sri Lanka
  • Tanzania
  • United Arab Emirates (Emirate of Fujairah only)

Contact ECJU

Email eco.antipiracy@trade.gov.uk for more help on export licensing for a VBA.

Published 25 July 2022
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