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.
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 바카라 사이트˜inward바카라 사이트™ OITCL from one of the 15 countries around the HRA to the VBA in international waters. The other is 바카라 사이트˜outward바카라 사이트™ 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 .
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 UK바카라 사이트™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 company바카라 사이트™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:
- Shipowners바카라 사이트™ Protection and Indemnity (P&I) insurance
- public and employers바카라 사이트™ 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, accredited as certifying to UK standards, 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 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 VBA바카라 사이트™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.