Licensing for private maritime security companies
Information on licensing needed for private maritime security companies (PMSC's) to provide maritime anti-piracy services in the ‘high risk area’ (HRA).
This guidance applies to PMSCs who need licences to provide maritime anti-piracy services when in the HRA of the Indian Ocean through the supply, transfer or delivery of certain controlled goods.
PMSC licensing for UK companies
As a PMSC with the objective of providing maritime anti-piracy services within the HRA, you must apply for an open general trade control licence maritime anti-piracy (OGTCL MA-P).
The purpose of the OGTCL MA-P is to permit the provision of maritime anti-piracy services in the HRA, subject to certain conditions. This is through the supply, delivery or transfer of any of the controlled goods listed in Schedule 1 of the licence document.
The geographic boundaries of the HRA will change from time to time. Therefore, it is important that you use the latest information on current threats when planning routes through the HRA.
Subject to its conditions, the OGTCL MA-P licence is available for use by any PMSC if you are operating from the UK or operate and run a PMSC as a UK national.
You must comply with all the terms and conditions within the licence in order for it to be valid.
Securing controlled goods
The terms and conditions of your OGTCL MA-P licence requires controlled goods to be under your control at all times.
This can be through:
- your personnel
- the personnel of a PMSC subsidiary over which you have 100% control
- an approved in-country representative
- an approved vessel-based armoury
If you need to move your controlled goods by air, land or sea you must ensure:
- they remain in secure storage throughout the journey
- at least one member of your team accompanies them
- they do not enter ports or territorial waters which are under embargo or sanction unless approved in advance and noted in writing by Export Control Joint Unit (ECJU) on your licence approval letter
The term ‘Goods held in bond’ is not relevant to this sector. Controlled goods which are held securely on board PMSC vessels should not be described as ‘in bond’.
Voluntary declarations
Schedule 2 of the OGTCL MA-P lists countries that you cannot export or transfer controlled goods from or to when using this licence. You should remain alert as to when other countries may be added to the list of countries under embargo or sanctions. If you breach the licence you must report the irregularity to HMRC as soon as possible.
Applying for an OGTCL MA-P
To apply for an OGTCL MA-P, you should follow this process:
1. Log in or set up an account for SPIRE, the online export licensing system. See guidance on using SPIRE to get an export licence.
2. In SPIRE, you will be asked to select the licence you would like to register for from a drop-down list. You should select OGTCL MA-P and follow the instructions.
3. Following submission, you will receive a registration document from SPIRE allocating you a unique licence number starting with ‘GBOGE’. You must use this GBOGE reference in the subject of all correspondence regarding your OGTCL MA-P application thereafter. This registration document does not permit you to use the OGTCL MA-P licence at this stage.
4. Alongside receiving the automated notice from the SPIRE system, you will receive a letter from the ECJU Maritime Anti-Piracy team thanking you for registering to use the OGTCL MA-P and advising you of the next steps.
5. The next steps will require you to supply copies of specific additional documents in support of your application to comply with the terms and conditions of the licence.
Find out more about supplying documentation in support of a maritime anti-piracy licence registration.
Contact ECJU
Contact our helpline for any queries on maritime anti-piracy licensing.
Maritime Anti-Piracy Unit
Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY
Email [email protected]
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