Private Armed Guards
Since the IMO allows for Privately Contracted Armed Security Personnel (PCASP) on board of ships sailing through high risk areas (HRA), the Luxembourg government has been authorizing shipowners to hire Private Maritime Security Companies (PMSC) to protect their vessels from pirate attacks.
This has to be done in accordance to the existing legislative framework and in order to apply for such an authorisation, a request (form (321 Kb)) has to be sent to the Commissariat aux affaires maritimes (CAM) by the accredited shipping manager in charge of the concerned vessel (only contacts confirmed by the shipowner or his representative in Luxembourg can be processed).
As of today, the accepted security companies to provide armed maritime security services on board of Luxembourg flagged ships are the following:
- TRIAENA MARITIME SECURITY Ltd
Shipowners are free to work with any of these providers or, if they prefer to work with a new PMSC, they need to follow the procedure mentioned below.
In case of new PMSC (not listed on the website):
For new security companies, a meeting with representatives of the PMSC will be organized in Luxembourg in order to discuss several issues like rules for "use of force", training and background checks of personnel, etc.
Therefore, an advance notice of at least 2 to 3 weeks should be allowed for and prior to the first mission, a copy of license of PMSC as security firm within the European Union (EU) will be requested.
It is important to note that PMSC that are not incorporated in the EU can unfortunately not be considered.
Security companies do not need to contact the Maritime Administration in order to be added to the list. It is solely based on a documented declaration of intend to contract a PMSC as maritime security provider issued by a shipowner or manager of a vessel under Luxembourg flag, that the Maritime Administration will agree to organize this meeting with representatives of that company.
Final decisions will always be taken on a case by case basis.
In case of accepted PMSC (already listed on the website):
In addition to the request form (321 Kb) which will mention the expected route and time frame for the mission (from embarkation of armed guard’s team to disembarkation), several other documents will have to be provided by the ship-owner or operator:
- a copy of the contract between ship owner/operator and security firm;
- a detailed list of armed personal (minimum 4 team members*) with copies of passports, extracts of criminal records and CVs (all relevant documents should be assembled into one single file per agent)
- a detailed list of weapons (with proof of ownership/license) for which carrying licenses are issued.
In order to allow for the administration to properly process the request, it needs to be received at least three working days prior to the planned mission.
A license to carry weapons for personal will be issued by the Luxembourg authorities.
OMI Circular MSC.1/Circ.1405/Rev. 2 shall serve as guideline for organizing the protection of a vessel by a team of private armed guards (PAG).
The use of PCASP must however never be considered as an alternative to Best Management Practices (BMP) and other protective measures.
As per CAM’s instructions, ship operators and masters have to consult and follow advice provided by the latest version of BMP.
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*In case of reduced availability of PAG
In case of shortage in numbers of security guards available to embark on ships sailing through the HRA, PAG teams of less than 4 members may be authorized on a temporary basis and under certain conditions.
In addition to existing Luxembourg authorization criteria (see above), exemption requests for a team of less than 4 guards must be accompanied by the following:
1. Ship and Voyage Specific Risk Assessment assessing ship and crew safety
2. PCASP Risk Assessment confirming the appropriate PCASP team size taking into consideration the following factors:
- Estimated transit time of the ship through the HRA
- Latest threat assessment
- Agreed PCASP team duties
- Vessel size, type, speed and freeboard to be evaluated in regards to the risk
Due to the additional time needed for verification and validation of this supplementary information, it is important to remind ship-owners that they, or their representatives, introduce their requests in due time, minimum 1 week, to the CAM.
No exemption will be granted without prior verification and validation of all requested documents.
Introducing the requested documents in due time is solely the responsability of the relevant shipowners and of the accredited shipping manager, thus the Luxembourg authorities could not be held to account for any encountered delays if the procedure mentioned above together with the circular CAM 07/2023 are not fully adhered to.
Information about public holidays in Luxembourg can be found here (in order to comply with the deadlines stated above).
Accredited shipping manager are therefore kindly asked to provide adequate dissemination of this information to all parties involved .
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