COMMISSARIAT AUX AFFAIRES MARITIMES OFFICES RELOCATION

 

The Commissariat aux affaires maritimes would like to inform all interested parties of its relocation:

Since 28 October 2021, our new address is :      

3-5, rue Auguste Lumière

L-1950 Luxembourg

Email addresses and telephone numbers remain unchanged.

Luxembourg Maritime Administration

Use of Private Armed Guards (PAG) on board of Luxembourg Flagged Ships

Reduced availability of Private Armed Guards (PAG) personnel

Given the current situation with COVID-19 related travel restrictions and the shortage in numbers of security guards available to embark on ships sailing through the high-risk area (HRA), private armed guards (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 below), 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 to the Luxembourg Maritime Administration. No exemption will be granted without prior verification and validation of all requested documents.

Request may be introduced as of today to the Luxembourg Maritime Administration.

Since the IMO allows for Privately Contracted Armed Security Personnel (PCASP) on board of ships sailing through high risk areas (of piracy attacks), 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 has to be sent to the Commissariat aux affaires maritimes either by the shipowner or 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).

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.

The request form will mention the expected route and time frame for the mission (from embarkation of armed guard’s team to disembarkation) and several documents will have to be provided by the ship-owner or operator together with the request:

‐ copy of license of PMSC as security firm within the EU (PMSC that are not incorporated in the EU can unfortunately not be considered). This document is only requested for the first mission of any security firm;

‐ copy of the contract between the ship-owner or -operator and the PMSC;

‐ 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);

‐ detailed list of weapons (with proof of ownership/license) for which the carrying license is to be issued. In case of an expired End User Certificate, a statement from the security company certifying that the listed weapons are in the possession of the company since the emission of the certificates has to be provided.

A license to carry weapons for personal will be issued by the Luxembourg authorities.

It is important to note that for first time service providers (PMSCs), an advance notice of 2 to 3 weeks should be allowed for.

OMI Circular MSC.1/Circ. 1405/Rev. 1 should serve as guideline for organizing the protection of a vessel by a team of private armed guards. The use of PCASP must however never be considered as an alternative to Best Management Practices (BMP) and other protective measures. As per this administrations instructions, ship operators and masters have to consult and follow advice provided by the latest version of BMP (BMP4 attached).

Additionally and for new security companies only, 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 and more.

Final decisions will always be taken on a case by case basis.

As of today, the following security companies have been accepted to provide armed maritime security services on board of Luxembourg flagged ships:

-         DIAPLOUS Maritime Services

-         ESC Global Security

-         ESS Maritime

-         GALLICE Developments Ltd

-         KAHL SICHERHEIT

-         LSS-SAPU Ltd

-         PRORISK INTERNATIONAL Ltd

-         SEAGULL MARITIME SECURITY Ltd

-         TRIAENA MARITIME SECURITY Ltd

-         UNITED GUARDS SERVICES Ltd

Shipowners are free to work with any of these providers or, if they prefer to work with a PMSC not listed here, to contact the Maritime Administration in order to organize a preliminary meeting with executives of the security company.

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 a meeting with representatives of that company.