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armed defense. The use of arms should be the responsibility of trained, experienced, professional security personnel. We currently engage two different security companies; their personnel embark on our vessels when the vessels commence operation in high risk areas like the Gulf of Aden and the Persian Gulf.

Second, although we have demonstrated that arming our vessels can be done, U.S. and international laws present significant impediments to arming. As a general rule, private security teams are prohibited by various national laws from travelling with arms to embark aboard a vessel. To the extent that the U.S. Government can obtain cooperation from other governments to permit armed security to travel with arms for deployment aboard vessels, it should do so. We would much prefer to stay out of the arms business altogether, and leave it to trained security forces to bring their weapons with them when they board our vessels.

In the interim, because of these limitations, if security teams are used aboard our vessels, we must provide the weapons, and the weapons must be aboard the vessel when the security teams embark.

Under U.S. regulations, placing weapons aboard a vessel departing the U.S. is considered an “export” of weapons, even if those weapons are intended as a permanent part of ship’s equipment and the weapons are intended to be brought back to the U.S. when the vessel returns. To “export” weapons as part of ship’s equipment, U.S. regulations the “ITAR” regulations, require an International Arms Dealer Export License. These regulations are found at 22 CFR 123.1 et seq. Obtaining a “temporary export license,” is virtually impossible because the State Department requires explicit consent from every country to which the vessel will call prior to issuing a permit. We have attempted to obtain such consent from some of the countries where we call, to no avail.

Therefore, the only way to place arms aboard a vessel is under the regulations at 22 CFR 123.17(c), which permits individual seamen to bring up to three semi-automatic weapons, less than 50 caliber, aboard the vessel as personal effects. We have had our crew sign for weapons (semi-automatic AK47s or their equivalent) aboard our vessels departing the U.S. The weapons are kept in secure storage by the Captain and are released to the security team when required.

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