1.

11.2. On the movement of weapons, ammunition to it, main parts of weapons, devices and cartridges for them between the objects of the permit system.

The instructions indicate the movement of weapons between the objects of the permit system in accordance with the movement order. Are there still legal grounds for the movement of weapons belonging to the economic entity (hereinafter referred to as the SGT) in order to exclude the “abuse of responsible persons”?

If there are legal grounds for transporting weapons, then regardless of their quantity, the requirements of paragraph 10.2., namely, escort by two armed persons must be complied with?

Malyar Oleksandr

Partially taken into account.

During the preparation of the draft amendments to the Instruction of the Order of the Ministry of Internal Affairs No. 622, the Ministry of Internal Affairs of Ukraine took into account the proposals of business entities operating in the sphere of circulation of objects, materials and substances subject to the licensing system of internal affairs bodies, to simplify procedures, including those related to the movement of weapons, devices between objects of the permit system that belong to the same business entity.

2.

https://zakon.rada.gov.ua/laws/show/z0079-95#Text — application of the requirements of the above Rules in the commission sale of weapons.

Malyar Oleksandr

Not taken into account.

This issue is regulated by the License Terms approved by the Resolution of the Cabinet of Ministers of Ukraine dated December 02, 2015 No. 1000.

3.

6.2. [...] About all actions committed related to the circulation of weapons, ammunition for it, main parts of weapons, devices, cartridges for devices, objects and materials, as well as their owners, relevant information is entered into the ERZ.

During the sale (acceptance for sale) of weapons, basic parts of weapons, devices by an arms trade store in an arbitrary form, an act of acceptance and transfer is drawn up, one copy of which is provided to the person who purchased (handed over) weapons, main parts of weapons, devices. A scanned copy of the act of acceptance and transfer by an arms trade store is submitted to the ERZ.

Malyar Oleksandr

Taken into account.

4th.

9.18. [...] referral for commission sale (in case of acquisition from an individual — owner or other business entity, enterprise, institution, organization); [...]

An extract from the ERZ on the availability of permission to purchase objects and materials by legal entities is the basis for transportation by an entity, enterprise, institution, organization to the place of storage of purchased weapons, ammunition for it, main parts of weapons, devices within the territory, city, district, settlement, regardless of distance.

Malyar Oleksandr

Taken into account.

5.

10.4. Without permits of police bodies (units) for the transportation of weapons, main parts of weapons, combat supplies, devices and ammunition for them belonging to enterprises, institutions, organizations and business entities that have a valid permit for the operation of the permit system object are transported within the territory, city, district, the settlement, regardless of the distance.

On the movement of weapons, ammunition for it, main parts of weapons, devices, and cartridges for them between the objects of the permit system belonging to the same business entity, the entity shall enter into the ERZ information on the change of the storage location of the relevant items and means of the ERZ shall inform the UPP GUNP at the place of storage of weapons, devices, the main parts. Such movement takes place according to the order of the business entity, which indicates the type, brand, model, series, number of weapons, devices, main parts of firearms, the total number of ammunition, cartridges required for transportation, without additional obtaining the appropriate permission to purchase them.

Malyar Oleksandr

Not taken into account.

(second paragraph, point 10.4 of the project)

This requirement is provided for in paragraph 11.2 of the project.