Omega Research Foundation requirement that SUCAMEC checks the equipment for export before it leaves the warehouse and again at the point of departure.228 A 2013 amendment to the law authorised electric shock devices and pneumatic weapons that fire ‘rubber bullets’ for civilian use, meaning their import and export by civilians is now controlled by SUCAMEC, which was not previously the case.229 However, the law also has weaknesses. The UN Protocol against the Illicit Manufacturing of and Trafficking in Firearms, Their Parts and Components and Ammunition provides that in cases involving international transactions of firearms, state records should include the equipment’s final recipient.230 This would normally take the form of an end user certificate. Peruvian law governing the export of firearms and related material seemingly makes no mention of end user certificates231 and the absence of such a requirement suggests that Peruvian authorities may not be required to consider who the end user will be when deciding whether or not to award an export license. This loophole could potentially be exploited to sell weaponry covered by the law (including electric shock devices) to states, individuals or groups involved in human rights violations. In addition, it appears that the export and import of some types of law enforcement equipment, including pepper spray and mechanical restraints, are not controlled by this or other laws. State-owned manufacturer FAME is governed by a different legal regime. According to Peruvian law, FAME has administrative, technical, commercial and financial autonomy and its operations and foreign trade agreements are to be bound only by ‘the uses and customs of international trade and generally accepted international legal norms’.232 Although FAME’s objectives include the trade of weapons and ammunition in both national and international markets,233 there appears to be very little control of such activities and neither Law No 29314, which establishes the legal framework within which FAME is required to act, nor the FAME Regulation of Organisation and Functions make any reference to human rights. The Arms Trade Treaty (ATT) represents an advance in the regulation of the international trade in conventional weapons and ammunition, but it does not cover most law enforcement equipment. The ATT has been ratified by Argentina, Guyana, Paraguay, Peru and Uruguay, and signed by Brazil, Chile, Colombia and Suriname. Omega encourages those states that have yet to ratify the ATT to do so as soon as possible, as well as expanding controls to cover law enforcement equipment. The ATT’s focus is on military assistance and the international trade in conventional weapons. The Treaty consolidates the requirements on states to assess the risks of serious human rights violations before licensing the export of ‘the broadest range of conventional weapons’. Article 7 prohibits arms exports where there is an overriding risk of committing or facilitating a serious violation of international human rights law. Article 13 of the Treaty requires States Party to submit detailed annual <http://www.peru.gob.pe/docs/PLANES/13933/PLAN_13933_2015_SEGUIMIENTO_PEI__A%C3%91O_2014.PDF> [accessed 1 June 2016], p.5. 228 Decreto Supremo No 007-98-IN, Articles 64 and 65. 229 Decreto Supremo N° 006-2013-IN. 230 UN Protocol against the Illicit Manufacturing of and Trafficking in Firearms, Their Parts and Components and Ammunition, Article 7. 231 United Nations Regional Centre for Peace, Disarmament and Development in Latin America and the Caribbean (UNLIREC), Normas e instrumentos legales sobre armas de fuego, municiones y explosivos, 2010, <http://www.unlirec.org/ourwork/documents/nationalstudies/peru.pdf>, p. 76, accessed 21/12/2015. 232 Ley No 29314, Ley de la Fábrica de Armas y Municiones del Ejército FAME S.A.C., 2009, Article 3. 233 Ibid. Article 2(b). 52