I received a response to my email from the :
"Advisor: Firearms Licensing" attached to the Office of the Commissioner at National Police HQ
Sounds like the right guy to talk to.
He advised that Reg. 19 has not changed and that if my security complies to Reg. 19 then it should be accepted.
He's seems a reasonable and approachable guy, and responds well to a straight, succinct question.
regards
Tim
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