dangerous and counterinsurgency operations such as members of US SEALs, or SWCC, the British SAS or the French Legion[51]. The criteria of nationality and residence could not be applied to contractors from the United States, the United Kingdom, Canada, Australia, and other countries which have been involved in the conflicts in Afghanistan and Iraq. It could be applied to nationals of countries such as Peru, Honduras, and Chile that are not parties to the conflict. In the case of Chile, it is interesting to point out that while the government of Chile voted against the UN Security Council resolution to intervene in Iraq Chilean citizens were contracted by PMSCs to provide "passive protection" in Iraq. The requirement that a mercenary must not be a member of the armed forces of a party to the conflict could easily be circumvented by a given state that utilizes PMSCs by incorporating these employees into its own armed forces. Each of the elements taken individually poses problems to classify PMSCs as mercenaries. For PMSCs and their employees to be considered mercenaries, all the requirements in the definition of the international instruments must be cumulatively met. PMSCs are commercial firms legally registered in their home countries, a large number of which have obtained contracts from governments (the Pentagon and the State Department in the United States). In addition, only 32 states have ratified the International Convention against the Recruitment, Use, Financing and Training of Mercenaries and most of the governments which contract PMSC are not