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Sanctions Compliance Undertaking

1. This Sanctions Compliance Undertaking is mandatory for all PARTNUGGET CAR PARTS TRADING DWC-LLC Buyers located in, or delivering goods to, jurisdictions identified as high-risk for diversion or re-export of goods to sanctioned countries. These jurisdictions include, but are not limited to: Turkey, UAE, Kazakhstan, Kyrgyzstan, Armenia, Georgia, Uzbekistan, and other countries neighboring or maintaining significant trade corridors with comprehensively sanctioned territories.

2. Purpose and Use of Goods - The Buyer agrees and confirms that all automotive spare parts delivered under this Agreement are intended strictly for final end-use in the declared country of delivery and exclusively for civilian, non-military purposes. Any re-export, transshipment, resale, or other form of diversion is strictly prohibited without prior written consent of the Supplier and in full compliance with all applicable laws.

3. Prohibited Destinations and Transactions - The Buyer undertakes not to sell, re-export, transfer, or otherwise make available any goods, directly or indirectly, to:

The Russian Federation, The Republic of Belarus, The Islamic Republic of Iran, The Syrian Arab Republic, The Democratic People’s Republic of Korea (North Korea), the disputed regions including Crimea, Donetsk People’s Republic (DNR), Luhansk People’s Republic (LNR) and Any other country, territory, entity, or individual subject to comprehensive sanctions or trade restrictions under:

  • EU Council Regulation (EU) No 833/2014, as amended

  • UK Sanctions and Anti-Money Laundering Act 2018

  • U.S. Department of the Treasury – Office of Foreign Assets Control (OFAC) regulations, including but not limited to Executive Orders 13662, 14024, and 14071

  • UN Security Council Resolutions

The Buyer shall not facilitate or participate in any transaction involving individuals or entities on the EU Consolidated Sanctions List, UK OFSI List, or OFAC Specially Designated Nationals (SDN) List.

4. End-Use and Documentation - The Buyer certifies that the goods will not be used in connection with any military, surveillance, dual-use, or sanctioned activities. The Buyer agrees to maintain and provide upon request full documentation proving: The identity of the end-user, The civilian nature of the end-use, That no diversion, re-export, or indirect transfer has occurred

5. Subcontractors and Downstream Responsibility
The Buyer shall ensure full compliance by its affiliates, logistics providers, resellers, and customers. The Buyer shall remain fully liable for any breach of this undertaking by third parties under its control or within its distribution chain.

6. Right to Audit and Termination - The Supplier reserves the right to conduct compliance audits or request documentation at any time. Any breach of this Undertaking shall be deemed a material breach of the Agreement and may result in immediate termination, notification to relevant authorities, and further legal action.

7. Governing Compliance - The Parties agree that this Undertaking is governed by applicable EU, UK, and US sanctions and export control laws, and shall be interpreted in light of the strictest applicable standard.



By using PARTNUGGET website  buyer undertakes to comply fully and continuously with all obligations set out in this Annex. 

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