Sanctions Compliance Policy
NOVOTEST Ltd Commitment to International Trade Compliance
NOVOTEST Ltd is committed to conducting business in full compliance with applicable international trade laws, export control regulations, and economic sanctions regimes.
As a responsible Ukrainian manufacturer and exporter of non-destructive testing (NDT) equipment, NOVOTEST Ltd applies strict compliance standards in all international transactions and reserves the right to refuse cooperation with any company, distributor, intermediary, payer, or end user whose activities may violate applicable sanctions or export control requirements.
Restricted Countries and Territories
NOVOTEST Ltd does not conduct business, directly or indirectly, with companies, organizations, or individuals located in, registered in, operating from, or connected with the following sanctioned or high-risk countries / territories:
- Afghanistan
- Belarus
- Eritrea
- Iran
- Iraq
- North Korea
- Cuba
- Nicaragua
- Syria
- Russia
- Venezuela
- Democratic Republic of the Congo
- Yemen
- Zimbabwe
- Libya
- Myanmar
- South Sudan
- Sudan
- Somalia
Additionally, the following disputed / restricted territories are subject to restrictions:
- Crimea
- Abkhazia
- South Ossetia
- Northern Cyprus
- Transnistria
- Kosovo (subject to case-by-case review)
Indirect Supply Restrictions
NOVOTEST Ltd does not cooperate with any companies, intermediaries, distributors, freight forwarders, or other persons/entities involved in the direct or indirect supply, resale, export, re-export, transfer, diversion, or unauthorized redistribution of our products to sanctioned countries or sanctioned parties.
This includes attempts to conceal:
- final destination
- end user
- ownership structure
- payment source
- intended use of goods
Customer Obligations
By purchasing goods from NOVOTEST Ltd, the customer undertakes not to sell, export, re-export, transfer, supply, or otherwise make available any goods purchased from NOVOTEST Ltd, directly or indirectly, to:
- Russia
- Belarus
- Iran
- any sanctioned jurisdiction listed above
- any sanctioned company or sanctioned person
- any individual or legal entity associated with such countries
- any person acting on behalf of such parties
- any use within such countries
Mandatory Confirmation Letter for Each Shipment
Together with each order placement and prior to every shipment, the customer (payer / purchasing company) must provide an official signed confirmation letter on company letterhead confirming that:
- the customer is the legitimate purchaser of the goods;
- the final destination, delivery address, and end user have been fully and accurately disclosed;
- the goods purchased from NOVOTEST Ltd will not be sold, exported, re-exported, transferred, supplied, or otherwise made available, directly or indirectly, to any sanctioned country, sanctioned company, sanctioned person, or any party acting on their behalf;
- the goods will not be delivered to, used in, or routed through any restricted jurisdiction in violation of applicable sanctions laws;
- NOVOTEST Ltd will be immediately notified of any change regarding ownership, destination, end user, or payment structure.
Provision of such confirmation letter is mandatory for each shipment. Failure to provide the required confirmation may result in suspension, cancellation, or refusal of order processing and shipment.
Right to Refuse or Terminate Cooperation
NOVOTEST Ltd reserves the right to:
- refuse quotations, orders, or deliveries;
- suspend negotiations;
- cancel confirmed orders where legally permitted;
- terminate distributor, dealer, or reseller relationships;
- request end-user certificates or additional compliance documentation;
- report suspicious requests to relevant authorities where required by law.
Compliance Screening
All new customers, distributors, counterparties, and selected transactions may be subject to internal compliance screening, including:
- sanctions screening
- ownership verification
- end-user review
- destination control
- payment route review
- fraud / diversion risk assessment
Our Commitment
NOVOTEST Ltd supports lawful international trade, transparency, ethical business practices, and responsible export operations.
We thank our customers, distributors, and partners for their cooperation and understanding.