Defence Armament OÜ, registry code 17555647, registered in the Republic of Estonia, European Union, trading as Defence.us

 

1. STATEMENT OF COMPLIANCE

Defence.US and its affiliated entities operate in full compliance with all applicable international export control laws and regulations, including the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), UN Security Council arms embargoes, and all relevant national export licensing regimes in the jurisdictions in which we operate. All defense articles, services and technical data handled by Defence.US are subject to applicable export control laws. End User Certificates (EUC) are required for all defense article transactions. Defence.US does not sell, broker or facilitate sales to any individual, entity or country subject to UN Security Council arms embargoes or applicable national sanctions lists. All buyers are subject to end user verification prior to any transaction. Technical documentation and specifications are provided only to verified government and institutional buyers under appropriate non-disclosure and end use agreements. Defence.US does not act as a principal seller for Government-to-Government (G2G) items. For items requiring G2G procurement procedures, Defence.US provides facilitation and advisory services to connect qualified government buyers with appropriate manufacturer representatives. For compliance enquiries: [email protected]

2. GOVERNING REGULATIONS

Defence.US adheres to the following export control frameworks:

Regulation Scope
ITAR (22 CFR Parts 120-130) International Traffic in Arms Regulations — US Munitions List (USML) defense articles, technical
data, and defence services
EAR (15 CFR Parts 730-774) Export Administration Regulations — dual-use items, commercial satellites, and less-sensitive
military commodities
UN Security Council Arms Embargoes Comprehensive alignment with all UNSC arms embargoes and targeted sanctions
Wassenaar Arrangement Export controls for conventional arms and dual-use goods & technologies
UK Export Control Order 2008 United Kingdom strategic export controls
EU Dual-Use Regulation (2021/821) European Union dual-use export controls
National Export Licensing Regimes All relevant national laws in jurisdictions where we operate

3. END USER CERTIFICATE (EUC) REQUIREMENT

3.1 Mandatory Requirement

An End User Certificate (EUC) is required for all defense article transactions facilitated through Defence.US. No exceptions.

3.2 EUC Must Include

  • Full identification of the end-user (individual or entity)
  • Description of the defense articles to be procured
  • Statement of intended end-use
  • Certification that no re-export or transfer will occur without authorisation
  • Government-issued letterhead or official stamp
  • Authorised signature with title and date

3.3 Verification

Defence.US reserves the right to:

  • Verify the authenticity of any EUC submitted
  • Request additional supporting documentation
  • Refuse any transaction where EUC is incomplete or suspect
  • Report fraudulent EUCs to relevant authorities

4. SANCTIONS AND PROHIBITED PARTIES

4.1 Prohibited Transactions

Defence.US does not engage with, facilitate sales to, or accept enquiries from:

  • Any individual, entity, or country subject to UN Security Council arms embargoes
  • Parties listed on the US Department of Commerce Entity List
  • Parties listed on the US Department of Commerce Unverified List
  • Parties listed on the US Department of Commerce Denied Persons List
  • Parties listed on the US Department of State Debarred Parties List
  • Parties subject to OFAC sanctions (Specially Designated Nationals – SDN List)
  • Parties listed on UK HM Treasury sanctions lists
  • Parties listed on EU consolidated sanctions lists
  • Any jurisdiction prohibited by applicable export control laws

4.2 Current Embargoed / Restricted Destinations (Indicative)

Based on UN, UK, US, and EU sanctions regimes, Defence.US does not facilitate transactions involving:
[Note: This list changes based on current sanctions. Buyers should consult official sources for complete and current
restrictions.]

Region Restricted Destinations
Europe Belarus, Russia (comprehensive sanctions), Ukraine (Crimea, Donbas regions)
Middle East Iran, Syria, Yemen (Houthi-controlled areas)
Africa Democratic Republic of Congo (armed groups), Libya, Somalia, Sudan, South Sudan
Asia North Korea, Myanmar (certain sanctions)
Other Any territory subject to UNSC arms embargo

4.3 Buyer Obligations

By engaging with Defence.US, you certify that neither you nor your organisation is subject to any applicable sanctions
or debarments. You agree to promptly notify us of any change in your sanctions status.

5. END USER VERIFICATION PROCESS

5.1 Standard Verification

All buyers are subject to end user verification prior to any transaction. The verification process includes:

  1. Identity verification — Confirmation of individual identity and organisational affiliation
  2. Authority verification — Confirmation of procurement authority
  3. Sanctions screening — Check against all applicable sanctions lists
  4. End-use verification — Assessment of legitimate end-use
  5. Documentation review — Validation of EUC and supporting documents

5.2 Enhanced Due Diligence

Certain transactions may require enhanced due diligence, including:

  • Independent third-party verification
  • Government-to-government confirmation
  • Physical inspection or audit
  • Additional compliance certifications

5.3 Verification Timeline

Standard verification is typically completed within 5-10 business days. Enhanced due diligence may take longer.

6. G2G (GOVERNMENT-TO-GOVERNMENT) POLICY

6.1 Facilitation Only

Defence.US does not act as a principal seller for Government-to-Government (G2G) items.

6.2 Covered Items

Items requiring G2G procurement procedures include, but are not limited to:

  • Main Battle Tanks (MBTs)
  • Frigates and Destroyers
  • Submarines (SSK and SSN)
  • Certain Air Defence Systems
  • Strategic missile systems
  • Other sovereign-controlled defence platforms

6.3 Our Role

For G2G items, Defence.US provides:

  • Advisory services — Guidance on procurement pathways and export eligibility
  • Channel facilitation — Connecting qualified government buyers with appropriate manufacturer
    representatives or government export agencies
  • Documentation support — Assistance with EUC and compliance documentation

6.4 What We Do NOT Do

For G2G items, Defence.US does not:

  • Act as a seller or principal party
  • Take title to or possession of defence articles
  • Execute G2G agreements or memoranda of understanding
  • Represent any government in G2G negotiations

7. TECHNICAL DATA AND DOCUMENTATION

7.1 Restricted Access

Technical documentation and specifications are provided only to:

  • Verified government buyers
  • Verified institutional buyers
  • Parties under appropriate non-disclosure agreements (NDAs)
  • Parties with executed end use agreements

7.2 Export Control Classification

Technical data provided by Defence.US may be subject to export control classification under:

  • ITAR (USML categories)
  • EAR (ECCN classification)
  • National export control regimes

7.3 User Obligations

Recipients of technical data agree to:

  • Not re-export or transfer technical data without authorisation
  • Protect technical data from unauthorised access
  • Comply with all applicable export control laws
  • Return or destroy technical data upon request

8. PROHIBITED ACTIVITIES

The following activities are strictly prohibited:

Prohibited Activity Description
Unauthorised re-export Transferring defense articles or technical data without required authorisations
Sanctions violations Engaging with sanctioned parties or embargoed destinations
False EUC submission Submitting fraudulent or misleading End User Certificates
Diversion Diverting defense articles to unauthorised end-users or end-uses
Transshipment violations Using intermediary countries to circumvent export controls
Brokering to prohibited parties Facilitating transactions involving prohibited parties

9. COMPLIANCE ENQUIRIES

9.1 Contact Information

General Compliance Enquiries: [email protected]
End User Certificate (EUC) Submission: [email protected]
Sanctions Screening Questions: [email protected]
Legal / Regulatory Enquiries: [email protected]

9.2 Response Times

  • General compliance enquiries: 2-3 business days
  • EUC review: 5-10 business days
  • Urgent compliance matters: 24 hours (mark subject line “URGENT”)

9.3 Confidentiality

All compliance correspondence is treated with the highest confidentiality. We do not disclose compliance enquiries to
third parties except as required by law.

10. REPORTING VIOLATIONS

If you become aware of any violation of export control laws, sanctions, or this Compliance Statement, you are required
to immediately report such violation to:
Email: [email protected]
Subject Line: COMPLIANCE VIOLATION REPORT — CONFIDENTIAL
Defence.US will investigate all reports promptly and take appropriate action, including notification to relevant
authorities where required by law.

11. RECORDKEEPING

11.1 Retention Period

Defence.US maintains records of all export compliance-related transactions, including:

  • End User Certificates (EUC)
  • Sanctions screening records
  • Compliance correspondence
  • Transaction documentation

Retention Period: Minimum ten (10) years from the date of transaction or as otherwise
required by applicable law.

11.2 Audit Rights

Defence.US reserves the right to audit compliance records of buyers and partners as necessary to ensure adherence to
export control laws.

12. AMENDMENTS

Defence.US reserves the right to amend this Compliance Statement at any time. Material changes will be communicated
through:

  • Posting on the Defence.US website
  • Direct notification to active buyers and partners (where contact information is available)

Continued engagement with Defence.US following any amendment constitutes acceptance of the revised Compliance Statement.

APPENDIX A: KEY DEFINITIONS

Term Definition
Defense Article Any item, technical data, or service designated on the US Munitions List (USML) or equivalent
national control lists
End User Certificate (EUC) Official document certifying the identity, location, and intended end-use of a defense article
purchaser
EAR Export Administration Regulations — US regulations governing dual-use items
ECCN Export Control Classification Number — alpha-numeric code identifying export control status under
EAR
G2G Government-to-Government — procurement channel between sovereign governments
ITAR International Traffic in Arms Regulations — US regulations governing defense articles
OFAC Office of Foreign Assets Control — US sanctions enforcement agency
SDN List Specially Designated Nationals List — OFAC sanctions list
UNSC United Nations Security Council

APPENDIX B: RELEVANT LEGISLATION

Legislation Jurisdiction
Arms Export Control Act (AECA) United States
International Traffic in Arms Regulations (ITAR) United States
Export Administration Regulations (EAR) United States
Export Control Act 2002 United Kingdom
Export Control Order 2008 United Kingdom
EU Dual-Use Regulation (2021/821) European Union
UN Security Council Resolutions (various) International

DEFENCE.US — LAWFUL DEFENSE TRADE. FULL EXPORT COMPLIANCE.