Trade compliance and sanctions

Nooryva moves goods across borders, which means the rules that govern who may buy what, from where, and to where, are part of our daily work rather than a formality. This page sets out how we handle them, so that a counterparty assessing us can see our position before asking.

The basic commitment

We comply with the export controls, import restrictions, sanctions and embargoes that apply to us, including those of Pakistan and those of the countries our goods move through. Where regimes conflict, we take the stricter reading. We will decline business that we cannot clear, whatever the margin on it.

Who we check, and when

Before we act for a new counterparty, and again when something material changes, we check:

• the identity and ownership of the party we are dealing with, including who ultimately controls it;
• whether that party, its owners or its officers appear on applicable restricted-party or sanctions lists;
• the destination country, and any measures in force against it;
• the goods themselves, and whether they are controlled, restricted or require a licence;
• whether the stated end use and end user are plausible for the goods in question.

We keep records of these checks for as long as the law requires.

Dual-use and controlled goods

Some ordinary-looking goods are controlled because of what they could also be used for. Where a commodity may be dual-use, we will ask you for the end use and the end user, and we will ask for an end-user statement. We will not move controlled goods without the licence they require, and we will not help structure a shipment so that a licence appears not to be needed.

Warning signs we act on

We will pause a shipment and ask questions where, for example:

• the stated end use does not fit the goods, the quantity or the buyer’s business;
• a buyer is unusually incurious about price, lead time or specification;
• routing or payment is arranged through a country with no evident connection to the trade;
• a party asks us to describe goods, values or origin inaccurately on any document;
• delivery is to a freight forwarder or address unconnected with the stated consignee, with no explanation.

Asking is not an accusation. Most such questions have an ordinary answer, and we would rather ask it than find out later.

What we will not do

• We will not misdeclare goods, values, weights or origin on any customs document, at any customer’s request, for any reason.
• We will not split or restructure a consignment to evade a threshold, a licence, a quota or a duty.
• We will not supply a party we are prohibited from supplying, nor route goods through a third country to reach one.
• We will not carry goods whose trade is prohibited, including counterfeits, protected wildlife and their products, hazardous waste in breach of the relevant conventions, and narcotics.
• We will not falsify a certificate of origin, a phytosanitary certificate, or any other document a border relies on.

A request to do any of these ends the relationship, not just the shipment.

Accuracy is a shared duty

Customs declarations rest on what you tell us. If you give us a description, a value, an origin or a commodity code, we rely on it, and you remain responsible for it being true. If you are unsure, tell us you are unsure and we will work it out together, or send you to the authority that can rule on it. The disclaimer explains why a code that was right once may not be right again.

If we get it wrong

If we discover that a shipment breached a control, we will stop, tell the relevant authority where we are required to, cooperate with them, and tell the affected counterparty. We would rather disclose an error than hope it is not noticed.

Raising a concern

If you believe a shipment of ours breaches a control or a sanction, write to . Reports are taken seriously and investigated. Nobody who raises a concern in good faith, inside or outside this company, will suffer for it: our anti-bribery and ethical conduct policy sets out that protection.

Which language applies

This policy is published in every language this site is published in. If the versions disagree, the English version applies.