1. Purpose
This policy sets out Murzo Group's approach to anti-diversion, end-use checks, re-export control, sanctions, controlled goods, dual-use technology, military end-use, and suspicious trade red flags.
The purpose is to reduce the risk that goods, software, technology, services, data, funding, or support are diverted to prohibited end users, restricted destinations, unauthorised military uses, sanctioned parties, or unlawful re-export routes.
2. Scope
This policy applies to exports, imports, re-exports, transfers, brokering, technical assistance, software, design files, product data, prototypes, samples, security equipment, surveillance items, controlled materials, cultural goods, and any goods that could have military, security, dual-use, or restricted end-use concerns.
3. Anti-Diversion Position
Murzo Group will not knowingly supply goods, services, technology, funds, or support where there is a credible risk of unlawful diversion, sanctions breach, prohibited end use, unauthorised military use, terrorism, weapons of mass destruction, human rights abuse, illicit cultural trade, or organised criminal misuse.
Where end-use or end-user information is unclear, inconsistent, or suspicious, Murzo Group may pause, refuse, cancel, or seek advice before proceeding.
4. Red Flags
- Customer refuses to identify end user, destination, ownership, or intended use
- Goods are inconsistent with the customer's business, country, or stated purpose
- Unusual routing, freight forwarding, transhipment, or re-export request
- Requests to remove labels, serial numbers, origin markings, safety warnings, or documentation
- Payment from unrelated third parties, high-risk jurisdictions, cash-heavy channels, or unclear funds
- Urgent pressure to ship before licences, checks, or authority requirements are complete
- Military, security, surveillance, nuclear, chemical, biological, drone, weapons, or controlled technology indicators
5. End-Use Controls
Murzo Group will check whether export, trade control, sanctions, military end-use, dual-use, WMD, firearms, cultural property, CITES, or other restrictions may apply before supply.
End-use statements, undertakings, licences, contractual restrictions, or customer confirmations may be required where risk justifies them. They must be meaningful and not treated as a box-ticking exercise.
6. Re-Export and Third-Country Movement
Where goods, software, technology, or data may be re-exported, transferred, resold, integrated into another product, or moved through a third country, Murzo Group will consider destination controls and customer restrictions before supply.
Distributors, agents, and brokers must not re-route goods to restricted destinations or end users contrary to law, contract, or Murzo Group instruction.
7. Escalation
Suspicious transactions must be escalated before shipment, transfer, payment acceptance, technical support, or release of controlled information. If a shipment has already occurred, Murzo Group will consider authority disclosure, customer hold, recall, contract remedies, and legal advice.
8. Required Evidence Only
Sanctions, end-use, licence, customer, shipment, and decision evidence should be limited to what is required by law, authority request, contract, insurer, or legitimate compliance need.
9. Review
This policy will be reviewed when Murzo Group enters a higher-risk market, handles controlled goods or technology, appoints overseas distributors, or receives new sanctions or export control information.
