LUDUSHA (hereinafter referred to as "we," "our," or "LUDUSHA") strictly adheres to international export control laws and regulations, and is committed to conducting international defence trade in a legal and compliant manner. This statement outlines our export control policy framework and compliance requirements.
1. Applicable Laws and Regulations
All of our export activities strictly comply with the following international and domestic legal frameworks:
- ITAR — U.S. International Traffic in Arms Regulations compliance management
- MTCR — Missile Technology Control Regime participating state
- Wassenaar Arrangement — Participating state
- UN Register of Conventional Arms
- China's Regulations on the Administration of Arms Exports and relevant laws and regulations
📋 Compliance Commitment: All exports require the appropriate export licenses. Transactions without licenses or without compliance review are strictly prohibited.
2. End-User Certificate (EUC) Requirements
All purchasers must provide:
- End-User Certificate (EUC) — Certified official document
- Final Use Statement — Document clearly stating the end-use
- Import License — Import authorization from the purchaser's country (if applicable)
The above documents must be signed and stamped by official authorities of the purchaser's country (such as the Ministry of Defence, Ministry of Interior, or similar government agencies).
3. Prohibited Actions and Restrictions
We strictly prohibit the following actions:
- Exporting any defence materials to countries or entities subject to international arms embargoes
- Selling defence products to any non-sovereign states, non-governmental organizations, individuals, or unauthorized commercial entities
- Any form of unauthorized re-export or resale
- Delivering equipment without first obtaining the End-User Certificate
- Intentional or grossly negligent violations of applicable export control regulations
4. Export Licensing Process
The standard export license application process is as follows:
- Step 1: Purchaser submits RFI (Request for Information) and eligibility documents
- Step 2: We complete preliminary compliance review and risk assessment
- Step 3: Sign Non-Disclosure Agreement (NDA) and initiate technical discussions
- Step 4: Purchaser submits formal EUC and Final Use Statement
- Step 5: We apply for the export license
- Step 6: Sign the procurement contract upon license approval
- Step 7: Execute the contract and complete export customs clearance
The entire process typically takes 3 to 12 months, depending on the purchasing country and product category.
5. Prohibited Use Declaration
We explicitly prohibit the use of supplied equipment for:
- Aggressive wars or military actions contrary to the UN Charter
- Attacks against civilians or civilian infrastructure
- International terrorist activities
- Cross-border criminal activities such as drug trafficking and human trafficking
- Any form of chemical, biological, or nuclear weapons proliferation
The purchaser must provide a written commitment not to use the equipment for any of the above purposes.
6. Re-Export Control
Any re-export or resale of defence equipment requires prior written consent from us and approval from the purchasing government.
- Without authorization, the purchaser may not transfer equipment to any third party
- The purchaser must commit to complying with re-export control provisions in the contract
- Any violation of re-export restrictions will result in legal liability
7. Compliance Oversight and Internal Audit
We have established a comprehensive export control compliance system, including:
- Designating a dedicated Export Control Compliance Officer
- Conducting regular compliance training and internal audits
- Maintaining an export license document archiving system
- Engaging external legal counsel to ensure compliance
8. Violation Reporting
Anyone who discovers actual or suspected violations of export control regulations may report them through:
- Email: compliance@ludusha.com
- All reporting information will be kept strictly confidential, and whistleblowers will be protected to the extent permitted by law
9. Policy Changes
We reserve the right to update this statement in accordance with changes in laws and regulations. The latest version as published on this website shall prevail.
10. Contact Us
For questions regarding export control, please contact:
- Export Control Compliance Officer: compliance@ludusha.com
- General Inquiries: contactus@ludusha.com
- PGP Public Key: Available upon request via email