Sanctions Undertaking
1. Definitions
Affiliate: means in relation to the Customer any entity controlled, directly or indirectly, by the
Customer, any entity that controls, directly or indirectly, the Customer or any entity directly or
indirectly under common control with the Customer. For this purpose, “control” of any entity or
person means ownership of a majority of the voting power of the entity or person.
“Embargoed and Sanctioned Countries or Territories” means Cuba, Iran, Crimea Region of Ukraine,
Donetsk People's Republic, Luhansk People's Republic, the non-government controlled areas of
Zaporizhzhia and Kherson region of Ukraine, North Korea, and Syria and “Embargoed and Sanctioned
Country” means each of them.
"Restricted Party" means a person that is:
(a) listed on any Sanctions List;
(b) at least 50% owned or otherwise controlled (as such term is used and applied in the relevant
Sanctions) by, or (to the knowledge of the Borrower) acting on behalf, or at the direction, of
any persons that are listed on any Sanctions List;
(c) located in or organized under the laws of a country or territory that is the subject of country-
or territory-wide Sanctions defined as such by a Sanctions Authority, or a person who is
owned or controlled by, or acting on behalf of such a person;
(d) otherwise a target of Sanctions ("target of Sanctions") signifying a person with whom a US
person or other national of a Sanctions Authority would be prohibited or restricted by law
from engaging in trade, business, or other activities).
“Sanctions" means any economic, trade or financial sanctions laws, regulations, embargoes, or
restrictive measures administered, enacted, or enforced by a Sanctions Authority.
"Sanctions Authorities" means the United States of America, the United Nations, the European Union,
the United Kingdom, the United Arab Emirates or the respective governmental institutions and
agencies of any of the foregoing, including, without limitation the Office of Foreign Asset Control of
the US Department of the Treasury ("OFAC"), the United States Department of State, the United States
Department of Commerce, and the UK Office of Financial Sanctions Implementation (“OFSI”), the
Executive Office for Control and Non-proliferation (“EOCN”) of UAE, and “Sanctions Authority” means
each of them.
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"Sanctions List" means the "Specially Designated Nationals and Blocked Persons" Sectoral Sanctions
Identifications and Foreign Sanctions Evaders lists maintained by OFAC, the Consolidated List of
Financial Sanctions Targets (Asset Freeze Targets and the Investments Ban Lists) maintained by UK
OFSI, the UAE Terrorist List, or any similar lists maintained by, or public announcement of Sanctions
designation made by, any of the Sanctions Authorities, each as amended, supplemented or substituted
from time to time.
2. Undertaking
On behalf of [MHD ZEIN MAHMOUD AJDAD] [including all of its Affiliates] [MHD ZEIN MAHMOUD
AJDAD], as a condition of receiving banking services from First Abu Dhabi Bank PJSC (“FAB”) and
maintaining accounts with FAB, [MHD ZEIN MAHMOUD AJDAD] hereby certifies and agrees to the
following:
a) Regardless of currency, [MHD ZEIN MAHMOUD AJDAD] shall not engage, or shall not permit
to engage in any of the following transactions through accounts, facilities, any service, or
product held with FAB, related to:
I. Transactions related to Embargoed and Sanctioned Countries including its
governments, or an entity owned or controlled by an Embargoed and Sanctioned
Country/territory.
II. Transactions involving or for the benefit of any Restricted Party.
III. Transactions with, on behalf of, or for the benefit of any person or entity domiciled
or operating out of or branch/ subsidiary / representative office of an entity or
located in Embargoed and Sanctioned Countries.
IV. Transactions involving (a) the purchase or sale of goods or services to or from
Embargoed and Sanctioned Countries, either directly or indirectly through a third
country.
V. Transactions with, on behalf of, or for the benefit of an individual or entity
targeted under a Sanctions List.
VI. Transactions involving the sale, supply, or transfer of the following items, or related
services directly or indirectly to Russia or Russia’s military-industrial base:
- Russia Critical Items
- Common high priority items
- Dual-use goods & technology (goods, software and technology that can be used
for both civilian and military applications)
- Military goods
b) FAB may permit a transaction under Clause (2)(a), but without the obligation on FAB’s part to
do so, provided that the Customer (i) has first notified FAB in writing about the transaction; (ii)
demonstrated that such transaction complies with all conditions related to the applicable
Sanctions (as determined by FAB at its sole discretion); (iii) FAB has agreed to process the
transaction in accordance with FAB's compliance policies and procedures.
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c) Upon FAB’s request, [MHD ZEIN MAHMOUD AJDAD] shall provide all relevant information with
respect to transactions or activities related to [MHD ZEIN MAHMOUD AJDAD]’s accounts,
facilities, services, or products held with FAB, including but not limited to invoices or trade
documents, as determined by FAB.
d) FAB reserves the right to reject or refuse any transaction related to Customer’s account(s) held
with FAB, and/or to terminate the relationship in the event the Customer fails to comply with
any of the obligations or restrictions set out in this Sanctions Undertaking.
On behalf of [MHD ZEIN MAHMOUD AJDAD]
________________
Authorized signatory:
Name: [MHD ZEIN MAHMOUD AJDAD]
Date: 26/09/2024
MHD AJDAD
26 Sep 2024 16:26:37 GMT 04:00
ID: 784-2002-8281280-7
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