ST0894
(11) Respondent will continue to promote and publicize the availability of Respondent's program for internal reporting of possible violations of the AECA and the ITAR without fear of recrimination or retaliation. Complaints or concerns about matters involving compliance with the AECA and the ITAR…
Plain-language summary
What it actually means.
Plain-language summary forthcoming. Source text below.
Source text
As written.
(11) Respondent will continue to promote and publicize the availability of Respondent's program for internal reporting of possible violations of the AECA and the ITAR without fear of recrimination or retaliation. Complaints or concerns about matters involving compliance with the AECA and the ITAR will be reported to the General Counsel and the SCO or ISCO. The General Counsel, either directly or through a qualified person working under the General Counsel's oversight, will be responsible for resolving such matters. If the General Counsel is the subject of the complaint or concern involving the AECA and the ITAR, the matter will be referred to the Chief Executive Officer for resolution in accordance with Respondent's Board of Directors' policy. The General Counsel shall submit to the Board of Directors a semiannual report assessing the effectiveness of the existing internal reporting program relating to AECA and ITAR matters, and will provide a copy to the Director, DTCC.
Assessed by HEXDI
What HEXDI assesses.
- M11
4 — AUDITS AND ASSESSMENTS
Program has procedures for promptly communicating audit results to Board of Directors (or equivalent).
- M12
1 — HANDLING VIOLATIONS
Program includes a Suspicious Activity Reporting (SAR) system for collecting, analyzing, and using information on suspected violations.
- M12
5 — HANDLING VIOLATIONS
Program includes an Ombudsman Program as a reporting mechanism safe from reprisals, and as a means for reporting employees to track…
- M12
2 — HANDLING VIOLATIONS
SAR system has a 24-hour mechanism for employees to report suspected violations.
- M12
3 — HANDLING VIOLATIONS
SAR system has an anonymous mechanism for employees to report suspected violations.
- M12
4 — HANDLING VIOLATIONS
SAR system immediately notifies management of employee reports of suspected violations.
Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- Aug 11, 2026 (3d ago)
- Source
- DDTC Consent Agreement(s)