ST0181DOJDOJ

ST0181

prosecutors should examine “the comprehensiveness of the compliance program,” JM 9-28.800, ensuring that there is not only a clear message that misconduct is not tolerated, but also policies and procedures – from appropriate assignments of responsibility, to training programs, to systems of…

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Plain-language summary

What it actually means.

Plain-language summary forthcoming. Source text below.

Source text

As written.

prosecutors should examine “the comprehensiveness of the compliance program,” JM 9-28.800, ensuring that there is not only a clear message that misconduct is not tolerated, but also policies and procedures – from appropriate assignments of responsibility, to training programs, to systems of incentives and discipline – that ensure the compliance program is well-integrated into the company’s operations and workforce.

Assessed by HEXDI

What HEXDI assesses.

M1
2 — MANAGEMENT COMMITMENT
Policies instruct that no transactions will be made contrary to export/import or other U.S. laws.
M1
3 — MANAGEMENT COMMITMENT
Policies identify the penalties for violations of export/import laws and the program.
M1
1 — MANAGEMENT COMMITMENT
Policies clearly communicate the organization’s commitment to compliance with export/import laws and ethical conduct in international trade.
M1
2 — MANAGEMENT COMMITMENT
Policies clearly explain why the commitment is important for the company and to national security and foreign policy interests.

Other DOJ standards.

Source & revisions

First mapped: Jun 8, 2022
Last updated: May 26, 2026 (13m ago)
Source: Evaluation of Corporate Compliance Programs