ST0190DOJDOJ

ST0190

Evolving Updates – How often has the company updated its risk assessments and reviewed its compliance policies, procedures, and practices? Has the company undertaken a gap analysis to determine if particular areas of risk are not sufficiently addressed in its policies, controls, or training? What…

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Source text

As written.

Evolving Updates – How often has the company updated its risk assessments and reviewed its compliance policies, procedures, and practices? Has the company undertaken a gap analysis to determine if particular areas of risk are not sufficiently addressed in its policies, controls, or training? What steps has the company taken to determine whether policies/procedures/practices make sense for particular business segments/subsidiaries? Does the company review and adapt its compliance program based upon lessons learned from its own misconduct and/or that of other companies facing similar risks?

Change history

When and why it changed.

Present in the original catalog

This standard has not changed since it was added.

Assessed by HEXDI

What HEXDI assesses.

M2
4 — PROGRAM SETUP AND ADMINISTRATION
The Export/Import Compliance Council (or equivalent) creates working groups as needed to address specific areas, to include corrective…
M2
5 — PROGRAM SETUP AND ADMINISTRATION
Risk analysis and identification considers customer base, countries of exports/import activities, and product lines.
M2
6 — PROGRAM SETUP AND ADMINISTRATION
Risk analysis and identification considers risks posed by interactions with third parties, to include suppliers, brokers, contractors,…
M2
7 — PROGRAM SETUP AND ADMINISTRATION
Risk analysis and identification considers findings from audits, evaluations, and other assessments and history of compliance problems.
M2
8 — PROGRAM SETUP AND ADMINISTRATION
Risk analysis and identification considers risks posed by new legislation, regulations, agency opinions and rulings, and court decisions.  
M2
9 — PROGRAM SETUP AND ADMINISTRATION
Risk analysis and identification considers risks posed by business, political, or economic changes.

Other DOJ standards.

Source & revisions

First mapped: Jun 8, 2022
Last updated: Oct 28, 2026 (6d ago)
Source: Evaluation of Corporate Compliance Programs