ST0191DOJDOJ

ST0191

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…

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Plain-language summary

What it actually means.

Plain-language summary forthcoming. Source text below.

Source text

As written.

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?

Assessed by HEXDI

What HEXDI assesses.

M2
2 — PROGRAM SETUP AND ADMINISTRATION
Membership of the Export/Import Compliance Council (or equivalent) includes relevant management personnel, to include a team of managers…
M2
9 — PROGRAM SETUP AND ADMINISTRATION
Risk analysis and identification considers risks posed by business, political, or economic changes.  
M2
10 — PROGRAM SETUP AND ADMINISTRATION
Risk analysis and identification considers risks posed by internal factors such as changes to product lines, staffing, operating processes,…
M2
1 — PROGRAM SETUP AND ADMINISTRATION
Program is developed and maintained with input from all internal company stakeholders in the export/import process.
M2
2 — PROGRAM SETUP AND ADMINISTRATION
Program is reviewed and approved by the divisions or other relevant operational units with ownership of particular procedures.
M2
4 — PROGRAM SETUP AND ADMINISTRATION
Program provides a mechanism for employees to provide feedback on effectiveness of the program and to recommend improvements to increase…

Other DOJ standards.

Source & revisions

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