ST0236DOJDOJ

ST0236

Gatekeepers – What, if any, guidance and training has been provided to key gatekeepers in the control processes (e.g., those with approval authority or certification responsibilities)? Do they know what misconduct to look for? Do they know when and how to escalate concerns?

Assess my company

Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

Source text

As written.

Gatekeepers – What, if any, guidance and training has been provided to key gatekeepers in the control processes (e.g., those with approval  authority or certification responsibilities)? Do they know what misconduct to look for? Do they know when and how to escalate concerns?

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.

  • M3

    1 — TRAINING

    Program requires annual top-level export/import training for Board of Directors (or equivalent).

  • M3

    2 — TRAINING

    Program requires annual top-level export/import training for Senior Management.

  • M3

    3 — TRAINING

    Program requires introductory export/import compliance training for employees upon initial hire and refresher training for all employees on…

  • M3

    4 — TRAINING

    Program requires intermediate and advanced export/import control training for employees with key program responsibilities to ensure…

  • M3

    5 — TRAINING

    Program requires cross-training of backups to assume tasks of employees with key program responsibilities when the employees are on leave,…

Related

Other DOJ standards.

Source & revisions

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