ST0237DOJDOJ

ST0237

Risk-Based Training – What training have employees in relevant control functions received? Has the company provided tailored training for high-risk and control employees, including training that addresses risks in the area where the misconduct occurred? Have supervisory employees received different…

Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

Source text

As written.

Risk-Based Training – What training have employees in relevant control functions received? Has the company provided tailored training for high-risk and control employees, including training that addresses risks in the area where the misconduct occurred? Have supervisory employees received different or supplementary training? What analysis has the company undertaken to determine who should be trained and on what subjects?

Assessed by HEXDI

What HEXDI assesses.

  • 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,…

  • M3

    3 — TRAINING

    Training schedule includes, but is not limited to, the following topics: purpose, scope, and restrictions of export/import controls; high…

Source & revisions

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