ST0975DOJDOJ

ST0975

In answering these questions, the prosecutor should consider the comprehensiveness of the compliance program; the extent and pervasiveness of the criminal misconduct; the number and level of the corporate employees involved; the seriousness, duration, and frequency of the misconduct; and any…

Source text

As written.

In answering these questions, the prosecutor should consider the comprehensiveness of the compliance program; the extent and pervasiveness of the criminal misconduct; the number and level of the corporate employees involved; the seriousness, duration, and frequency of the misconduct; and any remedial actions taken by the corporation, including, for example, disciplinary action against past violators uncovered by the prior compliance program, and revisions to corporate compliance programs in light of lessons learned

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.

  • M12

    2 — HANDLING VIOLATIONS

    Remediation procedures address the treatment of unlawfully exported/imported items and/or technical information upon discovery of a…

  • M12

    1 — HANDLING VIOLATIONS

    Program has procedures to timely remediate potential violations.

  • M12

    1 — HANDLING VIOLATIONS

    Program has procedures for tracking and ensuring timely completion of corrective actions for violations.

  • M12

    2 — HANDLING VIOLATIONS

    Program has procedures for the fair and consistent application of disciplinary actions for employee violations.

  • M12

    3 — HANDLING VIOLATIONS

    Senior Management takes reasonable steps to exclude employees responsible for intentional violations of export/import laws from management…

Source & revisions

First mapped
Jun 8, 2022
Last updated
Oct 28, 2026 (6d ago)
Source
U.S. Attorneys' Manual