ST1149DOJDOJ

ST1149

Prosecutors should consider whether the program is appropriately “designed to detect the particular types of misconduct most likely to occur in a particular corporation’s line of business” and “complex regulatory environment[].” JM 9-28.800.3 For example, prosecutors should consider whether the…

Assess my company

Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

Source text

As written.

Prosecutors should consider whether the program is appropriately “designed to detect the particular types of misconduct most likely to occur in a particular corporation’s line of business” and “complex regulatory environment[].” JM 9-28.800.3 For example, prosecutors should consider whether the company has analyzed and addressed the varying risks presented by, among other factors, the location of its operations, the industry sector, the competitiveness of the market, the regulatory landscape, potential clients and business partners, transactions with foreign governments, payments to foreign officials, use of third parties, gifts, travel, and entertainment expenses, and charitable and political donations.

Assessed by HEXDI

What HEXDI assesses.

  • M2

    1 — PROGRAM SETUP AND ADMINISTRATION

    Program is developed using a reasoned methodology that is based on a thorough analysis and identification of risks pertaining to company…

  • M2

    2 — PROGRAM SETUP AND ADMINISTRATION

    Methodology includes monitoring, collecting, and reporting of information on the number of exports/imports, nature and number of…

  • M2

    3 — PROGRAM SETUP AND ADMINISTRATION

    Senior Management, with the assistance of legal counsel and/or compliance personnel, takes responsibility for determining the significance…

  • M2

    4 — PROGRAM SETUP AND ADMINISTRATION

    Risk analysis and identification occurs at Senior Management meetings as part of short- and long-term forecasting and strategic planning.

  • 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,…

Related

Other DOJ standards.

Source & revisions

First mapped
Jun 8, 2022
Last updated
May 26, 2026 (15m ago)
Source
DoJ Evaluation of Corporate Compliance Programs