ST1150
Prosecutors should also consider “[t]he effectiveness of the company’s risk assessment and the manner in which the company’s compliance program has been tailored based on that risk assessment” and whether its criteria are “periodically updated.” See, e.g., JM 9-47-120(2)(c); U.S.S.G. § 8B2.1(c)…
Plain-language summary
What it actually means.
Plain-language summary forthcoming. Source text below.
Source text
As written.
Prosecutors should also consider “[t]he effectiveness of the company’s risk assessment and the manner in which the company’s compliance program has been tailored based on that risk assessment” and whether its criteria are “periodically updated.” See, e.g., JM 9-47-120(2)(c); U.S.S.G. § 8B2.1(c) (“the organization shall periodically assess the risk of criminal conduct and shall take appropriate steps to design, implement, or modify each requirement [of the compliance program] to reduce the risk of criminal conduct”).
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.
- DOJ41 citations
ST1166
DoJ Evaluation of Corporate Compliance Programs
- DOJ25 citations
ST1160
DoJ Evaluation of Corporate Compliance Programs
- DOJ24 citations
ST1154
DoJ Evaluation of Corporate Compliance Programs
- DOJ22 citations
ST0028
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ST0535
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Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- May 26, 2026 (15m ago)
- Source
- DoJ Evaluation of Corporate Compliance Programs