ST1159DOJDOJ

ST1159

Prosecutors should also determine “whether the corporation’s employees are adequately informed about the compliance program and are convinced of the corporation’s commitment to it.” JM 9-28.800; see also JM 9-47.120(2)(c) (criteria for an effective compliance program include “[t]he company’s…

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Plain-language summary

What it actually means.

Plain-language summary forthcoming. Source text below.

Source text

As written.

Prosecutors should also determine “whether the corporation’s employees are adequately informed about the compliance program and are convinced of the corporation’s commitment to it.” JM 9-28.800; see also JM 9-47.120(2)(c) (criteria for an effective compliance program include “[t]he company’s culture of compliance, including awareness among employees that any criminal conduct, including the conduct underlying the investigation, will not be tolerated”).

Assessed by HEXDI

What HEXDI assesses.

M1
1 — MANAGEMENT COMMITMENT
Program includes a Policy Statement signed by a senior executive officer or equivalent that clearly communicates the organization’s…
M1
3 — MANAGEMENT COMMITMENT
Policy Statement emphasizes the importance of knowledge and understanding of when and how export controls affect company products and…
M1
4 — MANAGEMENT COMMITMENT
Policy Statement is integrated into the company code of conduct.
M1
5 — MANAGEMENT COMMITMENT
Policy Statement is communicated to employees on an ongoing basis by a variety of means, to include but not limited to: company…
M1
6 — MANAGEMENT COMMITMENT
Policy Statement is reissued periodically to reaffirm the company’s commitment to compliance and to reflect any changes to the senior…
M1
1 — MANAGEMENT COMMITMENT
Policies explain the general nature and scope of export/import laws applicable to military, dual-use, and commercial items, and how export…

Other DOJ standards.

Source & revisions

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