ST0638
[Annex of Compliance Measures] (5)(a) [the ISCO must monitor ES's ITAR compliance program and policy with specific attention related to the following areas:] 2. Policies and procedures for preventing, detecting and reporting AECA and ITAR violations by ES business units.
Plain-language summary
What it actually means.
Plain-language summary forthcoming. Source text below.
Source text
As written.
[Annex of Compliance Measures] (5)(a) [the ISCO must monitor ES's ITAR compliance program and policy with specific attention related to the following areas:] 2. Policies and procedures for preventing, detecting and reporting AECA and ITAR violations by ES business units.
Assessed by HEXDI
What HEXDI assesses.
- M12
2 — HANDLING VIOLATIONS
Policies encourage employees to report suspected violations without fear of reprisal.
- M12
3 — HANDLING VIOLATIONS
Program requires initial hire and regular employee training on how to recognize possible violations and how to report suspected violations.
- M12
1 — HANDLING VIOLATIONS
Program includes a Suspicious Activity Reporting (SAR) system for collecting, analyzing, and using information on suspected violations.
- M12
2 — HANDLING VIOLATIONS
SAR system has a 24-hour mechanism for employees to report suspected violations.
- M12
3 — HANDLING VIOLATIONS
SAR system has an anonymous mechanism for employees to report suspected violations.
- M12
4 — HANDLING VIOLATIONS
SAR system immediately notifies management of employee reports of suspected violations.
Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- May 26, 2026 (18m ago)
- Source
- DDTC Consent Agreement(s)