ST0721
(16)(a) [The SCO or ISCO shall monitor Respondent's AECA and ITAR compliance program, including but not limited to the remedial measures already established by the Respondent with specific attention to the following areas some of which associated with the offenses alleged in the Proposed-Charging…
Source text
As written.
(16)(a) [The SCO or ISCO shall monitor Respondent's AECA and ITAR compliance program, including but not limited to the remedial measures already established by the Respondent with specific attention to the following areas some of which associated with the offenses alleged in the Proposed-Charging Letter:] 8. Policies and procedures for preventing, detecting, and reporting AECA and ITAR violations;
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
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
- Oct 28, 2026 (5d ago)
- Source
- DDTC Consent Agreement(s)