ST0722DOSDDTC

ST0722

(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…

Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

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:] 9. Policies and procedures that encourage Respondent's employees to report ITAR compliance problems without fear of reprisal. These policies and procedures should include multiple avenues by which problems can be reported safe from reprisals and a method of documenting the event under review, management's action, and the result of any action taken by management in resolving the issue;

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

    5 — HANDLING VIOLATIONS

    Program includes an Ombudsman Program as a reporting mechanism safe from reprisals, and as a means for reporting employees to track…

  • 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.

Source & revisions

First mapped
Jun 8, 2022
Last updated
May 26, 2026 (20m ago)
Source
DDTC Consent Agreement(s)