ST0865
(10)(a)(1) [The ISCO shall monitor Respondent's AECA and ITAR compliance program with specific attention to the following areas associated with the offenses alleged in the Proposed- Charging Letter:] (v) Policies and procedures for preventing, detecting and reporting AECA and ITAR violations;
Plain-language summary
What it actually means.
Plain-language summary forthcoming. Source text below.
Source text
As written.
(10)(a)(1) [The ISCO shall monitor Respondent's AECA and ITAR compliance program with specific attention to the following areas associated with the offenses alleged in the Proposed- Charging Letter:] (v) Policies and procedures for preventing, detecting and reporting AECA and ITAR violations;
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 (24m ago)
- Source
- DDTC Consent Agreement(s)