ST0870DOSDDTC

ST0870

(11) Respondent will continue to promote and publicize internally the availability of Respondent's program for reporting violations of the AECA and the ITAR to ensure that violations may be readily reported via this channel, without fear of recrimination or retaliation. Complaints or concerns about…

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Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

Source text

As written.

(11) Respondent will continue to promote and publicize internally the availability of Respondent's program for reporting violations of the AECA and the ITAR to ensure that violations may be readily reported via this channel, without fear of recrimination or retaliation. Complaints or concerns about matters involving compliance with the AECA and the ITAR shall be reported to the Senior Vice President and General Counsel and the ISCO. The Senior Vice President and General Counsel shall be responsible for resolving such matters. If the Senior Vice President and General Counsel is the subject of the complaint or concern involving the AECA and the ITAR, the matter will be referred to Respondent's President for resolution. The Senior Vice President and General Counsel shall submit to the Board of Directors, or the appropriate committee thereof, a semiannual report assessing the effectiveness of the Ombudsman Program relating to export, re-export or retransfer matters, and will provide a copy to the Director, DTCC.

Assessed by HEXDI

What HEXDI assesses.

  • M11

    4 — AUDITS AND ASSESSMENTS

    Program has procedures for promptly communicating audit results to Board of Directors (or equivalent).

  • M12

    4 — HANDLING VIOLATIONS

    Program identifies the office and/or employee(s) available to answer questions on the legitimacy of a transaction, report possible…

  • 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.

Related

Other DOS standards.

Source & revisions

First mapped
Jun 8, 2022
Last updated
May 26, 2026 (24m ago)
Source
DDTC Consent Agreement(s)