ST0887
(10)(m)(1) [Policy and Procedure: The SCO or ISCO shall monitor Respondent's AECA and ITAR compliance programs, with specific attention to the following areas:] xii. Policies and procedures for encouraging Respondent's employees to report AECA any ITAR compliance problems without fear of reprisal.…
Plain-language summary
What it actually means.
Plain-language summary forthcoming. Source text below.
Source text
As written.
(10)(m)(1) [Policy and Procedure: The SCO or ISCO shall monitor Respondent's AECA and ITAR compliance programs, with specific attention to the following areas:] xii. Policies and procedures for encouraging Respondent's employees to report AECA any ITAR compliance problems without fear of reprisal. These policies and procedures should promote Respondent' s reporting mechanisms safe from reprisals and as a means to document the issue to be looked at, 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 (25m ago)
- Source
- DDTC Consent Agreement(s)