ST0909DOSDDTC

ST0909

(10)(l)(1) [Policy and Procedures: The ISCO shall monitor Respondent 's AECA and ITAR compliance program with specific attention to the following areas and those associated with the offenses alleged in the Proposed Charging Letter:] (xiii) Policies and procedures for encouraging Respondent's…

Assess my company

Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

Source text

As written.

(10)(l)(1) [Policy and Procedures: The ISCO shall monitor Respondent 's AECA and ITAR compliance program with specific attention to the following areas and those associated with the offenses alleged in the Proposed Charging Letter:] (xiii) Policies and procedures for encouraging Respondent's employees to report AECA and ITAR compliance problems without fear of reprisal. These policies and procedures should promote the reporting program as a reporting mechanism 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.

Related

Other DOS standards.

Source & revisions

First mapped
Jun 8, 2022
Last updated
May 26, 2026 (25m ago)
Source
DDTC Consent Agreement(s)