ST0924
[Respondent shall enhance its AECA and ITAR compliance program with specific attention to the areas described in paragraphs 9(1)(1)(i) through 9(1)(1)(ix)] 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.
[Respondent shall enhance its AECA and ITAR compliance program with specific attention to the areas described in paragraphs 9(1)(1)(i) through 9(1)(1)(ix)] Policies and procedures for preventing, detecting and reporting AECA and ITAR violations;
Assessed by HEXDI
What HEXDI assesses.
- M12
1 — HANDLING VIOLATIONS
Program describes the system for reporting potential violations and instructs that all company employees and Senior Management will report…
- 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
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…
Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- May 26, 2026 (25m ago)
- Source
- DDTC Consent Agreement(s)