ST0932
[Strengthened Compliance Policies, Procedures, Training] Within twelve (12) months of the date of the Order, Respondent shall have instituted strengthened corporate compliance procedures focused principally on Respondent's business operations such that: (a) all Respondent employees engaged in…
Source text
As written.
[Strengthened Compliance Policies, Procedures, Training] Within twelve (12) months of the date of the Order, Respondent shall have instituted strengthened corporate compliance procedures focused principally on Respondent's business operations such that: (a) all Respondent employees engaged in ITAR-regulated activities are familiar with the AECA and the ITAR, and their own and Respondent's responsibilities thereunder; (b) all persons responsible for supervising those employees, including senior managers of those units, are knowledgeable about the underlying policies and principles of the AECA and the ITAR; and (c) there are records indicating the names of employees, trainers, and level and area of training received.
Change history
When and why it changed.
Present in the original catalog
This standard has not changed since it was added.
Assessed by HEXDI
What HEXDI assesses.
- M2
1 — PROGRAM SETUP AND ADMINISTRATION
Program has procedures to ensure that persons with appropriate competencies are recruited and trained to perform key responsibilities under…
- M2
1 — PROGRAM SETUP AND ADMINISTRATION
Employees with key responsibilities under the program understand the interconnection of their roles with other program processes and where…
- M3
1 — TRAINING
Program requires annual top-level export/import training for Board of Directors (or equivalent).
- M3
2 — TRAINING
Program requires annual top-level export/import training for Senior Management.
- M3
3 — TRAINING
Program requires introductory export/import compliance training for employees upon initial hire and refresher training for all employees on…
- M3
4 — TRAINING
Program requires intermediate and advanced export/import control training for employees with key program responsibilities to ensure…
Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- Oct 28, 2026 (6d ago)
- Source
- DDTC Consent Agreement(s)