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…
Plain-language summary
What it actually means.
Plain-language summary forthcoming. Source text below.
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.
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
- May 26, 2026 (26m ago)
- Source
- DDTC Consent Agreement(s)