ST0932DOSDDTC

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.

to be determined

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)