ST0651
Senior management demonstrates recognition of the seriousness of apparent violations of the laws and regulations administered by OFAC, or malfunctions, deficiencies, or failures by the organization and its personnel to comply with the SCP’s policies and procedures, and implements necessary measures…
Plain-language summary
What it actually means.
Plain-language summary forthcoming. Source text below.
Source text
As written.
Senior management demonstrates recognition of the seriousness of apparent violations of the laws and regulations administered by OFAC, or malfunctions, deficiencies, or failures by the organization and its personnel to comply with the SCP’s policies and procedures, and implements necessary measures to reduce the occurrence of apparent violations in the future. Such measures should address the root causes of past apparent violations and represent systemic solutions whenever possible.
Assessed by HEXDI
What HEXDI assesses.
- M1
1 — MANAGEMENT COMMITMENT
Program includes a Policy Statement signed by a senior executive officer or equivalent that clearly communicates the organization’s…
- M1
2 — MANAGEMENT COMMITMENT
Policy Statement explains why the commitment is important for the company and to U.S. national security and foreign policy interests.
- M1
3 — MANAGEMENT COMMITMENT
Policies identify the penalties for violations of export/import laws and the program.
- M1
1 — MANAGEMENT COMMITMENT
Policies clearly communicate the organization’s commitment to compliance with export/import laws and ethical conduct in international trade.
- M1
6 — MANAGEMENT COMMITMENT
Senior Management maintains sufficient oversight over employee adherence to the program.
- M11
2 — AUDITS AND ASSESSMENTS
Audit guide requires verification that prior audit corrective actions/recommendations were completed.
Related
Other DOT standards.
Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- May 26, 2026 (29m ago)
- Source
- Framework for OFAC Compliance Commitments