ST0933DOTOFAC

ST0933

II.B.3. Management Involvement. In the case of an entity, was the conduct undertaken with the explicit or implicit knowledge of senior management, or was the conduct undertaken by personnel outside the knowledge of senior management? If the apparent violation was undertaken without the knowledge of…

Source text

As written.

II.B.3. Management Involvement. In the case of an entity, was the conduct undertaken with the explicit or implicit knowledge of senior management, or was the conduct undertaken by personnel outside the knowledge of senior management? If the apparent violation was undertaken without the knowledge of senior management, was there oversight intended to detect and prevent violations, or did the lack of knowledge by senior management result from disregard for its responsibility to comply with applicable sanctions laws?

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.

  • M1

    4 — MANAGEMENT COMMITMENT

    Senior Management maintains sufficient oversight over development and implementation of the program.

  • M1

    5 — MANAGEMENT COMMITMENT

    Senior Management maintains sufficient oversight over maintenance of the program.

  • M1

    6 — MANAGEMENT COMMITMENT

    Senior Management maintains sufficient oversight over employee adherence to the program.

  • M1

    7 — MANAGEMENT COMMITMENT

    Senior Management reviews audit reports and recommendations and regularly evaluates effectiveness of the program.

  • M1

    8 — MANAGEMENT COMMITMENT

    A specific member of Senior Management is assigned with overall responsibility for the program.

Source & revisions

First mapped
Jun 8, 2022
Last updated
Oct 28, 2026 (6d ago)
Source
Economic Sanctions Enforcement Guidelines