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…
Plain-language summary
What it actually means.
Plain-language summary forthcoming. Source text below.
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?
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.
Related
Other DOT standards.
Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- May 26, 2026 (29m ago)
- Source
- Economic Sanctions Enforcement Guidelines