ST0934DOTOFAC

ST0934

II.E. Compliance Program: the existence, nature and adequacy of a Subject Person's risk-based OFAC compliance program at the time of the apparent violation, where relevant. In the case of an institution subject to regulation where OFAC has entered into a Memorandum of Understanding (MOU) with the…

Assess my company

Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

Source text

As written.

II.E. Compliance Program: the existence, nature and adequacy of a Subject Person's risk-based OFAC compliance program at the time of the apparent violation, where relevant. In the case of an institution subject to regulation where OFAC has entered into a Memorandum of Understanding (MOU) with the Subject Person's regulator, OFAC will follow the procedures set forth in such MOU regarding consultation with the regulator with regard to the quality and effectiveness of the Subject Person's compliance program. Even in the absence of an MOU, OFAC may take into consideration the views of federal, state, or foreign regulators, where relevant. Further information about risk-based compliance programs for financial institutions is set forth in the annex hereto.

Assessed by HEXDI

What HEXDI assesses.

  • M2

    1 — PROGRAM SETUP AND ADMINISTRATION

    Program is developed using a reasoned methodology that is based on a thorough analysis and identification of risks pertaining to company…

  • M2

    2 — PROGRAM SETUP AND ADMINISTRATION

    Methodology includes monitoring, collecting, and reporting of information on the number of exports/imports, nature and number of…

  • M2

    3 — PROGRAM SETUP AND ADMINISTRATION

    Senior Management, with the assistance of legal counsel and/or compliance personnel, takes responsibility for determining the significance…

  • M2

    4 — PROGRAM SETUP AND ADMINISTRATION

    Risk analysis and identification occurs at Senior Management meetings as part of short- and long-term forecasting and strategic planning.

  • M2

    5 — PROGRAM SETUP AND ADMINISTRATION

    Risk analysis and identification considers customer base, countries of exports/import activities, and product lines.

  • M2

    6 — PROGRAM SETUP AND ADMINISTRATION

    Risk analysis and identification considers risks posed by interactions with third parties, to include suppliers, brokers, contractors,…

Related

Other DOT standards.

Source & revisions

First mapped
Jun 8, 2022
Last updated
May 26, 2026 (29m ago)
Source
Economic Sanctions Enforcement Guidelines