ST0936DOTOFAC

ST0936

II.F.3. In the case of an entity, whether the Subject Person adopted new and more effective internal controls and procedures to prevent a recurrence of the apparent violation. If the Subject Person did not have an OFAC compliance program in place at the time of the apparent violation, did it…

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.F.3. In the case of an entity, whether the Subject Person adopted new and more effective internal controls and procedures to prevent a recurrence of the apparent violation. If the Subject Person did not have an OFAC compliance program in place at the time of the apparent violation, did it implement one upon discovery of the apparent violations? If it did have an OFAC compliance program, did it take appropriate steps to enhance the program to prevent the recurrence of similar violations? Did the entity provide the individual(s) responsible for the apparent violation with additional training, and/or take other appropriate action, to ensure that similar violations do not occur in the future?

Assessed by HEXDI

What HEXDI assesses.

  • M2

    2 — PROGRAM SETUP AND ADMINISTRATION

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

  • M12

    2 — HANDLING VIOLATIONS

    Remediation procedures address the treatment of unlawfully exported/imported items and/or technical information upon discovery of a…

  • M12

    1 — HANDLING VIOLATIONS

    Program has procedures to timely remediate potential violations.

  • M12

    1 — HANDLING VIOLATIONS

    Program has procedures for tracking and ensuring timely completion of corrective actions for violations.

  • M12

    2 — HANDLING VIOLATIONS

    Program has procedures for the fair and consistent application of disciplinary actions for employee violations.

  • M12

    3 — HANDLING VIOLATIONS

    Senior Management takes reasonable steps to exclude employees responsible for intentional violations of export/import laws from management…

Related

Other DOT standards.

Source & revisions

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