ST1126DOTOFAC

ST1126

Respondent commits to ensuring that its compliance unit(s) are delegated sufficient authority and autonomy to deploy its policies and procedures in a manner that effectively controls Respondent’s OFAC risk.

Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

Source text

As written.

Respondent commits to ensuring that its compliance unit(s) are delegated sufficient authority and autonomy to deploy its policies and procedures in a manner that effectively controls Respondent’s OFAC risk.

Assessed by HEXDI

What HEXDI assesses.

  • M2

    2 — PROGRAM SETUP AND ADMINISTRATION

    Employee responsible for coordinating the program has adequate resources, sufficient authority, and direct access to Senior Management or…

  • M2

    3 — PROGRAM SETUP AND ADMINISTRATION

    Employees with key compliance responsibilities have sufficient authority to perform their tasks.

  • M2

    4 — PROGRAM SETUP AND ADMINISTRATION

    Employees with key compliance responsibilities are located in a company unit that minimizes any potential conflicts of interest between the…

  • M11

    1 — AUDITS AND ASSESSMENTS

    Program designates a qualified employee with requisite authority, training, and experience to coordinate and supervise program audits.

  • M11

    2 — AUDITS AND ASSESSMENTS

    Program requires that only qualified personnel with requisite authority, training, and experience perform audits.

  • M11

    3 — AUDITS AND ASSESSMENTS

    Program has a procedure for addressing actual and potential conflicts of interest between the auditor and the unit, functional level,…

Source & revisions

First mapped
Jun 8, 2022
Last updated
May 26, 2026 (30m ago)
Source
OFAC Settlement Agreements