ST1128DOTOFAC

ST1128

Respondent commits to ensuring that Senior Management promotes a “culture of compliance” throughout the organization and empowers its sanctions compliance program and personnel.

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 Senior Management promotes a “culture of compliance” throughout the organization and empowers its sanctions compliance program and personnel.

Assessed by HEXDI

What HEXDI assesses.

  • M1

    1 — MANAGEMENT COMMITMENT

    Program includes a Policy Statement signed by a senior executive officer or equivalent that clearly communicates the organization’s…

  • M1

    2 — MANAGEMENT COMMITMENT

    Policy Statement explains why the commitment is important for the company and to U.S. national security and foreign policy interests.

  • M1

    3 — MANAGEMENT COMMITMENT

    Policy Statement emphasizes the importance of knowledge and understanding of when and how export controls affect company products and…

  • M1

    4 — MANAGEMENT COMMITMENT

    Policy Statement is integrated into the company code of conduct.

  • M1

    2 — MANAGEMENT COMMITMENT

    Policies instruct that no transactions will be made contrary to export/import or other U.S. laws.

  • M1

    4 — MANAGEMENT COMMITMENT

    Policies explain that Senior Management values employee comments and recommendations for improvement of the program.

Source & revisions

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