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.
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.
Related
Other DOT standards.
Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- May 26, 2026 (30m ago)
- Source
- OFAC Settlement Agreements