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.

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.

Change history

When and why it changed.

Present in the original catalog

This standard has not changed since it was added.

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
Oct 28, 2026 (6d ago)
Source
OFAC Settlement Agreements