ST1129
Respondent’s Senior Management demonstrates recognition of the seriousness of apparent violations of the laws and regulations administered by OFAC, and acknowledges its understanding of the apparent violations at issue, and commits to implementing necessary measures to reduce the risk of…
Plain-language summary
What it actually means.
Plain-language summary forthcoming. Source text below.
Source text
As written.
Respondent’s Senior Management demonstrates recognition of the seriousness of apparent violations of the laws and regulations administered by OFAC, and acknowledges its understanding of the apparent violations at issue, and commits to implementing necessary measures to reduce the risk of reoccurrence of similar conduct and apparent violations from occurring in the future.
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
Policies identify the penalties for violations of export/import laws and the program.
- M1
1 — MANAGEMENT COMMITMENT
Policies clearly communicate the organization’s commitment to compliance with export/import laws and ethical conduct in international trade.
- M1
6 — MANAGEMENT COMMITMENT
Senior Management maintains sufficient oversight over employee adherence to the program.
- M11
2 — AUDITS AND ASSESSMENTS
Audit guide requires verification that prior audit corrective actions/recommendations were completed.
Related
Other DOT standards.
Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- Aug 11, 2026 (3d ago)
- Source
- OFAC Settlement Agreements