ST1132
Respondent has designed and implemented written policies and procedures outlining its sanctions compliance plan. These policies and procedures are relevant to the organization, capture the Respondent’s day-to-day operations and procedures, are easy to follow, and prohibit employees from engaging in…
Plain-language summary
What it actually means.
Plain-language summary forthcoming. Source text below.
Source text
As written.
Respondent has designed and implemented written policies and procedures outlining its sanctions compliance plan. These policies and procedures are relevant to the organization, capture the Respondent’s day-to-day operations and procedures, are easy to follow, and prohibit employees from engaging in misconduct.
Assessed by HEXDI
What HEXDI assesses.
- M1
1 — MANAGEMENT COMMITMENT
Senior Management establishes a formal written international trade compliance program, principally comprised of top-level policies and…
- M2
1 — PROGRAM SETUP AND ADMINISTRATION
Program is developed using a reasoned methodology that is based on a thorough analysis and identification of risks pertaining to company…
- M2
10 — PROGRAM SETUP AND ADMINISTRATION
Risk analysis and identification considers risks posed by internal factors such as changes to product lines, staffing, operating processes,…
- M2
1 — PROGRAM SETUP AND ADMINISTRATION
Program is written in a clear and logical manner that is understandable by all employees.
- M2
2 — PROGRAM SETUP AND ADMINISTRATION
Program contains written procedures that address key compliance tasks.
- M2
3 — PROGRAM SETUP AND ADMINISTRATION
Procedures are implemented and consistent with actual operations.
Related
Other DOT standards.
Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- May 26, 2026 (30m ago)
- Source
- OFAC Settlement Agreements