ST1136
Respondent commits to ensuring that, upon learning of a weakness in its internal controls pertaining to OFAC compliance, it will take immediate and effective action, to the extent possible, to identify and implement compensating controls until the root cause of the weakness can be determined and…
Plain-language summary
What it actually means.
Plain-language summary forthcoming. Source text below.
Source text
As written.
Respondent commits to ensuring that, upon learning of a weakness in its internal controls pertaining to OFAC compliance, it will take immediate and effective action, to the extent possible, to identify and implement compensating controls until the root cause of the weakness can be determined and remediated.
Assessed by HEXDI
What HEXDI assesses.
- M11
1 — AUDITS AND ASSESSMENTS
Program has procedures for investigating the underlying root causes giving rise to program deficiencies and other internal control problems…
- M11
7 — AUDITS AND ASSESSMENTS
Program has procedures for developing, tracking and ensuring timely completion of corrective actions within established time frames.
- M12
2 — HANDLING VIOLATIONS
Remediation procedures address the treatment of unlawfully exported/imported items and/or technical information upon discovery of a…
- M12
1 — HANDLING VIOLATIONS
Program has procedures to timely remediate potential violations.
- M12
9 — HANDLING VIOLATIONS
Investigation procedures require investigators to identify root causes and propose corrective actions for violations.
- M12
1 — HANDLING VIOLATIONS
Program has procedures for tracking and ensuring timely completion of corrective actions for violations.
Related
Other DOT standards.
Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- May 26, 2026 (30m ago)
- Source
- OFAC Settlement Agreements