ST1137DOTOFAC

ST1137

The Respondent has clearly communicated the sanctions compliance plan’s policies and procedures to all relevant staff, including personnel within the sanctions compliance function, as well as relevant gatekeepers and business units operating in high risk areas (e.g., customer acquisition, payments,…

Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

Source text

As written.

The Respondent has clearly communicated the sanctions compliance plan’s policies and procedures to all relevant staff, including personnel within the sanctions compliance function, as well as relevant gatekeepers and business units operating in high risk areas (e.g., customer acquisition, payments, sales, etc.).

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

    5 — MANAGEMENT COMMITMENT

    Policy Statement is communicated to employees on an ongoing basis by a variety of means, to include but not limited to: company…

  • M1

    1 — MANAGEMENT COMMITMENT

    Policies clearly communicate the organization’s commitment to compliance with export/import laws and ethical conduct in international trade.

  • M1

    2 — MANAGEMENT COMMITMENT

    Policies clearly explain why the commitment is important for the company and to national security and foreign policy interests.

  • M2

    1 — PROGRAM SETUP AND ADMINISTRATION

    Program is written in a clear and logical manner that is understandable by all employees.

  • M2

    1 — PROGRAM SETUP AND ADMINISTRATION

    Program is distributed to all employees who acknowledge in writing that they have read, understand, and will comply with all program…

Source & revisions

First mapped
Jun 8, 2022
Last updated
May 26, 2026 (30m ago)
Source
OFAC Settlement Agreements