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.
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…
Related
Other DOT standards.
Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- May 26, 2026 (30m ago)
- Source
- OFAC Settlement Agreements