ST1138DOTOFAC

ST1138

The Respondent has appointed personnel to integrate the sanction compliance program’s policies and procedures into the Respondent’s daily operations. This process includes consultations with relevant business units, and confirms that Respondent’s employees understand the policies and procedures.

Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

Source text

As written.

The Respondent has appointed personnel to integrate the sanction compliance program’s policies and procedures into the Respondent’s daily operations. This process includes consultations with relevant business units, and confirms that Respondent’s employees understand the policies and procedures.

Assessed by HEXDI

What HEXDI assesses.

  • M1

    3 — MANAGEMENT COMMITMENT

    Policy Statement emphasizes the importance of knowledge and understanding of when and how export controls affect company products and…

  • M1

    1 — MANAGEMENT COMMITMENT

    Senior Management maintains sufficient knowledge and understanding of export/import laws.

  • M1

    2 — MANAGEMENT COMMITMENT

    Senior Management maintains sufficient knowledge and understanding of the program.

  • M1

    8 — MANAGEMENT COMMITMENT

    A specific member of Senior Management is assigned with overall responsibility for the program.

  • M2

    1 — PROGRAM SETUP AND ADMINISTRATION

    Program provides for establishment and maintenance of an Export/Import Compliance Council (or equivalent), chaired by a member of Senior…

  • M2

    5 — PROGRAM SETUP AND ADMINISTRATION

    The Export/Import Compliance Council (or equivalent) regularly meets with the employee responsible for coordinating the program to review…

Source & revisions

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