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