Common use of Management Commitment Clause in Contracts

Management Commitment. i. Respondent commits that senior management has reviewed and approved Respondent’s sanctions compliance program. ii. Respondent commits to ensuring that its senior management, including senior leadership, executives, or the board of directors, are committed to supporting Respondent’s OFAC compliance program. iii. Respondent commits to ensuring that its compliance unit(s) are delegated sufficient authority and autonomy to deploy its policies and procedures in a manner that effectively controls Respondent’s OFAC risk. iv. Respondent commits to ensuring that its compliance unit(s) receive adequate resources—including in the form of human capital, expertise, information technology, and other resources, as appropriate—that are relative to Respondent’s breadth of operations, target and secondary markets, and other factors affecting its overall risk profile. v. Respondent commits to ensuring that senior management promotes a “culture of compliance” throughout the organization.

Management Commitment. i. Respondent commits that senior management has reviewed and approved Respondent’s sanctions compliance program. ii. Respondent commits to ensuring that its senior management, including senior leadership, executives, or and the board of directors, are committed to supporting Respondent’s OFAC compliance program. iii. Respondent commits to ensuring that its all compliance unit(s) units are delegated sufficient authority and autonomy to deploy its policies and procedures in a manner that effectively controls Respondent’s OFAC risk. iv. Respondent commits to ensuring that its all compliance unit(s) units receive adequate resources—including in the form of human capital, expertise, information technology, and other resources, as appropriate—that are relative to Respondent’s breadth of operations, target and secondary markets, and other factors affecting its overall risk profile. v. Respondent commits to ensuring that senior management promotes a “culture of compliance” throughout the organization.