US OFAC Sanctions Compliance Framework MC.IV: Promote a culture of compliance with speak-up without reprisal and SCP oversight of the whole organisation

Management commitment IV: senior management fosters a culture of compliance, measured by staff being able to report sanctions misconduct to senior management without fear of reprisal, management messages and actions that discourage misconduct and stress the consequences of non-compliance, and the SCP having oversight over the whole organisation including senior management.