Hidden Entanglement: Why Sanctions Compliance Is Failing American Companies Before They Ever Realize It
American companies operating across international markets are discovering, often through federal enforcement actions, that their supply chains and ownership structures harbor sanctions violations they never knowingly committed. The architecture of modern global commerce—layered intermediaries, opaque joint ventures, and multi-jurisdictional logistics networks—has made inadvertent OFAC exposure a systemic risk rather than an isolated compliance failure. Executives who assume that good-faith deali