A heavy equipment manufacturer sells its products globally. One of its distributors in Turkey finds that some of its equipment, including tractors, is making its way across the border into Syria for day-contract work in exchange for cash, off the books,
and thus violating sanctions compliance. First, the perpetrators hover along the border and sneak across in the morning, paying a bribe to border patrol agents to get across. Then they do a day’s worth of construction work in Syria (building whatever
it may be, possibly something sinister such as trenches or defense barriers), after which they truck the equipment back home to Turkey before anyone at “corporate” notices.
Policies, training and due diligence checks were completed and certified by the distributor and their employees. But sneaking equipment across the border for day work and then returning it back in the evening is a lucrative affair, so bad actors are tempted
to commit these sanctions violations regardless. While fictional, this is just one example of how companies are increasingly exposed to sanctions risks in a world where the line between corporate crime and geopolitics is becoming blurrier as the U.S.
uses its economic clout to clamp down on terrorists and weaken Russia in its invasion of Ukraine.