Banner image placeholder
Banner image
Site avatar
Zhizhen Lu
Assistant Professor of International Political Economy

Curriculum vitae



Global Studies Department

Bentley University



Regulatory Delegation as Cooperative Control: The U.S. Sanctions Framework and Compliance Consolidation in Cross-Border M&As


(Previous Title: Statecraft through State-directed Private Governance: Regulatory Guidelines Improve Business Sanction Compliance in Cross-border M&As)

Major powers increasingly issue compliance guidelines to delegate regulatory functions to private firms in enforcing economic sanctions. How do such initiatives influence business decisions? Focusing on a prominent 2019 U.S. corporate sanctions compliance framework, this article evaluates two competing hypotheses: the guideline may create a structural discontinuity that increases compliance burdens and slows cross-border investment, or it may consolidate expectations and reinforce existing compliance practices. Analyzing 19,116 announced cross-border mergers and acquisitions (M&As) from Orbis, sector-based risk exposure derived from prior enforcement cases significantly delays deal completion, conditional on due diligence duration. However, the 2019 framework does not significantly modify this relationship. This pattern suggests that the policy consolidated existing compliance expectations rather than fundamentally changing firms’ responses to sanctions risk. Qualitative and interview evidence show that policy discussions on public–private cooperation in sanctions compliance began as early as 2016, drawing on anti–money laundering and counter–terrorism financing regimes developed after 9-11. Businesses have also begun incorporating sanctions screening in the early 2010s. This study contributes to evidence that regulatory standards codifying existing compliance equilibria may produce limited market responses, even when introduced by a global power such as the United States. However, formalized compliance guidelines legitimize a "cooperative control" model of regulatory economic statecraft, in which firms actively internalize state objectives into routine business operations.

Translate to