Zhizhen Lu

PhD Candidate


Curriculum vitae



Department of Government

The University of Texas at Austin



Cooperative Control: How US Introduced Private Governance in Economic Sanction Enforcement


Multinational corporations are key to effective economic sanctions, yet aligning them with sanction objectives remains challenging due to conflicting market and political incentives. Starting in 2016, the US government began to shift from a coercion-based sanction enforcement model to "cooperative control," introducing private governance initiatives to encourage business self-regulation. What explains this change? I argue that private governance in sanction compliance builds on international financial transparency regulations, with the US playing a leading role in strengthening its global influence. Focused on risk assessment and client due diligence, financial transparency became an international standard under the US leadership to combat global terrorist financing and money laundering. This compliance model was later extended to economic sanctions as a general framework, given its overlapping regulatory objectives with sanctions and decades of established procedures and norms that could be readily applied to enforcement. Drawing on policy documents, Congressional hearings, and professional reports, I show that this transition reflects a systematic effort by the US government to develop the "next generation of sanctions, addressing enforcement challenges and regulatory fragmentation while engaging the private sector in compliance efforts. Critiques of private governance notwithstanding, cooperative control allows the US government to shape corporate decisions for national security without excessive use of coercive power.

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