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Zhizhen Lu
Assistant Professor of International Political Economy

Curriculum vitae



Global Studies Department

Bentley University



The Compliance Gap: Regulatory Knowledge and the Private Implementation of Sanctions


Economic sanctions depend on private organizations to translate foreign-policy rules into transaction-level decisions. This paper analyzes an original survey experiment of 564 managers with international business exposure and self-reported familiarity with sanctions issues. The survey distinguishes formal compliance infrastructure from basic regulatory knowledge and intended behavior. Approximately 90 percent of respondents report sanctions training, screening procedures, or external compliance services, but only 39 percent correctly identify the U.S. Treasury's Office of Foreign Assets Control (OFAC) as the principal administrator of U.S. economic sanctions. Correct OFAC identification is strongly associated with the response to a prospective Kazakhstan client: knowledgeable respondents are less likely to communicate without checking and more likely to conduct a thorough background check. By contrast, brief reward- and punishment-oriented enforcement messages produce no statistically detectable change in perceived risk or in a secondary binary measure that combines thorough checking with nonresponse. Exploratory latent class analysis identifies thin, formalized, and adaptive compliance configurations. Those profiles do not predict OFAC knowledge, and their association with intended behavior does not support a simple claim that more adaptive infrastructure produces either greater caution or more calibrated due diligence. The findings identify a political implementation problem: the reach and consistency of sanctions policy depend not only on state decisions, but also on whether private intermediaries understand and operationalize them.


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