Who is on the other side of your purchase order?
One unvetted supplier can drag your entire organization into a sanctions investigation.
§01Enforcement gazette
p. 01 / 08What inadequate supplier screening costs
Three companies. Three verdicts. All rooted in the same failure.
Total supply chain and third-party penalties in the last 3 years
$1.06B
Ericsson · 2022
DOJ found Ericsson paid bribes through intermediaries in Iraq, Djibouti, China, Vietnam, and Indonesia to win telecom contracts.
What they missed: No one traced who controlled the intermediary companies receiving payments.
$1.1B
Glencore · 2022
Glencore bribed officials across seven countries using a network of third-party agents — none of whom were screened for debarment.
What they missed: Supplier screening stopped at the named company. The agents behind it were never checked.
$635M
British American Tobacco · 2023
BAT was sanctioned for facilitating exports through a North Korea-linked distribution network embedded in their supply chain.
What they missed: The distributor had a clean company name. The UBO had a sanctions designation.
"They all passed a basic name check."
§02Sanctions screen — every source, two hits
p. 02 / 08A single-list check would have cleared this vendor.
OFAC SDN and DGT France both flag Novex Industrial Supplies LLC. A single-list check — or a check that skips French national designations — would have cleared this vendor for onboarding.
2 matches found — OFAC SDN (US) and DGT France (FR). Jurisdiction coverage matters.