An OFAC enforcement release issued on October 27, 2026, announced that a North Carolina company agreed to pay $1,529,685 to settle its potential civil liability for nine apparent violations arising from its dealings with a blocked Russian entity. The release noted that the company’s U.S.-led compliance team reviewed a March 2018 purchase agreement entered into by its Russian subsidiary. The agreement included a contract naming Joint Stock Company (JSC) Moskovskiy Mashinostroitelniy Zavod Avangard (MMZA) as the end user. Significantly, OFAC noted, the company did not do “sufficient due diligence to recognize that MMZA was blocked.” MMZA, you see, was blocked not because it was on the SDN list but because it was a majority-owned subsidiary of JSC Concern Almaz Antey (“Almaz Antey”), which was blocked on July 16, 2014.
What would “sufficient due diligence” have looked like when the company first reviewed the contract? OFAC’s statement provided no guidance on that, but I think it is easy to figure out.
When I used the great and wonderful wizard of Google and entered MMZA’s name, the very first entry in the search results was a Wikipedia article on MMZA. The second sentence of that article says that MMZA is part of the Almaz Antey group. If you click on the link on Almaz Antey, you are taken to another Wikipedia article which quite clearly states that Almaz Antey was put on the SDN list on July 16, 2014. That’s enough to know whose ownership stake to check. It would be “game over” under the 50 percent rule once the company confirmed that Almaz Antey owned a majority of MMZA.
What’s important here is that “sufficient due diligence” did not involve hiring a private investigator in Russia to break into government archives at night to get the scoop on MMZA. It could have started with typing “google.com” in a browser address bar and then searching for MMZA.
So why is OFAC being so cagey here? Why didn’t OFAC tell readers that a rudimentary Internet search could have pointed the company straight to Almaz Antey? Surely OFAC could have said that without giving Google a plug. Whatever the ultimate reason, there is a good lesson here: when dealing with a new and unknown customer, the first step, at the very least, is always and without fail to do a simple Internet search on them using the search engine of your choice.
Taylor Swift famously said “You can’t be in love with a Google search.” But that doesn’t mean you can’t have a rewarding relationship with one.