An interesting case study of trade compliance violation is posted in Wall Street Journal on January 5th.
Many US companies failed to screen trade with restricted Chinese entity, China Precision Machinery Import-Export Corp ("CPMIEC"), which is listed in Specially Designated Nationals List issued by OFAC, and imported various products from the affiliated companies in China.
For most US companies, it looks no willful violation intention, and just missed the screening.
The cause of screening failure is that the company name is not exactly match by using similar name or affiliated name, or a unit of CPMIEC with different name, etc. There are so many aka (also known as) names in one entity. It is easy to rename or make front company. OFAC added one more aka name for CPMIEC in SDN list on Dec 31, but it is like a endless race.
I understand the difficulty of this kind of screening, as I have similar experience in screening failure when I worked in US computer company. For example, there are some Japanese individuals who are listed on US Denied Persons or Debarred list. Call center happen to receive the call from one of these restricted entities in Japan and provided verbal technical service. Call center of this US company have capability to check such restricted entities by using the list in database, however the name of the person is always recognized in Kanji (Chinese character).
US government don't provide the name of restricted entities in local language, but provide only in alphabetical words. Japanese name expressed by alphabetical words often lead to so many types of Kanji names, so it is really difficult to exactly find the entity only by alphabetical name.