1. Podcasts
  2. Art of Supply
  3. Checkbox Supply Chain Compliance Just Got a Lot More Expensive
Art of Supply

30 Jul 2026 · 45m · 16 chapters

Episode artwork

Checkbox Supply Chain Compliance Just Got a Lot More Expensive

In short

The episode argues that supply chain compliance has become far more expensive and complex because US and other governments are shifting national-security and export-control responsibilities onto companies, moving from “checkbox” sanctions/export compliance to board/CEO-level due diligence across multiple tiers of suppliers and jurisdictions.

Guests (backgrounds)

  • Elisar Nurmagambit, co-founder and CEO of Tesari AI; technologist focused on risk intelligence for hard-to-reach/denied jurisdictions, previously worked on tech-enabled investigations including sanctions evasion and procurement-network mapping.
  • Brian Anderson, VP national security applications at Tesari AI; spent 20 years at US Homeland Security Investigations, including international investigations and helping stand up a unit to protect US supply chain interests.

Key claims and examples

  • Regulatory “super cycles” after 9/11 and now post–rules-based order require knowing “your counterparty’s counterparty.”
  • Bosch settlement and DOJ enforcement raise expectations for audit trails and corrective actions.
  • China decrees 834/835 can make it illegal to cut ties with Chinese parties using certain compliance rationales; outbound investment rules can let China reach back over assets, IP, and employees.
  • Meta’s acquisition of Manus (China AI) allegedly collapsed after Tesari warned it would; reasons included missed context about another agent (Monica), influencer signaling tied to Ministry of Commerce/CCP, and export-control exposure—costing “billions.”

Written by AI. May contain mistakes.

Chapters

0:46

Guest Introductions

Introducing Elisar Nurmagambit and Brian Anderson, their backgrounds and roles.

“and Brian Anderson is their vice president of national security applications.”
2:43

Brian's Transition to Private Sector

Brian discusses his transition from government investigations to the private sector.

“I think now we can add supply chain risk to that.”
5:00

Changing Landscape of Supply Chain Risk

Elisar explains the rising importance of understanding supply chain risks post-COVID.

“me, you know, my title changed, but the way I think about the work, well, that hasn't changed at all.”
8:53

Separating Signal from Noise in Risk Management

Discussion on the complexities of risk signals in global supply chains.

“As I was listening to talk, a phrase was coming into my mind that I will say over the last two or three months is probably the most often repeated phrase that I hear in conversations.”
12:02

Connecting Trade, Geopolitics, and National Security

Brian and Elisar discuss the interconnectedness of trade, regulation, and national security.

“They might be looking at these prepackaged data solutions or commercially generalized solutions and thinking, no, no, I'm just sourcing whatever it is from whatever place that should be enough.”
14:01

Corporate Responsibility in Compliance

Learn how recent government decisions impact corporate compliance responsibilities.

“It was my responsibility to try to show them how those things are connected.”
16:00

Understanding China's Decrees 834 and 835

Explore how China's regulations affect global supply chain relationships.

“And I think that historically is what entities or businesses have underestimated.”
18:52

Navigating the Regulatory Super Cycle

Discover the implications of China's outbound investment regulations.

“signals, domestic compliance matters, tax ratings, operational risk, ESG inside, well, China specifically in this case, but then other countries as well.”
23:17

Investigative Mindset in Supply Chain Management

Understand the importance of an investigative approach to supply chain risks.

“those disparate facts to understand a larger picture.”
28:03

Understanding China's AI and Commerce Landscape

Explore the significance of AI in China's commerce, highlighting the influence of government regulations on international transactions.

“Because Monika is still used by the majority of government agencies, national companies in China.”
Show all 16 chapters
30:00

Supply Chain Risks and Regulatory Frameworks

Discuss the impact of new regulatory frameworks and case-specific risks in global supply chains, emphasizing due diligence.

“So this is really the case that's showing the supply chain risk on one side for Meta.”
32:09

The Importance of Contextual Intelligence

Learn about the necessity of deep contextual understanding in supply chain operations to mitigate risks effectively.

“Nvidia chips is a case-by-case issue where regulators and authorities review each export in each counterpart.”
34:08

Evaluating Information in Risk Management

Gain insights into the importance of documenting and evaluating information before making decisions in risk management.

“I think the statistic is over 90 % of goods seized by CBP, and I think Brian will know more about this, they're denied release.”
36:21

Balancing AI and Human Judgment in Decision Making

Delve into the balance between leveraging AI for data gathering and maintaining human judgment in critical decision-making processes.

“but always looking at something that happened.”
42:03

AI's Role in Supply Chain Resilience

Explore how AI can enhance supply chain resiliency and risk management.

“But there is a fine line where I should provide facts, should ground itself in sources, but leave the decision making to the human.”
43:16

Concluding Insights and Gratitude

Hosts express appreciation for guests and summarize the conversation's value.

“it's supply chain, inward or outward, investment decisions, and overall risk management.”
A man walking through an airport, asking his phone a question

Ask about this episode

Get the gist, explore an idea or ask about something said.

Claude

On Art of Supply, what are the key points of this episode?

Searching your listening

Transcript

Automatic transcript. May contain errors.

0:01Hi, I'm Kelly Barner and this is the Art of Supply podcast. Every business story has a supply chain angle and those stories deserve to be told. This show digs deep into news headlines and interviews thought leaders, executives and newsmakers to capture their perspective in their own words. with no agenda to lead us in any particular direction. We'll offer you objective coverage of geopolitics, innovation, and competition. Facts will always take precedence over hype. The rest is up to you. Today on the show, I'm glad to welcome two guests. Elisar Nurmagambit is the co-founder and CEO at Tesari AI, and Brian Anderson is their vice president of national security applications.

0:54Now, you may actually remember Brian from Art of Supply episode 211, which was titled National Security Starts in the Supply Chain. We recorded that back when he was a supervisory special agent at Homeland Security Investigations Global Trade Division. So, Brian, welcome back, and Elisar, welcome to the show. Thank you for having us. Thanks, Kelly. Absolutely. Now, Elisar, because my audience has met Brian, I want to give you an opportunity to introduce yourself as well. Can you share a little bit about your background with us? Absolutely. Well, I'm a technologist by trade, and my job is usually fusing technology and actual applications and real problems and how those problems can be addressed with technology.

1:45I started in financial crime about a decade ago, but in 2020, half through my journey, I started my first company. It was a special investigations slash tech-enabled outfit focused on denied regions such as Russia, China, Central Asia, and other countries, where we addressed a few really interesting projects such as COVID-19 PPP checks, EIDL, Russian sanctions evasion, adversarial network, procurement networks, mapping, and things of the sort. And about a year ago, I started to focus specifically on that issue of covering risk, well, helping companies manage risk by analyzing data in hard-to-reach jurisdictions and really understanding who they're doing business with.

2:37Well, you couldn't have picked a better thing to focus on or a better time to focus on it in. I think the old expression was, what, can we be sure of two things, death and taxes? I think now we can add supply chain risk to that. It's the third category. So excellent business model. Brian, your transition here has been so incredibly interesting. So if I can ask you to do sort of two things for me, for people that are hearing this, that maybe didn't hear your other episode yet, and who I know are going to go back and listen to it. I will link to that in today's show notes. But talk a little bit about your background, but also what it was like transitioning from being in a government investigatory role to working in a similar area, but in the private sector.

3:23Yeah, there were no changes that I needed to accommodate at all. Besides, they took my credentials, my badges, my guns, my body armor. I mean, hardly anything. I spent 20 years working for HSI. And although the programmatic areas that I focused on throughout those 20 years, those changed over time, they were all complex international investigations. So if I go all the way back to my first days as an agent, I was working on human rights violators, people who commit genocide, war crimes, and torture. Most of those crimes don't occur in the United States, thankfully. And the evidence for those crimes is found overseas.

4:12And that's that mindset, that ability to work in foreign locations, to work with foreign governments, investigative agencies, that carried throughout my career. And by the time I spoke with you, I was working with colleagues to stand up a new unit to protect US supply chain interests, in particular, the Department of Defense or the Department of War. Again, all of the threats that we face largely start overseas and then come on shore. And then the US government and investigative bodies like HSI are then propelled to do something about that. The transition into the private sector, other than all the things that they took away from me, you know, my title changed, but the way I think about the work, well, that hasn't changed at all.

5:12I still think about what do I know? What more do I need to know? Am I ready to make a decision? Those are the same things that I was thinking about as an investigator. And Elazar and the team at Tesari encouraged me to think the same exact way. That's my responsibility in working with the application. So titles changed, but the way I think and the way I act hasn't changed very much. And I think what's so interesting about that is that if that's the kind of skill set that It translates so well to looking at supply chain risk. It's sort of a way of reflecting back on what it's like to try to manage global supply chain risk today.

6:00Elisar, question for you. You know, it's getting so much more press, especially in the follow on to COVID. You know, you gave the PPE example. Is supply chain risk or global trade risk and the related geopolitics, is it really bigger and more impactful now? Or has there been more of an awareness shift thanks to some of the media and coverage that even consumers that don't work in supply chain have been exposed to? I'd be really interested in your perspective on that. Absolutely. And that's a great question. And I think the short answer is both. It's both the awareness and the geopolitical tailwinds that create this.

6:39But if we think back on the overall private sector risk intelligence industry back maybe 10 to 20 years, it is always driven by geopolitics. So, for example, in financial crime, the Patriot Act and all the BSA compliance mandates have been really implemented. And it all started with a regulatory super cycle, which followed after 9-11. Now what we see is a much, well, in our opinion, it's a much bigger threat because the standard international rules-based order is largely gone. And as such, there is a new regulatory super cycle, at least on the United States side, which is Department of Commerce, Department of Justice, Department of War, and a lot of other agencies really shift the burden of the national security compliance piece onto the private sector, where each company now really needs to know everybody that they're doing business with, both on the inward and outward supply chain, so on the export side and on the import side.

7:55And that translates into, well, not just understanding your counterparty, but knowing your counterparty's counterparty. And it's no secret that the majority of global supply chains are really dependent on China. And it's also no secret that a lot of expert controls focus on Russia, for example, not allowing critical technology reaching, you know, Russian defense industrial sector and implementing that technology to harm civilians in Ukraine. um essentially these mandates put the pressure on the private sector to really stand up their own investigative function and it's moved the risk from a checkbox compliance type issue to a board level issue to the ceo level issue and that also results in awareness which On the other side, where the risk gets really complex is this bifurcated world where different countries issue diametrically opposing regulations.

9:04Yes. For example, countries like China. Absolutely. Now, you know, it's interesting. As I was listening to talk, a phrase was coming into my mind that I will say over the last two or three months is probably the most often repeated phrase that I hear in conversations. and I know it's true because AI is not a phrase, people keep talking about the challenge of separating signal from noise. Constantly, constantly, this is coming up on a number of fronts. And it absolutely connects to the work that you're talking about doing around supply chain risk. Everybody understands, I think, that there's usually an information solution to that challenge, but there's different structures to access that information through.

9:49Are there certain types of risk signals that either are difficult to isolate or harder to separate from the noise if you have a company and a team relying on traditional structured or commercially prepackaged data versus taking this more investigatory approach? That is also a great question where I think it all starts with the risk itself. So for example, within the financial crimes or the risk and compliance industry in general, the risk traditionally has been domestic. So it's really understanding who your customer is, who you're doing business with in the United States. Now, when the risk moves to denied regions, to opaque jurisdictions, well, first, most of the solutions don't really have any coverage there.

10:44Nobody really needed that coverage before. And the solutions that do have coverage in those denied areas, it's really, well, I think it's a combination of where the technology was at the time those solutions have been created and where the risk was. So on the risk side, it was really a checkbox compliance back office type function where you don't didn't really need to go deep on the technology side the only way you really could create a database of entities or high risk entities is really to create a data lake which would be without going too technical is creating a schema and putting all the entities in one place but when one does that really they miss all of the context related to those entities.

11:34So it's usually just registry level records. Here's the company, here's their name, here's their address. And maybe if you're lucky, you can see a director. And that's about it. But that doesn't really answer the question for the investigator or for the compliance officer really trying to figure out whether critical technology goes into adversarial hands or if their supply chain, if they're buying from a risky counterpart. Yeah. And Brian, I actually think this is where your background is certainly interesting, but it's also indicative. You know, companies that look at their supply chain and are focused on the kinds of risks that they're trying to anticipate and combat might still be surprised to think that they would need access to somebody with investigatory experience to help them do it.

12:22They might be looking at these prepackaged data solutions or commercially generalized solutions and thinking, no, no, I'm just sourcing whatever it is from whatever place that should be enough. It makes me think that there's probably a habit of underestimating the connections between global trade and geopolitics, which we know is present, regulation, which everybody is always trying to deal with, and national security, that maybe we acknowledge those things, but that companies may not have totally embraced just how interconnected all of these things are. I think you're right about that. while I have spent, as we talked about, 20 years working as an investigator, I've spent a lot of time talking to people in a business environment, in a corporate environment, and one of the things that came out time and time again was that some of those risk indicators that relate to trade or geopolitics or even national security, those are viewed generally as individual disciplines within a company.

13:34Trade, that's over there. Procurement, that's over here. National security, that's not our job. That's the government's job. Yeah. And so, over the years, I've been taking in those signals as a special agent and trying to convince folks in business that it's not my responsibility in that role to tell them that they're wrong. It was my responsibility to try to show them how those things are connected. Yeah. Eleazar talked about it a moment ago. He talked about the way the government is now signaling that those things are connected and that they are now the responsibility of corporations. And in fact, just recently, the Bosch decision was handed down, and that was the first major settlement under that CEP that came out of DOJ, which clearly has shifted the burden to industry.

14:41The government's expectation now is that trade, geopolitics, regulation, national security, those are all the responsibility of mindful businesses. And under the CEP, for example, as long as you attempt to do things correctly, if you later find out that your company made a mistake, you didn't abide by US regulations, you didn't check deeply enough, you did, I think what you were alluding to before was kind of the checkbox response to sanctions or export control. If you make a mistake under the CEP, you show your evidence, you show the way that you've corrected it, you show the bibliography or the audit trail and the government as they did in Bosch will sanction you, but your company won't be prosecuted, the CEO or the folks that sit in the C-suite that are often making these pretty important decisions, they won't face prosecution.

16:00And I think that historically is what entities or businesses have underestimated. That's clearly changing today. Yeah. Yeah. No, I think that's it's such a great example, that mindset shift, that burden of responsibility. And Alessar, it makes me actually think of another thing that I've covered here. So hopefully my audience will be familiar with it. And that is, for instance, China's new decrees, 834 and 835. So to Brian's point, there's not just a shift in expectations or responsibility from the federal government to corporations, but there's laws being made in other countries and jurisdictions that these corporations have to understand well enough to be able to prevent themselves from running afoul of.

16:49And I think these two decrees from China are good examples because at an extremely high level, they make it against the rules to do anything that harms a Chinese business, including not doing business with them anymore. So something that a procurement or supply chain professional would think of as entirely standard. I'm not going to buy from you. I am going to buy from them. If that contract leaves Chinese shores, you are in violation of one of these decrees. How can companies not just stay up on top of what's happening in other countries around the world, but make sure that their supply chain oversight efforts go multiple tiers deep into the supply chain, where I have a feeling some of these things are most likely to hit them?

17:37Well, it is a great question. And just specifically on Decrease 834 and 835, they make it, well, oversimplifying, but they make it illegal when you cut the relationship with the Chinese counterparty by citing different regulations. So, for example, OFAC or BIS 50 % or something like that. However, the interesting piece there is that if you cut the relationship with a counterparty under normal commercial practices, then you're fine. And in that sense, from a legal perspective or a compliance perspective of a U.S. corporation or maybe an EU corporation, if you really essentially go to the Chinese regulators and say, well, why cut this relationship with the supplier because of operational risk, ESG or litigation risk or anything of the sort, then you will be all right.

18:37And that's actually part of our appeal to the audience where we show a lot of the context around the entity, not just the compliance aspect of it, but their litigation history, their adverse signals, domestic compliance matters, tax ratings, operational risk, ESG inside, well, China specifically in this case, but then other countries as well. In addition to decrease 834 and 835, however, China really issued this new, started this new regulatory super cycle just like the U.S. to counter U.S. regulatory measures. So it's not just decreased 834 or 835. There is another law that actually just went into effect this month, and that's promulgated regulation on outbound investment.

19:33And while most of the people think it's a capital control story, it really isn't. And it really touches the U.S., M &A, private equity or transnational capital in a massive way where it's not just a capital controls issue. Rather, it is a essentially it's a legal basis for the Chinese authorities to reach back and assert regulatory authority over specific assets. And those assets could be technology, technological assets, IP and even employees. So if you really in a choir or an investor, the question is no longer whether, you know, a Chinese counterparty has the right paperwork. The question is really if you're buying an asset that was properly cleared to leave China.

20:21And that's a it's another piece, a little bit different from the supply chain factor itself. But it's the overall regulatory super cycle in general. Yeah. And and so I think so we've definitely established both the scale and complexity of the risk. I want to use the rest of the time that I have the two with you to start arming my audience to combat these risks. Brian, if I can start with you, you've kind of talked about taking on this investigatory mindset that as more of the responsibility shifts into a corporate setting, you can't just think like a supply chain manager anymore. You actually have to start thinking like an investigator.

21:01So if you go back to the beginning of any of the investigations that you've worked on, you've got maybe some of those early signals. You're trying to figure out what is the signal, what is the noise. If you have experience as an investigator and you're starting to sense some of these early signals, what are sort of the best practices or the advised practices at that point early on?

21:27How much time do you have? Give us the Reader's Digest version. We'll fill in the test. Sure. It's a great question. I think one of the things that I've thought about for years, where you enter an investigation is not the investigation itself. And the question that I've been handed many times also isn't the question that I ultimately need to answer. And I'm not sure that the business environment is trained to think that way. I often think about, let's talk about that entry point. It's a piece of information. It might relate to an inspection of a commodity, might relate to the inspection of a person.

22:22And if I go way back in my history, it might relate to a motor vehicle stop. That's where you enter, and you only have a limited amount of information. So as an investigator, I'm trained to want to know more. I'm not sure that in a corporate environment, that's necessarily the way they are trained to think. And so, if I'm focusing on an inspection, I want to know where did those goods come from? Where are they going? Who handled them? What can you tell me about the financial transaction that supports them? What other businesses does the, we'll just say China, for example, we've been talking about it a lot.

23:07So, what other businesses to that same company in China, what do they own? and so I start piecing together those disparate facts to understand a larger picture. Now, as I start to fill in that tapestry, I can start making some reasonable decisions. So when I was an investigator, those decisions often were, well, is there a threat? Is there a problem here? If there's a problem, do I know enough? Can I take some action based on what I know? Well, maybe I can, maybe I can't. And if I can't, well, what do I need to find out? How am I going to do that? Eventually, you stack those originally disconnected pieces of information on top of each other.

23:57Now they're connected. Now I can see what's in front of me and I can see beyond it. And when I have the ability to do that, I think I can make pretty good decisions about what I should do next. So as an investigator, we talked about it, I can decide that I want to inspect a shipment. I can decide that I want to seize a shipment. I can go to the U.S. attorney's office. But what does that translate to in the corporate sector? It may be that if you work in the compliance department, you need to flag a particular transaction. You need to elevate that for additional review. It may be that you're going to move out of the compliance department and go to the legal department.

24:36It may be that something, some decision that you have been working on in that setting is going to find its way to the C-suite. Well that's where the risk sits. And as we've seen, not to beat the drum about DOJ, but as we have seen over the last couple of years, those decisions carry a lot of weight, both financial and potential criminal weight. And so I think that is one of the spaces where investigators, to get back to your original question, where investigators, I think, have the benefit of trying to develop a broader picture or a greater understanding about what's happening and not looking only at a document that's in front of them or a checklist, for example.

25:26And I think the other thing that's hard, so there's this investigatory mindset to be learned. There's this developing the practice of asking all of these questions and then figuring out which ones you really truly need answers to. But for so many supply chain professionals, they're also not necessarily experts in the different cultures that either they're sourcing from or that their suppliers and their suppliers' suppliers operate in. L.S.R., how much does a culturally based context matter in all of this? I mean, certainly there's language, there's regional behaviors, there's different regulations and legal structures.

26:04It's not as simple as asking a question, is this company risky? There's so many pieces that go into that. How much of that ends up sort of being contextualized based on the location of where that supplier is? Great question. And I appreciate you asking that, especially after the context of Brian Gape. I'll give you one example. And that is the Meta Manus example. So a quick story there where Meta acquired this AI agent company Manus out of China. And a third party, like it normally happens, cleared a transaction. So this was a due diligence function, essentially. we're buying a company in China, it's an AI company.

26:54So you really need to look at risk from several factors where you have to think about the supply chain and the regulation on the US side. You also need to understand the export controls and the foreign laws in China. And you need to really understand how will this impact your business. So that, as we know, that transaction collapsed and it costed meta billions of dollars uh and the reason it did collapse so if we look um you know step by step uh on one side there was a treasury u.s treasury investigation into this company before um but it wasn't uh anything about meta it was about benchmark which is a u.s venture capital firm that invested uh in manis so treasury started investigating that then meta buys this company and we actually warned uh meta four months before this transaction happened that it will collapse because when we ran manis in our system not only did we see the overall static information about manis who they are and what they do but here is the regional context so manis is not the only agent there is another uh ai agent called monica and monica is the chinese pride and joy And the first level where you need to understand the culture, it's very common in China to have a product aimed at the Chinese market and the product for export aimed at the English speaking world in the international world.

28:22So that piece was missed. Why does that matter? Because Monika is still used by the majority of government agencies, national companies in China. So it's critical technology for China. The second piece, we identified a local influencer talking about Chinese Ministry of Commerce, that Chinese commerce would potentially block this transaction due to export controls. So, well, why is that signaling not noise? Well, if you are an influencer in China, you need a CCP-issued license to speak. So there is no freedom of speech as such. So the next thing, if you actually are talking about a regulation or a legal matter, what you really need to know, what you really need to do in China is, A, qualify for that.

29:16So you need to have some sort of a degree or some other accolades that make you a credible voice. But then you also need approval from the appropriate agency, which in this case was Ministry of Commerce. So when we analyze the words of that influencer or scholar through that lens, we know it's not just a random person signaling something. It's really Ministry of Commerce and the CCP and the Chinese government overall signaling that this is what can happen. So from a, you know, out of context view of a traditional standard static type of due diligence, all of that will be missed. And this particular case costed$2 billion in the acquisition itself, billions of dollars in the integration and billions of dollars in the stock market in general.

30:07So this is really the case that's showing the supply chain risk on one side for Meta. The other thing is Chinese regulation for their own export controls, which obviously touches our supply chains. And it talks about that case itself really created this new regulatory framework that the Chinese call substance over four. And that is what's underpinning all of their regulations on capital controls and expert controls on Decrease 834 and 835 and all the rest, you know, combining both sides into this one case. And I think what that example does such a great job of illustrating is why it's not enough to just look at sort of broad country level information.

30:55You know, you could say to any supply chain manager, hey, do you think it's kind of risky to source in China? I'm going to say, yeah, it's probably pretty risky. But is the price point right? Yeah, the price point is right. And if you're just painting in those broad strokes, you can see why companies can very easily find themselves afoul of these situations. But for you and the Tesari AI team to dig into this and say, for this company and this deal down to the particulars of that specific influencer and the certifications they had to have in order to speak, that's not something you're going to get if you're just looking at what's the general risk level in.

31:36And it doesn't just have to be China. It could be any country in Southeast Asia. It could be Central America. It could be in Africa, depending on where you're doing trade. it's literally anywhere. And it's, you can tell me if you think it's sort of context or nuance, Alisar, but it really seems like it's getting down into those specifics that makes the difference when you come to these, let's say, high exposure decisions. Well, absolutely. It is always a case by case matter. I mean, even if we look at the NVIDIA chips, right, each export for latest Nvidia chips is a case-by-case issue where regulators and authorities review each export in each counterpart.

32:19Well, we can safely assume that every bit in the supply chain of any company is now a case-by-case issue, both on the export side and on the import side. And what you really need to look for is, well, cross-border risk. It's not the way that the Chinese talk about you know substance over for uh their capital controls you can buy like if you're a us acquirer uh you can purchase a cayman islands registered entity or a singapore registered entity but if their substance if their engineering of their manufacturing if their ip is centered in mainland china china has jurisdictions jurisdiction over same thing for russia iran um africa central America.

33:07It's really substance of reform. And in order to get to the substance, you really have to start with an entity and understand everything you can about that entity, all their counterparties, their ownership structures, corporate networks, litigation context, domestic compliance context. It's really piecing that information from multiple sources into a cohesive picture to understand what actually you're dealing with and what is the risk. And that is also why a one-point in time snapshot diligence will not really tell you that. You really need to understand what happened before, you know, and what will happen after.

33:46So it's more of a context of interpretive intelligence and understanding of, you know, in the quickly changing geopolitical and global order, what is going to happen with your supply chain. And the risk is not really just the regulatory fine. The risk is also like, for example, on the forced labor and human trafficking concerns. I think the statistic is over 90 % of goods seized by CBP, and I think Brian will know more about this, they're denied release. So the cost is not just the regulatory or the legal matter. It's really if you're an automotive manufacturer, well, the car you're about to manufacture is delayed.

34:29And the cost of that is much higher and much harder to calculate down the line. Yeah. Now, Brian, I want to come to you from sort of one last piece of advice. We've talked a lot today about separating signal from noise. But I think the other thing that we probably need to get a little bit stronger at doing is separating smoke from fire. You know, there's such a deluge of information and it's very easy. I mean, we've used a lot of examples from China today. We've talked about Russia. It's very easy to look at a situation if we're being overly broad with our information sources and say, oh yeah, I'm sure this is a risky situation.

35:10I'm going to make a change or I'm not going to do business there, even if an opportunity looks good. What advice would you give to somebody without investigatory experience that thinks they have evidence that wants to make sure it's something that will stand up. You know, LSR talked about auditability before, before they actually take action based on that. And that action could be changing a contract, but it could also be putting something in writing, making a question or a statement formal in a way that becomes part of the record. If we do go down this road of starting together more information, how do you advise people to evaluate that information before they take steps and act on it?

35:59That's a great question. One that I think I spent a fair amount of time talking to folks about. When I was with HSI, typically we were involved in examining things that had already happened. always with an eye towards making sure that it doesn't happen again, preventing further risk or further damage, but always looking at something that happened. And so certainly we had the benefit of hindsight. Talking to folks when I would sit down in offices, whether with compliance people, with their legal department, asking them the steps that they went through. And I was surprised at how often folks were not very good at being able to produce the documentary evidence that supported the questions that they had been trying to answer.

37:00It's one of the things that I like about what Tesari does because we provide that capability within our platform. But it's not just because of that. It's because it's the way I was trained. Ask questions, receive information, document what you did. That documentation occurs in a variety of ways. But Eleazar and I and you in the form of your questions have been talking a lot about the information, the signals, and there is a way to document everything when it is appropriate. It's a little bit of, somebody was talking to me the other day about a lesson that I learned from 20 years or 28 years really in law enforcement of investigations.

37:56And there comes a point in time where you do have a feeling that something's not right, therefore I need to ask more, especially in a corporate environment. I don't think we are encouraging people to shut off every deal that their company might engage in just because they find one thing that maybe raises a question. No, pursue that question and document how you went about it. Document what sources, who you talk to, and then ultimately what we're talking about is make a decision. The human gets to make the decision, right? We at Tesari, we when I was with HSI, right? We still turn the key. We decide to act and now we've got a defensible action.

38:51We can point to the things that drove us to that moment in time and to that decision. I think I saw enough times where that wasn't occurring with the type of regularity that I would have expected in that environment. It certainly was a requirement in my field because when I'm with HSI, ultimately I'm bringing cases to the U.S. Attorney's Office for prosecution. And all of those steps that I undertook and all of those documents are going to be part of the discovery obligation to share the evidence that the government has. So I found that to be one of the areas that I was surprised about. And that's the advice that I would provide people today.

39:40Yeah. And and Elisar, so what Brian just shared makes me think of one more question that I want to ask of you. the human judgment and experience piece is absolutely critical right you you develop that that spidey sense not to make light of it by any means but you do something enough times you get a sense for something is not right i need to go find evidence i need to do my homework but i just know something's off here and yet in 2026 we're also aware of the amazing power and potential of AI-enabled technologies. When you think about the decisions that have to be made and the investigations that are going on, how do you see the balance that we're trying to strike between leveraging the power of the technology without making sure that we brush aside all of that human judgment and experience and sense?

40:35Let's finish with that thought from you. Absolutely. Well, every industry reacts differently to AI and our industry is very particular where, in our opinion, AI will never replace that human judgment. And the number one reason for that is responsibility. If you are a national security analyst and you produce intelligence that is a cohesive narrative, but it is unsubstantiated. And if there is a policy level result from that and that intelligence was faulty, then you're really risking your career. If you are a compliance officer or even if you're a due diligence firm and you miss a risk signal, like with Meta and Manus example, well, you're risking your career again.

41:30And you cannot outsource responsibility to AI. So it's always going to be the human that really ultimately makes that decision. Now, where AI is particularly useful is at gathering the information, is understanding the jurisdictional context, because nobody can really check manually every source. Nobody can be an expert in every jurisdiction. Nobody can know the laws and regulation of every country. It's AI will certainly help with that. But there is a fine line where I should provide facts, should ground itself in sources, but leave the decision making to the human. And that really puts the profession, whether it's supply chain or risk and compliance in general, national security, the level of responsibility for the human in charge versus AI really is in a very tricky place.

42:29because what we see now, the trend is supply chains are being converted from an efficiency-driven model to a resiliency-based model, where you have to make sure your supply chains are resilient, but also think about the business side of the house, the regulatory side, the legal side, and make that decision. So in thinking in all of these different risk modalities, if you will, AI can be extremely helpful in helping map that risk, in getting the job that usually would take months to conduct an investigation, for example, cross border network investigation. that can be done in 10 minutes. And that is something, at least we're obviously biased, but in our view, that is something every corporation will need at every level, whether it's supply chain, inward or outward, investment decisions, and overall risk management.

43:27Yeah. Well, I know we're just about out of time. Elisar and Brian, I want to thank both of you for being here. It's interesting. You have such different experiences, and it's fascinating to me that they meet so well in the world that we're all trying to wrangle today. So thank you both for sharing some of these examples, sharing your insights and your experience. I will make sure that there are links to both of your profiles so that people can connect with you, learn more about Tesari AI if they discover you through this conversation. But genuinely, I want to thank you both for being with me today.

44:00Thank you so much for having us. Really great conversation, great questions. Enjoyed this very much.

44:11Art of Supply is part of the Art of Procurement family of brands. To ensure you never miss new content, I invite you to sign up for our newsletter at artofsupply.com. If this episode of the Art of Supply podcast made you think, please spread the word. You can support the show by giving us a thumbs up, a star rating, or a review wherever you find your podcast audio. Join me next week for another deep dive into the art of supply.

From the publisher

"AI will never replace that human judgment. And the number one reason for that is responsibility." — Elisar Nurmagambet, Co-Founder and CEO, Tesari AI

When Meta acquired the Chinese AI agent startup Manus for roughly $2 Billion, the due diligence looked clean.  

Four months later, China's government blocked the deal and ordered it unwound. 

Elisar Nurmagambet, Co-Founder and CEO of Tesari AI, and Brian Andersen, their Vice President of National Security Applications, join Kelly Barner to explain why the compliance model most companies still run on wasn't built for this moment, and why some of the sharpest early-warning signals in global trade never show up in a standard database at all.

 In this episode Elissar and Brian discuss:

- Why "checkbox compliance" has become a board-level, CEO-level liability

- What a government-licensed social media influencer in China revealed about the Meta-Manus deal, months before it collapsed

- Why "substance over form" now determines whose jurisdiction your supply chain falls under, regardless of where an entity is legally registered

- The investigative mindset that supply chain professionals have to develop to succeed in today's challenging conditions

 

Links:

Elisar Nurmagambet on LinkedIn: https://www.linkedin.com/in/elissarn/ 

Brian Andersen on LinkedIn: https://www.linkedin.com/in/tbrianandersen/ 

Tesari AI: https://www.tesari.ai 

National Security Starts in the Supply Chain (AOS, Ep 211): https://artofprocurement.com/blog/supply-national-security-starts-in-the-supply-chain 

Kelly Barner on LinkedIn: https://www.linkedin.com/in/kelly-barner-6884443/ 

Art of Supply LinkedIn newsletter: https://www.linkedin.com/newsletters/art-of-supply-6895142546301960193 

Art of Supply on AOP: http://www.artofsupply.com 

Subscribe to the Art of Procurement Newsletter: https://resources.artofprocurement.com/art-of-procurement-podcast-subscribe 

 

More from Art of Supply

All episodes