"These entities act as intermediaries, obscuring the connections between vendors, suppliers, and buyers. Oftentimes, intermediaries connect vendors to new regional markets."
"This creates an expanded and opaque spyware supply chain which makes corporate structures, jurisdictional arbitrage, and ultimately accountability measures a challenge to disentangle,"
"US policymakers have systematically targeted the proliferation and misuse of spyware through robust policy action, but there is a critical gap between them and US investors-where US dollars continue to fund the very entities US policymakers are trying to combat,"
Resellers and brokers function as intermediaries that obscure connections between vendors, suppliers, and buyers and often connect vendors to new regional markets. Their activity expands an opaque spyware supply chain and complicates corporate structures, jurisdictional arbitrage, and accountability measures. Resellers and brokers remain largely absent from current policy responses. New jurisdictions linked to spyware activity include Japan, Malaysia, and Panama; Japan is a signatory to international efforts to curb spyware abuse, including the Joint Statement on Efforts to Counter the Proliferation and Misuse of Commercial Spyware and the Pall Mall Process Code of Practice for States. US policy measures have constrained the market, but US investment continues to fund targeted entities.
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