Major powers increasingly issue compliance guidelines to delegate regulatory functions to private firms in enforcing economic sanctions. How do such initiatives influence business decisions? Focusing on the 2019 U.S. corporate sanctions compliance framework, this article evaluates two competing possibilities: the guideline may create a structural discontinuity that increases compliance burdens and slows cross-border investment, or it may consolidate expectations and reinforce existing compliance practices. Analyzing 19,116 cross-border mergers and acquisitions (M&As) from Orbis, sector-based risk perceptions derived from prior enforcement cases significantly delay deal completion, conditional on due diligence duration. However, the 2019 framework does not significantly modify this relationship. This pattern suggests that the policy consolidated existing compliance expectations rather than fundamentally changing firms’ responses to sanctions risk. Qualitative and interview evidence show that policy discussions on public–private cooperation in sanctions compliance began as early as 2016, drawing on anti–money laundering and counter–terrorism financing regimes developed after 9/11. Compliance professionals also view the framework as a formalization of existing best practices in corporate compliance. This study contributes to evidence that technical changes in financial crime standards may not trigger drastic market enforcement (Case-Ruchala and Nance, 2024), even when introduced by a global power such as the United States. Formalized compliance guidelines also legitimize a "cooperative control" model of economic statecraft, in which firms internalize state sanctions objectives into routine business operations.