A structural governance item describes how third-party broker intermediaries are systematically routing commercial spyware (including tools reported to be linked to NSO Group and Intellexa) to buyers outside regulatory export control visibility, representing an elevated supply chain and insider threat risk for any organization regardless of whether it is a direct sanctioned target. No CVE or patch exists for this item; risk is addressed through supply chain trust reviews, endpoint behavioral monitoring for spyware indicators, MDM profile auditing, and third-party vendor assessment updates. GRC teams should incorporate commercial spyware delivery chain visibility as an explicit control in vendor risk assessments, referencing NIST SP 800-161 for supply chain risk management framing.