Evaluating risk: Concentration, jurisdiction and shadow AI

Foreign dependency is a real risk, but the exposure that matters is a sudden cutoff: A model you cannot audit, switch or exit, shut off by someone else’s order. A vendor’s nationality is a poor guide to that risk; control is. Two markers matter. The first is concentration. In July 2024, a single faulty CrowdStrike update crashed about 8.

5 million Windows machines, disrupting airlines, hospitals, banks and governments worldwide. No attacker was involved; one homogeneous dependency failed everywhere at once. The lesson points away from vendor nationality and toward uniformity as the fault line, making portability and provider diversity resilience controls. The second is jurisdiction. In June 2025, Microsoft’s legal director for France told a Senate inquiry, under oath, that it could not guarantee that French public-sector data, even in French data centers, would be protected against US demands under the 2018 CLOUD Act.

No such request had been made, and EU data has stayed in the EU since January 2025; senators called the assurance purely declarative. For the most sensitive data, residency does not equal control; the parent’s jurisdiction can matter as much as the server’s. Three US hyperscalers hold about 70% of the European cloud market, while European providers’ share fell from 29% in 2017 to roughly 15%. Concentration plus jurisdiction is the exposure a CIO must price. I have watched teams treat vendor selection as the moment risk was solved; it rarely was.

The wrong response is self-isolation. Most countries will never build frontier models, advanced chips, hyperscale clouds and talent pipelines at once; the Tony Blair Institute calls full self-sufficiency “too expensive, too slow and, for most countries, simply impossible. ” The better test is workload sensitivity.