Should a company enter into an agreement with a foreign state when its own human rights due diligence suggest that the engagement would simultaneously advance human rights and constitute complicity in the breach of human rights by the client government? That is the question examined in this essay. Using the example of an element of Rwanda’s response to the challenge of the COVID pandemic by leasing the use of surveillance drones, the essay considers how the human rights duties of states are both entangled and collide with the corporate responsibility to respect human rights. In the process the essay examines the relevance of emerging understanding of complicity first as a domestic and international legal norm and societal principle, second as a privatized human rights principle. Lastly it suggests that the resulting regulatory dead spaces may not be filled by the mechanisms of traditional international law but by delegated private law compliance responsibilities.