4 ms·

how does this prevent anything, a sanctioned country can create shell companies in near by countries and resell it back to themselves right?

by m3kw9 3y ago

omgJustTest 3y ago
Avoiding sanctions has penalties for both the companies that enable it and the companies that are sanctioned.
- lardo 3y ago
  Does that matter for a disposable shell?
  - kimixa 3y ago
    It might to the originating company who dealt with said shell company.
    - hef19898 3y ago
      And any individuals involved. Unless it is a full blown covert operation run by the intelligence service of a country under embaego. In that case some of the ivvolved people will get decorations and promotions, if successful.
  - alphabetting 3y ago
    DOJ has ramped up it's efforts this year to identify sanction and export control violations with a focus on shell companies https://www.akingump.com/en/insights/alerts/doj-focuses-on-corporate-crime-involving-sanctions-evasion-export-controls-violations-and-similar-economic-crimes https://www.akingump.com/en/insights/alerts/doj-focuses-on-c...
RandomLensman 3y ago
At a minimum, it increases the costs of accessing the sanctioned goods.
- omgJustTest 3y ago
  This is basically the goal of this stuff, not to stop it but to slow it.
  - jvanderbot 3y ago
    That's not true. At least not in the US. It gives legal over sight so that investigation can occur, and places legal responsibility on builders and buyers such that they'd be culpable if they are connected even accidentally to exporting restricted items. Honestly I think efficient market hypothesis is overreaching here
  - godelski 3y ago
    Isn't this the motto of security in general? "There are no roadblocks, only speed bump." (obviously you can make pretty powerful speed bumps that make you essentially stop but hey, you could try to crack AES256 if you're willing to spend astronomical time)
krisoft 3y ago
Yeah, they can. But then that is illegal and the authorities are on the lookout for it. One among the leaked wikileak messages was a communication from the state department to their german counterparts to warn them that a company trying to buy fiber optic gyroscopes from a german company is actually north korea. When my friends were building a micro satelite as a university project in Hungary the local secret service showed up uninvited. They were absolutely friendly, geeked out with them about the project, and asked the group to upgrade their alarm system. Even recommended a brand. They also gave them tips on which countries better to avoided when they travel with the satelite to the launch pad. How did they hear about their project? In short we don’t know. The speculation is that they got a tip that someone is buying space related hardware at this adress from a partner agency and they have been asked to check them out if they are a legit operation or a shell company smuggling parts. Watchers be watching, and there is an extensive aparatus for this.
bluGill 3y ago
As a creator of something restricted you are responsible for not selling to shell companies. You are required to do due diligence on everyone you sell to, and who they sell to ensure things never get to a shell company. Convince the courts you did your best and you are okay, but you need to be able to show you tried hard to prevent it. This can be tricky. As an American I can sell to Canada but not Cuba. I cannot sell to someone in Canada who resells to Cuba. Someone in Canada is legally required to lie to me if I ask if they will resell to Cuba. Therefore asking Canadians if they resell to Cuba is not enough to show I did due diligence to ensure my stuff doesn't go to Cuba. (My information on US/Cuba relations are 10-15 years out of date, but the example is good even though I'm not sure if it applies anymore)
jacquesm 3y ago
Yes, they can. But it's not going to end well: https://www.nu.nl/economie/6285728/drie-jaar-cel-geeist-tegen-ondernemer-die-chips-en-drone-aan-russen-verkocht.html https://www.nu.nl/economie/6285728/drie-jaar-cel-geeist-tege... The USA is at least as good at discovering these tricks as the Dutch are.
2OEH8eoCRo0 3y ago
This isn't about stopping them all but Frontier was built with 37,888 GPUs. Have fun sourcing export controlled GPUs at that scale. By the time you do you're two generations behind.

how does this prevent anything, a sanctioned country can create shell companies in near by countries and resell it back to themselves right?

by m3kw9 3y ago

how does this prevent anything, a sanctioned country can create shell companies in near by countries and resell it back to themselves right?

omgJustTest 3y ago

Avoiding sanctions has penalties for both the companies that enable it and the companies that are sanctioned.

lardo 3y ago
Does that matter for a disposable shell?
- kimixa 3y ago
  It might to the originating company who dealt with said shell company.
  - hef19898 3y ago
    And any individuals involved. Unless it is a full blown covert operation run by the intelligence service of a country under embaego. In that case some of the ivvolved people will get decorations and promotions, if successful.
- alphabetting 3y ago
  DOJ has ramped up it's efforts this year to identify sanction and export control violations with a focus on shell companies https://www.akingump.com/en/insights/alerts/doj-focuses-on-corporate-crime-involving-sanctions-evasion-export-controls-violations-and-similar-economic-crimes https://www.akingump.com/en/insights/alerts/doj-focuses-on-c...

RandomLensman 3y ago

At a minimum, it increases the costs of accessing the sanctioned goods.

omgJustTest 3y ago
This is basically the goal of this stuff, not to stop it but to slow it.
- jvanderbot 3y ago
  That's not true. At least not in the US. It gives legal over sight so that investigation can occur, and places legal responsibility on builders and buyers such that they'd be culpable if they are connected even accidentally to exporting restricted items. Honestly I think efficient market hypothesis is overreaching here
- godelski 3y ago
  Isn't this the motto of security in general? "There are no roadblocks, only speed bump." (obviously you can make pretty powerful speed bumps that make you essentially stop but hey, you could try to crack AES256 if you're willing to spend astronomical time)

krisoft 3y ago

Yeah, they can. But then that is illegal and the authorities are on the lookout for it. One among the leaked wikileak messages was a communication from the state department to their german counterparts to warn them that a company trying to buy fiber optic gyroscopes from a german company is actually north korea. When my friends were building a micro satelite as a university project in Hungary the local secret service showed up uninvited. They were absolutely friendly, geeked out with them about the project, and asked the group to upgrade their alarm system. Even recommended a brand. They also gave them tips on which countries better to avoided when they travel with the satelite to the launch pad. How did they hear about their project? In short we don’t know. The speculation is that they got a tip that someone is buying space related hardware at this adress from a partner agency and they have been asked to check them out if they are a legit operation or a shell company smuggling parts. Watchers be watching, and there is an extensive aparatus for this.

bluGill 3y ago

As a creator of something restricted you are responsible for not selling to shell companies. You are required to do due diligence on everyone you sell to, and who they sell to ensure things never get to a shell company. Convince the courts you did your best and you are okay, but you need to be able to show you tried hard to prevent it. This can be tricky. As an American I can sell to Canada but not Cuba. I cannot sell to someone in Canada who resells to Cuba. Someone in Canada is legally required to lie to me if I ask if they will resell to Cuba. Therefore asking Canadians if they resell to Cuba is not enough to show I did due diligence to ensure my stuff doesn't go to Cuba. (My information on US/Cuba relations are 10-15 years out of date, but the example is good even though I'm not sure if it applies anymore)

jacquesm 3y ago

Yes, they can. But it's not going to end well: https://www.nu.nl/economie/6285728/drie-jaar-cel-geeist-tegen-ondernemer-die-chips-en-drone-aan-russen-verkocht.html https://www.nu.nl/economie/6285728/drie-jaar-cel-geeist-tege... The USA is at least as good at discovering these tricks as the Dutch are.

2OEH8eoCRo0 3y ago

This isn't about stopping them all but Frontier was built with 37,888 GPUs. Have fun sourcing export controlled GPUs at that scale. By the time you do you're two generations behind.