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The entire chain all the way down is sanctioned, the US can and will climb up and down that chain to punish sanctions violations. A company like Disney will ha

The entire chain all the way down is sanctioned, the US can and will climb up and down that chain to punish sanctions violations. A company like Disney will have to have a Sanctions Compliance Program and like any other compliance regime, there are standards, external auditors, etc. to make sure enough is being done, and "enough" can be a bit of a moving target. If you get caught having sanctioned suppliers, those standards and auditing get kicked up a notch, if you did a really bad job maybe fines or criminal charges. There isn't ever a sense of "I'm doing enough and therefore the sanctions violations happening are no longer my fault". It's somewhat up to you to determine your risk and tailor your compliance program to address them and to adjust if you're ever wrong. How guilty you are is a function of how good a job the state department thinks you're doing trying to avoid sanctions violations.

10000truths 3y ago
> How guilty you are is a function of how good a job the state department thinks you're doing trying to avoid sanctions violations. Is the standard for this codified in clear language anywhere, or is it merely based on the whims of some federal prosecutor/judge? If I make digital watches, and I buy coin cell batteries from a supplier who buys battery precursors from a supplier who buys LiCoO2 from a manufacturer who buys lithium-rich brine from a supplier who buys lithium mining equipment from a sanctioned entity, how much of the full brunt of Uncle Sam's retribution can I expect to come crashing down on me?
- beaeglebeachh 3y ago
  Feds have 99+% conviction rate and infinite money and time, meanwhile you sit in cage and deal with frozen accounts while trying to pay your attorney. They imprisoned weev for doing arithmetic on wget'ing a public website. Worst sin is angering the gods. I would imagine most the time theyll probably just ask nicely for you to stop, then bury you if you don't, but for political or convenient targets they seem fine going straight for the throat.
  - acdha 3y ago
    The hyperbole isn’t helping your argument here. Weev spent time brute-forcing collection of personal information which they discussed using for phishing, manipulating AT&T’s stock price, and potentially shorting the stock: https://arstechnica.com/gadgets/2011/01/goatse-security-trolls-were-after-max-lols-in-att-ipad-hack/ https://arstechnica.com/gadgets/2011/01/goatse-security-trol... They were too bumbling to actually do anything that serious but being too broke to run a stock scam isn’t exactly a great character testimonial, and all of that is well outside of professional ethical boundaries in the infosec community.
    - beaeglebeachh 3y ago
      Its not hyperbole, you're just using misguided rhetoric of the prosecution. Weev has escaped to Ukraine in any case, those same bumbling idiots making your argument had their conviction dropped on appeal.
      - acdha 3y ago
        His appeal was decided on a technicality over where the case was brought: https://arstechnica.com/tech-policy/2014/04/appeals-court-reverses-hackertroll-weev-conviction-and-sentence/ https://arstechnica.com/tech-policy/2014/04/appeals-court-re... It’s certainly possible that a court might have found his actions did not violate the relevant laws, but that was not the case in the first trial where he had full opportunity to challenge the prosecution’s claims. You might characterize that as “misguided rhetoric” but that should be your cue to ask whether it’s really true that you understand the situation better than his real legal team.
        beaeglebeachh 3y ago
        The "real" prosecuting legal team didn't even prosecute in the right venue. That's how far off the mark they were.
  - colechristensen 3y ago
    The main reason the Feds’ conviction rate is so high is they’re lazy cowards who only try cases that are extremely easy to convict. It’s not that they do nothing but there are shitty incentives in place to only put cases in front of judges that are certain.
- blackhawkC17 3y ago
  More based on the whims of a prosecutor. Many small companies violate sanctions (usually unknowingly) and don't get prosecuted. But stick out too much, and you'll likely get hammered.
- chiggsy 3y ago
  State Department will have all the docs one needs to avoid any problems. In your example, the real risk would be that the lithium mining equipment is dual-use, ie: they also use it to mine yellowcake uranium ore, or when your watch business takes off, they struggle to provide enough brine, and bring in specialists from Afghanistan, who streamline the process and who's Dari has a Tehran accent. They can let you keep making money until it's promotion time, or an example needs to be made for an election campaign or they find out your watches seem to be the chronometer of choice of the latest insurgency.
thriftwy 3y ago
Quite contrary I would say. An American megacorp will always know how much profit from the US sanctions it can do and get away with it. Sometimes a slap on the wrist can happen, but in general... You do want those campaign donations flowing, do you? Then there is no reason to rock the boat. Smaller companies from other countries may not be so lucky so they may actually refrain from such activities.
1123581321 3y ago
Thanks; this is helpful. Looking up what sanctions compliance/export control professionals proactively do yields a ton of additional information.

10000truths 3y ago

> How guilty you are is a function of how good a job the state department thinks you're doing trying to avoid sanctions violations. Is the standard for this codified in clear language anywhere, or is it merely based on the whims of some federal prosecutor/judge? If I make digital watches, and I buy coin cell batteries from a supplier who buys battery precursors from a supplier who buys LiCoO2 from a manufacturer who buys lithium-rich brine from a supplier who buys lithium mining equipment from a sanctioned entity, how much of the full brunt of Uncle Sam's retribution can I expect to come crashing down on me?

beaeglebeachh 3y ago
Feds have 99+% conviction rate and infinite money and time, meanwhile you sit in cage and deal with frozen accounts while trying to pay your attorney. They imprisoned weev for doing arithmetic on wget'ing a public website. Worst sin is angering the gods. I would imagine most the time theyll probably just ask nicely for you to stop, then bury you if you don't, but for political or convenient targets they seem fine going straight for the throat.
- acdha 3y ago
  The hyperbole isn’t helping your argument here. Weev spent time brute-forcing collection of personal information which they discussed using for phishing, manipulating AT&T’s stock price, and potentially shorting the stock: https://arstechnica.com/gadgets/2011/01/goatse-security-trolls-were-after-max-lols-in-att-ipad-hack/ https://arstechnica.com/gadgets/2011/01/goatse-security-trol... They were too bumbling to actually do anything that serious but being too broke to run a stock scam isn’t exactly a great character testimonial, and all of that is well outside of professional ethical boundaries in the infosec community.
  - beaeglebeachh 3y ago
    Its not hyperbole, you're just using misguided rhetoric of the prosecution. Weev has escaped to Ukraine in any case, those same bumbling idiots making your argument had their conviction dropped on appeal.
    - acdha 3y ago
      His appeal was decided on a technicality over where the case was brought: https://arstechnica.com/tech-policy/2014/04/appeals-court-reverses-hackertroll-weev-conviction-and-sentence/ https://arstechnica.com/tech-policy/2014/04/appeals-court-re... It’s certainly possible that a court might have found his actions did not violate the relevant laws, but that was not the case in the first trial where he had full opportunity to challenge the prosecution’s claims. You might characterize that as “misguided rhetoric” but that should be your cue to ask whether it’s really true that you understand the situation better than his real legal team.
      - beaeglebeachh 3y ago
        The "real" prosecuting legal team didn't even prosecute in the right venue. That's how far off the mark they were.
- colechristensen 3y ago
  The main reason the Feds’ conviction rate is so high is they’re lazy cowards who only try cases that are extremely easy to convict. It’s not that they do nothing but there are shitty incentives in place to only put cases in front of judges that are certain.
blackhawkC17 3y ago
More based on the whims of a prosecutor. Many small companies violate sanctions (usually unknowingly) and don't get prosecuted. But stick out too much, and you'll likely get hammered.
chiggsy 3y ago
State Department will have all the docs one needs to avoid any problems. In your example, the real risk would be that the lithium mining equipment is dual-use, ie: they also use it to mine yellowcake uranium ore, or when your watch business takes off, they struggle to provide enough brine, and bring in specialists from Afghanistan, who streamline the process and who's Dari has a Tehran accent. They can let you keep making money until it's promotion time, or an example needs to be made for an election campaign or they find out your watches seem to be the chronometer of choice of the latest insurgency.

thriftwy 3y ago

Quite contrary I would say. An American megacorp will always know how much profit from the US sanctions it can do and get away with it. Sometimes a slap on the wrist can happen, but in general... You do want those campaign donations flowing, do you? Then there is no reason to rock the boat. Smaller companies from other countries may not be so lucky so they may actually refrain from such activities.

1123581321 3y ago

Thanks; this is helpful. Looking up what sanctions compliance/export control professionals proactively do yields a ton of additional information.