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by lucasgw 4192 days ago
No idea about NK. But re: #2 - I believe that sort of trade is regularly transacted with Iran through resellers in UAE/Dubai. US companies with overseas subsidiaries. They are legally separate companies. The goods are manufactured in Asia and never touch US soil. The employees are citizens of a country without restricted trade. The end result is the same - what are essentially US-backed goods make their way to a country with enforced economic sanctions, but without violating US law or OFAC regulations.
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I can't find it right now, but I've read that U.S. companies cannot do business with other companies that are within 2 degrees of separation from a state sponsor of terror under some crazy penalties. In other words, if I make a widget, sell it to somebody in Dubai who sells it to the North Koreans, I can be held responsible unless I break off business ties with my Dubai customer. So they'd likely need to be going through 2 or 3 middlemen for a reliable source. It's hard to enforce though, once your good go through Dubai and Beijing or wherever the U.S. ability to track a chain of ownership becomes impossible.
Exactly. Even if your product was bought on US soil, sold on eBay to someone outside of the U.S., and then sold to the 4th party via the black market or 2nd hand market again, now it's legal that a NK spy picks it up. That's the same effect as saying "I picked up this US Dell computer from a recycle shipment from US to China last week." Yeah a lot of electronics are "re-used" that way oversea.

The U.S. government is aware of this but for as long as their US companies are never directly selling to NK the sanction is enforced from the US's perspective. This including banks cannot do transaction (via multiple middlemen? yes sure! Money laundering, but the FBI will be looking at it).