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lmm an hour ago

> Incorporating a subsidiary in a foreign country doesn't make the parent company immune to the legal obligations it has in it's home country.

We're not talking about legal obligations in its home country though. I can buy Jack Daniels at age 19 in my country from their local subsidiary, and no-one thinks that this should be a crime for their US parent company because the US drinking age is higher. (Of course it would be a crime for either the parent or the subsidiary to sell to 19 year olds in the US)

(No-one is blaming Dell or Let's Encrypt here, to be clear, it's the US' excessive extraterritorial laws that are the problem)

kube-system an hour ago | parent [-]

If you are in the US you must ensure that your local company, and any sub-entity you control abroad complies with sanctions law. That is US law, and the US can apply that law to Dell the parent company, because it is in the US and controls the subsidary.

> I can buy Jack Daniels at age 19 in my country from their local subsidiary, and no-one thinks that this should be a crime for their US parent company because the US drinking age is higher.

Because there is no US law that says you cannot sell alcohol to people abroad under 19. Heck, there's no US federal law that says Jack Daniels can't sell to people in the US under 19, either. And in fact, there are some places in the US where you can legally drink at 18, e.g. Puerto Rico. But if the US congress wanted to pass one of these laws and enforce it, it could.

lmm an hour ago | parent [-]

US sanctions law saying that you must not transfer X from the US to Iran, directly or indirectly, is reasonable. US sanctions law saying that you must not transfer X from Brazil to Iran is gross overreach. Yes, of course the US can apply its absurdly extraterritorial laws to any parent company in the US, just as Iran could penalise any Iranian company whose US subsidiary distributed a depiction of the prophet or whatever, but that doesn't make it good law or good practice.

kube-system an hour ago | parent [-]

That's a fair opinion to have.

But the US isn't really unique in applying their laws extraterritorially. See GDPR, Universal jurisdiction laws, China's National Security Law, etc... Every jurisdiction with sizable power does it. Some of these are even more extraterritorial in scope than US sanctions are.