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If this is true, then it seems modern sanction enforcement needs a completely different approach.
I don’t know if it’s possible at all to make them that leak-proof in a neoliberal, free-trade world. Painful, sure. But leak-proof, I doubt it. TSMC has profit incentives to make Huawei chips. They’re gonna try to skirt it any way they can. Perhaps you’d have to impose much more significant penalties such as jail for individuals. In the case of TSMC, its profitability is aligned with the interests of the country. The silicon shield only works so long as TSMC is doing well and innovating faster than China.
You could definitely make things more efficient. E.g. have a complete ban on economic transactions with shell companies.