I was going by this which states that "importing technology" is covered by sanctions.
If encryption can get classified as munitions export (which, pre 1992 it was) I could imagine a PR from NK can fairly easily be classified as "importing technology".
IANAL but if I was taking a risk averse approach like this Iranian dude then I'd err on the side of caution and not merge.
I certainly wouldn't want to try and establish case law that a PR is not importing technology, either, even if, say, the lack of a financial transaction meant it technically didn't count. It's playing with fire.
I was going by this which states that "importing technology" is covered by sanctions.
If encryption can get classified as munitions export (which, pre 1992 it was) I could imagine a PR from NK can fairly easily be classified as "importing technology".
IANAL but if I was taking a risk averse approach like this Iranian dude then I'd err on the side of caution and not merge.
I certainly wouldn't want to try and establish case law that a PR is not importing technology, either, even if, say, the lack of a financial transaction meant it technically didn't count. It's playing with fire.