Joint locks in judo must nominally be on the elbow joint only. Ude garami, translated as the entangled arm lock and with variants are known as the Kimura or Americana in BJJ, often affects the shoulder joint. This also seems to depend upon the flexibility of the person on the receiving end. Ude garami is a legal technique even if it affects only the shoulder because referees cannot tell which joint is being affected.
Is there a way to perform ude garami against a bent arm such that it reliably affects only the elbow joint and not the shoulder?