ZTE Corporation · United States
ZTE 2017 U.S. sanctions and export-control settlement: third-party channels are not safe harbors
ZTE reached major settlements with DOJ, BIS, and OFAC over shipments of U.S.-origin items to restricted destinations using third-party arrangements.
Facts
The DOJ stated that ZTE agreed to plead guilty and pay criminal fines and forfeiture; the combined U.S. government penalty and suspended amount reached about USD 1.19 billion.
Compliance lessons
Export-control compliance must cover group sales, agents, repairs, spare parts, end users, and payment routes, with complete and accurate investigation records.
Legal issues
- 伊朗制裁 / Iran sanctions
- 美国原产物项 / U.S.-origin items
- 第三方规避 / third-party evasion
Sources
- U.S. DOJ, ZTE guilty plea and penaltiesprosecutor
- OFAC, ZTE settlementregulator