ZTE Corporation has agreed to enter a guilty plea and to pay a combined penalty of $1.19 billion to U.S. regulators and agencies for conspiring to violate the International Emergency Economic Powers Act (IEEPA) sanctions on Iran by illegally shipping US-origin items to Iran, obstructing justice and making a material false statement.
According to the investigation, ZTE obtained US-origin items – including controlled dual-use goods on the Department of Commerce’s Commerce Control List (CCL) – incorporated some of those items into ZTE equipment and shipped the ZTE equipment and US-origin items to customers in Iran. ZTE engaged in this conduct knowing that such shipments to Iran were illegal.
ZTE not only violated sanctions regulations, but also made false statements to federal investigators, their own counsel and internal investigators about their dealings. ZTE’s plea agreement, alleges that the company’s senior management was aware of and approved the illegal exports scheme.