The U.S. Department of Commerce lifted the denial order on Zhongxing Telecommunications Equipment Corporation (ZTE Corporation) and ZTE Kangxun Telecommunications Ltd. (ZTE Kangxun) (collectively "ZTE"). The order was suspended on Friday, July 13, 2018, after ZTE paid a $1.4 billion penalty (including $1 billion to the Department of Commerce and an additional $400 million placed into an escrow account). This payment was in addition to the $892 million in penalties ZTE already paid under the March 2017 settlement agreement. As a result, ZTE can again receive and participate in transactions involving commercial items exported from the U.S. This denial order will be suspended for the next 10 years. As part of its settlement with the Department of Commerce, ZTE also is required to retain a compliance team selected by the Commerce Department's Bureau of Industry and Security (BIS). Any future violations could again lead to reenactment of the denial order.

If you would like to discuss this matter or have any questions about export compliance, please contact Josephine Aiello LeBeau, 202-973-8813, jalebeau@wsgr.com or Anne Seymour, 202-973-8874, aseymour@wsgr.com.