If you have any questions about this warning, or if we can help you manage the impact of this agreement on current or ongoing engagements with ZTE or DOC, please contact your attorney Akin Gump or: ZTE, whose survival is threatened by the ban, got the Trump administration`s lifeline on Thursday. The new agreement, outlined by Minister Ross and officially finalized by the BIS and ZTE on June 7, 2018 (and published on June 11, 2018), confirms that the BIS will impose its largest fine to date on a non-U.S. treaty. and will impose unprecedented compliance requirements. Under the new agreement, ZTE will have to pay additional fines of $1 billion and separately place $400 million in an escrow account before the BIS removes zTE from its list of rejected persons and the rejection order dated the 15th. April. These penalties are separate and are in addition to the $892 million in ZTE paid under the March 2017 settlement, bringing the already record fines to a new record $2.29 billion. ZTE paid the $1,000,000,000,000 in full and on time and met the esc escling requirements with respect to the suspended portion of the $400,000,000 civil penalty. Therefore, BIS hereby terminates the order of 15 April 2018 and BIS will remove ZTE from the list of rejected persons. On March 23, 2017, ZTE entered into a settlement agreement with the U.S. government to resolve civil and criminal allegations that ZTE violated U.S. sanctions and export control laws by illegally shipping products originating in the U.S. to Iran and North Korea.
Under the agreement, ZTE agreed to pay a combined fine of up to $1.19 billion and pledged not to commit any further violations, subject to the sanction of revoking its export privileges for a period of seven years.  The Settlement Agreement also subjects ZTE to mandatory periodic reports. In accordance with this requirement, on February 2, 2018, the U.S. government requested a progress report on individuals whose ZTE had previously stated to have been disciplined as part of the Company`s efforts to respond to violations that led to the settlement agreement. ZTE`s progress report showed that the company provided false information about its disciplinary actions and only committed to correcting its previous misrepresentations after receiving the request for information dated February 2, 2018. As a result, the BIS activated the seven-year rejection order and placed ZTE on the list of rejected persons. This decision effectively cut ZTE off from the United States. Components and software and has had a far-reaching global impact on network operators and consumers with ZTE mobile phones. In June 2018, following talks between President Trump and the Chinese government, the BIS announced a replacement agreement (previously described here) that provided for the revocation of the rejection order against ZTE in exchange for additional fines and increased compliance measures. .