Background

The Department of Commerce announced Aug. 24 the selection of former U.S. Attorney Roscoe C. Howard, Jr., to be the special export compliance coordinator for Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd. (collectively, ZTE). Howard will be tasked with coordinating, monitoring, assessing, and reporting on compliance with U.S. export control laws by ZTE and its subsidiaries and affiliates worldwide.

This appointment was one of several actions taken under an agreement to lift a ban on exports to ZTE that was imposed after the company lied about the steps it took to discipline employees involved in hundreds of U.S. sanctions violations involving shipments to Iran and North Korea. Others include a $1.761 billion penalty, a ten-year conditionally-suspended denial of export privileges, and a requirement that ZTE replace the entire board of directors and senior leadership of the company. The DOC has called these measures “the harshest penalties and strictest compliance measures ever imposed in such a case.”

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