The Department of Commerce’s Bureau of Industry and Security’s July 23, 2018 Federal Register notice confirmed ZTE’s removal from the Denied Person’s List.
ZTE made full and timely payment of the assessed $1,000,000,000 penalty (see previous blog post of July 6, 2018). Moreover, ZTE complied with the escrow requirements respecting the $400,000,000 suspended portion of the civil penalty. Therefore, BIS terminated the April 15, 2018 Order and removed ZTE from the Denied Persons List.
It will remain to be seen whether ZTE can stay the course of compliance or whether it might yet have another failure. The stakes are likely high enough now, with painful lessons learned, to hope for continued compliance. This is particularly so now with the appointed U.S. compliance team in place.