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ZTE Pleads Guilty and Agrees to Combined U.S. $1.19 Billion Penalty for Iran and North Korea Transactions

By Jeffrey I. Snyder, Cari Stinebower & Dj Wolff on March 9, 2017
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On March 7, Zhongxing Telecommunications Equipment Corporation and its subsidiaries and affiliates, as well as ZTE Kangxun Telecommunications Ltd. and its subsidiaries and affiliates (collectively referred to as ZTE or ZTE Corporation) entered into a guilty plea with the U.S. Department of Justice and “agreed to pay a $430,488,798 penalty to the U.S. for conspiring to violate the International Emergency Economic Powers Act (IEEPA) by illegally shipping U.S.-origin items to Iran, obstructing justice and making a material false statement.”

Simultaneously, ZTE also entered into settlement agreements with the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) for $100,871,266 related to the same conduct, as well as the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) for $661 million for illegal exports of U.S.-origin product to Iran and North Korea.

In total, ZTE’s settlement reached $1.19 billion; BIS has agreed to suspend payment of $300,000,000, which ZTE will be required to pay if it violates the BIS settlement agreement.

For more information, contact: Jeff Snyder, Carlton Greene, Cari Stinebower, Dj Wolff

Photo of Dj Wolff Dj Wolff

David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with Crowell Global Advisors, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice

…

David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with Crowell Global Advisors, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice focuses on all aspects of compliance with U.S. economic sanctions, including day-to-day compliance guidance, developing compliance programs, responding to government inquiries, conducting internal investigations, and representation during civil and criminal enforcement proceedings. Dj works regularly with non-U.S. clients, both in Europe and Asia, to evaluate the jurisdictional reach of U.S. sanction authorities to their global operations, identify and manage the potential conflict of laws that can result from that reach, as well as to support client’s design, implementation, and evaluation of a corresponding risk-based sanctions compliance program. Dj also regularly leads teams in diligence efforts on trade and related regulatory areas on behalf of his U.S. and non-U.S. clients in the M&A arena, having successfully closed more than 30 deals with an aggregate valuation of several billion dollars over the last 18 months.

Dj is ranked by Chambers USA in International Trade: Export Controls & Economic Sanctions. He has previously been recognized by Law360 as a Rising Star in International Trade (2020), by The National Law Journal as a “DC Rising Star” (2019), by Who’s Who Legal: Investigations as a “Future Leader” (2018 and 2019), Acritas Star as an Acritas Stars Independently Rated Lawyers (2019), by Global Investigations Review as one of the “40 under 40” in Investigations internationally (2017), and WorldECR as one of the five finalists for the WorldECR Young Practitioner of the Year award (2016).

Read more about Dj WolffEmail
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  • Posted in:
    Business and Commercial
  • Blog:
    International Trade Law
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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