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BIS Again Extends ZTE Temporary General License

By Alexandra Baj on February 23, 2017
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On February 24, 2017, the US Department of Commerce, Bureau of Industry and Security (BIS) is publishing in the Federal Register a notice again extending its temporary general license for exports, reexports, and in country transfers to Zhongxing Telecommunications Equipment (ZTE) Corporation (ZTE Corporation) and ZTE Kangxun.  BIS is extending the period of the license from its current expiration date of February 27, 2017 to March 29, 2017.  BIS established the license in a notice published on March 24, 2016 (81 Fed. Reg. 15,633) after adding the two ZTE entities to its Entity List on March 8, 2016 (81 Fed. Reg. 12,004), and has extended the temporary license several times since that time.  See our previous posts here, here, and here.  The temporary general license allows the use of the authority of No License Required (NLR) and license exceptions that were available for exports to the two entities prior to March 8th.  BIS has previously indicated that it will continue to renew the temporary general license if the US government determines that ZTE Corporation and ZTE Kangxun continue to cooperate with the US government in resolving the matter that resulted in their addition to the Entity List.  According to the March 8th notice, that issue involved a scheme developed by ZTE Corporation to reexport controlled items to Iran contrary to US law.

Photo of Alexandra Baj Alexandra Baj

Alex Baj’s practice primarily involves export controls and economic sanctions laws and regulations, anti-corruption investigations and compliance, international trade, and security clearance issues. Alex advises clients on export control and economic sanctions laws and regulations, including the Export Administration Regulations (EAR), International…

Alex Baj’s practice primarily involves export controls and economic sanctions laws and regulations, anti-corruption investigations and compliance, international trade, and security clearance issues. Alex advises clients on export control and economic sanctions laws and regulations, including the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), US sanctions regulations administered by the Office of Foreign Assets Control (OFAC), and nuclear export controls under the jurisdiction of the Nuclear Regulatory Commission (NRC).  Alex specializes in the development and implementation of export and anti-corruption compliance policies and procedures and training, internal investigations and voluntary disclosures under the EAR, the ITAR, and OFAC rules, due diligence for mergers and acquisitions, and on encryption and cybersecurity export controls.  Her clients include companies involved in defense, aerospace, software, semiconductor, and uranium processing industries.

Read Alex’s full bio.

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  • Posted in:
    Other
  • Blog:
    International Compliance Blog
  • Organization:
    Steptoe LLP

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