resumed business with Iran. After ZTE informed its counsel of the scheme, counsel reported – with permission from ZTE – the conduct to the US government. Uncovered in the investigation were two ZTE corporate documents entitled “Report Regarding Comprehensive Reorganization and the Standardization of the Company Export Control Related Matters” and “Proposal for Import and Export Control Risk Avoidance.” These documents outline a ZTE-developed scheme to violate U.S. export control laws by establishing, controlling, and using a series of “detached” (e.g., shell or front) companies to illicitly reexport controlled items to sanctioned countries without authorization. ZTE agreed to enter a guilty plea and to pay a $430,488,798 penalty to the U.S., and simultaneously reached settlement agreements with BIS and the US Department of the Treasury's Office of Foreign Assets Control. In total ZTE agreed to pay the US Government $892,360,064. BIS originally suspended an additional $300,000,000, which would be reinstated if ZTE were to violate its settlement agreement. On April 15, 2018, BIS activated the suspended denial order against ZTE in response to ZTE falsely informing the US Government that it would or had disciplined numerous employees responsible for the violations, when in fact ZTE had rewarded that illegal activity with bonuses. Under this agreement, ZTE paid $1 billion and placed an additional $400 million in suspended penalty money in escrow before BIS removed ZTE from the Denied Persons List. These penalties are in addition to the $892 million in penalties under the March 2017 settlement agreement. See also Export Administration Regulations International Traffic in Arms Regulations United States sanctions References External links https://www.congress.gov/bill/114th-congress/house-bill/2578 Further reading Seyoum, Belay. "Export Controls and International Business: A Study with Special Emphasis on Dual-Use Export Controls and Their Impact on Firms in the US." Journal of Economic Issues 51.1 (2017): 45-72. United States Department of Commerce agencies Federal law enforcement agencies of the United States United States trade policy Counterterrorism in the United States Weapons trade United States trade law Export and import control National security institutions Civil defense organizations based in the United States