; and required each of the team members to sign a non-disclosure agreement covering the ZTE transactions and activities the team was tasked with hiding. . (5) The Department of Commerce further disclosed a 2011 internal ZTE document detailing its ongoing business in Iran, North Korea, Syria, Sudan, and Cuba, at the time all listed by the United States as state sponsors of terrorism and subject to embargoes. (6) ZTE plead guilty to the charges and the Department of Commerce fined ZTE $1.19 billion, the largest-ever combined civil and criminal penalty. (7) In announcing the plea and subsequent fine, Secretary of Commerce, Wilbur L. Ross, Jr., stated, Those who flout our economic sanctions and export control laws will not go unpunished—they will suffer the harshest of consequences. . (8) As part of ZTE’s plea agreement with the United States, ZTE would be subject to a seven-year suspended denial of export privileges, which could be quickly activated if any aspect of the deal was not met. (9) On April 16, 2018, the Department of Commerce announced it had imposed a denial of export privileges against ZTE due to its determination that ZTE made false statements to [the Bureau of Industry and Security of the Department of Commerce] in 2016, during settlement negotiations, and 2017, during the probationary period, related to senior employee disciplinary actions the company said it was taking or had already taken. . (10) In 2012, a report of the Permanent Select Committee on Intelligence of the House of Representatives entitled, Investigative Report on the United States National Security Issues Posed by Chinese Telecommunication Companies Huawei and ZTE , it was recommended that U.S. government systems, particularly sensitive systems, should not include Huawei or ZTE equipment, including in component parts. Similarly, government contractors—particularly those working on contracts for sensitive U.S. programs—should exclude ZTE or Huawei equipment in their systems. . (11) The Federal Bureau of Investigation, in a February