and used the methods discussed in paragraph (6) to mask its transaction history in an effort to undermine investigations of the Department of Commerce. (9) Since 2008, ZTE Corporation has been the defendant, counterclaimant, or respondent in 722 court actions. (10) On March 23, 2017, the Department of Justice stated that ZTE Corporation has agreed to enter a guilty plea and to pay a $430,488,798 penalty to the United States for conspiring to violate the International Emergency Economic Powers Act by illegally shipping U.S.-origin items to Iran, obstructing justice and making a material false statement. . (11) ZTE Corporation has also previously reached settlement agreements with the Bureau of Industry and Security of the Department of Commerce and the Office of Foreign Assets Control of the Department of the Treasury. (12) The Bureau of Industry and Security subsequently found ZTE Corporation in violation of the settlement agreement with the Bureau due to— (A) falsification of reports and correspondence with the Bureau