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During the course of the settlement and the probationary period which followed, ZTE sent letters assuring the government that ZTE had taken or would take action against 39 employees and officials that ZTE identified as having a role in the violations. In early 2018, BIS requested information and documentation showing proof of the employee discipline promised in those letters. Through further investigation and communications with ZTE, the Department of Commerce determined that ZTE’s letters contained false statements made to cover up the fact that ZTE paid full bonuses to employees that had engaged in illegal conduct, and failed to issue letters of reprimand to said employees.

 

ZTE made false statements to the U.S. Government when they were originally caught and put on the Entity List, made false statements during the reprieve it was given, and made false statements again during its probation.

ZTE misled the Department of Commerce.  Instead of reprimanding ZTE staff and senior management, ZTE rewarded them.  This egregious behavior cannot be ignored,