The reference case for export control evasion by a large manufacturer, and the one that established the modern enforcement posture toward Chinese technology companies.
OFAC’s enforcement information for 7 March 2017 records that ZTE and its affiliates settled potential civil liability for 251 apparent violations of the Iranian Transactions and Sanctions Regulations for $100,871,266, concurrently with a settlement with the Department of Commerce’s Bureau of Industry and Security and a plea agreement with the Department of Justice’s National Security Division and the US Attorney’s Office for the Northern District of Texas.
The conduct ran from about January 2010 to about March 2016 and involved the export, sale or supply, directly or indirectly, of goods from the United States to Iran.
Why it appears on four technique pages
The case is a compendium. It involves controlled US-origin items reaching a restricted destination through intermediaries; corporate entities interposed to hold the contracts; representations about destination that were not true; and a documented internal awareness of the control regime the conduct was designed to work around.
The enforcement architecture
The three concurrent resolutions are the point. OFAC addressed the sanctions violations, BIS addressed the export control violations, and DOJ addressed the criminal conduct, and no one of them would have captured the whole. Export control cases of any size now routinely take this tripartite form, which is worth knowing when reading a penalty figure: the OFAC number is frequently a fraction of the total.