equipment to North Korea in violation of the Export Administration Regulations (15
C.F.R. Parts 730-774 (2017)) ("EAR" or the "Regulations" ). ZTE also admitted to
engaging in an elaborate scheme to hide the unlicensed transactions from the U.S.
Government, by deleting, destroying, removing, or sanitizing materials and information.
Under the terms of the Settlement Agreement and the March 23, 2017 Order, BlS
imposed against ZTE a civil penalty totaling $661,000,000, with $300,000,000 of that
amount suspended for a probationary period of seven years from the date of the Order.
1
This suspension was subject to several probationary conditions stated in the Sett lement
Agreement and March 23, 20 l 7 Order, including that ZTE commit no other violation of
the Export Administration Act of 1979, as amended (50 U.S.C. §§ 4601-4623 (Supp. Ill
2015)), the Regulations, or the March 23 2017 Order. The March 23, 20 I 7 Order also
imposed, as agreed to by ZTE, a seven-year denial of ZTE's export p ri vileges under the
EAR that was suspended subject to the same probationary conditions.