Settlement Agreement between the OFAC and Zhongxing Telecommunications Equipment Corporation


March 7 2017

This settlement agreement (the “Agreement”) is made by and between Zhongxing Telecommunications Equipment Corporation and its subsidiaries and affiliates, as well as ZTE Kangxun Telecommunications Ltd. and its subsidiaries and affiliates (collectively referred to hereafter as “ZTE” or “Respondent”), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).

OFAC has determined that the Respondent did not make a voluntary self disclosure of the apparent violations to OFAC, and that the apparent violations constitute an egregious case. Accordingly, the base civil monetary penalty for the apparent violations equals the sum of the maximum statutory civil monetary penalty amount for each apparent violation, which in this case is $106,180,280.