RecordLens

Claim review. Sanctions

Contradicted

A reliable and applicable record states the opposite.

ZTE told the US government it had disciplined the employees responsible for its earlier export violations.

About
ZTE Corporation
Claim made by
US Department of Commerce, regulator statement
Published
13 July 2018
Original
Commerce Department Lifts Ban After ZTE Deposits Final Tranche of $1.4 Billion Penalty
Evidence score
86 How it was scored
Last reviewed
25 October 2026

Why this label

The Commerce Department says that on 15 April 2018 it activated the suspended denial order in response to ZTE falsely informing the government about the discipline of employeesS2. The April 2018 order says ZTE now admits the reprimand letters were not issued until about a month after a February 2018 BIS requestS7. ZTE then accepted a new settlement with a US$1 billion penalty, US$400 million in escrow and a new 10-year suspended denial orderS2S8. In 2017 the Justice Department had said ZTE repeatedly lied to and misled federal investigatorsS1. The company's representation about discipline is contradicted by the regulator's order and by ZTE's own admission recited in it.

Current procedural position

Denial order activated by the Bureau of Industry and Security on 15 April 2018S2. It was terminated by an order of July 2018 published on 23 July 2018, under an 8 June 2018 superseding settlementS8. A new denial order is suspended for 10 yearsS2S8.

Record supporting the assessment

activated the suspended denial order against ZTE in response to ZTE falsely informing the U.S. Government
S2 Tier A US Department of Commerce, Commerce Department Lifts Ban After ZTE Deposits Final Tranche of $1.4 Billion Penalty, 13 July 2018
were never issued until approximately a month after
S7 Tier A US Department of Commerce, Bureau of Industry and Security, Order Activating Suspended Denial Order Relating to Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd., April 2018
Shortly after the deposit, the Department lifted the denial order on ZTE pursuant to a June settlement agreement.
S2 Tier A US Department of Commerce, Commerce Department Lifts Ban After ZTE Deposits Final Tranche of $1.4 Billion Penalty, 13 July 2018
ZTE then repeatedly lied to and misled federal investigators, its own attorneys and internal investigators
S1 Tier A US Department of Justice, ZTE Corporation Agrees to Plead Guilty and Pay Over $430.4 Million for Violating U.S. Sanctions by Sending U.S.-Origin Items to Iran, 7 March 2017
BIS is hereby terminating the April 15, 2018 Order
S8 Tier A Federal Register, US Department of Commerce, Bureau of Industry and Security, Order Terminating Denial Order Issued on April 15, 2018, Against Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd., 23 July 2018

Conflicting or limiting record

No record located that conflicts with this assessment.

Evidence score: 86 of 100

The score grades how well the record establishes this assessment. It is not a score of ZTE Corporation. Score = source authority + directness + corroboration + procedural accuracy + currency + reproducibility.

ComponentPointsMaxReason
Source authorityIs the source competent to establish the proposition?2730The Commerce Department is the agency that issued and lifted the denial order.
DirectnessDoes the source state the proposition or only discuss adjacent facts?1720The release states that ZTE falsely informed the government.
CorroborationDo independent records support the same material point?1315The April 2018 order, the termination order and the DOJ release agree.
Procedural accuracyDoes the record settle the procedural state the claim describes?1215The finding led to an agreed settlement, which ZTE accepted.
CurrencyHas the record been checked against later developments?810Reuters reported in December 2025 that Commerce is reviewing compliance with the 2018 agreement.
ReproducibilityCan a reader locate the passage and repeat the assessment?910The release is on the archived Commerce site.
Total86100

Timeline

  1. Plea agreement and penalties announcedS1
  2. Commerce activates the suspended denial order over false statements about disciplineS2S7
  3. Commerce lifts the denial order after the US$400 million escrow depositS2
  4. Termination of the 15 April 2018 order published in the Federal RegisterS8

Related cases

  • Bureau of Industry and Security v. ZTE CorporationUS Department of Commerce, Bureau of Industry and Security. Regulatory. Not published. The July 2018 termination order is Federal Register document 2018-15633.Stage: June 2018 settlement in force with a denial order suspended for 10 years.
    • Denial order lifted after the US$400 million escrow depositS2
    • Termination order publishedS8

Revision history

  • Assessment first published with label Contradicted.

Have a record that changes this assessment? See corrections and responses.

Sources

  1. S2Tier A Commerce Department Lifts Ban After ZTE Deposits Final Tranche of $1.4 Billion PenaltyUS Department of Commerce. Regulator press release. 13 July 2018.Supports the 15 April 2018 activation, its reason, the US$1 billion penalty, the US$400 million escrow and the 10-year suspended order.
  2. S7Tier A Order Activating Suspended Denial Order Relating to Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd.US Department of Commerce, Bureau of Industry and Security. Regulator order. April 2018.Recites the 2017 settlement, including ZTE's admission of North Korea shipments, and the false statements on discipline. The day of issue is illegible in the copy read and is taken from S2 and S8.
  3. S1Tier A ZTE Corporation Agrees to Plead Guilty and Pay Over $430.4 Million for Violating U.S. Sanctions by Sending U.S.-Origin Items to IranUS Department of Justice. Regulator press release. 7 March 2017.Supports the plea, the three counts, the Iran conduct and the combined US$1.19 billion penalty. It does not mention North Korea or give a docket number.Link working, checked 25 October 2026
  4. S8Tier A Order Terminating Denial Order Issued on April 15, 2018, Against Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd.Federal Register, US Department of Commerce, Bureau of Industry and Security. Regulator order. 23 July 2018.Confirms the 15 April 2018 order, the 8 June 2018 superseding order, the payments and the 10-year suspended denial. It does not mention North Korea.Link working, checked 25 October 2026

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