Documents Pertaining to the Addition of ZTE Corporation and Related Entities to the Entity List
BIS has added ZTE Corporation and three affiliated entities to the Entity List. The Entity List (Supplement No. 4 to Part 744) includes foreign entities that are subject to specific license requirements for the export, reexport, or transfer of items subject to the Export Administration Regulations (EAR).
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The principal bases for the addition of these entities were two ZTE corporate documents entitled “Report Regarding Comprehensive Reorganization and the Standardization of the Company Export Control Related Matters” and “Proposal for Import and Export Control Risk Avoidance.” These documents outline a ZTE-developed scheme to violate U.S. export control laws by establishing, controlling, and using a series of “detached” (e.g., shell or front) companies to illicitly reexport controlled items to sanctioned countries without authorization.
These documents, in original language and English translation, are:
1. “Report Regarding Comprehensive Reorganization and the Standardization of the Company Export Control Related Matters”
2. “Proposal for Import and Export Control Risk Avoidance”