老美的接口不是39人的问题,是中兴没有真实执行承诺的行动。
In sum, through those two letters, ZTE infom1ed the U.S. Government that the company had taken or would take action against 39 employees and officials that ZTE identified as having a role in the violations that led to the criminal plea agreement and the settlement agreements with BIS and the U.S. Department of the Treasury's Office of Foreign Assets Control. In fact, and as ZTE now admits, the letters ofreprimand described in the November 30, 2016 Jetter were never issued until approximately a month after Bl S's February 2, 20 18 request for information, and all but one ofthe pertinent individuals identified in the November 30, 2016 or July 20, 2017 letters received his or
ZTE Corporation and ZTE Kangxun Order Activating Denial Order
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her 2016 bonus.2 These false statements were not corrected by ZTE even in part until March 2018, more than 15 months from ZTE's November 30, 2016 letter, approximately a year from the Setllement Agreement (which ZTE executed on March 2, 2017) and the March 23, 20 l 7 Order, and nearly eight months from the July 20, 2017 letter. During a conference call on March 6, 2018, ZTE indicated, via outside counsel, that it had made false statements in the November 30, 2016 and the July 20, 2017 letters. As discussed below, ZTE. s first detailed notification occurred on March 16, 2018.