ZTE’s guilty plea for criminal conduct follows a five-year investigation which found that it conspired to violate the International Emergency Economic Powers Act by shipping US-origin items to Iran and North Korea, both countries of which are subject to sanctions regimes.
Commenting to CDR, Josh Wong, who was recently appointed to the partnership of London boutique Signature Litigation from DLA Piper, and who regularly advises Chinese parties, says that the agreement by ZTE to pay the fine comes after the appointment of new management, particularly that of new chairman and chief executive Zhao Xianming last April, which has taken a new approach to settling the criminal and civil charges in the US and also towards monitoring compliance issues globally.
“ZTE, like many of the Chinese corporates I advise, are putting in place more rigorous compliance systems,” he says, “this marks a desire to adopt a positive and less reactive stance on compliance and a willingness to take responsibility for issues in the past”.