1) CLIENT ALERT
March 23, 2016
U.S. Commerce Department Expected to
Temporarily Lift Sanctions on Chinese Global
Telecommunications Manufacturer ZTE
Corporation
SPEED READ
The U.S. Department of Commerce is expected to issue a temporary general license to lift sanctions on Chinese
telecommunications equipment manufacturer ZTE Corporation just two weeks after the U.S. Commerce Department placed ZTE
on the Entity List. The temporary general license will be effective from March 24, 2016 until June 30, 2016.
On March 8, 2016, the U.S. Department of Commerce placed Zhongxing Telecommunications Equipment (ZTE) Corporation, ZTE Kangxun
Telecommunications Ltd. (ZTE Kangxun), and affiliates Beijing 8­Star International Co. and ZTE Parsian on the Entity List. This designation
made it unlawful to export, reexport, or transfer U.S.­origin items to ZTE and these affiliates without an export license.
On Thursday, March 24, the Commerce Department is expected to add a general license that temporarily suspends the effect of the Entity
List designation as it applies to ZTE and ZTE Kangxun (but the relief does not apply to ZTE’s affiliates Beijing 8­Star International Co. and
ZTE Parsian). The temporary general license is expected to be effective from March 24, 2016 until June 30, 2016, and will be renewed “if the
U.S. Government determines, in its sole discretion, that ZTE Corporation and ZTE Kangxun are timely performing their undertakings to the
U.S. Government and otherwise cooperating with the U.S. Government in resolving this matter.” A draft of the general license is available
here.
* * * * *
This alert does not constitute legal advice and anyone seeking to do business with ZTE, its affiliated companies, or any other individual or
business on the Entity List should consult legal counsel before doing so.
If you would like additional information about the issues addressed in this Client Alert, please contact Rich Matheny, who chairs Goodwin
Procter’s National Security & Foreign Trade Regulation Practice, or the Goodwin Procter attorney with whom you typically consult.
Authors: Richard L. Matheny III, Jacob R. Osborn
GET IN TOUCH
For more information about the contents of this alert,
please contact:
Richard Matheny III
Partner
+1 202 346 4130
rmatheny@goodwinprocter.com
Jacob Osborn
Associate
+1 202 346 4133
josborn@goodwinprocter.com
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