On March 7, 2017, Attorney General Jeff Sessions announced that ZTE Corporation agreed to plead guilty for conspiring to violate the International Emergency Economic Powers Act (“IEEPA”), obstructing justice and making a material false statement.  ZTE’s agreement to plead guilty is the DOJ component of a series of settlements that ZTE reached with U.S. agencies, which totals to an agreement to pay the U.S. Government $892,360,064.  On the criminal side, ZTE will enter a guilty plea, pay a $430,488,798 penalty ($143,496,266 of which is criminal forfeiture), obtain a corporate monitor and submit to a period of corporation probation for three years.  This is the largest criminal fine in connection with an IEEPA prosecution.  According to court documents, ZTE shipped U.S.-origin items to customers in Iran, knowing that this conduct was illegal.  ZTE used “isolation companies” to obscure its involvement with the purchasing and shipments of the U.S.-origin items.  Additionally, court documents state that ZTE had its employees sign nondisclosure agreements that required employees to keep confidential information related to the company’s U.S. exports to Iran.  ZTE also continued to make these illegal sales after defense counsel began conducting an internal investigation into the company’s conduct.  ZTE hid data related to its continuing conduct from a forensic accounting firm investigating the conduct and kept outside counsel that was representing ZTE in its discussions with federal law enforcement agents unaware that it had resumed the illegal sales.  United States v. ZTE Corporation, 17-cr-00120 (N.D. Tex.). DOJ Press Release