Civil Enforcement Information - Zhongxing Telecommunications Equipment Corporation

Date issued: Mar. 07 2017

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TURBOFAC Commentary (519 words)

Notes:

1) Largest non-bank fine ever levied by OFAC (2006-12/2020).

2) The jurisdictional bases for the fine are relatively straightforward in light of facts, but note that, as of the date of the announcement of the enforcement action, this is the first time since OFAC began providing details concerning its enforcement actions (in 2006) that 560.205 (reexportation by a non-U.S. person) was explicitly cited as a ground for jurisdiction. See General Note on the Distinction between ITSR Sections 560.204 and 560.205, and "Causing" Violations of 560.204 from Abroad (System Ed. Note), and also Civil Enforcement Information - Keysight Technologies, Inc., for an enforcement action (2020) based solely on 560.205.

The most likely reason for the rare citation of 560.205 (in the context...