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ENF 22663
Zhang Ping-an [JUN 27 2012]
Chief Operating Officer
Chengdu Huawei Symantec Technologies Co. Ltd.
West Zone Science Park of UESTC
No. 88 Tianchen Road
611731, Chengdu, PRC
Dear Mr. Ping-an:
Thank you for your letters dated December 14, 2009, February 26, 2010, April 20, 2010, May 17, 2010, and March 17, 2011, to the Office of Foreign Assets Control ("OFAC"), regarding Chengdu Huawei Symantec Technologies Co. Ltd.'s potentially prohibited activities pursuant to the Iranian Transactions Regulations, 31 C.F.R. part 560, and the Sudanese Sanctions Regulations, 31 C.F.R. part 538.
This letter is notice that we are closing this file without taking any further action. A no-action determination represents a final determination regarding the investigation, unless OFAC later learns of other relevant facts.
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1) This is one of two No Action Letter samples in the Research System (see also ENF 51470 (Sample No Action Letter). In OFAC Descriptions of 17 Huawei-related VSDs and Dispositions, OFAC describes its decision to close this case with a No Action Letter as follows: "Chengdu Huawei Symantec Technologies Co. Ltd. (“Huawei Symantec”) submitted disclosures to OFAC and BIS which indicated that some of Huawei Symantec’s products may have ultimately been shipped by third party resellers to Iran or Sudan. Huawei Symantec is not a U.S. person and there is no indication that a U.S. person exercised control or authority over any of the third party resellers involved in the de-minimis sales in Sudan or Iran. Therefore, OFAC Enforcement issued Huawei Symantec a No Action Letter."
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