"[C]urrently our company has on‐going projects in all five major embargoed countries..." "in connection with its Iran transactions, including using “Qatar” as code for “Iran” in documents"
Anatomy of an Investigation, ZTE (PDF) https://www.bis.doc.gov/index.php/forms-documents/update-2017/2156-zte-the-investigation-settlement-and-lessons-learned-recap/file …
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