[stefan_]

ZTE pretty much admitted the denial order is their end. From the denial order:

note that in its response to BIS 's notice of proposed activation of suspended sanctions and in making its case for leniency, ZTE acknowledged that it had submitted false statements, but argued that it would have been irrational for ZTE to knowingly or intentionally mislead the U.S. Government in light of the seriousness ofthe suspended sanctions. The heart ofits argument is the question, posed by the company in rhetorical fashion, asking " why would ZTEC risk paying another $300 million suspended fine and placement on the denied parties list, which would effectively destroy the Company, to avoid sending out employee letters of reprimand and deducting portions of employee bonuses?" ZTE argued that BIS should not act until the company completed an internal investigation so that ZTE could answer such questions.