The Man From FCPA is continually reminded that much of the basis of compliance is grounded in wisdom imparted by our parents. Today, we are reminded of one of the most basic ones: Do not lie.
That lesson apparently did not reach Chinese state-owned telecom company ZTE, which engaged in one of the most basic violations of protocols when it apparently lied to the Justice Department about actions it had agreed to take when it secured its Deferred Prosecution Agreement for export control violations.
