“In sum, through those two letters, ZTEinformed the U.S。 Government that the company had taken or would take actionagainst 39 employees and officials that ZTE identified as having a role in theviolations that led to the criminal plea agreement“”
“In fact, and as ZTE now admits, theletters of reprimand described in the November 30, 2016 Jetter were neverissued until approximately a month after BlS‘s February 2, 20 18 request forinformation, and all but one of the pertinent individuals identified in theNovember 30, 2016 or July 20, 2017 letters received his or her 2016 bonus。