Those are not Compliance Officers at ZTE
In a commentary on FCPA Blog, Gerry Zack, the incoming CEO of the Society of Corporate Compliance and Ethics, says that the officials embedded at Chinese telecom ZTE are not compliance officers. As part of a deal to lift Department of Commerce sanctions that threatened to cripple the firm, ZTE agreed to retain a team of special compliance coordinators selected by and answerable to the department for ten years. These individuals are intended to monitor ZTE’s adheres to its agreement and avoids sanctions violations in the future, but Zack says they shouldn’t be confused with actual compliance officials.
“They are government enforcement monitors and they should be referred to as such,” Zack writes. “Compliance officers are employed by the corporation and are charged with ensuring that the organization and its employees operate lawfully and according to regulations…And I’d be willing to bet none of them have a role remotely similar to what the Commerce Department has in mind.”
