Share this on Twitter Share this on Facebook Share this on LinkedIn Share this on Sina Weibo Share this on Wechat Share this on LinkedIn Illustration by Sam Ward As the summer of 2011 wound down in the city of Shenzhen, high-ranking executives at the ZTE Corporation, China’s second largest telecommunications equipment company, found themselves strategizing about their American nuisance. In a series of memos marked “top secret,” they discussed various ways the company might evade American sanctions — the U.S. laws that explicitly bar companies from selling goods containing U.S.-made components to Iran, Sudan, North Korea, Syria and Cuba. “As our overseas businesses have grown rapidly in recent years, so have U.S. export control risks,” the general counsel, Guo Xiaoming, wrote in an August 25 memo to ZTE’s chief executive, Shi Lirong. “Currently our company has ongoing projects in all five embargoed countries — Iran, Sudan, North Korea, Syria and Cuba." An internal ZTE report highlights the company’s plan to evade U.S. procurement bans. Credit: Department of Commerce's Bureau of Industry and Security At the Subscribe or register to read the rest. Registered users can access a limited amount of content for free.Subscribers get full access to: Exclusive longform investigative journalism, Q&As, news and analysis, and data on Chinese business elites and corporations. We publish China scoops you won't find anywhere else. A weekly curated reading list on China from David Barboza, Pulitzer Prize-winning former Shanghai correspondent for The New York Times. A daily roundup of China finance, business and economics headlines. We offer discounts for groups, institutions and students. Go to our Subscriptions page for details.