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