The escrow payment was made in addition to a $1 billion penalty imposed by Commerce, which Treasury collected last month.
Commerce and the Chinese government made an agreement in June to lift the denial order should Beijing complete penalty and escrow payments combining for $1.4 billion and replace ZTE senior managers and board members, among other things.
ZTE has replaced “the entire board of directors and senior leadership for both” ZTE Corporation and ZTE Kangxun Telecommunications Ltd., Commerce said in its Friday announcement.
ZTE also is required under the agreement to retain a team of special compliance coordinators selected by and answerable to Commerce’s Bureau of Industry and Security (BIS) for 10 years, Commerce noted.
ZTE sources about 60 percent of the materials and components for its smartphones from U.S. suppliers.
The agreement establishes a suspended export denial order to be in place for 10 years that BIS can activate in the event of additional violations.
The compliance team installed via the agreement “vastly improves the speed” with which Commerce can detect and deal with any violations, Commerce said.