PPT教學
https://www.bis.doc.gov/index.php/forms-documents/update-2017/2156-zte-the-investigation-settlement-and-lessons-learned-recap/file

節錄
"When our company launches business in the countries of the "Z" Group, [we will]
avoid using the names of our company to directly sign contract(s) with client(s)
from the countries of the "Z" Group, our company needs to avoid directly
exporting products and providing services to these clients...Such operating method
is called "Detached [Business] Model ("Proposal for Import…, page 4).“

白手套模式
"Under the [Completely Detached Business Model]…7S will purchase parts from
the U.S. through Kangxun or on its own, and then, resell [the parts] to 8S; 8S will
export all the project equipment from China to Dubai and deliver to 10S, and 10S
will then reexport the equipment from Dubai to YL and deliver to the YL Client. 9S
can purchase parts from the US outside of China and export the parts to Dubai and
deliver to 10S, and then transfer the parts to YL ("Proposal for Import…, page 5).“