U.S.

Department of Justice

United States Attorney

Eastern District of New York
AAS:SME/JN/DKK 271 Cadman Plaza East
Brooklyn, New York 112Q1

December 3, 2018

Andrew Finkelman
Margaret O'Malley
Office of International Affairs
United States Department of Justice
1301 New York Ave. NW
Washington DC 20530

Re: In the Matter of the Attorney General of Canada on Behalf of the

United States of America and Wanzhou Meng

Dear Mr. Finkelman & Ms. O'Malley:

The United States respectfully submits this letter to provide additional information in
opposition to the application for conditional release pending extradition on behalf of
Wanzhou Meng ("Meng") in the above-referenced matter.

Meng is a national of the People's Republic of China ("PRC"). She is not a Canadian
citizen, does not reside in Canada, and has no legal status in Canada of which the United
States is aware. Meng is facing a lengthy prison sentence in the United States, should she be
convicted of the charges pending against her. Given Meng's position and personal
connections—outlined below—United States authorities believe that there are no conditions
or combination of conditions that will assure her continued appearance at extradition
proceedings in Canada and will maintain the confidence in the administration of justice.
The United States has no extradition treaty with the PRC and, were Meng to be
released, she would likely flee to China, from which the United States would not be able to
obtain her extradition. Moreover, because her provisional arrest has placed Meng and her
employer, Huawei Technologies Co. Ltd. ("Huawei") on notice that the United States has
filed criminal charges against Meng, Meng could further be expected to refrain from travel
for work purposes or otherwise to any jurisdiction with which the United States has an
extradition treaty or relationship.
% * * * - "■*

Mens Faces a Lenethv Prison Sentence

Meng, the Chief Financial Officer ("CFO") of Huawei, has been charged in
connection with a conspiracy to defraud multiple international financial institutions. The
alleged fraud conspiracy was perpetrated at Huawei's highest levels, with Meng personally
making key misrepresentations to one of Huawei's banking partners. As a result of those
misrepresentations, among other things, multiple financial institutions engaged in millions of
dollars of transactions in which they would not otherwise have participated. As detailed in
the Statement of Facts included with the government's Provisional Arrest Warrant, the
government's evidence against Meng includes, inter alia, testimony from numerous
witnesses and extensive documentary evidence, such as financial records, emails and internal
Huawei documents, including a detailed PowerPoint presentation personally delivered by
Meng to one of Huawei's banking partners that contains multiple material misrepresentations
as to the nature of Huawei's business in a high-risk jurisdiction. Meng faces multiple
criminal charges in the United States as a result of her criminal activity, each of which
carries a maximum sentence of thirty years' imprisonment. These potential penalties give
Meng a strong incentive to flee.
Meng's Access to Financial Resources

According to information known to the United States, Meng has tremendous financial
and logistical resources at her disposal and could easily flee Canada, should she so choose.
She is a senior executive at one of the largest telecommunications companies in the world,
and the daughter of its founder, one of the world's wealthiest individuals. According to
recent reporting, Meng's father, Ren Zhengfei, has an approximate net worth of US $3.2
billion and is the 83rd wealthiest individual in the world. As a result of Meng and her
family's extensive net worth, there is no question that Meng has the resources to flee from
prosecution and to remain a fugitive indefinitely.
Meng's Extensive Travel and Lack of Ties to Canada

Meng is also a risk of flight because she has access to numerous passport and visa
documents, which could allow her to flee with greater ease. In the past eleven years, Meng
has been issued no fewer than seven different passports from both China and Hone Kong.
Notably, these are passports Meng has used to travel to the United States; it is entirely
possible that Meng has additional passports of which the United States government is not
aware. Even if Canadian authorities seized Meng's travel document that she used to arrive in
Canada, she could use any number of additional travel documents to flee from Canada.

Meng Passport Number Passport Country

Gl9293757 China
\

G32666585 China

G41848183 China

G54811804 China

KJ0209563 Hong Kong

KJ0403962 Hong Kong

KJ0479108 Hong Kong

Meng is also a frequent global traveler. Meng obtained eight U.S. visas between July
2007 and April 2016. A brief review of open sources further reveals Meng's attendance in
recent years at conferences in locations ranging from Cancun, Mexico, to Singapore to
Beijing.

Moreover, Meng has no incentive to remain in Canada solely to attend extradition

proceedings. Meng was only transiting Canada, arriving in Vancouver at 11:30 AM PST on
December 1,2018 and scheduled to depart to another country approximately twelve hours
later.

Intent to Flee

Meng has already evinced an intent to evade apprehension in the United States, U.S.
authorities believe that after in or about April 2017, Huawei - and, by virtue of her position
at Huawei, Meng - became aware of a U.S. criminal investigation when Huawei's U.S.
subsidiaries were served with a grand jury subpoena. As a result, Huawei executives began
altering their travel patterns, to avoid any travel to or through the United States. Specifically,
Meng and certain other high-level Huawei executives have ceased traveling to the United
States altogether.

Although Meng previously traveled to the United States on numerous occasions in

2014,2015, and 2016, her last trip to the United States was from late February through early
March 2017—one month before Huawei is believed to have learned of an investigation.
Meng has not traveled to, or through, the United States since, even though one of her
children attends boarding school in the United States. Another senior Huawei executive
came to the United States at least four times between 2013 and 2016, and has similarly not
traveled to the United States since.

Additionally, following the issuance of the grand jury subpoena to the Huawei U.S.
subsidiaries, described above, Huawei took steps to move U.S.-based Chinese national
~ % r -

employees who may have had knowledge of facts related to the investigation out of the
United States. Specifically, the government is aware of Huawei's efforts on an institutional
level to obstruct the government's investigation by removing from the United States potential
witnesses who had information about Huawei's operations in Iran. These actions further
demonstrate the efforts that Meng and Huawei would likely take to hinder U.S. prosecutorial
efforts and prevent Meng's apprehension, should Meng be released on bond.

Respectfully submitted,

RICHARD P. DONOGHUE
Un&ed~5tates~"AttQrney

Alexander A. Solomon
David K. Kessler
Julia Nestor
Sarah Evans
Assistant U.S. Attorneys
(718)254-7000
 %

<£§> |] Court File: 27761

i\Q ^S7/ Va n c o u v e r Registry

^/PRn^5J^HE SUPREME COURT OF BRITISH COLUMBIA

IN THE MATTER OF
the Extradition Act, SC 1999, c. 18, as amended

AND IN THE MATTER OF

the Attorney General of Canada on behalf of
the United States of America
and
Wanzhou Meng, also known as "Cathy Meng" and "Sabrina Meng'

AFFIDAVIT

I, Constable Winston Yep, peace officer, of the City of Surrey, Province of British Columbia, make
oath and say as follows:

1. I am a member of the Royal Canadian Mounted Police ("RCMP"), currently assigned to

its Foreign and Domestic Liaison Unit located in Surrey, British Columbia. I am also the
officer assigned to assist the Department of Justice in this case. As such, I have knowledge
of the matters deposed to in this affidavit, except where they are stated to be based on
information and belief and where so stated, I believe them to be true.

2. I swear this affidavit in support of an application for a warrant for the provisional arrest of
Wanzhou Meng ("Meng"), also known as "Cathy Meng" and "Sabrina Meng" pursuant to
section 13 of"the Extradition Act.

3. In accordance with the Treaty on Extradition between the Government of Canada and the
Government of the United States of America, on November 30, 2018, the Government of
the United States of America (the "Requesting State") requested the Government of
Canada to have Meng provisionally arrested (the "Request") to be prosecuted for offences
contrary to the laws of the United States of America (the "U.S. Charges").
 On November 30,2018, the Minister of Justice, through her authorized official, authorized
the Attorney General of Canada to apply for a warrant for the provisional arrest of Meng
pursuant to section 12 of the Extradition Act. A copy of the Minister's authorization is
attached to this affidavit as Exhibit A.

5. I have read the Request and believe its contents to be true. Unless otherwise stated, the
contents of this affidavit are based on the Request.

Identifying Information of Meng

6. The Request lists the following identifying information for Meng:

Name: Wanzhou Meng

Aliases: "Cathy Meng" and "Sabrina Meng"

Date of birth: February 13,1972

Birth place: People's Republic of China

Citizenship: People's Republic of China

Gender: Female

Ethnicity: Asian
Hair colour: Brown

Eye colour: Brown

Passport: Hong Kong passport KJ0403962

Appearance: attached as Exhibit B to this affidavit is a copy of a photograph of Meng

provided by the Requesting State in the Request.

Existence of an Arrest Warrant Issued in the United States of America

7. According to the Requesting State, on August 22,2018, the Honourable Roanne L. Mann,
Magistrate Judge for the Eastern District of New York, issued a warrant for the arrest of
Meng to stand trial on the U.S. Charges. This warrant remains valid and outstanding.
Summary of the Alleged Facts Surrounding the U.S. Charges

8. Briefly summarized, the Request alleges that starting in at least 2009, Meng and others,
conspired to make misrepresentations to numerous multinational financial institutions,
inducing them to continue to provide banking services to Huawei Technologies Co. Ltd.
("Huawei") despite the fact they were operating in sanctioned countries. The alleged facts
are more fully described in the "Summary of Facts" portion of the Request, a copy of which
is attached to this affidavit as Exhibit C.

Reasonable Grounds to Believe Meng is on her way to Canada

9. According to the Request, on November 29,2018, the Requesting State learned that Meng
will be travelling to Vancouver, British Columbia, on Saturday, December 1, 2018, on
Cathay Pacific (CX) Flight 838 which is scheduled to arrive in Vancouver at 11:30 a.m.
(PST). The Requesting State believes that Meng will only be making a brief stopover in
Vancouver and that her final destination is a third country (believed to be Mexico).

A Provisional Arrest Warrant is Necessary in the Public Interest

10. I have reasonable grounds to believe that it is necessary in the public interest to arrest Meng
on an arrest warrant to prevent her from escaping this jurisdiction. I base my beliefs on the
following grounds:

(a) Meng is charged in the United States of America on serious charges of fraud
involving millions of dollars. If convicted, she would likely face a sentence of
substantial j ail time;

(b) Meng is the CFO of Huawei, the world's largest telecommunications company and
the daughter of Huawei's founder. As such, she would have access to large
amounts of resources to escape the jurisdiction;

(c) Huawei executives, appear to have altered their travel plans to avoid the United
States jurisdiction since becoming aware of the United States' criminal
investigation into Huawei in April 2017. Meng, who previously visited the United

s*>
 4

States multiple times in 2014, 2015 and 2016 has not made a trip to the United
States since March 2017, prior to Huawei becoming aware of the criminal
investigation; and

(d) Meng is not ordinarily resident in Canada and appears to have no ties to Canada.

11. In light of the foregoing, I believe it is in the public interest that this Court order the arrest
of Meng. I further believe that it is in the public interest that the Court order Meng to
remain in detention pending the outcome of his extradition proceedings or only to release
Meng on stringent bail conditions, including the appointment of sureties, to help ensure
that she remains within this jurisdiction.

12. I believe that the information set out in this affidavit is true and request that a warrant for
the provisional arrest of Meng be issued pursuant to section 13 of the Extradition Act.

Sworn before me in the City of Vancouver

Province of British Columbia,
this 30th day of November, 2018

$/jwdj-
Kerry L. Swift, i Consta
A commissioner for taking affidavits
within the Province of British Columbia

Jfc • JKerry L. Swift

Barrister Sc Solicitor
International Assistance Group.
Department of Justice
tjfck* 900 -840 Howe Street
S§: Vancouver, B.C. V6Z 2S9
IL Tel: (604) 666*0918
 Form 1
Section 12 - Authority to apply For a
provisional arrest warrant

TO: The Attorney General of Canada

In the matter of an extradition request pursuant to the provisions of the

Extradition Aqt, S.C 1999, c.18

SUPREME COURT OF BRITISH COLUMBIA

BETWEEN:

THE ATTORNEY GENERAL OF CANADA

(on behalf of the United States of America)
-and

WANZHOU MENG ALSO KNOWN AS CATHY MENG; SABRINA MENG

AUTHORIZATION TO APPLY
FOR A PROVISIONAL ARREST WARRANT
(Section 12 Extradition Act)

The United States of America has requested that Canada seek the provisional
arrest of Wanzhou Meng also known as Cathy Meng; Sabrina Meng.

The Attorney General of Canada is authorized to apply for a provisional

arrest warrant.

DATED at Ottawa, Ontario, on the & day of November; 2018.

This is Exhibit" ' "referred to in the

affidavit of ..&iL.$k&te&.itf. or Counsel
Sworn before me at jMCflMiC nee Group
in the Province of British Columbia this stice of Canada
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A Commission w Tor takiqn Affidavits
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 Summary of Facts

Wanzhou Meng ("Meng"), also known as "Cathy Meng" and "Sabrina Meng," is the Chief
Financial Officer ("CFO") of Huawei Technologies Co. Ltd. ("Huawei"), a corporation organized under
the laws of the People's Republic of China ("PRC") and the world's largest telecommunications
equipment company, Meng is a citizen of the PRC and a daughter of Huawei's founder, Ren Zhengfei.
In addition to her role as CFO, Meng currently serves as Huawei's Deputy Chairwoman of the Board,
and serves or has served in various roles at other Huawei subsidiaries and affiliates. Meng also served on
the board of Hong Kong-based Skycom Tech Co. Ltd. ("Skycom") in or about and between February
2008 and April 2009. According to financial statements for Skycom for the years 2009 and 2010, the
"principal activities of Skycom were engaged in [sic] investment holding and acting as a contractor for
contracts undertaking [sic] in Iran."

According to information obtained through an investigation by U.S. authorities, including the

following, Huawei operated Skycom as an unofficial subsidiary to conduct business in Iran while
concealing Skycom's link to Huawei. In this manner and as explained in further detail below, Huawei
could conceal the nature of certain business it was conducting in and related to Iran, which is generally
considered a high-risk jurisdiction.

• Former employees of Skycom have stated, in sum and substance, that Skycom was not distinct
from Huawei. For example, Skycom employees had Huawei email addresses and badges,
individuals working in Iran used different sets of stationery ("Huawei" and "Skycom") for
different business'purposes, and the leadership of Skycom in Iran were Huawei employees;

• Documents show that multiple Skycom bank accounts were controlled by Huawei employees,
and Huawei employees were signatories on these accounts between 2007 and 2013;

• Documents and email records show that persons listed as "Managing Directors" for Skycom
were Huawei employees;

• Skycom official documents, including several Memoranda of Understanding, bore the Huawei
logo;
• Email correspondence and other records show that all identified Skycom business was conducted
using "@huawei.com" email addresses; and

• Documents show that a purportedly unrelated entity to which Skycom was supposedly "sold" in
2009 was actually also controlled by Huawei until at least in or about 2014.

Transactional records and other documents obtained by U.S. authorities further demonstrate that
Huawei operated Skycom as an unofficial subsidiary to conduct business in Iran while concealing
Skycom*s link to Huawei. Among other things, records obtained through the investigation show that
Skycom was used to transact telecommunications businesain Iran for major Iranian-based
telecommunications companies. THSTSISfoibrl'> Referred to in We
affidavit of..!&LMtlSti&?...l'tf....
Sworn before me et...i/&tl££tM)/.-£<£..
In the Province of British Columbia this

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 PROVISIONAL ARREST REQUEST FOR WANZHOU MENG
The investigation by U.S. authorities has revealed a conspiracy between and among Meng and
other Huawei representatives to misrepresent to numerous multinational financial institutions, including
a global financial institution which conducts business in the United States ("Financial Institution 1"),
Huawei's business practices, particularly Huawei's control of Skycom in or about and between 2009 and
2014. Specifically, Meng and other Huawei representatives repeatedly lied about the nature of the
relationship between Huawei and Skycom and the fact that Skycom operated as Huawei's Iran-based
affiliate in order to continue to obtain banking services from multinational financial institutions.

The motivation for these misrepresenations stemmed from Huawei's need to move money out of
countries that are subject to U.S. or E.U. sanctions—such as Iran, Syria, or Sudan—through the
international banking system. At various times, both the U.S. and E.U. legal regimes have imposed
sanctions that prohibit the provision of U.S. or E.U. services to Iran, such as banking services. Of
particular relevance, companies such as Huawei operating in sanctioned countries often need to
repatriate income out of those countries by relying on U.S.-doIlar clearing transactions, which typically
pass through the United States, or Euro-clearing transactions, which typically pass through E.U.
countries. Huawei was a customer of Financial Institution 1 and the other victim institutions, and
conducted a significant amount of its international banking activity, including U.S.-dollar-clearing
transactions, with Financial Institution 1. The financial institutions at issue, including Financial
Institution 1, maintained policies by which they would not onboard Iran-based clients or process Iran-
related transactions through the United States, so as to avoid exposure to U.S. civil and criminal liability.
In response to due diligence inquiries by the banks regarding these internal policies, Meng and other
Huawei representatives repeatedly stated that Huawei did not operate Skycom and mat, with respect to
Financial Institution 1, Huawei would not use Financial Institution 1 to process any Iran-related
transactions.

Because Meng and other Huawei representatives misrepesented to Financial Institution 1 and. the
other financial institutions about Huawei's relationship with Skycom, these victim banking institutions
were induced into carrying out transactions that they otherwise would not have completed. As a result,
they violated the banks' internal policies, potentially violated U.S. sanctions laws, and exposed the
banks to the risk of fines and forfeiture. In particular, these relationships included the clearing of
hundreds of millions of U.S.-dollar transactions through correspondent accounts at financial institutions
in New York City and Euro transactions through correspondent accounts at financial institutions in
Eurozone countries. In essence, these misrepresentations exposed the financial institutions to serious
harm and denied the institutions the opportunity to make decisions based on the true risk of processing
certain transaction and the reputational risk associated with banking high-risk-clients such as Huawei.

For example, during the relevant timeframe, Financial Institution 1 was under investigation for
U.S. sanctions violations involving Iran and later entered into a deferred prosecution agreement
pertaining to U.S. sanctions violations involving Iran, and could therefore have suffered criminal
consequences for processing Huawei's Iran-based transactions.
 PROVISIONAL ARREST REQUEST FOR WANZHOU MENG

Relying on the misrepresentations by Meng and other Huawei representatives, Financial

Institution 1 and its U.S. subsidiary cleared more than $100 million worth of transactions related to
Skycom through the United States between approximately 2010 and 2014.

Many of the misrepresentations at issue were in direct response to a series of articles published
by Reuters describing how Huawei controlled Skycom, and alleging that Skycom had attempted to
import U.S.-manufactured computer equipment into Iran in violation of U.S. sanctions. One of the
Reuters articles reported that Meng was a member of the board of directors of Skycom for several years.
In statements reported in those Reuters articles, Huawei denied control of Skycom or violations of law.

According to information obtained from international financial institutions that conducted

business with Huawei, after the Reuters articles were published, several of them, including Financial
Institution 1, asked Huawei whether the allegations regarding their control of Skycom and business with
Iran made in the Reuters articles were true. In response to those questions, Huawei employees and
executives made a series of misrepresentations, both publicly and in private communications, with
various banking executives, among other things, denying Huawei's control of Skycom and claiming
Huawei did not violate U.S. sanctions law.

For example, after the Reuters articles were published, Financial Institution 1 requested that
Huawei provide further information and clarification regarding the relationship of Huawei and Skycom.
Although those inquiries were not addressed to Meng, on or about August 2013, Meng arranged for a
meeting with an executive of Financial Institution 1, and during that meeting, made a number of
misrepresentations to an executive of Financial Institution 1.

During that meeting, Meng used an English interpreter and relied on a PowerPoint presentation
written in Chinese. Meng stated that she was using an interpreter to be precise with her language. After
the meeting, an executive from Financial Institution 1 asked for an English language version of Meng's
PowerPoint presentation. Meng arranged for hand delivery of the document to Financial Institution 1 on
or about September 3,2013. The PowerPoint presentation included numerous untrue or misleading
representations regarding Huawei's ownership and control of Skycom and Huawei's compliance with
applicable U.S. laws. For example:

• Meng stated that "Huawei operates in Iran in strict compliance with applicable laws, regulations
and sanctions of UN, US and EU," although Skycom was using the U.S. financial system to
conduct prohibited Iran-related transactions;

• Meng stated that "Huawei's engagement with Skycom is normal business cooperation. Through
its trade compliance organization and process, Huawei requires Skycom to make commitments
on observing applicable laws, regulations and export control requirements." However, as
discussed above, Huawei did not "cooperate" with Skycom; Skycom was entirely controlled by
Huawei;
• Meng stated that "Huawei was once a shareholder of Skycom, and I [Meng] was once a member
of Skycom's Board of Directors. Holding shares and a BOD

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 Exhibit 3H-R

CourtFile: 27761
Vancouver Registry

IN THE SUPREME COURT OF BRITISH COLUMBIA

IN THE MATTER OF
the Extradition Act, S.C. 1999, c. 18, as amended

AND IN THE MATTER OF

the Attorney General of Canada on behalf of the

United States of America

Wanzhou Meng, also known as "Cathy Meng" and "Sabrina Meng"

AFFIDAVIT OF DU FEI

I, Du Fei, of Ottawa, Canada, MAKE OATH AND SAY THAT:

1. I have personal knowledge ofthe facts to which I depose, except where they axe stated to
be on information and belief, and where so stated, I believe them to be true.

. 2. I ^ employed by Huawei Technologies^

Huawei Technologies Co., Ltd. (me "Company"), as the Associate Director ofthe
Canada Mellectual Property Rights Division, Intellectual Property Department in die
Legal Affeirs Department ofthe Company, residing in Ottawa, Canada,

3, Upon receipt ofthe Warrant of Provisional Arrest (the 'Warrant'") on December 3,2018,
I requested my colleagues in the legal affairs department ofthe Company in Shenzhen, '
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 Exhibit 3H-R

Huawei operates in Iran in strict compliance

with applicable laws, regulations and
sanctions of UN, US and EU.

Huawei's engagement with Skycom is normal

business cooperation. Through its trade
compliance organization and process,
Huawei requires Skycom to make
commitments on observing applicable laws,
regulations and export control requirements.

H U A W E I T E C H N O L O G I E S C O . , LT D . H u a w e i C o n f i d e n t i a l 2 J S ' f f l ' H U A W € I
 Exhibit 3H-R

Background of Sanctions: Multiple Sanctions

against Iran by UN, EU and US amid
Increasingly Intractable International Situations
> On June 9, 2010, the UN Security Council passed Resolution 1929 (2010)
UN Sanctions imposing the fourth sanction against Iran. The scope ofthe sanction mainly
covers nuclear-related products, weapons, energy and financial products.
> Of particular note, this resolution has an "Annex IV Possible Areas of Cooperation
with Iran". The "Environment, Infrastructure" section of this annex articulates
"Support for modernization of Iran's telecommunication infrastructure, including
by possible removal of relevant export restrictions". Therefore, Huawei's
telecommunications business is not covered in this sanction resolution of
the Security Council.
> On July 26, 2010, the restrictive measures against Iran ("Council Decision of 26
EU Sanctions July, 2010) were passed at the meeting ofthe EU's 27 foreign affairs ministers.
This sanction imposed by the EU covers "dual-use goods and technology",
including communications products.
> Huawei pays close attention to the blacklist of Iranian individuals and
entities released by the EU to ensure that neither Huawei nor its partners
carry out business cooperation with the enterprises or individuals on the
blacklist.

HUAWEI TECHNOLOGIES CO., LTD. Huawei Confidential

H U AW 6 I
 Exhibit 3H-R

Background of Sanctions: Multiple Sanctions

against Iran by UN, EU and US amid
Increasingly Intractable International Situations
> On July 1, 2010, President Obama signed the Comprehensive Iran Sanctions, Accountability, and
Divestment Act of 2010 (CISADA). According to this act, sanctions will be imposed on any
business or individual that has conducted any commercial or financial transaction with Iran's
Islamic Revolutionary Guard Corps or Iranian banks that are included on the sanction list.
> The US laws and regulations regarding sanctions against Iran are very complicated, but they
mainly target Iran's oil and energy industry, entities controlled by Iran's Revolutionary Guard Corps,
and Iranian banks and insurance companies, and prohibit US financial institutions from engaging
in any related transactions.
> Huawei attaches great importance to this act. Our Trade Compliance Office released a
formal document in April 2011 requiring observance ofthe act across the company.
> The US Government Accountability Office (GAO) submitted a report on June 30, 2011, concerning
the establishment of procedures by the US government for a ban against firms that sell Iran
technology to disrupt communications. No firm has been identified in the report. The GAO thinks
there are several possible reasons for the difficulty in identifying any such firms, including (1) the
lack of a clear distinction between technology exported to Iran to disrupt the free flow of
information versus technology exported to Iran to support necessary and acceptable filtering and
monitoring of communication and (2) Iran's growing capacity to develop its own monitoring,
filtering, and disrupting technology suggests it is relying less on non-Iranian technology to monitor
and filter internal communications. Therefore, GAO is making no recommendations in this report.

HUAWEI TECHNOLOGIES CO., LTD. Huawei Confidential $£ huawgi

 Exhibit 3H-R

Background of Sanctions: Analysis of US

Export Control Against Iran

o US entities and individuals are prohibited from dealing

Direct
with entities or individuals of comprehensive embargoed
Control countries (Iran) or those on the blacklist.

• All entities and individuals are prohibited from trading US

controlled products or uncontrolled products that do not
Re-export comply with the de minimis exemption rule (US-origin
Control
technology valued at 10% or less) with entities or individuals
of comprehensive embargoed countries (Iran) or those on
the blacklist.

• All entities and individuals are prohibited from providing

Iran with technologies or services used for monitoring,
filtering and interception.

HUAWEI TECHNOLOGIES CO., LTD. Huawei Confidential

# * HUAW€I
 Exhibit 3H-R

Relationship with Skycom: About

Cooperation

▶ As a business partner of Huawei, Skycom works with Huawei

in sales and services in Iran.
> Huawei conducts normal business activities in Iran and
provides civilian telecommunications solutions in line with
global standards (e.g., ITU/3GPP) and export control
requirements ofthe US and the EU. Huawei works with local
suppliers, distributors and carriers in strict compliance with its
well-established business conduct guidelines.

HUAWEI TECHNOLOGIES CO., LTD. Huawei Confidential &£ HUAW€I

 V v V V

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 Exhibit 3H-R

About Iran: Huawei Announced Restriction of Its

Business in Iran
> There are primarily four telecommunications equipment
vendors in Iran: Ericsson, Nokia Siemens Networks, Huawei
and ZTE.
> Huawei has four customers in Iran: TIC, TCI, MCI (including its
subsidiary MobinNet) and IRANCELL Products we sell in Iran
include fixed and mobile (except CDMA) products, devices,
optical networks and software.
> In 2011, Huawei publicly announced restriction of its business
in Iran.

H U A W E I T E C H N O L O G I E S C O . , LT D . H u a w e i C o n f i d e n t i a l 8 9 S * & H U A W € I
 Exhibit 3H-R

About Iran: Huawei Only Provides Standard,

Civilian and Commercial Telecommunications
Equipment and Services
> Like all the other global communications equipment vendors, Huawei
sells civilian communications equipment and necessary after-sales
services to local telecommunications carriers. All these equipment
and services are used to improve local telecommunications
infrastructure, and enable local people to enjoy convenient
communications services.
> Huawei has never researched, developed, manufactured, or sold any
technology or product for military use. Equipment and services we
provide to the Iranian telecommunications carriers are the same as
those we provide to other business customers around the world.
> Huawei has never provided and will never provide any technology,
product, or service for monitoring communications flow, tracking user
locations, or filtering media contents in the Iranian market.

H U A W E I T E C H N O L O G I E S C O . , L T D . H u a w e i C o n fi d e n t i a l 9 & r &
HUAW€I
 Exhibit 3H-R

About Iran: Risks of Doing Business in Iran

While we have done everything we can to comply with applicable laws
and regulations, there are still some risks in doing business in Iran.

US sanctions are
changing and they are
essentially a set of
principles; the blacklist is
frequently updated; and
sanction-related laws are
complicated.
Understanding and
commanding these laws
and regulations presents
a challenge to all
companies.
All the Iranian carriers While the fast evolving
have state ownership. At communications technologies
the end of 2009, Iran make it easier for people to
privatized several state- communicate, potentially illegal
owned carriers, but they leakage of user information
still have some threatens user privacy. This
investments from state- challenge in the
owned enterprises. This telecommunications industry
is a fact that has also becomes more prominent in a
been questioned. sanctioned country as Iran.

HUAWEI TECHNOLOGIES CO., LTD. Huawei Confidential 10 » HUAW€I

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 Exhibit 3H-R

Enforcing Partners' Compliance

We require compliance by our partners through qualification,
regular communication and cooperation on compliance review.

Cooperation on
Qualification Regular Communication Compliance Review

Huawei has strict We maintain We work with our

rules on supplier and communication with partners on export

partner selection. suppliers and control. For example,

partners on export we work with US

Export control review
is part of qualification
process.
control. suppliers on export
control audit to build
trust in trade

compliance practices.

HUAWEI TECHNOLOGIES CO., LTD. Huawei Confidential 14 4'& HUAW€I

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 Exhibit 3H-R

Looking Into the Future: Continued Effort to

Improve Compliance Practices
Huawei's commitments in the 2012 CSR Report:
> We effectively fulfill our export control responsibilities and obligations, and prioritize these obligations over Huawei's
commercial interests.
We will continue to learn from industry best practices and observe applicable rules, laws, and regulations.
> HSBC has been working with Huawei for a long time and has a deep understanding of Huawei's history of growth
around the world. We have been and will continue to be transparent in our financial operation and across the
company. Open processes and voluntary disclosure of our annual reports are examples of transparency. The Huawei
that you see and interact with is who we really are. Huawei'e engagement with Skycom is normal and controllable
business cooperation, and this will not change in the future.
> HSBC has rich experience in trade compliance. We look forward to discussions on compliance and good experience
from HSBC to help us further improve our compliance practices.
> Huawei subsidiaries in sensitive countries will not open accounts at HSBC, nor have business transactions with HSBC.
> In the spirit of openness and transparency, Huawei is willing to share any information with HSBC.
> Huawei will set up a sales entity at GCC countries to directly handle sales into sensitive countries. The GCC entity will
help ensure effective monitoring and transparency of all businesses in the area. We are ready to discuss and work with
HSBC on sales compliance and channel of fund at sensitive countries.

H U A W E I T E C H N O L O G I E S C O . , LT D . H u a w e i C o n fi d e n t i a l 1 6 4*4 HUAW€I
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