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conditioned on CTA abiding by the commitments and undertakings contained in the July 2007 security agreement.^[1]

3. Team Telecom's Oversight of CTA Since 2007 Has Consisted of Two Site Visits and Intermittent Email Communication

Team Telecom had limited engagement with CTA for nearly a decade after entering into the security agreement. Between 2007 and 2016, Team Telecom's oversight was limited to written correspondence in which CTA informed Team Telecom of changes to the company's law enforcement point of contact, among other information.^[2] Documents provided to the Subcommittee by DOJ mention a meeting with CTA, the FCC, and Team Telecom sometime in 2014, during which CTA briefed the government officials on an anticipated China Telecom corporate restructuring.^[3] Neither the FCC nor Team Telecom, however, could locate any contemporaneous records detailing the meeting.

When asked to explain the lack of oversight during this period, despite the security agreement being in effect, Team Telecom officials pointed to the security agreement, noting that because it was broadly written, demonstrating compliance was straightforward.^[4] Officials also pointed to Team Telecom's lack of a compliance process before 2010.^[5] Further, one official noted that Team Telecom's understanding of the risks associated with China and its state-owned entities evolved over time.^[6] Still, even after 2011, Team Telecom believed it should complete review of China Mobile USA's pending application, as those deliberations

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1. See Fed. Commc'ns Comm'n, Public Notice—International Authorizations Granted, Rep. No. TEL-01179, DA 07-3632, 22 FCC Red 15266, 15268 (Aug. 16, 2007) (listing the authorization "date of action" as August 15, 2007).
2. See TT-DOJ-155-59. In addition to updating its point of contact, in November 2016, CTA informed Team Telecom of a 2014 corporate reorganization, during which, for a brief period, records of U.S. persons were stored outside of the United States. CTA also informed Team Telecom that it launched mobile virtual network operator ("MVNO") services under the brand name CTExcel in 2015; CTA resold T-Mobile services. See TT-DOJ-157-59.
3. See TT-DOJ-157-59, at TT-DOJ-158.
4. Briefing with the Dep't of Homeland Sec. (Feb. 7, 2020); Email from the Dep't of Homeland Sec. to the Subcommittee (June 4, 2020) (on file with the Subcommittee).
5. Briefing with the Dep't of Homeland Sec. (Feb. 7, 2020).
6. Id.; Email from the Dep't of Homeland Sec. to the Subcommittee (June 4, 2020) (on file with the Subcommittee). The official referenced the House of Representatives Permanent Select Committee on Intelligence's 2012 Report on Huawei as evidence of the evolving understanding across the U.S. government. U.S. House of Rep. Permanent Select Comm. on Intelligence, Investigative Report on the U.S. National Security Issues Posed by Chinese Telecommunications Companies Huawei and ZTE (Oct. 8, 2012).

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