important window on China's opening to the outside world."[1] The diagram below depicts the relevant ownership structure:
CITIC reviews ComNet's budget and U.S. locations and may be able to access U.S. customer records. During the 2014 site visit, ComNet representatives told Team Telecom officials that the Chinese government's ownership in ComNet was passive and that it provided no input into the company's operational decisions.[3] ComNet representatives similarly informed the Subcommittee that its daily operations are managed by its local management team in California.[4] The representatives, however, acknowledged that CITIC reviews the company's budget and U.S. locations.[5] CITIC also guides ComNet on its information security
- ↑ Major Shareholder—About CITIC Group, CITIC Telecom International, https://www.citictel.com/about-us/major-shareholder/.
- ↑ The diagram is derived from information ComNet provided to the Subcommittee, as well as publicly available information. See Major Shareholder—About CITIC Group, CITIC Telecom International, https://www.citictel.com/about-us/major-shareholder/; CITIC Telecom International, Annual Report 99, 250 (2019), https://www.citictel.com/wp-content/uploads/2020/03/EW01883_AR_20200327.pdf; ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee); In the Matter of Pacific Networks Corp. and ComNet (USA) LLC, Response to Order to Show Cause, GN Docket No. 20-111, at Exhibit A (June 1, 2020), http://licensing.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/reports/related_filing.hts?f_key=710677&f_number=ITC2142009042400199.
- ↑ DHS00460PSI-65, at DHS00462PSI.
- ↑ Briefing with ComNet (Apr. 13, 2020).
- ↑ Id.
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