International Trade Enforcement Roundup | March 2023


On March 24, OFAC announced it had designated three entities and nine individuals in response to the parties’ efforts to undermine democracy in the country. In addition, OFAC designated Belarusian President Lukashenko’s presidential aircraft as blocked property. A list of the designated parties and property can be found here.


Justice Department Announces Charges and Sentence in Connection with Iranian Procurement Network’s Attempts to Acquire Sophisticated Military Technology (DOJ Action) Two indictments were unsealed on March 21, alleging five defendants violated the Arms Export Control Act (AECA) and the International Emergency Economic Powers Act (IEEPA) while executing separate schemes to allegedly procure and illegally export sensitive technologies to Iran between 2005 and 2013 to, among other things, support the country’s drone industry.

United States v. Paidar, et al.

Those involved. Amanallah Paidar, Iranian national; Murat Bükey, a Turkish national.

Charges with penalties. One Count of Conspiracy (maximum of five years in prison); One Count of Attempting to Unlawfully Export Defense Articles to Iran (maximum of 20 years); One Count of Smuggling (maximum of 10 years); One Count of Conspiracy to Launder Monetary Instruments (maximum of 20 years); One Count of False Statements (maximum of five years); Four Counts of Attempting to Unlawfully Exports to Iran (maximum of 20 years for each count). What happened? Paidar and Bükey used their companies to procure U.S. technology and illegally export it through Turkey to Iran. The defendants successfully exported a fuel cell test station, a device used to test the efficacy of fuel cells, from the United States to Iran. The pair failed to export a device, listed as a defense article on the United States Munitions List (USML), used to detect biological agents in the air, water, or ground. (An undercover U.S. law enforcement agent thwarted this scheme.) Paidar also attempted to export spectrum analyzers, spectrometers, night vision cameras, and gamma-ray projectors in violation of the IEEPA and the Iranian Transactions and Sanctions Regulations (ITSR). Bükey was extradited to the United States from Spain and pleaded guilty to conspiring to violate the AECA and IEEPA. He was sentenced to 28 months in prison. Paidar remains at large.

The indictment can be found here.

United States v. Mahmoudi, et al.

Those involved. Agshar Mahmoudi and Mahmoud Alilou, Iranian nationals; and Shahin Golshani, a UAE national.

Charges and penalties. One Count of Conspiracy (maximum of five years in prison); Three Counts of Unlawful Exports or Attempted Exports of U.S.-Origin Goods to Iran (maximum of 20 years for each offense); Three Counts of Smuggling (maximum of 10 years for each offense); One Count of Attempting to Export Defense Articles (maximum of 20 years for each offense); and Two Counts of Making a False Statement (maximum of five years for each offense). What happened? Between 2005 and 2009, the three defendants conspired to procure and export a high- speed camera used for ballistic and nuclear missile testing, landing gear for a fighter jet, and a meteorological

3 International Trade Enforcement Roundup |

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