International Trade Enforcement Roundup | March 2023

sensor to Iran without the required license and in violation of IEEPA and the AECA. Assistant Attorney General Matthew Olsen stated, “The defendants’ efforts to unlawfully export advanced U.S. technology that could benefit the Iranian regime’s military and weapons of mass destruction research pose a threat to all Americans.” The defendants remain at large.

The press release detailing both indictments can be found here. You can find the indictment here.

Notably. Bükey, Mahmoudi, Paidar, and their companies, Farazan Industrial Engineering, Inc. and Ozone Aircraft and Defense Industry LLC, were designated by OFAC. As a result of these designations, all property of these individuals is blocked, and must be reported to OFAC. Additionally, entities owned by the individuals are also blocked and all transactions by U.S. persons, or persons within the U.S., involving the property or interests in property of the blocked or designated persons are prohibited. Paidar was designated after being identified as a procurement agent for the Iran-based Defense Technology and Science Research Center (DTSRC) (also designated with this action). Bükey was also identified as a procuring agent as he supported Paidar in his DTSRC-related endeavor. Mahmoudi similarly aided Paidar and the DTSRC. In conjunction with the unsealing of both indictments, the designations reflect the interoperability between multiple U.S. government agencies to hold individuals accountable for violations of U.S. export laws.

The OFAC press release can be found here.

Iranian National Charged with Illegally Exporting Electrical Equipment to Iran (DOJ Action)

Those involved. Mehdi Khoshghadam, an Iranian national and managing director of Pardazan Systems Namad Arman. Charges with penalties. One Count of Violating the IEEPA (maximum 20 years in prison); One Count of Conspiracy to Commit Money Laundering (maximum 20 years in prison); One Count of Conspiracy (maximum of five years in prison). The indictment also alleges forfeiture seeking all ill-gotten gains. What happened? On March 9, a federal grand jury voted to indict Khoshghadam for illegally exporting electrical cables and connectors from the United States to Iran. Koshghadam used a front company – Merlin International Trading Company – and an alias – David Lei – to mislead U.S. companies into shipping the cables and connectors to a Hong Kong freight forwarder which would then ship the items to Iran. These items were exported to Iran without the required U.S. government license. Khoshghadam allegedly falsified the identity and location of the true end-user on a BIS-issued form – the BIS-711. He also allegedly made, or caused to be made, three transactions using foreign bank accounts to transfer funds to U.S. bank accounts or used U.S. correspondent accounts in connection with “the unlawful exports to Iran.” A warrant has been issued for Khoshghadam’s arrest.

The press release can be found here.

Notably. While Khoshghadam’s actions were flagrant violations of U.S. export controls, this matter is also a reminder of the importance of robust compliance due diligence on transaction partners and the long arm of U.S. sanctions jurisdiction, which can reach virtually any transaction involving a U.S. financial institution.

BIS Imposes 20-Year Denial Order for Alleged Attempted Unauthorized Export of Communica- tions Equipment to Iran (BIS Action) Those involved. Kenneth Peter Scott, U.S. national and owner of Scott Communications, Inc. and Mission Communications, LLC. Both companies are also subject to the Denial Order.

Charges and penalties. Denial Order.

What happened? The Denial Order resolves a June 7 Charging Letter, which alleged five violations of the EAR. Scott admitted to using his two companies to export communications equipment to Jordan, even though

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