International Trade Enforcement Roundup | April 2023 Update

What happened? On April 18, Ahmad and eight co-defendants were charged with various crimes related to a scheme designed to help Ahmad evade U.S. sanctions. Ahmad, designated by OFAC in 2019 as a Hizballah financier, used a “complex web of business entities” to obtain U.S. artwork and diamond grading services. In addition, to avoid paying foreign taxes, the defendants sought to obscure the value of goods exported from the United States. The indictment alleges that from January 2020 to August 2022, the defendants imported more than $207 million in goods to the United States and exported more than $234 million in goods. While one defendant has been arrested in the United Kingdom, the others remain at large.

The press release can be found here.

Notably. The action further underscores the U.S. government’s concerted efforts to cut off sanctions evasion networks, including those involving prominent individuals. In addition to this matter, as described above, similar action was taken in April related to Viktor Vekselberg and Sergey Kurchenko.

International Business Organizations Convicted of Criminal Conspiracy to Violate Iranian Sanctions (DOJ Action) Those involved. DES International Co., Ltd (DES), a Taiwan-based company; Soltech Industry Co., Ltd. (Soltech), a Brunei-based organization; and Chin Hua Huang (Huang), a sales agent of both DES and Soltech. Charges with penalties. One Count of Conspiring to Defraud the United States; One Count of Violating IEEPA ($83,769 fine and a five-year term of corporate probation). What happened? On April 18, DES and Soltech both pleaded guilty to conspiring to defraud the United States and violate IEEPA by purchasing goods from U.S. companies and causing them to be shipped, via Hong Kong, to Iran. As an agent of the companies, Huang orchestrated the plot, which ultimately led to the unauthorized transfer to an Iranian research organization of a power amplifier, its power source, and cybersecurity software. As a result of the plea agreement, the companies were fined $83,769 (three times the value of the goods) and agreed to serve a five-year term of corporate probation. Notably. This is an example of a common means to evade sanctions, and we expect enforcement of such evasion to increase, particularly given DOJ’s recent announcement that 25 additional prosecutors are being hired to enforce U.S. export control laws.

The press release can be found here.

Woman Sentenced to 48 Months in Prison for Conspiring to Violate U.S. Sanctions Against Iran

Those involved. Niloufar Bahadorifar, a U.S. citizen originally from Iran.

Charges with penalties. Violation of IEEPA (four years in prison).

What happened? On April 7, the DOJ announced that Bahadorifar had been sentenced for conspiring to violate IEEPA. The violations involved the provision of financial support and other services to Iranian agents in furtherance of a plot to kidnap a prominent Iranian human rights activist and journalist living in New York City. Among other actions, Bahadorifar caused a payment to be made to a private investigator who surveilled the activist and “structured at least approximately $476,100 in more than 120 individual deposits.”

The press release can be found here.

5 International Trade Enforcement Roundup |

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