1

______________________________________________________________________________

FEBRUARY 2015 NSD 

WWW.JUSTICE.GOV (202) 514-2007

 

SUMMARY OF MAJOR U.S. EXPORT ENFORCEMENT, ECONOMIC ESPIONAGE, 

TRADE SECRET AND EMBARGO-RELATED CRIMINAL CASES

(January 2009 to the present: updated February 23, 2015)

Below is a brief description of some of the major export enforcement, economic espionage, theft of trade 

secrets, and embargo-related criminal prosecutions by the Justice Department since January 2008. These 

cases resulted from investigations by the Homeland Security Investigations (HSI) [formerly Immigration 

and Customs Enforcement , (ICE)], the Federal Bureau of Investigation (FBI), the Department of 

Commerce's Bureau of Industry and Security (BIS), the Pentagon's Defense Criminal Investigative 

Service (DCIS), and other law enforcement agencies. This list of cases is not exhaustive and only 

represents select cases.

Satellite Communications Equipment to Sudan – On February 18, 2015, in the Eastern District 

of Virginia, Richard John Dagher, a Lebanese national who was a resident of Lebanon, pled 

guilty to a one count Information charging him with conspiring to defraud the United States by 

filing false Electronic Export Information (EEI) in his attempt to export goods from the United 

States to Sudan without first obtaining a license. Dagher was employed by BCom Offshore SAL, 

a satellite communication service provider based in Lebanon with an office in Switzerland. He 

was the Director of Operations. Dagher held a visa which allowed him to do business in the 

United States. Court documents show that from March 14, 2012 through February 26, 2013, 

Dagher cased the filing of false EEI, which stated that an export from the United States to Sudan 

of satellite communications equipment was destined for Switzerland. This case was investigated 

by the Department of Homeland Security.

Military Articles to China – On February 18, 2015, in the Northern District of Illinois, an 

indictment was made public charging an Arlington Heights company, its president, and a former 

employee with unlawfully exporting and importing military articles, including components used 

in night vision systems and on the M1A1 Abrams tank, which is the main battle tank used by the 

U.S. Armed Forces. The defendants were charged in an indictment returned by a federal grand 

jury on January 14, 2015. Vibgyor Optical Systems, Inc., purported to manufacture optics and 

optical systems, including items that were to be supplied to the U.S. Department of Defense 

(DOD). Instead of manufacturing the items domestically, as it claimed, Vibgyor illegally sent the 

technical data for, and samples of, the military articles to manufacturers in China, then imported 

the items from China to sell to its customers – including DOD prime contractors. Vibgyor’s 

president, Bharat “Victor” Verma, and Urvashi “Sonia” Verma, a former Vibgyor employee and 

owner of a now-defunct company that operated as a subcontractor for Vibgyor, were also charged 

in the indictment. According to the indictment, between November 2006 and March 2014, the 

defendants conspired to defraud the United States and violate both the Arms Export Control Act 

(AECA) and International Traffic in Arms Regulations (ITAR). Vibgyor won subcontracts to 
2

supply optical components and systems to DOD prime contractors by misrepresenting the 

location of manufacture of the items it supplied. Bharat Verma falsely claimed that the items 

Vibgyor supplied were manufactured domestically, when they actually had been manufactured in 

China, based on information illegally exported to Chinese manufacturers. In addition to illegally 

providing technical data for a military item to China, Urvashi Verma attempted to ship an 

example of one of the military items to the Chinese manufacturer. Vibgyor, Bharat Verma, and 

Urvashi Verma are charged with one count of conspiracy to violate both the Arms Export Control 

Act and the International Traffic in Arms Regulations; one count of conspiracy to defraud the 

United States; and, one count of violating the Arms Export Control Act. Vibgyor and Bharat 

Verma were also charged with international money laundering. This case was investigated by 

Homeland Security Investigations, Internal Revenue Service, Department of Defense Criminal 

Investigative Service.

Military Night Vision Devices Overseas – On February 9, 2015, in the District of Maryland, 

David Kelley was sentenced to 18 months in prison followed by three years of supervised release 

after a plea of guilty on May 9, 2014 for the unlawful export of arms and munitions, specifically, 

night vision devices, in violation of 22 U.S.C. § 2778. According to his plea agreement, Kelley 

ran a business named "Optical Solutions and More" that sold night vision and other military-style 

items, primarily over eBay. Kelley entered into distributor agreements with night vision 

manufacturers in which he acknowledged that he was aware of restrictions known as the 

International Traffic in Arms Regulations (ITAR), 22 U.S.C. §§ 120-130, which prohibited the 

unlicensed export of U.S. munitions list items, including the export of night vision devices using 

Generations 2 and newer technology. After entering into these agreements, Kelley discussed 

circumventing ITAR restrictions with foreign customers who responded to his internet 

listings. Between May 2011 and February 2012, Kelley made approximately 60 shipments 

containing ITAR-restricted weapons parts and night vision devices destined for customers in 24 

countries, including Argentina, Australia, Russia, the Philippines, United Kingdom and Japan. To 

disguise the ITAR violations, Kelley variously labeled these shipments as "toys," "toy blocks," 

"spotting scope," and "monocular parts." In exchange for these shipments, Kelley collected over 

$140,000 in 150 separate PayPal transactions. In September 2011, an undercover HSI agent 

located in Baltimore posed as a buyer from New Zealand and contacted Kelley to ask if Kelley 

would export an ATN Generation 4 Monocular Night Vision Device. Kelley acknowledged in an 

email that such an export violated ITAR and demanded additional payment for risking 

prosecution. On October 24, 2011, Kelley exported the device, which is designated as a defense 

article on the U.S. munitions list, to New Zealand, without first obtaining a license from the State 

Department.

Industrial Products to Iran – On February 2, 2015, in the District of Maryland, Ali Saboonchi, a 

U.S. citizen, was sentenced to 2 years in prison, 1 year supervised, and $800 special assessment 

Previously, on August 11, 2014, a federal jury convicted Saboonchi of conspiracy and seven 

counts of exporting U.S. manufactured industrial products and services to Iran, in violation of the 

International Emergency Economic Powers Act. On March 7, 2013, an indictment was unsealed 

charging Saboonchi and Arash Rashti Mohammad, a citizen and resident of Iran, with conspiracy 

to export and exporting U.S. manufactured industrial products and services to Iran. The 

indictment was returned on March 4, 2013, and unsealed upon Saboonchi's arrest. From 

November 2009 to the present, Saboonchi and Rashti conspired to evade the Iranian embargo by 

exporting U.S. manufactured industrial goods and services to Iranian businesses. Rashti, located 

in Iran, allegedly asked Saboonchi, located in Maryland, to create and operate Ace Electric 

Company for the purpose of obtaining goods to send to Iran. Rashti, who operated businesses in 

Iran and the United Arab Emirates (UAE), allegedly solicited business from customers in Iran for 

industrial parts and components manufactured in the United States. Saboonchi obtained price 
3

quotes for, paid for, and took delivery of most of the U.S. goods. He then caused the goods to be 

shipped to co-conspirators in UAE, and in at least one case, China. Rashti would repay 

Saboonchi and then arrange for the entities in the UAE and China to send the goods to him and 

his customers in Iran. Finally, the defendants did not obtain a license or authorization to export 

these goods to Iran. Rashti remains at large. The investigation was conducted by the FBI and 

ICE.

Nuclear Weapons Data to Venezuela – On January 28, 2015, Pedro Leonardo Mascheroni, a 

naturalized U.S. citizen from Argentina, was sentenced in the District of New Mexico to 60 

months imprisonment, 3 years supervised release, and special assessment of $1,100. On August 

20, 2014, Majorie Mascheroni, a U.S. citizen, was sentenced to 12 months and 1 day in prison, 3 

years supervised release, $20,000 fine, and $900 special assessment. Previously, on June 21, 

2013, Pedro Mascheroni and his wife, Majorie Mascheroni, who both previously worked as 

contractors at the Los Alamos National Laboratory (LANL) in New Mexico, pleaded guilty to 

charges under the Atomic Energy Act and other charges relating to their communication of 

classified nuclear weapons data to a person they believed to be a Venezuelan government official. 

According to court filings, Mascheroni, a Ph.D. physicist, worked as a scientist at LANL from 

1979 to 1988 and held a security clearance that allowed him access to certain classified 

information, including restricted data. Roxby Mascheroni worked at LANL between 1981 and 

2010, where her duties included technical writing and editing. She also held a security clearance 

at LANL that allowed her access to certain classified information, including restricted data. As 

defined under the Atomic Energy Act, restricted data is classified information concerning the 

design, manufacture, or use of atomic weapons; the production of special nuclear material; or the 

use of special nuclear material in the production of energy. Pedro Mascheroni and Roxby 

Mascheroni were indicted in September 2010 and charged with conspiracy to communicate and 

communicating restricted data to an individual with the intent to secure an advantage to a foreign 

nation. The indictment also charged the couple with conspiracy to convey and conveying 

classified restricted data. The indictment also charged Pedro Mascheroni with concealing and 

retaining U.S. records with the intent to convert them to his own use and gain and both 

defendants with making false statements. Mascheroni pleaded guilty to two counts of conversion 

of government property, and two counts of making false statements. Pedro Mascheroni also 

pleaded guilty to an information charging him with two counts of communication of restricted 

data and one count of retention of national defense information. Mascheroni admitted that in 

November 2008 and July 2009, he unlawfully communicated restricted data to another individual 

with reason to believe that the data would be utilized to secure an advantage to Venezuela. He 

also admitted unlawfully converting Department of Energy information to his own use and selling 

the information in November2008 and July 2009 and failing to deliver classified information 

relating to the United States’ national defense to appropriate authorities and instead unlawfully 

retaining the information in his home. Finally, Pedro Mascheroni admitted making materially 

false statements to the FBI when he was interviewed in October 2009. Roxby Mascheroni 

pleaded guilty to one count of conspiracy and two counts of making false statements. She also 

pleaded guilty to an information charging her with conspiracy to communicate restricted data. In 

entering her guilty plea, Roxby Mascheroni admitted that between October 2007 and October 

2009, she conspired with Pedro Mascheroni to convey restricted data belonging to the United 

States to another person with reason to believe that the information would be used to secure an 

advantage to Venezuela. She also admitted making materially false statements to the FBI when 

she was interviewed in October 2009. This case was investigated by the FBI, the Department of 

Energy and LANL.

Sanctions Violations to Aide Zimbabwean Government Officials – On January 21, 2015, C. 

Gregory Turner, also known as Greg Turner, was sentenced in the Northern District of Illinois to 
4

15 months in prison, one year supervised release, $100 special assessment, and received an 

abstract of judgment in the amount of $90,000. Previously, on October 10, 2014, Turner was 

convicted by a federal jury of conspiracy to violate the International Emergency Economic 

Powers Act (IEEPA) from late 2008 through early 2010 by agreeing to assist Zimbabwe President 

Robert Mugabe and others in an effort to lift economic sanctions against Zimbabwe. Turner met 

multiple times in the United States and in Africa with Zimbabwean government officials, 

including President Mugabe and Gideon Gono, governor of the Reserve Bank of Zimbabwe, who 

were individually subject to U.S. sanctions. A November 2008 consulting agreement provided 

for a total payment of $3.4 million in fees for Turner and his co-defendant, Prince Asiel Ben 

Israel, to engage in public relations, political consulting, and lobbying efforts to have sanctions 

removed by meeting with and attempting to persuade federal and state government officials, 

including Illinois members of Congress and state legislators, to oppose the sanctions. The 

sanctions against President Mugabe and other specially designated individuals in Zimbabwe ― 

for human rights abuses ― were initially imposed in 2003 by President George W. Bush, and 

have been continued annually by President Obama, starting in March 2009. President Mugabe 

and his ruling ZANU-PF party have governed Zimbabwe since its independence in 1980. The 

sanctions neither bar travel to Zimbabwe nor prohibit public officials from meeting with specially 

designated nationals to discuss removing the sanctions. But, individuals may not provide services 

on behalf of or for the benefit of specially designated nationals. According to the evidence at 

trial, in early November 2008, Turner and Ben Israel began having discussions with Mugabe, 

Gono, and other ZANU-PF leaders regarding the influence Turner and Ben Israel could wield to 

have the sanctions removed. The defendants discussed with Mugabe, Gono, and others their 

association with many public officials who purportedly had close connections with then 

President-Elect Obama. Turner violated IEEPA by conspiring to engage in public relations, 

political consulting, and lobbying efforts on behalf of President Mugabe and other Zimbabwe 

officials. In early December 2008, Ben Israel’s U.S. bank blocked a wire transfer of $89,970 into 

his account from a Zimbabwean official affiliated with ZANU-PF; and, Ben Israel later traveled 

to Africa and personally withdrew $90,000 from the bank account of that same Zimbabwean 

official. Turner and Ben Israel arranged for trips by federal and state government officials to 

meet with President Mugabe and other Zimbabwean officials, including in November and 

December 2008, and January and December 2009; attempted to have Gono and other 

Zimbabwean officials speak at an issues forum in Washington, D.C., sponsored by a then U.S. 

Representative from California, and to assist those officials in obtaining visas to travel to the U.S. 

to attend the event; arranged for President Mugabe to meet with federal and state government 

officials in New York; lobbied a caucus of state legislators on behalf of Zimbabwean officials; 

and failed to apply to the Treasury Department for a license to engage in transactions and services 

on behalf of specially designated nationals. In early December 2008, Turner and Ben Israel 

arranged for a delegation to travel to Zimbabwe. After members of the delegation returned, 

President-Elect Obama’s transition team forwarded information about contact from a member of 

the delegation to the FBI based on its concerns that sanctions may have been violated by traveling 

to Zimbabwe, which was not itself prohibited. Throughout 2009, Turner and Ben Israel 

continued to pass communications between Zimbabwean leaders and, purportedly, U.S. public 

officials while seeking payment for their services from Gono. Turner led an effort to have Gono 

speak at an issues forum hosted by a then U.S. Representative from California in September 

2009. Turner attempted to assist Gono, as well as two other Zimbabwean officials, obtain visas to 

ensure that they could attend and participate in the forum. Ben Israel was sentenced on August 

21, 2014 to seven months in prison, one year supervised release, $100 special assessment and a 

$500 fine after pleading guilty to violating the Foreign Agents Registration Act (FARA). This 

case was investigated by the Federal Bureau of Investigation and the Internal Revenue Service 

Criminal Investigation Division.
5

Lockheed Martin Fuel Quantity Indicators to Malaysia – On January 13, 2015, in the District of 

New Hampshire, Netria Corporation was sentenced to one year of probation and ordered to forfeit 

$12,560. On October 2, 2014, Netria pled guilty to a one-count Information charging it with 

exporting without a license two Lockheed Martin Fuel Quantity Indicators, which are defense 

articles on the Munitions List, in violation of the Arms Export Control Act (AECA). According 

to court documents, in September 2008, a domestic undercover storefront received a request from 

a Netria employee for a quote for a Northrup Grumman F-14 Tomcat fighter aircraft part. 

Subsequent to the request, federal agents began an investigation into Netria’s sales and export 

activities. During the course of the investigation, it was discovered that Netria had made sales 

and exports of numerous shipments of parts belonging to the Lockheed Martin C-130 Hercules 

military aircraft. A portion of those sales and exports consisted of parts and equipment which 

were classified as defense articles under the AECA and require a license from the Department of 

State prior to export out of the United States. In all, Netria exported nine shipments of C-130 

parts from September 2008 through April 2009 without a license and brokered the sale and export 

of approximately $2 million in such aerospace parts between July 2007 and October 2009. This

case was investigated by ICE/HIS and DCIS.

Drone, Missile and Stealth Technology to China – On January 9, 2015, Hui Sheng Shen, aka 

"Charlie," was sentenced in the District of New Jersey to 49 months in prison and $200 special 

assessment. On January 6, 2015, Huan Ling Chang aka, “Alice” was sentenced to time served 

and $200 special assessment. Previously, on September 22, 2014, Shen and Chang, both 

Taiwanese nationals, each pleaded guilty to one count of conspiracy to violate the Arms Export 

Control Act and one count of conspiracy to import illegal drugs. On April 25, 2012, Shen and 

Chang were charged separately by amended criminal complaints with conspiracy to violate the 

Arms Export Control Act. The defendants were arrested on February 25, 2012 in New York in 

connection with a complaint in New Jersey charging them with conspiring to import and 

importing crystal methamphetamine from Taiwan to the United States. According to the 

amended complaint, during negotiations with undercover FBI agents over the meth deal, the 

defendants asked FBI undercover agents if they could obtain an E-2 Hawkeye reconnaissance 

aircraft for a customer in China. In subsequent conversations, Shen and Chang allegedly 

indicated they were also interested in stealth technology for the F-22 fighter jet, as well missile 

engine technology, and various Unmanned Aerial Vehicles (UAV), including the RQ-11b Raven, 

a small, hand-launched UAV used by the U.S. Armed Forces. Shen and Chang allegedly stated 

that their clients were connected to the Chinese government and its intelligence service. 

According to the complaint, they sent undercover agents a code book to facilitate 

communications relating to the proposed arms exports and opened a bank account in Hong Kong 

to receive and disburse funds related to the transactions. On a visit to New York in February 

2012, the defendants allegedly examined a Raven RQ-11b UAV and manuals relating to the RQ4 Global Hawk UAV (provided by undercover FBI agents) that they allegedly intended to export 

to China. Shen and Chang were arrested shortly thereafter. The export investigation was 

conducted by the FBI, while ICE was responsible for a parallel investigation into the import of 

counterfeit goods from China involving other defendants.

Military-Grade Accelerometers to South Korea – On December 19, 2014, Jae Shik Kim, a 

citizen of South Korea, had his initial court appearance in the Central District of California 

pursuant to an Indictment charging the defendant with violations of the Arms Export Control Act 

and the International Emergency Economic Powers Act. According to the indictment, Kim 

exported military-grade accelerometers from the U.S. to Iran without first obtaining a license. 

Kim was the president and CEO of Karham Eng., Corp., a company located in Seoul, South 

Korea. Beginning in December 2007 to March 2010, Kim and Karham conspired with 
6

individuals located in China and Iran to procure U.S.-origin aircraft parts that were used in the 

navigation systems of aircraft and missiles, and to export the parts from the U.S. to Iran. 

WMD Materials to North Korea – On December 16, 2014, in the Northern District of Illinois, 

Yueh-Hsun Tsai, a.k.a. “Gary Tsai”, pleaded guilty to a superseding information charging him 

with making a false bill of lading. In his plea agreement, Gary Tsai admitted to arranging the 

export of a grinder to Taiwan by falsely identifying the consignee of the shipment. His father, 

Hsien Tai Tsai, a.k.a. “Alex Tsai”, pleaded guilty on October 10, 2014, to conspiracy to defraud 

the United States in its enforcement of regulations targeting proliferators of weapons of mass 

destruction. In his plea agreement, Alex Tsai admitted that he engaged in illegal business 

transactions involving the export of U.S. origin goods and machinery. Previously, on June 6, 

2013, Alex Tsai, who the U.S. government has linked to the supply of weapons machinery to 

North Korea, and his son, Gary Tsai, were indicted in the Northern District of Illinois for 

allegedly conspiring to violate U.S. laws designed to thwart the proliferation of weapons of mass 

destruction. On May 1, 2013, both Alex Tsai and Gary Tsai were arrested pursuant to criminal 

complaints filed on April 19, 2013. Alex Tsai, who was believed to have resided in Taiwan, was 

arrested in Tallinn, Estonia, and was later extradited to the United States, where he remains in 

federal custody. Gary Tsai, who is from Taiwan and is a U.S. legal permanent resident, was 

arrested at his home in Illinois. Each were charged with conspiring to defraud the United States

in its enforcement of laws prohibiting the proliferation of weapons of mass destruction; 

conspiracy to violate the International Emergency Economic Powers Act (IEEPA) by conspiring 

to evade the restrictions imposed on Alex Tsai and two of his companies by the U.S. Treasury 

Department, and money laundering. Agents had been investigating the pair, as well as Individual 

A (a Taiwanese associate of Alex Tsai), and a network of companies engaged in the export of 

U.S. origin goods and machinery that could be used to produce weapons of mass destruction. 

The investigation revealed that Alex and Gary Tsai and Individual A are associated with at least 

three companies based in Taiwan - Global Interface Company, Inc., Trans Merits Co., Ltd., and 

Trans Multi Mechanics Co., Ltd. - that have purchased and then exported, and attempted to 

purchase and then export, from the United States machinery used to fabricate metals and other 

materials with a high degree of precision. On January 16, 2009, the Treasury Department 

designated Alex Tsai, Global Interface, and Trans Merits as proliferators of weapons of mass 

destruction, isolating them from the U.S. financial system and prohibiting any U.S. person or 

company from doing business with them. In announcing the order, the Treasury Department said 

that Alex Tsai was designated for providing support for, or goods or services in support of the 

Korea Mining Development Trading Corporation (KOMID), which was designated as a 

proliferator by the U.S. in 2005. The Treasury Department asserted that Alex Tsai "has been 

supplying goods with weapons production capabilities to KOMID and its subordinates since the 

late 1990s, and he has been involved in shipping items to North Korea that could be used to 

support North Korea's advanced weapons program." After the OFAC designations, Alex and 

Gary Tsai and another individual allegedly continued to conduct business together, but attempted 

to hide Alex Tsai's and Trans Merit's involvement in those transactions by conducting business 

under different company names, including Trans Multi Mechanics. For example, approximately 

eight months after the OFAC designations - Alex and Gary Tsai, Individual A and others 

allegedly began using Trans Multi Mechanics to purchase and export machinery on behalf of 

Trans Merits and Alex Tsai. Specifically, the charges allege that in September 2009 they 

purchased a Bryant center hole grinder from a U.S. company based in suburban Chicago, and 

exported it to Taiwan using the company Trans Multi Mechanics. The charges further allege that 

by at least September 2009, Gary Tsai had formed a machine tool company named Factory Direct 

Machine Tools, in Glenview, Ill., which was in the business of importing and exporting machine 

tools, parts, and other items to and from the United States. However, the charges allege that Alex 

Tsai and Trans Merits were active partners in Factory Direct Machine Tools, in some instances 
7

procuring the goods for import to the United States for Factory Direct Machine Tool customers. 

This investigation was conducted by the FBI, ICE-HSI and BIS. 

Trade Secrets to Competitors in China – On December 10, 2014, Janice Kuang Capener, a 

citizen of China, was sentenced in the District of Utah to 90 days in prison, 24 months supervised 

release, $100 special assessment, and a $3,000 fine. Capener pleaded guilty on September 11, 

2014 to Count 3 of a second Superseding Indictment which charged the defendant with theft of 

trade secrets. Previously, on May 7, 2012, prosecutors unsealed an indictment charging Capener, 

Jun Luo and two companies, Sunhills International LLC, a California company established by 

Capener, and Zhejiang Hongchen Irrigation Equipment Co., LTD., with theft of trade secrets, 

wire fraud, and conspiracy to commit wire fraud in connection with the alleged theft of trade 

secrets from Orbit Irrigation Products, an irrigation company headquartered in Utah. According 

to court documents, Capener worked at Orbit from June 2003 through November 1, 2009, 

including serving as the chief of operations at Orbit's manufacturing plant in Ningbo, China. 

Capener allegedly stole Orbit’s trade secrets relating to sales and pricing and used that 

information for herself and others to the detriment of Orbit. Capener also allegedly worked with 

Luo, Sunhills International and Zhejiang Hongchen Irrigation Equipment to devise a scheme to 

undermine Orbit's position in the marketplace using illegally obtained proprietary pricing 

information. Capener and Luo were arrested on May 4, 2012. On August 29, 2012, all charges 

against Luo, also a citizen of China, were dismissed. Zhejiang Hongchen Irrigation Equipment 

Co., Ltd., a Chinese company under contract with Orbit, pleaded guilty to Counts 1-5 of the 

original indictment and was sentenced to 36 months of probation, and ordered to pay a fine of 

$100,000 and restitution in the amount of $300,000 for its role in a scheme to defraud and 

conspiracy to commit wire fraud. This case was investigated by the FBI.

Firearms Parts to Russia – On December 9, 2014, Viacheslav Zhukov was sentenced in the 

Southern District of Georgia to 51 months in prison, 3 years supervised release and $100 special 

assessment following his plea of guilty on December 5, 2014 for his role in illegally exporting 

firearm parts from the United States to Russia. An indictment was unsealed on June 4, 2014, 

charging Zhukov with illegally exporting firearm parts from Savannah, Georgia to others in 

Russia. The indictment alleged that Zhukov, a Russian citizen and lawful permanent resident of 

the United States living in Savannah, GA, mailed multiple packages containing firearm magnifier 

scopes to Russia without first obtaining an export license from the United States Department of 

Commerce. Various firearm magnifier scopes are controlled under the Export Administration 

Regulations for crime control purposes and require a license from the United States Department 

of Commerce to export to Russia. The indictment further alleges that Zhukov misrepresented the 

contents of packages he mailed to Russia on the customs declarations forms presented to the 

United States Postal Service. This case was investigated by HSI, CBP, USPS, and the SavannahChatham Metropolitan Police Department.

Pressure Transducers to Iran – On Dec. 5, 2014, Sihai Cheng, a citizen of the People’s Republic 

of China (PRC), arrived in Boston from the United Kingdom. In Feb. 2014, he was arrested by 

the British authorities on U.S. charges during a trip to the United Kingdom. He was detained in 

the United Kingdom pending extradition to the United States. On Apr. 4, 2014, Cheng and a codefendant were indicted along with two Iranian companies, Nicaro Eng. Co. and Eyvaz Technic 

Manufacturing Co., for conspiring to export American-made pressure transducers to Iran. 

Pressure transducers can be used in gas centrifuges to enrich uranium and produce weapons-grade 

uranium. Cheng and Seyed Abolfazl Shahab Jamili, an Iranian national, were indicted by a 

federal grand jury in the District of Massachusetts following an international investigation. The 

indictment alleges that between November 2005 and 2012, Cheng supplied thousands of parts 

that have nuclear applications, including U.S.-origin goods, to Eyvaz, an Iranian company 
8

involved in the development and procurement of parts for Iran's nuclear weapons program. In 

2011, the Council of the European Union designated Eyvaz as an entity "involved in [Iran's] 

nuclear or ballistic missile activities" and imposed restrictive measures against it. In so doing, it 

found that Eyvaz had produced vacuum equipment, which it supplied to two of Iran's uranium 

nuclear enrichment facilities, Natanz and Fordow, and that it also had supplied pressure 

transducers to Kalaye Electric Company, an Iranian company which has been designated by the 

United States and United Nations as a proliferator of Weapons of Mass Destruction. Specifically, 

the indictment alleges that in 2005, Cheng began doing business with Seyed Jamili, an Iranian 

national who worked for Eyvaz and ran his own importing business in Iran. Since 2005, Cheng 

sold Jamili thousands of Chinese manufactured parts with nuclear applications knowing that these 

parts were destined for Iran. Beginning in February 2009, Cheng and Jamili conspired with others 

in the PRC to illegally obtain hundreds of U.S. manufactured pressure transducers manufactured 

by MKS Instruments, Inc., headquartered in Massachusetts, on behalf of Eyvaz. As a result of the 

illegal activities of Cheng and his co-conspirators, hundreds of MKS pressure transducers were 

illegally exported from the United States to China. Upon receipt of these parts in China, Cheng 

caused the MKS pressure transducers to be exported to Eyvaz or Jamili in Tehran, Iran, in 

violation of U.S. export laws. The indictment further alleges that by 2007, Iran was operating 

thousands of gas centrifuges at the Natanz uranium enrichment facility. Iran has sought and 

illicitly obtained MKS pressure transducers to use in its centrifuge plants. Publicly available 

photographs of Natanz (with then President Mahmoud Ahmadinejad) show numerous MKS 

pressure transducers attached to Iran's gas centrifuge cascades. Because pressure transducers can 

be used in gas centrifuges to convert natural uranium into a form that can be used in nuclear 

weapons, they are subject to export controls and cannot be shipped to China without an export 

license or to Iran at all. This case was investigated by the FBI, U.S. Immigration and Customs 

Enforcement's (ICE) Homeland Security Investigations (HSI) and the Department of Commerce's 

Office of Export Enforcement.

Schematics of the Navy’s Nuclear Aircraft Carrier to Egypt – On December 5, 2014, Navy 

Engineer Mostafa Ahmed Awwad, was arrested in the Eastern District of Virginia on charges of 

attempting to steal schematics of the Navy’s newest nuclear aircraft carrier, the USS Gerald R. 

Ford, and pass the schematics to whom he believed was an Egyptian government official. Awwad 

was indicted on December 3, 2014 and charged with two counts of attempted exportation of 

defense articles and technical data. According to court documents, Awwad began working for the 

Department of the Navy in February 2014 as a civilian general engineer in the Nuclear 

Engineering and Planning Department at Norfolk Naval Shipyard. Based on a joint investigation, 

an FBI undercover agent speaking in Arabic contacted Awwad by telephone on September 18, 

2014, and asked to meet him the following day. Without seeking additional information from the 

caller, Awwad agreed. The next day Awwad met with the undercover FBI agent, who was posing 

as an Egyptian intelligence officer, in a park in Hampton, VA. During the meeting, Awwad 

claimed it was his intention to utilize his position of trust with the U.S. Navy to obtain military 

technology for use by the Egyptian government, including but not limited to, the designs of the 

USS Gerald R. Ford nuclear aircraft carrier. Awwad agreed to conduct clandestine 

communications with the undercover FBI agent by email and unattributable telephones and to 

conduct “dead drops” in a concealed location in the park. On October 9, 2014, Awwad and the 

undercover FBI agent met at a hotel where Awwad described a detailed plan to circumvent U.S. 

Navy computer security by installing software on his restricted computer system that would 

enable him to copy documents without causing a security alert. At this time Awwad also provided 

the undercover FBI agent four Computer Aided Drawings of a U.S. nuclear aircraft carrier 

downloaded from the Navy Nuclear Propulsion Information system. These drawings were marked 

with warnings that foreign distribution could result in criminal prosecution. During the 

discussion, Awwad indicated his understanding that the drawings would be sent to and used in 
9

Egypt. Awwad also asked the undercover FBI agent for $1,500 to purchase a pinhole camera he 

would wear around the shipyard to photograph restricted material. At the conclusion of the 

meeting, Awwad agreed to provide the undercover FBI agent with passport photos which would 

be used to produce a fraudulent Egyptian passport so Awwad could travel to Egypt without 

alerting U.S. government officials. On October 23, 2014, Awwad traveled to the pre-arranged 

dead drop site situated on a secluded hiking trail, and utilized a concealed container disguised in a 

hole in the ground. He retrieved $3,000 in cash before placing a one terabyte external hard drive 

and two passport photos inside. The FBI later collected the contents of the dead drop container. 

On November 28, 2014, Awwad was observed entering his office at the Norfolk Naval Shipyard 

holding a cardboard tube about three feet long. Once in his office, Awwad opened the cardboard 

tube and took out several white sheets which appeared to be design schematics of an aircraft 

carrier. Awwad then placed the schematics on the floor of his office and photographed them. 

After approximately 45 minutes of viewing the schematics and taking photographs, Awwad 

placed all the schematics back in the cardboard tube and left his office. This case was investigated 

by the FBI’s Norfolk Field Office and the Naval Criminal Investigative Service, in cooperation 

with the Department of Navy.

Embargo Violations by Alleged Arms Dealer – On December 4, 2014, Richard Ammar 

Chichakli, an associate of international arms dealer Viktor Bout, was sentenced in the Southern 

District of New York to 60 months in prison, 2 years supervised release, $900 special assessment 

and $70,000 restitution. He was also ordered to forfeit $1,732,756. Chichakli was arrested in 

Australia in January 2013, and then extradited to the U.S. in May 2013. On December 13, 2013, 

he was convicted by a jury of conspiring with Bout and others to violate the International

Emergency Economic Powers Act ("IEEPA") by attempting to purchase commercial airplanes 

from American companies, in violation of U.S. sanctions. Chichakli, a citizen of Syria and the 

U.S., was also found guilty of money laundering conspiracy, wire fraud conspiracy, and six 

counts of wire fraud, in connection with the attempted aircraft purchases. According to evidence 

at trial and documents previously filed in Manhattan federal court: Chichakli conspired with 

Bout and others to violate IEEPA by engaging in prohibited business transactions with companies 

based in the United States. The focus of these transactions was the purchase of commercial 

airplanes for a company that Bout and Chichakli controlled, and the ferrying of those aircraft to 

Tajikistan. At the time of these unlawful transactions, both Chichakli and Bout had been 

designated by the U.S. Treasury Department as Specially Designated Nationals ("SDNs"), which 

meant that individuals and businesses in the United States were prohibited from engaging in 

financial transactions with them. Chichakli sought to evade these SDN sanctions by, among other 

things, concealing his identity and his SDN listing, and by concealing Bout's involvement in the 

airplane transactions. In connection with this fraudulent scheme, Chichakli helped to make a 

series of wire transfer payments, totaling more than $1.7 million. These payments were sent from 

overseas bank accounts into accounts in the United States. Chichakli's co-conspirator, Bout, is 

currently serving a 25-year prison term as a result of his November 2011 conviction in the 

Southern District of New York in connection with his conspiring to sell millions of dollars of 

weapons to a designated foreign terrorist organization. This case was investigated by the DEASpecial Operations Division.

Aluminum Tubes to Iran – On December 4, 2014, in the Northern District of Illinois, Nicholas 

Kaiga of Brussels and London, pleaded guilty to one count of attempting to violate the export 

control regulations. Previously, on October 24, 2013, a federal grand jury returned a three -count 

indictment charging Kaiga with one count of violating the International Emergency Economic 

Powers Act (IEEPA) and two counts of making false statements on U.S. export forms. The 

defendant allegedly attempted to export aluminum tubes that were controlled for nuclear 

nonproliferation purposes from a company in Schaumburg, through Belgium, to a company in 
10

Kuala Lumpur, Malaysia, without obtaining a license from the U.S. Commerce Department. 

According to the complaint affidavit and indictment, the Schaumburg company, identified as 

"Company A" in court documents, began cooperating with law enforcement in December 2007. 

The cooperation began after a person identified as "Individual A," who was at times located in 

Iran, attempted to purchase 7075 aluminum from Company A, to be shipped to a company in the 

United Arab Emirates, but was denied an export license. In late 2009, an undercover agent began 

posing as an employee of Company A. Between November 2009 and February 2012, the 

indictment alleges that Kaiga, who was managing director of a Belgian company, Industrial 

Metals and Commodities, attempted to export 7075 aluminum from Company A to Company B 

in Malaysia without an export license. The complaint affidavit alleges that Company B was a 

front for Individual A in Iran. The false statements charges allege that Kaiga lied on Commerce 

Department export declaration forms, which stated that the ultimate destination and recipient of 

the 7075 aluminum were in Belgium. In November 2011, material that was purported to be 7075 

aluminum, but was actually substituted with a different aluminum by Company A in cooperation 

with law enforcement, was picked up from Company A by a freight forwarding company 

designated by Kaiga's Belgian company. The material arrived in the Belgian port of Antwerp on 

December 1, 2011, and two months later it was shipped by a freight forwarding company to 

Individual A's front company in Malaysia. This investigation was conducted by HSI, FBI, BIS, 

and OEE.

Military-Grade Weapons Exported Outside of the U.S. – On November 21, 2014, Justin Gage 

Jangraw, a former U.S. Army officer who was once deployed to Iraq, was sentenced in the 

District of Columbia to 8 months in prison, 1 year of supervised release and $125 special 

assessment. Previously, on August 29, 2014, Jangraw pled guilty to violating the Arms Export 

Control Act by selling restricted items without a license. He also pled guilty to a separate charge 

stemming from his unauthorized removal and retention of classified documents that he obtained 

while he was in the Army. According to court documents, Jangraw operated an online business 

in Portland using the names “Heapeach” and “Sexyweapon.com”. The business sold strictly 

regulated military-grade weapons parts and accessories to customers located worldwide. From 

November 2009 through January 2011, Jangraw sold and exported from the United States a total 

of 287 Munitions List items – including riflescopes manufactured to military specifications - to 

international customers in 34 different foreign countries, generating more than $12,000. Jangraw 

exported Munitions List parts and accessories even though he and his business never applied for 

or obtained a license to export defense articles from the United States. He did so with full 

knowledge of the licensing requirements. Following an undercover HSI investigation, HSI agents 

obtained a warrant to search Jangraw’s residence, which was then in Portland. During the search, 

in April 2011, agents seized four computers and electronic media, gun magazines, documents and 

products such as a weapon sight, gun rails, gun parts, and an AR-15 assault rifle. A subsequent 

review of images seized from Jangraw’s laptop computer led to the discovery of classified 

material that included e-mails from Jangraw’s work with the Army. The FBI was alerted and 

performed a follow-up search in July 2011 that led to the discovery of additional material that 

Jangraw had removed, without authorization, from Iraq. He took the laptop with him to numerous 

foreign countries and accessed unprotected Wi-Fi networks with the laptop while it contained the 

classified documents. The hundreds of classified documents contained information on military 

plans, weapons systems or operations, and other subjects pertaining to national security. This 

case was investigated by ICE-HSI, FBI, and assisted the U.S. Central Command.

Theft of Trade Secrets for Technologically Advanced Titanium to China – On November 7, 

2014, in the District of Connecticut, Yu Long was arrested in Ithaca, NY, pursuant to a federal 

criminal complaint which charged Long with attempting to travel to China with sensitive 

proprietary documents that set forth detailed equations and test results used in the development of 
11

technologically advanced titanium for U.S. military aircraft. The documents were taken from a 

Connecticut defense contractor where Long had been employed. Long attempted, two days 

earlier, to fly to China from Newark Liberty International Airport in New Jersey. As alleged in 

the complaint affidavit and in statements made in court, Long holds Chinese citizenship and is a 

lawful permanent resident of the U.S. From approximately August 2008 to May 2014, Long 

worked as a Senior Engineer/Scientist at a research and development center for a major defense 

contractor in Connecticut (“Company A”). Both during and after his employment there, Long 

traveled to the People’s Republic of China. Most recently, on August 19, 2014, Long returned to 

the U.S. from China through John F. Kennedy International Airport in New York. During a 

secondary inspection screening by U.S. Customs and Border Protection (CBP) officers, Long was 

found in the possession of $10,000.00 in undeclared U.S. cash, registration documents for a new 

corporation being set up in China, and a largely completed application for work with a statecontrolled aviation and aerospace research center in China. The application materials highlighted 

certain of Long’s work history and experiences that he claimed to have obtained while employed 

at Company A, including work on F119 and F135 engines. The F119 engine is employed by the 

U.S. Air Force F-22 Raptor fighter aircraft. The F135 engine is employed by the U.S. Air Force 

F-35 Lightning II fighter aircraft. According to the criminal complaint and statements made in 

court, on November 5, 2014, Long boarded a flight from Ithaca to Newark Liberty International 

Airport, with a final destination of China. During Long’s layover in Newark, CBP officers 

inspected Long’s checked baggage and discovered that it contained, among other things, 

sensitive, proprietary and export controlled documents from another major defense contractor 

located outside the state of Connecticut (“Company B”). Further investigation determined that the 

U.S. Air Force had convened a consortium of major defense contractors, including Company A 

and Company B, to work together to see whether they could collectively lower the costs of 

certain metals used. As part of those efforts, members of the consortium shared technical data, 

subject to stringent restrictions on further dissemination. Company B reviewed the Company B 

documents found in Long’s possession at Newark Liberty Airport and confirmed that it provided 

the documents to Company A as part of the consortium. Company B further confirmed that Long 

was never an employee of Company B. A review of Company A’s computer records indicated 

that Long had printed the documents while employed at Company A. The documents bore 

warnings that they contained sensitive, proprietary and export controlled material, which could 

not be copied or communicated to a third party. This investigation was conducted by the FBI, 

HSI, and CBP.

High Tech Night Vision Devices to Russia – On October 9, 2014, Dmitry Ustinov, of Moscow, 

Russia, was sentenced in the District of New Jersey to 18 months in prison and 3 years supervised 

release, for conspiracy to export high-tech military technology, in violation of federal law, 

including the Arms Export Control Act (AECA) and the International Traffic in Arms 

Regulations (ITAR). Ustinov will be deported from the United States upon his release from 

federal prison. Ustinov has been incarcerated since April 15, 2013, when he was arrested at the 

request of the U.S. Government in Vilnius, Lithuania after entering the country from Russia. On 

August 23, 2013, Lithuania extradited Ustinov to the United States. On July 10, 2013, Ustinov 

pled guilty to the above offense. According to court documents, between July 2010 and April 

2013, Ustinov, working with a supplier based in Virginia, caused or attempted to cause the export 

from the United States to Russia of approximately seventeen different night vision devices and 

thermal imaging scopes, which are designated on the United States Munition List (USML) as 

defense articles, and are prohibited from export outside the United States. The defense articles at 

issue, including Insight Mini Thermal Monoculars, D-740 night vision scopes, and Flir Tau 640 

thermal imaging cameras, are primarily used as weapons’ mounted or helmet mounted night 

vision devices, and in the case of the Flir Tau 640s, can even be mounted to fast moving vehicles 

or aircrafts, such as unmanned aerial vehicles. Given the sensitive nature of the defense articles at 
12

issue, Ustinov’s scheme was designed to avoid detection by law enforcement at each step in the 

process. First, Ustinov worked closely with a United States-based straw purchaser to conceal his 

involvement at the point of sale. Second, once a specific defense article was identified for 

purchase, Ustinov wired money to the straw purchaser to buy the defense article from front 

companies located in off-shore accounts in Cyprus. Finally, Ustinov also caused the packages 

containing USML defense articles to be falsely labeled so that customs officials from the United 

States and other countries would be less likely to search the package. Moreover, Ustinov also 

discussed using less traditional methods to obtain and export these night vision devices outside 

the United States, such as establishing a phony front company in the United States, and placing 

these high-tech devices inside chopped up car parts to conceal them from customs officials. At no 

time, however, did Ustinov ever apply for or receive a license to export these devices from the 

U.S. Department of State. This case was investigated by ICE-HSI.

Thermal Imaging Camera to Pakistan – On October 2, 2014, Bilal Ahmed pled guilty in the 

Northern District of Illinois to count one of a superseding indictment charging him with violating 

export control regulations. Previously, on May 7, 2014, a federal indictment was returned 

charging Ahmed with one count of violating the International Emergency Economic Powers Act 

(IEEPA) and one count of attempted smuggling of goods, in violation of U.S. export regulations. 

The indictment alleges that Ahmed violated U.S. export laws by attempting to ship a FLIR HRCU thermal imaging camera from his company in Schaumburg to a company in Pakistan without 

obtaining a license from the U.S. Commerce Department. The FLIR HRC-U thermal imaging 

camera is on a Commerce Department list of controlled export goods for reasons of national 

security and regional stability. Ahmed was initially charged in a criminal complaint and arrested 

on March 14. According to the complaint affidavit and the indictment, Ahmed was the owner, 

president, and registered agent of Trexim Corp., which used the address of a virtual office in 

Schaumburg. Between November 2013 and February 2014, Ahmed corresponded via email with 

a company in California and negotiated the purchase of a FLIR HRC-U thermal imaging camera 

for approximately $102,000, which he paid with two checks in February. Ahmed took delivery of 

the camera on Feb. 27 at a commercial shipping store in Bolingbrook, IL. On March 7, Ahmed 

allegedly took the camera, packaged in two boxes, to a different commercial shipper located in 

Elk Grove Village and left the packages to be shipped to a company in Pakistan. The waybill 

included a handwritten note containing the letters “NLR,” meaning “no license required.” A 

search of U.S. State and Commerce Department databases showed there were no licenses applied 

for or obtained by Ahmed, Trexim or any other related individual or company names for the 

export of a FLIR HRC-U thermal imaging camera from the U.S. to Pakistan, the indictment 

alleges. This case was investigated by the Federal Bureau of Investigation and the U.S. 

Department of Commerce, Bureau of Industry and Security, Office of Export Enforcement.

Oilfield Service Equipment to Iran – On September 24, 2014, Patrick Jean Zuber pled guilty in 

the Southern District of Texas to a Criminal Information charging the defendant with conspiracy 

to smuggle oilfield service equipment from the United States to Iran. Zuber was the Vice 

President of Middle East and North Africa (MENA) Underbalanced Drilling business operating 

under Weatherford International, Ltd., one of the world’s largest oilfield services companies in 

the world which specializes in drilling systems and technology. According to court documents, in 

January 2007, Zuber received an email from a Weatherford manager operating in Thailand asking 

about services Weatherford could provide in Iran. Zuber forwarded the request to a Canadian 

citizen who was Vice President of MENA West and responsible for Weatherford’s sales to Iran. 

Zuber did this while knowing that facilitating the sale of equipment through the United Arab 

Emirates and on to Iran was illegal under United States law.
13

Restricted Laboratory Equipment to Syria – On September 16, 2014, in the Middle District of 

Pennsylvania, Harold Rinko pleaded guilty to conspiracy to illegally smuggle laboratory 

equipment, including items used to detect chemical warfare agents, from the U.S. to Syria, in 

violation of federal law. During the guilty plea hearing, Rinko admitted that he conspired to 

export items from the U.S. through third party countries to customers in Syria, without the 

required U.S. Commerce Department licenses. According to a factual stipulation signed by 

Rinko and made part of the record, the conspirators prepared false invoices that undervalued and 

mislabeled the goods being purchased and also listed false information as to the identity and 

geographic location of the purchasers of the goods. The stipulation indicates that the items would 

be shipped from the U.S. to Jordan, the United Arab Emirates, and the United Kingdom, and 

thereafter transshipped to Syria. Previously, on April 23, 2014, an indictment was unsealed 

charging three individuals, including Ahmad Feras Diri of London, United Kingdom, Harold 

Rinko of Hallstead, Pa., and Moawea Deri, a Syrian citizen, and a firm with which Ahmad Feras 

Diri and Moawea Deri were associated, for their alleged involvement in a conspiracy to illegally 

export laboratory equipment, including items used to detect chemical warfare agents, from the 

U.S. to Syria. The indictment, returned Nov. 20, 2012, charges the three individuals and the 

company with criminal conspiracy, wire fraud, illegal export of goods, money laundering and 

false statements. According to the indictment, the items allegedly included: a portable gas 

scanner used for detection of chemical warfare agents by civil defense, military, police and border 

control agencies; a handheld instrument for field detection and classification of chemical warfare

agents and toxic industrial chemicals; a laboratory source for detection of chemical warfare 

agents and toxic industrial chemicals in research, public safety and industrial environments; a 

rubber mask for civil defense against chemicals and gases; a meter used to measure chemicals 

and their composition; flowmeters for measuring gas streams; a stirrer for mixing and testing 

liquid chemical compounds; industrial engines for use in oil and gas field operations and a device 

used to accurately locate buried pipelines. The indictment alleged that federal legislation and 

export controls seek to shut down the supply chain used by the Syrian state to support terrorism 

and to develop and proliferate weapons of mass destruction, including chemical weapons. 

Pursuant to regulations of the U.S. Department of Commerce’s Export Administration, a license 

is required to export goods and services from the U.S. to Syria, other than limited categories of 

humanitarian food and medicine. Ahmad Feras Diri was arrested by the Metropolitan Police in 

London on March 14, 2013, and is facing extradition to the U.S. in connection with the charges in 

the Middle District of Pennsylvania. Harold Rinko previously waived arraignment on the sealed 

indictment. Rinko, the owner-operator of Global Parts Supply, was allegedly engaged in the 

export business. Ahmad Feras Diri and Moawea Deri are brothers in the business of purchasing 

and transferring goods from the U.S. to Syria through a firm known as d-Deri Contracting & 

Trading. Moawea Deri, remains at large, and is considered a fugitive. The case was investigated 

by HSI in partnership with the Department of Commerce, Office of Export Enforcement.

Military Technical Drawings Downloaded/Exported Outside of the U.S. – On September 13, 

2014 in the District of New Jersey, Alper Calik of Ankara, Turkey and the former owner of two 

New Jersey defense contracting businesses was arrested upon his entry into the United States. 

Calik was charged by complaint with two counts of mail fraud, in connection with allegedly 

fraudulent contracts entered into with the U.S. Department of Defense (DoD), and one count of 

violating the Arms Export Control Act, in connection with his download of thousands of military 

technical drawings while outside the United States without prior approval from the U.S. 

Department of State. According to the complaint, starting in November 2009, Calik was the coowner of Clifmax LLC in Clifton, New Jersey. The company contracted with DoD to supply 

defense hardware items and spare parts. Starting in May 2011, Calik started a second defensecontracting company, Tunamann LLC, based at the same address in Clifton. Both Clifmax and 

Tunamann were allegedly “shell” companies for manufacturing facilities in Turkey, created to 
14

obtain DoD contracts that the manufacturers were not permitted to receive. Calik, on numerous 

occasions, falsely claimed to the DoD that Clifmax and Tunamann were U.S.-based 

manufacturers, when, in fact, neither company ever had any manufacturing capabilities in the 

United States. Calik is charged with violating the Arms Export Control Act. For both Clifmax and 

Tunamann, Calik submitted Military Critical Technical Data Agreements in which he claimed his 

companies were U.S.-based manufacturers. Calik also acknowledged that he understood export 

control laws and agreed not to disseminate export-controlled data and technical drawings in a 

manner that would violate export control laws. Based on his false representations, Calik was 

granted electronic access to drawings and technical data subject to U.S. export control 

regulations. Beginning in 2009, Calik downloaded approximately one hundred thousand 

drawings, some of which were subject to U.S. export control regulations. Calik was not in the 

United States when the majority of the drawings were downloaded and he did not obtain export 

licenses from the U.S. Department of State. On May 23, 2013, Calik, who at that time was 

operating Tunamann, downloaded from a DoD database the technical drawings for parts that go 

into the NSSN Class Submarine. Those drawings contained warnings stating that the export of the 

drawings to places outside the United States is restricted by the Arms Export Control Act. Calik 

was not in the United States when those drawings were downloaded and he did not obtain an 

export license from the U.S. Department of State for the export of those drawings. This case was 

investigated by the Department of Defense, Defense Criminal Investigative Service and HSI, 

Counter Proliferation Investigations.

F-16 Military Parts to Venezuela – On September 10, 2014, Ronald A. Dobek was sentenced in 

the Eastern District of Wisconsin to 84 months in prison, 3 years supervised and $100 special 

assessment. Previously, on June 5, 2014, following a three-day jury trial, Ronald A. Dobek was 

convicted of conspiring to export and exporting F-16 military parts to the Venezuelan Air Force 

(“VAF”) without a license or authority from the U.S. Department of State. The jury returned 

guilty verdicts on all three counts of the indictment that charged Dobek with conspiring to violate 

U.S. export laws and unlawfully exporting F-16 parts to Venezuela on December 29, 2007 and 

December 6, 2008. The evidence presented at trial showed that despite knowing about the U.S. 

embargo of Venezuela, Dobek conspired with a member of the VAF to supply the VAF with F-16 

canopy seals for Venezuelan’s fleet of F-16 military jets. The evidence showed that Dobek 

exchanged numerous emails with a member of the VAF in which they discussed obtaining the F16 canopy seals and the need to keep their operation secret. Dobek took other steps to conceal his 

illegal activity, including misidentifying the shipments as “t-molding” on shipping documents. As 

a result, Dobek sent shipments of F-16 canopy seals to a member of the VAF in Venezuela on or 

about December 29, 2007, and December 6, 2008. This case was investigated by the Federal 

Bureau of Investigation, Department of Homeland Security, Homeland Security Investigations, 

and the Department of Defense, Office of Inspector General.

Military Aircraft Components to UAE, Thailand – On August 28, 2014, John Nakkashian 

pleaded guilty in the Central District of California to a 1st Superseding Information. Nakkashian 

admitted that he knowingly made a false statement on a Shipper’s Export Declaration Form that a 

military gyroscope being shipped to Thailand did not require an export license, when in fact it 

did. Nakkashian was a Vice President for International Sales at Air Shunt Instruments, Inc. Air 

Shunt, a Chatsworth, California company that buys and sells aircraft and aerospace components, 

was charged via criminal information and pleaded guilty on July 15, 2008. Nakkashian was 

responsible for obtaining the required licenses for such exports. On May 20, 2008, Nakkashian 

was indicted on four counts of violating the Arms Export Control Act. The indictment alleged 

that Nakkashian illegally exported components for the J85 engine used on the F-5 fighter jet, and 

other military items to Dubai, United Arab Emirates, without first obtaining the required export 

license from the State Department. The indictment also alleged that Nakkashian illegally exported 
15

a military gyroscope to Thailand. On July 17, 2008, in the Central District of California, Air 

Shunt Instruments, Inc., was sentenced to pay a criminal fine of $250,000 and a special 

assessment of $400 for making false statements on a Shipper's Export Declaration in claiming 

that a military gyroscope being sent overseas in 2003 did not require an export license, when in 

fact the item required such a license. Nakkashian was arrested on June 16, 2014 after fleeing the 

country during the investigation. He is scheduled to be sentenced in early 2015. The 

investigation was conducted by DCIS and ICE. 

DuPont Trade Secrets to China – On August 26, 2014, Robert J. Maegerle was sentenced in the 

Northern District of California to serve 30 months imprisonment, pay $367,679 in restitution and 

a $400 special assessment. On July 10, 2014, Walter Lian-Heen Liew and his company, USA 

Performance Technology, Inc. (USAPTI), were both sentenced. Liew was sentenced to serve 15 

years imprisonment, forfeit $27.8 million in illegal profits, and pay $511,487.82 in restitution and 

a $2,000 special assessment. USAPTI was sentenced to 5 years probation and to pay a fine of 

$18.9 million and a $3,600 special assessment. Previously, on March 5, 2014, Liew, his 

company, USAPTI, and Maegerle were found guilty of economic espionage, theft of trade 

secrets, bankruptcy fraud, tax evasion, and obstruction of justice for their roles in a long-running 

effort to obtain U.S. trade secrets for the benefit of companies controlled by the government of 

the People's Republic of China (PRC). The jury found that Liew, USAPTI, and Maegerle 

conspired to steal trade secrets from E.I. du Pont de Nemours & Company (DuPont) regarding 

their chloride-route titanium dioxide production technology and sold those secrets for large sums 

of money to state-owned companies of the PRC. The purpose of their conspiracy was to help 

those companies develop large-scale chloride-route titanium dioxide production capability in the 

PRC, including a planned 100,000-ton titanium dioxide factory in Chongqing. This case marks 

the first jury conviction for economic espionage (18 U.S.C. Section 1831). Liew was convicted 

of conspiracy to commit economic espionage, conspiracy to commit theft of trade secrets, 

attempted economic espionage, attempted theft of trade secrets, possession of trade secrets, 

conveying trade secrets, conspiracy to obstruct justice, witness tampering, conspiracy to tamper 

with evidence, false statements, filing false tax returns for USAPTI and Performance Group, a 

predecessor company to USAPTI, and false statements and oaths in bankruptcy proceedings. 

Liew was an owner and president of USAPTI, a company headquartered in Oakland, Calif., that 

offered consulting services. USAPTI was found guilty of conspiracy to commit economic 

espionage, conspiracy to commit theft of trade secrets, attempted economic espionage, attempted 

theft of trade secrets, possession of trade secrets, conveying trade secrets, and conspiracy to 

obstruct justice. Evidence at trial showed that in the 1990s, Liew met with the government of the 

PRC and was informed that the PRC had prioritized the development of chloride-route titanium 

dioxide (TiO2) technology. TiO2 is a commercially valuable white pigment with numerous uses, 

including coloring paint, plastics, and paper. DuPont's TiO2 chloride-route process also produces 

titanium tetrachloride, a material with military and aerospace uses. Liew was aware that DuPont 

had developed industry leading TiO2 technology over many years of research and development 

and assembled a team of former DuPont employees, including Maegerle, to assist him in his 

efforts to convey DuPont's TiO2 technology to entities in the PRC. Liew executed contracts with 

state-owned entities of the PRC for chloride-route TiO2 projects that relied on the transfer of 

illegally obtained DuPont technology. Liew, Maegerle, and USAPTI obtained and sold DuPont's 

TiO2 trade secret to the Pangang Group companies for more than $20 million. Maegerle was 

convicted of conspiracy to commit theft of trade secrets, attempted theft of trade secrets, 

conveying trade secrets, and conspiracy to obstruct justice. Evidence at trial showed that 

Maegerle was employed by DuPont as an engineer from 1956 to 1991 where he had developed 

detailed knowledge of DuPont's TiO2 technology and expertise in building TiO2 production 

lines. He also had access to DuPont TiO2 trade secrets, including specific information regarding 

DuPont's TiO2 facility at Kuan Yin, Taiwan. He provided these trade secrets to Liew and 
16

USAPTI in furtherance of their contracts with state-owned companies of the PRC for chlorideroute TiO2 projects. Liew, Maegerle, and USAPTI's obstructing justice convictions stem from 

causing an answer to be filed in a federal civil lawsuit in which they falsely claimed that no 

information from DuPont's Kuan Yin plant was used in the USAPTI designs for the development 

of TiO2 manufacturing facilities. Liew's witness tampering conviction stems from his efforts to 

influence a co-defendant's testimony in the civil lawsuit. The jury also convicted Liew of 

conspiring with his wife, Christina Hong Qiao Liew (aka Qiao Hong), who was charged in the 

second superseding indictment, to mislead the FBI by corruptly concealing records, documents, 

and other objects during the FBI's investigation into their criminal activity. Christina Liew, as coowner of USAPTI, entered into contracts worth in excess of $20 million to convey TiO2 trade 

secret technology to Pangang Group companies. Liew and his wife received millions of dollars of 

proceeds from these contracts. The proceeds were wired through the United States, Singapore, 

and ultimately back into several bank accounts in the PRC in the names of relatives of Christina 

Liew. DuPont is a company based in Wilmington, Del., that manufactures a wide variety of 

products, including TiO2. DuPont invented the chloride-route process for manufacturing TiO2 in 

the late-1940s and since then has invested heavily in research and development to improve that 

production process. The global titanium dioxide market has been valued at roughly $12 billion 

per year, and DuPont has the largest share of that market. The chloride-route process is cleaner, 

more efficient, and produces a higher-quality product than the sulfate-route process prevalent in 

the PRC. The object of the defendants' conspiracy was to convey DuPont's secret chloride-route 

technology to the PRC companies for the purpose of building modern TiO2 production facilities 

in the PRC without investing in time-consuming, costly research and development. The second 

superseding indictment charged Christina Liew, Tze Chao (aka Zhao Zhi) and Hou Shengdong 

each with conspiracy to commit economic espionage. Ms. Liew was also charged with 

conspiracy to commit theft of trade secrets, attempted theft of trade secrets, possession of trade 

secrets, witness tampering, conspiracy to tamper with evidence, and false statements. The charges 

against Ms. Liew were severed from those against Walter Liew, Maegerle, and USAPTI. Ms. 

Liew is still awaiting trial. Chao, a former DuPont employee, pleaded guilty to conspiracy to 

commit economic espionage on March 1, 2012. Shengdong, the Vice Director of the Chloride 

Process TiO2 Project Department for the Pangang Group, was also charged with conspiracy to 

commit theft of trade secrets and attempted economic espionage. He is currently a fugitive. 

Charges of conspiracy to commit economic espionage, conspiracy to commit theft of trade 

secrets, and attempted economic espionage are also pending against the four PRC state-owned 

companies charged in the second superseding indictment. This case was investigated by the FBI 

and the IRS Criminal Investigation.

F-14 Fighter Jet Parts to Iran – On August 26, 2014, Oguzhan Aydin was arrested pursuant to 

an arrest warrant in the Northern District of Georgia. Previously, a federal grand jury returned an 

indictment charging Aydin and his co-conspirators with violations of the Arms Export Control 

Act and the International Emergency Economic Powers Act (IEEPA). According to court 

documents, between September 2009 and August 2010, Saeid Kamyari, while in Iran, worked 

through AGM Ltd. Co., a company located in Tehran, Iran, to procure aircraft parts for the F-14 

Fighter Jet and other aircraft parts for shipment from the U.S. to Iran. Aydin, while in the 

Republic of Turkey, assisted Kamyari through his association with Blue Sky Aviation a.k.a. BSA 

Hava Kargo Ltd. Sti. Using e-mails, Kamyari and Aydin coordinated and arranged through AGM 

LTD Co. and Blue Sky Aviation, the purchase and export of microcircuits designed for use on F14 fighter jets and other aircraft parts for shipment from the U.S. through Turkey to Iran. At no 

time did the co-conspirators obtain a license to export aircraft parts from the U.S. to Iran. This 

investigation was conducted by DHS.
17

Electronics to UAE and Africa – On August 13, 2014, R&A International Logistics (R&A), a 

privately-owned freight-forwarding company, was sentenced in the Eastern District of New York 

to 2 years probation, $4,000 special assessment and $100,000 fine. Rukhsana Kadri, the owner 

and president of R&A, was sentenced to 3 years probation, $100 special assessment, $30,000 

fine, and ordered to forfeit $125,262. Previously, on December 9, 2013, during her initial 

appearance, Kadri pled guilty to falsifying Shipper’s Export Declarations (SEDs) in connection 

with the international shipment of hundreds of Hewlett Packard computers, in violation of 13 

U.S.C. 305. According to court documents, Kadri was responsible for the day-to-day operations 

of R&A’s New York City Office. In addition, she supervised R&A’s compliance with 

international export regulations. Between January 2008 and April 2012, R&A and Kadri

repeatedly filed false SEDs relating to the shipment of electronics from the United States to the 

United Arab Emirates, Zimbabwe and Kenya.

Pressure Transducers with Nuclear Applications to China and Elsewhere – On July 24, 2014, 

in the District of Massachusetts, Qiang Hu aka Johnson Hu, a Chinese national and resident of 

Shanghai, was sentenced to 34 months in federal prison and $100 special assessment. Hu pleaded 

guilty on October 16, 2013 for his role in a conspiracy scheme to export dual-use pressure 

transducers from the United States to China. Previously, on June 13, 2012, a grand jury returned 

an indictment charging Hu with conspiracy to illegally export from the United States to China 

and elsewhere dual-use pressure transducers, in violation of the International Emergency 

Economic Powers Act (IEEPA). Pursuant to a criminal complaint, Hu was arrested on May 22, 

2012, after he arrived in Massachusetts for a business meeting. According to the indictment, the 

pressure transducers in question, manufactured by MKS Instruments headquartered in Andover, 

Mass., are controlled for export by the Commerce Department because they can be used in gas 

centrifuges to enrich uranium and produce weapons-grade uranium. Specifically, they can be 

used to measure gas pressure of uranium hexafluoride in centrifuge cascades. The indictment 

claims that Hu worked as a sales manager for a subsidiary of MKS Instruments in Shanghai, 

where he has been employed since 2008. Hu and his co-conspirators allegedly caused thousands 

of MKS export-controlled pressure transducers, worth more than $6.5 million, to be illegally 

exported from the United States to unauthorized end-users in China and elsewhere using export 

licenses fraudulently obtained from the Department of Commerce. The indictment alleges that 

Hu and his co-conspirators used two primary means of deception to export the pressure 

transducers. First, the conspirators used licenses issued to legitimate MKS business customers to 

export the pressure transducers to China, and then caused the parts to be delivered to other endusers who were not themselves named on the export licenses or authorized to receive the parts. 

Second, the conspirators obtained export licenses in the name of a front company and then used 

these fraudulently obtained licenses to export the parts to China, where they were delivered to the 

actual end-users. MKS is not a target of the federal investigation into these matters. This 

investigation was conducted by FBI, ICE, and BIS. 

Military Sensors Manufactured for Department of Defense Exported to China – On July 23, 

2014, Bo Cai, a Chinese national, pleaded guilty in the District of Mexico to violating the Arms 

Export Control Act and the International Traffic in Arms Regulations. Bo Cai and his cousin, 

Wentong Cai, a Chinese national in the U.S. on a student Visa, participated in a scheme to 

illegally export defense articles with military applications to the People’s Republic of China. In 

Bo Cai’s plea agreement, he admitted that from March 2012 to December 2013, he conspired to 

illegally export sensors primarily manufactured for sale to the Department of Defense for use in 

high-level applications, such as line-of-sight stabilization and precision motion control systems, 

without first obtaining the required export license. According to the plea agreement, in March 

2012, Bo Cai, who was then employed by a technology company in China, embarked on an 

illegal scheme to smuggle sensors out of the U.S. to China for one of his customers despite 
18

knowledge that the sensors could not be exported without a license and that the U.S. did not issue 

licenses to export the sensors to China. Bo Cai enlisted Wentong Cai to acquire the sensors under 

the ruse that he planned to use the sensors at Iowa State University where he was a graduate 

microbiology student. The investigation of this case began in October 2013 when an undercover 

HSI agent responded to Wentong Cai’s overtures. After negotiations by telephone and email, Bo 

Cai and Wentong Cai traveled to New Mexico in December 2013 where they obtained a sensor 

from undercover HSI agents and developed a plan for smuggling the sensor out of the U.S. to 

China. On December 11, 2013, Bo Cai was arrested at an airport in Los Angeles, CA, after the 

sensor was discovered concealed in a computer speaker in his luggage. Bo Cai was preparing to 

board a flight to China. Wentong Cai was arrested in Iowa in January 2014. Wentong Cai 

pleaded guilty on December 16, 2014 to the three count superseding indictment. This 

investigation was conducted by Homeland Security Investigations, USAF Office of Special 

Investigations, Defense Security Service, FBI.

Information Technology Services and Support to Iran - On July 17, 2014, Randy Dale Barber 

was sentenced in the Middle District of Florida to 60 months probation for conspiracy to commit 

mail fraud. Barber was also ordered to forfeit $413,106 and to pay restitution to Hitachi Data 

Systems (HDS) in the amount of $37,921.20. Barber previously pleaded guilty on February 28, 

2014 to a superseding indictment. On April 30, 2014, Barber’s co-defendants, John Alexander 

Talley and his company, Tallyho Peripherals, Inc. d/b/a Enterprise Solutions Systems, were 

sentenced after pleading guilty on September 17, 2013 to conspiracy to violate the International 

Emergency Economic Powers Act and the Iranian Transaction Regulations. Talley was sentenced 

to 30 months in federal prison, 36 months supervised release and $100 special assessment. 

Tallyho Peripherals, Inc., was sentenced to 12 months probation and $400 special assessment. 

According to plea agreements, from approximately 2009 to September 2012, Barber, Talley and 

his company conspired with others to unlawfully export sophisticated enterprise level computer 

equipment from the United States to Iran, and to provide computer IT support services for the 

equipment, all in violation of the United States embargo. Talley's role was to provide training 

and computer IT support to ensure that the computer equipment operated in Iran. In an effort to 

conceal their activities, the conspirators in the United States caused shipments of the computers 

and related equipment, as well as the payments for same, to travel to and from the United States 

and Iran through the United Arab Emirates. Similarly, payments for Talley's support services 

were transmitted through the United Arab Emirates. On September 12, 2013, two Iranian 

nationals, Mahmood Akbari a/k/a John Wassermann and Reza Hajigholamali, and three United 

Arab Emirate "front" companies, Patco Group Ltd., Managed Systems and Services (FZC), and 

TGO General Trading LLC a/k/a Three Green Orbit, were indicted in connection with the same 

conspiracy to violate the Iranian Embargo. Those parties are charged with conspiracy to violate 

the International Emergency Economic Powers Act and the Iranian Transactions and Sanctions

Regulations, and a conspiracy to commit international money laundering. If convicted, Akbari 

and Hajigholamali each face a maximum penalty of up to 40 years in federal prison. On July 11, 

2012, co-conspirator Mohammad Reza "Ray" Hajian and three of his companies, RH 

International LLC, Nexiant LLC, and P & P Computers LLC, pleaded guilty to conspiracy to 

violate the International Emergency Economic Powers Act and the Iranian Transactions and 

Sanctions Regulations. On October 18, 2012, Hajian was sentenced to 4 years in federal prison 

and ordered to forfeit $10 million. This investigation was conducted by ICE and DOC.

Military Software Used For China's First Modern Attack Helicopter – On July 14, 2014, in the 

District of Connecticut, the court signed an order dismissing the criminal information against 

United Technologies Corporation (UTC) and Hamilton Sundstrand Corporation (HSC) and 

dismissing counts three of the information against Pratt & Whitney Canada Corp. (PWC). 

Previously, on June 28, 2012, PWC, a Canadian subsidiary of Connecticut-based defense 
19

contractor UTC, pleaded guilty to violating the Arms Export Control Act and making false 

statements in connection with its illegal export to China of U.S.-origin military software that was 

used in the development of China's first modern military attack helicopter, the Z-10. In addition, 

UTC, its U.S.-based subsidiary HSC, and PWC all agreed to pay more than $75 million as part of 

a global settlement with the Justice Department and the State Department in connection with 

various export violations, including those related to the Z-10, and for making false and belated 

disclosures to the U.S. government about the illegal exports for the Z-10. A three-count criminal 

information was filed against the companies. Count one charged PWC with violating the Arms 

Export Control Act for the illegal export of defense articles to China for the Z-10 helicopter. 

Specifically, in 2002 and 2003 PWC knowingly and willfully caused HSC military software used 

to test and operate PWC engines to be exported to China for the Z-10 without any U.S. export 

license. PWC knew from the start of the Z-10 project in 2000 that the Chinese were developing 

an attack helicopter and that supplying it with U.S.-origin components would be illegal. 

According to court documents, PWC's illegal conduct was driven by profit. PWC anticipated that 

its work on the Z-10 attack helicopter in China would open the door to a far more lucrative 

civilian helicopter market in China potentially worth as much as $2 billion to PWC. Count two of 

the information charged PWC, UTC, and HSC with making false statements about these illegal 

exports to the State Department in their belated disclosures, which did not begin until 2006. 

Count three charged PWC and HSC for their failure to timely inform the State Department of the 

unlawful export of defense articles to China, an embargoed nation, as required by U.S. export 

regulations. This is the first case in which the provisions in count three have been enforced 

criminally. While PWC pleaded guilty to counts one and two, prosecution of PWC, UTC, and 

HSC on the other charges was deferred for two years, provided that the companies abided by the 

terms of a deferred prosecution agreement with the Justice Department. In addition to the 

resolution of the criminal charges, as part of a global settlement, UTC also resolved over 500 

additional administrative charges with the State Department. Those charges involved more than 

800 exports in violation of the Arms Export Control Act from the mid-1990s to 2011. In 

connection with the global settlement with the Justice and State Departments, PWC, UTC, and 

HSC agreed to pay more than $75 million in penalties, subject themselves to independent 

monitoring for several years, and be required to comply with an extensive training and remedial 

action program to strengthen their export compliance. This investigation was conducted by ICE, 

DCIS, FBI, Commerce and the State Department.

Prohibited Investments in Iran – On June 20, 2014, former Tennessee Valley Authority (TVA) 

vice president, Masoud Bajestani, of Chattanooga, Tenn., was sentenced in the Eastern District of 

Tennessee to 2 years probation, $300 special assessment and the forfeiture of $600,000. On 

September 4, 2013, Bajestani pleaded guilty to violating the International Emergency Economic 

Powers Act and filing false tax returns. On February 4, 2013, agents arrested Bajestani as he 

arrived at the Atlanta airport on a flight from Dubai. Bajestani was charged by superseding 

indictment in the Eastern District of Tennessee with violating the International Emergency 

Economic Powers Act, making false statements to the TVA, international money laundering, 

filing false tax returns and failure to file reports of foreign bank accounts. According to the 

superseding indictment, Bajestani filed a false document with TVA in order to withdraw 

$1,500,000 from his deferred compensation account when he was employed as a vice president at 

the Watts Bar Unit II nuclear power plant during its construction phase. Bajestani then conspired 

with others and sent $600,000 of those funds to Iran for financial investment purposes, without 

authorization from the U.S. Office of Foreign Assets Control. The case was investigated by ICE, 

IRS, the TVA Office of Inspector General, and the FBI.

Electronics Used in Military Radar & Electronic Warfare to China – On April 30, 2014, 

Yufeng Wei, a Chinese national, was re-sentenced to 23 months in prison, 2 years of supervised 
20

released, and $1100 special assessment. Previously, on September 10, 2013, Wei’s now exhusband Zhen Zhou Wu, also a Chinese national, was re-sentenced to 84 months in prison, 2 

years of supervised release, $1700 special assessment, and ordered to pay a $15,000 fine. Wei 

and Wu were re-sentenced for conspiring over a 10-year-period to illegally export military and 

sophisticated electronics used in military phased array radar, electronic warfare, and missile 

systems to the People's Republic of China (PRC) and illegally exporting sensitive electronic 

components to the PRC between 2004 and 2007, in violation of the Export Administration 

Regulations. After serving their convictions, both Wu and Wei, a Lawful Permanent Resident,

will be subject to deportation to the PRC. On March 19, 2013, the U.S. Court of Appeals for the 

First Circuit affirmed both Wei and Wu's convictions on export violation charges for which a jury 

convicted them after a six-week trial in May 2010. The First Circuit vacated two counts of the 

convictions that charged Wei and Wu with illegally exporting parts designated on the United 

States Munitions List because it held that the jury instructions given were constitutionally 

inadequate. However, the First Circuit observed that "from 1996 until 2008, Wei and Wu shipped 

tens of millions of dollars worth of sophisticated electronic components from the United States to 

China with little regard for whether the parts that they sold were export-controlled." Further, the 

First Circuit found that Wu's company "specifically pursued military customers; and Wu 

promoted himself as both an exporter of military supplies and an export compliance expert." 

Lastly, the First Circuit determined that "Wu and Wei repeatedly attempted to disguise the fact 

that they were exporting to China and that they lacked the necessary licenses to do so." Because 

two counts of both Wei and Wu’s convictions were vacated, the case was remanded for resentencing hearings. Wei and Wu were originally sentenced in 2011. Wei was sentenced on 

January 27, 2011 in the District of Massachusetts to 36 months in prison, while on January 26, 

2011, Wu, was sentenced to 97 months in prison. Their company, Chitron Electronics, Inc., was 

fined $15.5 million. Wei, Wu and Chitron Electronics, Inc. were convicted at trial on May 17, 

2010. As proven at trial, defendants illegally exported military electronic components to China 

through Hong Kong. The defendants also illegally exported Commerce Department-controlled 

electronics components to China with military applications such as electronic warfare, military 

radar, and satellite communications systems. Wu founded and controlled Chitron, with 

headquarters in Shenzhen, China and a U.S. office located in Waltham, Mass., where defendant 

Wei served as Manager. Wu and Chitron sold electronics from the U.S. to Chinese military 

factories and military research institutes, including numerous institutes of the China Electronics 

Technology Group Corporation, which is responsible for the procurement, development and 

manufacture of electronics for the Chinese military. Since as early as 2002, Wu referred to 

Chinese military entities as Chitron's major customer and employed an engineer at Chitron's 

Shenzhen office to work with Chinese military customers. By 2007, 25% of Chitron's sales were 

to Chinese military entities. Shenzhen Chitron Electronics Company Limited, Wu's Chinese 

company through which U.S. electronics were delivered to the Chinese military and other endusers, was also indicted. On February 9, 2011, Chitron-Shenzhen received a fine of $1.9 million 

for refusing to appear for trial. On July 22, 2010, co-defendant Bo Li, aka Eric Lee, pleaded 

guilty and was sentenced to time served for making false statements on shipping documents. The 

case was investigated by BIS, ICE, FBI, and DCIS.

Nuclear-Related Dual-Use Equipment to Iran – On April 29, 2014, Li Fangwei, who is more 

commonly known by his alias “Karl Lee,” was charged with violating the International 

Emergency Economic Powers Act (“IEEPA”) by using United States-based financial institutions 

to engage in millions of dollars of U.S. dollar transactions in violation of economic sanctions that 

prohibited such financial transactions. In addition, Fangwei is also charged with conspiring to 

commit wire fraud and bank fraud, a money laundering conspiracy, two separate violations of 

IEEPA, and two separate substantive counts of wire fraud, in connection with such illicit 

transactions. Fangwei, a national of the People’s Republic of China, is a fugitive. According to 
21

the Superseding Indictment, Fangwei controls a large network of industrial companies based in 

eastern China, one of which is LIMMT Economic and Trade Company, Ltd. (“LIMMT”). Over 

the years, Fangwei’s companies have done millions of dollars in business with Iran. This business 

has included selling to Iranian entities various metallurgical goods and related components that 

are banned for transfer to Iran by, among others, the United Nations, because the items are 

controlled by the Nuclear Supplier’s Group (a multinational group that maintains “control lists,” 

which identify nuclear-related dual-use equipment, material, and technology). Fangwei has been, 

among other things, a long-time supplier to Iran’s Defense Industries Organization and Iran’s 

Aerospace Industries Organization. In addition, Fanwei has been a principal contributor to Iran’s 

ballistic missile program through China-based entities that have been sanctioned by the United 

States. In light of his supply of restricted items to Iran, the United States has imposed targeted 

sanctions on both Fangwei and LIMMT. Specifically, the United States Department of the 

Treasury’s Office of Foreign Asset Controls (“OFAC”) publicly added LIMMT (in 2006) and 

Fangwei (in 2009) to its List of Specially Designated Nationals and Blocked Persons (the “SDN 

List”). By virtue of their inclusion on the SDN List, Fangwei and LIMMT were effectively 

precluded from conducting any business within the United States without first obtaining a license 

or authorization from OFAC. Neither Fangwei nor LIMMT has sought such a license or 

authorization. The above-referenced restrictions have forced Fangwei to operate much of his 

business covertly. In response to United States sanctions, Fangwei has built an outsized network 

of China-based front companies – to conceal his continuing participation, and LIMMT’s 

continuing participation, in sanctioned activities. During the period from 2006 through 2014, 

Fangwei used front companies to engage in more than 165 separate U.S. dollar transactions, with 

a total value in excess of approximately $8.5 million. Included in those illicit transactions have 

been transactions involving sales to U.S. companies, sales of merchandise by Fangwei to Iranbased companies utilizing the U.S. financial system, as well as attempts to acquire on behalf of 

Iran-based entities so-called “dual use” items from the United States, China, and other countries 

that could be used in the production of weapons of mass destruction and/or devices used to 

deliver weapons of mass destruction. The U.S. Attorney’s Office and the FBI announced the 

seizure of over $6,895,000 in funds attributable to the Fangwei front companies, and the filing of 

a civil complaint seeking the forfeiture of those funds to the United States. The seized funds are 

substitutes for money held by Fangwei’s front companies at banks in China, and were seized from 

accounts at U.S. banks held in the name of foreign banks used by these front companies to 

conduct U.S. currency transactions. The funds were seized pursuant to seizure warrants issued on 

December 18, 2013, and April 25, 2014. The $6,895,000 represents funds used by the Fangwei 

front companies to engage in transactions that violate the U.S. sanctions laws and thus are subject 

to forfeiture. There are no allegations of wrongdoing by the U.S. or foreign banks that maintain 

these accounts. Because the funds used in those transactions are held in banks overseas, the 

United States is unable to seize the funds directly. This case was investigated by the Federal 

Bureau of Investigation, Department of Justice’s National Security Division Counterespionage 

Section, Department of State, Department of Treasury, and the Department of Commerce.

Military Aircraft Engines to Venezuela – On April 28, 2014, Roy Wayne Roby pleaded guilty 

and was sentenced in the District of Arizona to 18 months in federal prison, 3 years of supervised 

release, and $100 special assessment for his role in a conspiracy to violate the Arms Export 

Control Act. According to court documents, Roby was part of a Venezuelan air force team that 

negotiated with Mesa-based Marsh Aviation between November 2005 and February 2008 to 

refurbish 18 T-76 aircraft engines for use by the Venezuelan air force, under the guise that the 

engines were meant for civilian use. T-76 engines are a designated item on the U.S. Munitions 

List, which, under the Arms Export Control Act, makes it illegal for these engines to be exported 

without a license or written authorization from the Department of State. The T-76 aircraft engine 

was designed for the OV-10 Bronco Aircraft, a light armed reconnaissance aircraft specifically 
22

suited for counter-insurgency missions. Roby and codefendants Guiseppe Luciano MenegazzoCarrasquel, a dual Venezuelan and Italian citizen, and Oscar Rafael Colmenarez-Vellalobos were 

indicted on arms export charges in October 2010. Roby was arrested in Florida on September 4, 

2013. Menegazzo-Carrasquel, a Venezuelan air force colonel, was arrested in September 2012 

after he arrived in Houston on a flight from Caracas, using his Italian passport. On June 3, 2013, 

Menegazzo-Carrasquel pleaded guilty and on August 19, 2013, he was sentenced to 19 months in 

federal prison and 3 years of supervision. Indicted in a separate case, Floyd D. Stilwell, former 

president of Marsh Aviation, was also charged in the scheme. Stilwell pleaded guilty on October 

29, 2012 to conspiracy to violate the Arms Export Control Act and was sentenced on May 13 to a 

$250,000 fine and 5 years of probation. The case was investigated by ICE, DCIS and the FBI.

Dual-Use Items to Pakistan Atomic Energy Commission – On April 2, 2014, in the Middle 

District of Pennsylvania, a federal grand jury returned an Indictment against three individuals and 

two corporations, charging them with smuggling technology out of the United States for use by 

the Pakistan Atomic Energy Commission. The Indictment was unsealed on March 31, 2014, after 

it was determined that none of the individuals were in the United States. The Indictment alleges 

that Shafqat Rana, formerly of Lancaster, Pennsylvania, along with Abdul Qadeer Rana and 

Shahzad Rana, both of Lahore, Pakistan, used two corporations, Optima Plus International, a 

Pennsylvania corporation, and Afro Asian International, a Pakistani corporation, to export goods 

from the United States to Pakistan without first obtaining a license from the Department of 

Commerce. The goods were allegedly shipped through a common carrier in Dauphin County. 

Shafqat Rana allegedly took orders for dual-use items, that is, items with both a commercial and 

military or nuclear application, from Afro Asian and acquired the items in the United States. 

After the items were shipped to Pakistan, they were resold to the Pakistan Atomic Energy 

Commission, an arm of the Pakistani Army, in violation of United States law. The Indictment 

charges that the defendants shipped and exported goods from the United States to restricted endusers in Pakistan while providing false and fraudulent invoices to the freight forwarders, thereby 

causing the freight forwarders to fail to file the required export declarations. The defendants also 

allegedly created false and misleading invoices given to freight forwarders that undervalued and 

mislabeled the goods and listed false purchasers and end-users of the goods. According to the 

United States Attorney’s Office, Shafqat Rana left the United States and returned to Pakistan. 

This case was investigated by U.S. Department of Commerce and the FBI. 

Missiles, Aviation Equipment and Submarine Design Information to Terrorist Organization –

On March 25, 2014, Piratheepan Nadarajah, an alleged operative of the Liberation Tigers of 

Tamil Eelam (LTTE), a designated terrorist organization known as the "Tamil Tigers, was 

sentenced in the Eastern District of New York to 24 months in federal prison, 3 years supervised 

release and $100 special assessment. On October 8, 2013, Nadarajah pleaded guilty to 

attempting to provide material support to a foreign terrorist organization and conspiracy to 

acquire anti-aircraft missiles. Previously, on December 27, 2012, Nadarajah and Suresh 

Sriskandarajah made their initial court appearances in the Eastern District of New York after 

being extradited from Canada. Nadarajah is charged by superseding indictment with conspiring 

and attempting to acquire $1 million worth of anti-aircraft missiles, missile launchers and other 

military equipment, and conspiring and attempting to provide material support to the LTTE. 

Sriskandarajah is charged under a separate indictment with conspiring to provide material support 

to the LTTE and dealing in the property of a specially designated terrorist group. According to 

court filings, between July 1, 2006, and August 19, 2006, Nadarajah and several co-conspirators 

engaged in negotiations with an undercover FBI agent to purchase and export $1 million worth of 

high-powered weapons and military equipment for the LTTE, including 20 SA-18 heat-seeking, 

surface-to-air, anti-aircraft missiles, 10 missile launchers and 500 AK-47s. Nadarajah and his 

associates attempted to acquire these weapons at the direction of senior LTTE leadership in Sri 
23

Lanka, including Pottu Amman, then the LTTE's chief of intelligence and procurement and the 

top deputy to then LTTE leader Velupillai Prabakharan. The anti-aircraft weapons were to be 

used by the LTTE to shoot down Kfir aircraft used by the Sri Lankan military. The remaining coconspirators, Sahilal Sabaratnam, Thiruthanikan Thanigasalam, and Nadarasa Yograrasa, were 

each sentenced in September 2011. Sabaratnam was sentenced on September 23, 2011 to 25 

years imprisonment, 5 years supervised release, and $400 special assessment. Yograrasa was 

sentenced on September 23, 2011 to 14 years imprisonment, three years supervised release, and 

$200 special assessment. Sarachandran was sentenced on September 26, 2011 to 26 months 

imprisonment, 5 years supervised release, and $500 special assessment. Thanigasalam was 

sentenced on September 26, 2011 to 25 years imprisonment, 5 years supervised release and $400 

special assessment. This investigation was conducted by the Newark and New York Divisions of 

the FBI's Joint Terrorism Task Force.

Restricted Electronics to China – On March 23, 2014, General Technology Systems Integration 

was sentenced in the Central District of California to 5 years probation and a special assessment 

of $400. Previously, on October 11, 2010, York Yuan Chang, also known as David Zhang, and 

his wife, Leping Huang, were arrested on charges of conspiring to export restricted electronics 

technology to the People's Republic of China (PRC) without a license and making false 

statements. According to the October 9, 2010 criminal complaint, the defendants are the owners 

of General Technology Systems Integration, Inc., (GTSI), a California company involved in the 

export of technology to the PRC. GTSI allegedly entered into contracts with the 24th Research 

Institute of the China Electronics Technology Corporation Group in China to design and transfer 

to the PRC technology for the development of two-types of high-performance analog-to-digital 

converters (ADCs). The defendants allegedly hired two engineers to design the technology and 

provide training to individuals in the PRC. Twice in 2009, U.S. Customs and Border Protection 

officials stopped the engineers upon their return to the United States and allegedly found 

computer files and documents indicating illegal technology transfer involving GTSI and China. 

According to the complaint, Chang and Huang allegedly sought to cover up the project after 

authorities contacted the engineers. The ADCs that the defendants allegedly attempted to export 

to the PRC are subject to export controls for national security and anti-terrorism reasons. This 

investigation was conducted by the FBI, BIS, ICE, IRS and DCIS.

Ammunition and Night Vision Goggles to Mexico – On March 20, 2014, in the Western District 

of Texas, Oliver Bres-Carranza was sentenced to 51 months in federal prison after pleading 

guilty in October 2013 for his role in a scheme to smuggle defense articles into the Republic of 

Mexico. On January 15, 2014, Erik Alan Garza was sentenced to 44 months in federal prison and 

fined $3,000 for his role in the smuggling scheme. Garza, Bres-Carranza and Rolando Tamayo 

were charged in a June 2012 indictment with multiple counts of aiding and abetting the 

smuggling of goods from the United States. According to the indictment, between June 19, 2010 

and February 17, 2012, Garza and his accomplice, Tamayo, illegally attempted to smuggle 

defense articles into the Republic of Mexico from the United States. Those items included night 

vision monocular goggles, a thermal goggle, 400 sets of AR-15 front and rear flip-up tactical 

sights, approximately 5,000 high-capacity assault rifle magazines and approximately 6,000 

rounds of ammunition, including 100 rounds of .50 caliber ammunition. Tamayo remains a 

fugitive. This case was investigated by ICE and ATF.

Hazardous Materials to Saudi Arabia - On February 21, 2014, Hasan Ibrahim was sentenced in 

the Northern District of California to 30 days imprisonment, 3 years of supervised release, and a 

$2,200 special assessment. Previously, on July 3, 2013, Ibrahim was convicted by a federal jury 

of attempting to place destructive substances on an airplane. The jury found that the defendant 

willfully intended to place 9 different hazardous materials on a Lufthansa passenger airplane 
24

bound for Frankfurt, Germany. The hazardous materials were ultimately destined for Jeddah, 

Saudi Arabia. In related charges, the jury convicted Ibrahim of failing to properly label the 

packages containing the hazardous materials and failing to complete the requisite shipping papers 

as required by the Department of Transportation. On November 2, 2011, a grand jury returned an 

indictment charging MEDCHEM Corporation and its owner Hasan Ibrahim with two counts of 

attempted placement of destructive substance on an aircraft, one count of transportation of 

hazardous materials without shipping papers, nine counts of transportation of hazardous materials 

without labels, one count of failure to file export information, one count of attempted smuggling 

of goods, and one count of attempted smuggling of goods. The charges in the indictment stem 

from MEDCHEM, located in South San Francisco, exporting chemicals (including hazardous 

materials), medical equipment, and diagnostics to Constant Trading Activity ("CTA"), a business 

in Saudi Arabia. Ibrahim was the owner and president of MEDCHEM until one of his sons 

became involved in MEDCHEM prior to June 2010. Ibrahim was MEDCHEM's sole employee. 

Ibrahim was also a founder of CTA and served as CTA's vice president. According to the 

indictment, Ibrahim caused a shipment consisting of five pallets containing sixty-four boxes to be 

delivered to a freight forwarder for export to Saudi Arabia. None of the boxes were labeled as 

containing hazardous material. The shipment contained over 25 separate chemicals designated as 

hazardous materials under the Hazardous Materials Regulations. Two of the hazardous materials 

- Sulfuryl Chloride (classified as a corrosive) and Chloroacetonitrile (classified as poisonous 

material, with a subsidiary hazard that it is a flammable and combustible liquid) - were poisonous 

by inhalation and prohibited under federal law from transportation on any aircraft. The 

indictment against defendant MEDCHEM Corporation was dismissed on June 26, 2013. The 

investigation was conducted by the FBI, Department of Commerce, IRS and Federal Aviation 

Administration.

Firearms Parts to Thailand - On January 24, 2014, two brothers, Nares Lekhakul and Naris 

Lekhakul, were sentenced in the Western District of Washington. Nares Lekhakul, a lawful 

permanent resident living in the State of Washington, was sentenced to two years in prison and 

three years of supervised release. His brother, Naris Lekhakul, a Thai citizen, was sentenced to 

three years in prison. The Lekhakul brothers were arrested in June 2013 in connection with a 

conspiracy to illegally ship firearms parts to Thailand. In their October 2013 plea agreements, the 

brothers admitted that Naris, while living in Thailand, identified the firearms parts he wanted 

ordered and shipped overseas. Initially the gun parts were sent to his brother Nares' home in 

Washington, where Nares attempted to disguise the shipments which were sent on to Thailand. 

After one shipment was seized in 2011, Naris recruited four other people to receive the shipments 

of firearms parts, disguise them, and send them on to Thailand. The co-conspirators did not 

obtain appropriate licenses to make the shipments. The co-conspirators would use fake names 

and fake invoices to try to avoid detection, and they packed various firearms parts in specific 

ways to try to avoid detection by x-ray scanners. Members of the group shipped various firearms 

parts with false labels. In all, the group is believed to be responsible for more than 250 shipments 

of restricted firearms components, worth more than $750,000. The defendants did not ship any 

assembled firearms or entire firearms disassembled. The four codefendants previously pleaded 

guilty. Witt Sittikornwanish and Sangsit Manowanna, U.S. citizens, were each sentenced to ten 

months in prison and Supanee Saenguthai, a Thai citizen residing in California, was sentenced to 

probation. Wimol Brumme, a Thai citizen residing in Nevada, has not yet been sentenced. This 

investigation was conducted by ICE HSI and the USPIS. 

Theft of Military Trade Secrets to Iran – On January 21, 2014, in the District of Connecticut, a 

federal grand jury sitting returned an indictment charging Mozaffar Khazaee, also known as 

“Arash Khazaie,” with two counts of interstate transportation of stolen property. The indictment 

stems from Khazaee’s alleged attempt to ship to Iran proprietary material relating to military jet 
25

engines and the U.S. Air Force’s F35 Joint Strike Fighter program that he had illegally retained 

from defense contractors where he had been employed. As alleged in court documents, federal 

law enforcement agents began investigating Khazaee in November 2013 when officers with U.S. 

Customs and Border Protection Service (CBP), assisted by Homeland Security Investigations 

(HSI) special agents, inspected a shipment that Khazaee sent by truck from Connecticut to a 

freight forwarder located in Long Beach, California, which was intended for shipment from the 

U.S. to Iran. The documentation for Khazaee’s shipment indicated that it contained household 

goods. Upon inspecting the shipment, however, CBP officers and HSI agents discovered that the 

content of the shipment primarily contained numerous boxes of documents consisting of sensitive 

technical manuals, specification sheets, and other proprietary material relating to the U.S. Air 

Force’s F35 Joint Strike Fighter program and military jet engines. Upon further investigation, law 

enforcement learned that Khazaee holds Iranian and U.S. citizenship and, as recently as August 

2013, worked as an engineer for defense contractors, including firms that are the actual owners of 

the technical and proprietary documents and materials in Khazaee’s shipment. Khazaee, who 

became a naturalized U.S. citizen in 1991, and holds a valid U.S. passport. On January 9, 2014, 

Khazaee was arrested by HSI and FBI agents at Newark Liberty International Airport in New 

Jersey after flying from Indianapolis to Newark, before he was able to board a connecting flight 

to Frankfurt, Germany. Khazaee’s ticketed destination was Tehran, Iran. This case is being 

investigated by HSI, CBP, the U.S. Air Force’s Office of Special Investigations, DCIS, and the 

FBI.

Assault Weapon Parts and Gun Sights to Philippines - On January 6, 2014, Romulo Arca 

Reclusado was sentenced in the Central District of California to 60 months imprisonment, three 

years supervised released, a $100 special assessment, and a $7,500 fine. Previously, on June 10, 

2013, Reclusado pleaded guilty to conspiracy to violate the Arms Export Control Act and the 

International Emergency Economic Powers Act. On February 7, 2011, in the District of Arizona, 

codefendant Mike Cabatingan also pleaded guilty to conspiracy. On February 24, 2010, a federal 

grand jury in the Central District of California returned an indictment against Reclusado, 

Cabatingan, and Tirso Armando Aguayo for conspiring to illegally export defense articles and 

other controlled items from the United States to the Philippines. The defendants allegedly 

conspired to export to the Philippines molds used to make components for AR-15 assault rifles, as 

well as holographic rifle sights. Aguayo and Cabatingan were arrested on February 25, 2010. On 

January 12, 2011, the court granted a motion to dismiss the case against Aguayo. Reclusado was 

previously convicted in 1997 of conspiracy to transfer machine guns and illegally transferring 

machine guns for which he received a 27-month prison sentence. The investigation was 

conducted by ICE and DCIS.

Commercial Industrial Machines to Iran - On January 6, 2014, Mark Mason Alexander, a/k/a 

Musa Mahmood Ahmed, was sentenced in the Northern District of Georgia to 18 months in 

prison, followed by three years of supervised release and a $100 special assessment. Alexander 

was found guilty by a jury on September 26, 2013, of Conspiracy to violate the International 

Emergency Economic Powers Act. According to the charges and other information presented in 

court, between October 2006 and June 2008, Alexander conspired with two Iranian businessmen 

to sell Hydrajet water-jet cutting systems to customers located in Iran. Hydrajet Technology, 

located in Dalton, Ga., manufactured the water-jet cutting systems, which were used for the 

precision cutting of materials such as aluminum, glass, granite and steel. These machines were 

distributed to customers in the Middle East through Hydrajet Mena, another company that 

Alexander partly owned. Hydrajet Mena, for which Alexander was the CEO, was located in the 

United Arab Emirates. In 2007, as part of the conspiracy, Alexander negotiated the sale of two 

water-jet cutting systems to companies located in the Islamic Republic of Iran: the Parand 

Machine Company and the Negin Sanat Sadr. Company. In July 2007, after Alexander 
26

negotiated the terms of these sales and before the machines were shipped to the Islamic Republic 

of Iran, the Department of Commerce had conducted a community outreach meeting with 

Alexander, as the CEO of Hydrajet Technology. This outreach program was designed to make 

exporters like Alexander aware of the various export restrictions, including the trade embargo 

against Iran, and to educate exporters about the process for legally exporting items from the 

United States. The evidence further established that the machines that Alexander conspired to 

sell were in fact manufactured in Dalton, Ga. He concealed the true destination of these machines 

by causing them to be trans-shipped to the Islamic Republic of Iran via Alexander's company in 

the United Arab Emirates. Alexander additionally instructed Hydrajet Mena employees to travel 

to Islamic Republic of Iran to install the machines and to conduct software training for the 

Iranians who would operate them. This case was investigated by the U.S. Department of 

Commerce and the Department of Homeland Security.

Industrial Parts to Iran - On December 18, 2013, Mehdi Khorramshahgol was sentenced in the 

Eastern District of Virginia to 36 months in prison. Khorramshahgol was convicted on August 

22, 2013, after a bench trial for violating U.S. economic sanctions on Iran by sending explosiongraded industrial parts to a petrochemical company in Iran. Previously, on April 25, 2013, 

Khorramshahgol was indicted by a federal grand jury on four counts of violating and conspiring 

to violate the United States economic sanction on Iran, one count of conspiring to defraud the 

United States, and one count of aiding and abetting a material false statement. According to court 

records and evidence at trial, the defendant conspired with others in Iran to purchase industrial 

goods from United States businesses for the Iranian petrochemical industry. The defendant 

falsely represented that the end users for his purchases were in Dubai. After the defendant 

purchased the goods and shipped them to Dubai, other co-conspirators repackaged the goods for 

onward shipment to Tehran. The conspiracy used a series of false invoices, false end users, and 

front companies to hide its illicit activity. This case was investigated by HSI and the Department 

of Commerce's Office of Export Enforcement.

Military Aircraft Parts to Iran – On December 12, 2013, Mohammad Tabibi was sentenced in 

the Middle District of Georgia to 38 months in federal prison and a $200 special assessment. 

Tabibi pleaded guilty on August 21, 2012 to conspiring with others to violate the Arms Export 

Control Act, the International Traffic in Arms Regulations and the Iranian Transactions 

Regulations. According to the plea agreement, from March 2010 to May 2011, Tabibi, Hamid 

Seifi, and others conspired to export parts for the F-5 fighter jet from the U.S. to Iran via the 

United Arab Emirates (UAE) without a license. Seifi, who was located in the U.S. and Tabibi 

who was located in the UAE, negotiated over mail the quantity of parts, part numbers, prices, and 

shipping terms for the F-5 fighter jet parts. Seifi would then send shipments from the U.S. to 

Tabibi in Dubai, UAE. Tabibi ultimately provided the F-5 fighter jet parts to his Iranian client. 

In January 2011, a cooperating witness informed federal agents that Tabibi was involved in 

illegal export activity while doing business as New Eras, LLC, located in Dubai, UAE. With the 

assistance of the cooperating witness, Tabibi began conducting business with undercover U.S. 

federal agents in an attempt to purchase parts for an F-5 fighter jet for export to Iran. In e-mails 

and phone calls, Tabibi requested parts for the F-5 fighter jet for export to Iran. The components 

are prohibited for export from the United States to Iran because of the Arms Export Control Act 

and the International Emergency Economic Powers Act. This case was investigated by the 

Department of Homeland Security, Immigration and Customs Enforcement.

Aerospace-Grade Carbon Fiber to China - On December 10, 2013, Ming Suan Zhang, a citizen 

of the People's Republic of China, was sentenced in the Eastern District of New York to 57 

months incarceration. Previously, on August 19, 2013, Zhang pleaded guilty to violating the 

International Emergency Economic Powers Act by attempting to export massive quantities of 
27

aerospace-grade carbon fiber from the United States to China. On September 26, 2012, a 

criminal complaint was unsealed in the Eastern District of New York charging Ming Suan Zhang 

with attempting to illegally export thousands of pounds of aerospace-grade carbon fiber from the 

United States to China. According to the complaint, Zhang was arrested in the United States after 

trying to negotiate a deal to acquire the specialized carbon fiber, a high-tech material used 

frequently in the military, defense and aerospace industries, and which is therefore closely 

regulated by the U.S. Department of Commerce to combat nuclear proliferation and terrorism. 

The complaint alleges that Zhang came to the attention of federal authorities after two Taiwanese 

accomplices attempted to locate large quantities of the specialized carbon fiber via remote 

internet contacts. In July 2012, Zhang allegedly told an accomplice: "When I place the order, I 

place one to two tons. However, the first shipment will be for 100 kg [kilograms]." Shortly 

thereafter, Zhang contacted an undercover law enforcement agent in an effort to finalize the deal 

to export the carbon fiber from New York to China. In one recorded conversation, Zhang stated 

that he had an urgent need for the carbon fiber in connection with the scheduled test flight of a 

Chinese fighter plane. Zhang then arranged a meeting with an undercover agent to take 

possession of a carbon fiber sample, which was to be shipped to China and analyzed to verify its 

authenticity. Zhang was subsequently placed under arrest. This investigation was conducted by 

ICE and BIS.

Submarine and Warship Design Software to Terrorist Organization - On November 26, 2013, 

Suresh Sriskandarajah was sentenced in the Eastern District of New York to 24 months 

imprisonment, 3 years supervised release and $100 special assessment. Previously, on July 2, 

2012, Sriskandarajah pleaded guilty to conspiring to provide material support to a foreign terrorist 

organization, the Liberation Tigers of Tamil Eelam ("LTTE"), also known as the Tamil Tigers, in 

connection with his attempt to procure sophisticated military technology, including submarine 

and warship design software and night vision equipment, for the LTTE. Six of Sriskandarajah's 

co-defendants, Pratheepan Thavaraja, Murugesu Vinayagamoorthy, Namasivaya Viswanathan, 

Nachimuthu Socrates, Karunakaran Kandasamy, and Ramanan Mylvaganam, were previously 

convicted of terrorism-related offenses in connection with their support for the LTTE. As 

detailed in court filings, between September 2004 and April 2006, Sriskandarajah and several coconspirators assisted a principal LTTE procurement officer in researching and acquiring aviation 

equipment, submarine and warship design software, night vision equipment and communications 

technology. Sriskandarajah used students as couriers to smuggle prohibited items into a territory 

in Sri Lanka that was controlled by the LTTE at that time. Additionally, Sriskandarajah helped 

the LTTE launder its proceeds in the United States and elsewhere. Following his indictment in the 

Eastern District of New York, Sriskandarajah, who is a Canadian citizen, was extradited to the 

United States from Canada in December 2012. The LTTE was founded in 1976 and uses illegal 

methods to raise money, acquire weapons and technology, and publicize its cause of establishing 

an independent Tamil state in northern Sri Lanka. The LTTE began its armed conflict against the 

Sri Lankan government in 1983, and utilizes a guerrilla strategy that often includes acts of 

terrorism. At its height, the LTTE controlled most of the northern and eastern coastal areas of Sri 

Lanka. Over the past 19 years, the LTTE has conducted approximately 200 suicide bombings, 

resulting in the deaths of hundreds of victims, and carried out numerous political assassinations. 

In May 2009, the LTTE's forces in Sri Lanka were defeated by the Sri Lankan government. In 

1997, the LTTE was designated by the U.S. State Department as a Foreign Terrorist 

Organization, and the LTTE therefore may not legally raise money or procure equipment or 

materials in the United States. The investigation was conducted by the New York and Newark 

Field Offices of the FBI.

Carbon Fiber and Other Materials to Iran and China - On November 26, 2013, Peter 

Gromacki, a U.S. citizen and resident of Orange County, NY, was sentenced in the Southern 
28

District of New York to 3 months imprisonment, 3 years of supervised release, a $300 special 

assessment, and a fine of $5,000. The defendant also received an Order of Forfeiture/Money 

Judgment in the amount of $135,913.68. Previously, on July 30, 2013, Gromacki pleaded guilty 

to violating the International Emergency Economic Powers Act (IEEPA) by using his NY 

company to illegally export carbon fiber (which has nuclear applications in uranium enrichment 

as well applications in missiles) from the United States to China. According to the indictment, in 

June 2007, Gromacki arranged for the illegal export of more than 6,000 pounds of carbon fiber 

from the U.S. to Belgium, which was then shipped to China. He allegedly made a variety of false 

statements on shipper's export declaration forms. On July 10, 2013, Amir Abbas Tamimi, an 

Iranian citizen, pleaded guilty to violating IEEPA by working to export helicopter component 

parts from the U.S. to Iran, via South Korea. The components were for a particular type of 

helicopter that can be used for military purposes. On July 1, 2013, Hamid Reza Hashemi, an 

Iranian national, pleaded guilty to conspiracy to violate and violating IEEPA by working to 

arrange the illegal export of carbon fiber from the U.S. to Hashemi's company in Iran via Europe 

and the United Arab Emirates. Previously, on December 5, 2012, prosecutors in the Southern 

District of New York unsealed charges against Gromacki, Tamimi, and Hashemi and Murat 

Taskiran, a Turkish citizen, for exporting various goods to Iran and to China, including carbon 

fiber and helicopter components. Hashemi and Taskiran were charged in one indictment. 

Taskiran remains a fugitive. None of the defendants obtained the requisite approval from the 

Department of Treasury for such exports. This investigation was conducted by the FBI, ICE, and 

Department of Commerce.

Firearms to China - On November 15, 2013, in the Eastern District of New York, Zhifu Lin, a 

Chinese national and resident of West Virginia, was sentenced to 108 months imprisonment, 3 

years supervision and $100 special assessment. Previously, on October 4, 2012, Lin, pleaded 

guilty to violating the Arms Export Control Act and engaging in illegal weapons trafficking. 

Lin's plea came after co-defendant Joseph Debose, a resident of North Carolina and former Staff 

Sargent in a U.S. Special Forces National Guard Unit, pleaded guilty on September 6, 2012 to 

violating the Arms Export Control Act. Lin, Debose and others exported multiple shipments of 

firearms from the U.S. to China by secreting them in packages and transporting them to shipping 

companies, including one in Queens, N.Y., to be sent to China. The weapons included numerous 

semiautomatic handguns, rifles, and shotguns. The smuggling scheme came to light after 

authorities in China seized a package containing firearms with defaced serial numbers shipped 

from Queens, N.Y. Thereafter, U.S. agents traveled to China and examined the firearms. Using 

forensic techniques, agents learned that one of the seized weapons had originally been purchased 

in North Carolina. Among the weapons seized in China were those Debose provided to his 

associates for export. On May 20, 2012, Debose was arrested in Smithfield, N.C., pursuant to a 

May 17, 2012 criminal complaint charging him with illegally exporting firearms to China without 

the required licenses. Lin and another Chinese national, co-defendant Lila Li, were also arrested 

and charged in connection with the case in an April 16, 2012 indictment in the Eastern District of 

New York. This investigation was conducted by ICE, ATF, IRS and BIS

Circuit Boards Supplied to the U.S. Navy by Taiwan Company - On October 28, 2013, in the 

Western District of Washington, a Woodinville, WA based company and its owner were 

sentenced for violating the Arms Export Control Act and for wire fraud. The company, Precision 

Image Corporation, is operated by owner, Chih-Kwang Hwa, out of his Woodinville home. Hwa 

obtained contracts to supply circuit boards to the U.S. Navy, by falsely claiming the boards would 

be manufactured in the United States. Instead, Hwa illegally sent restricted information to a 

company in Taiwan for the boards to be manufactured there. The company was fined $300,000 

for violating the Arms Export Control Act. Hwa was sentenced for wire fraud to 4 months in 

prison, and 6 months of home detention as part of his 2 years of supervised release. According to 
29

the charging information and the plea agreements in the case, between 2009 and 2011, Hwa 

obtained contracts worth $180,034 to supply circuit boards to the U.S. Navy. The Navy supplied 

technical data to Precision Image that contained the technical specifications for the circuit boards. 

This technical data was designated on the United States Munitions List, International Traffic in 

Arms Regulations. As a result, this technical data could not legally be transmitted outside the 

United States without a license from the U.S. State Department. Hwa knew about this restriction 

at the time he received the technical data from the Navy. Hwa did not get the appropriate licenses, 

and sent the restricted data to the Taiwan manufacturer. One of the transmissions occurred in 

September 2011, and the Taiwanese manufactured circuit boards were later provided to the Navy. 

In addition, many of the contracts awarded to Hwa were set aside for companies that promised to 

manufacture the boards in the United States. Hwa falsely represented to the Navy in connection 

with these contracts that the boards were being manufactured in the United States, when instead 

they were being manufactured in Taiwan. This investigation was conducted by ICE HSI and the 

Naval Criminal Investigative Service.

Defense Materials to India - On October 28, 2013, in the District of New Jersey, Hannah Robert, 

the owner of two New Jersey defense contracting businesses, was arraigned for allegedly 

transmitting military blueprints to India without a license, in violation of export laws. She was 

indicted by a federal grand jury on October 10, 2013, on one count of violating the Arms Export 

Control Act and one count of conspiracy to violate the act. According to the documents filed in 

this case and statements made in court, Robert was the founder, owner, and President of One 

Source USA LLC, a company located at her then-residence in Mount Laurel, N.J., and contracted 

with the U.S. Department of Defense (DoD) to supply defense hardware items and spare parts 

pursuant to government contracts. In September 2012, Robert opened a second defensecontracting company, Caldwell Components Inc., based at the same address in Mount Laurel. 

Along with "R.P," a resident of India, Robert owned and operated a company in India, One 

Source (One Source India), that manufactured at its own facility defense hardware items and 

spare parts. From June 2010 to December 2012, Robert and R.P. conspired to export to India 

defense technical drawings without obtaining the necessary licenses from the U.S. Department of 

State. The exported technical drawings include parts used in the torpedo systems for nuclear 

submarines, in military attack helicopters, and in F-15 fighter aircraft. Robert allegedly lied on 

her bids for DoD contracts, stating that she would be supplying American-made products and that 

her N.J.-based company was a manufacturer, rather than a dealer, of defense spare parts. One 

Source USA also subcontracted to other American defense contractors, including those in Sussex 

County, N.J., and Boca Raton, Fla. Robert provided export-controlled items made in India to 

these defense contractors in the United States in such a way as to appear to the DoD that the items 

were manufactured in this country. In addition to United States' sales, Robert and R.P. sold 

defense hardware items to foreign customers. Robert transmitted export-controlled technical data 

to R.P. in India so that Robert and R.P. could submit bids to foreign actors, including those in the 

United Arab Emirates (UAE), to supply them or their foreign customers with defense hardware 

items and spare parts. Neither Robert nor R.P. obtained approval from the U.S. Department of 

State for this conduct. On August 23, 2012, R.P. e-mailed Robert from India requesting the 

technical drawing for a particular military item. R.P.'s e-mail forwarded Robert an e-mail from an 

individual purporting to be "an official contractor of the UAE Ministry of Defence," and who 

listed a business address in Abu Dhabi, UAE. The UAE e-mail requested quotations for a bid for 

the "blanket assembly" for the CH-47F Chinook military helicopter and listed the "End User" for 

the hardware item as the UAE Armed Forces. Later that same day, Robert replied to R.P.'s e-mail, 

attaching, among other things, the electronic file for an export-controlled technical drawing titled 

"Installation and Assy Acoustic Blankets, STA 120 CH-47F," to be used in the Chinook attack 

helicopter. Starting in October 2010, Robert transmitted the military drawings for these parts to 

India by posting the technical data to the password-protected website of a Camden County, N.J., 
30

church where she was a volunteer web administrator. This was done without the knowledge of the 

church staff. Robert e-mailed R.P. the username and password to the church website so that R.P. 

could download the files from India. Through the course of the scheme, Robert uploaded 

thousands of technical drawings to the church website for R.P. to download in India. On June 25, 

2012, R.P. e-mailed Robert from India, stating in part: "Please send me the church web site 

username and password." The e-mail was in reference to both an invoice to, and a quote for, an 

individual known to Robert as a broker of defense hardware items for an end-user in Pakistan. 

This individual (the "Pakistan trans-shipper") employed a UAE address for shipping purposes. 

Later that day, Robert replied to this e-mail, providing a new username and password for the 

church website so that R.P. could download the particular defense drawings. There were quality 

issues with the parts that Robert provided to the DoD. After the DoD in October 2012 disclosed 

the failure of certain parts used in the wings of the F-15 fighter aircraft, supplied by one of One 

Source USA's American customers, Robert and R.P. provided the principal of that company with 

false and misleading material certifications and inspection reports for the parts. These documents, 

to be transmitted to the DoD, listed only One Source USA's New Jersey address and not the 

address of the actual manufacturer in India, One Source India. As a result of the failed wing pins, 

the DoD grounded approximately 47 F-15 fighter aircraft for inspection and repair, at a cost 

estimated to exceed $150,000. Robert was, until November 2012, an employee of a separate 

defense contractor in Burlington County, N.J., where she worked as a System Analyst and had 

access to thousands of drawings marked with export-control warnings and to information on this 

defense contractor's bids on DoD contracts. During her employment, Robert misrepresented to 

her employer the nature and extent of her involvement with One Source USA. This investigation 

was conducted by DoD, DCIS, DHS HSI, Counter Proliferation Investigations.

Surface-to-Air Missiles to Iran - On October 25, 2013, the Southern District of New York 

announced the unsealing of charges against Reza Olangian, a dual citizen of the United States and 

Iran, in connection with his efforts to acquire surface-to-air missiles ("SAMs") for the 

government of Iran. The 4-count indictment charged Olangian with conspiring to acquire and 

transfer surface-to-air missile systems, attempting to acquire and transfer surface-to-air missile 

systems, conspiring to violate the International Emergency Economic Powers Act ("IEEPA") and 

attempting to violate IEEPA. Olangian was arrested in Estonia on October 10, 2012, pursuant to a 

U.S. request for his provisional arrest. He was extradited to the United States on March 26, 2013. 

According to the allegations in the Indictment, in 2007, Olangian worked with Iranian officials to 

obtain approximately 100 SAMs for use by the Iranian government. Ultimately, that missile deal 

was unsuccessful. Beginning in early 2012, Olangian worked to negotiate a separate missile deal, 

this time with a confidential source (CS) working with the DEA, who purported to be a weapons 

and aircraft broker. From his base of operations in Tehran from approximately May 2012 

through October 2012, Olangian arranged for the purchase of "IGLA-S" SAMs and various 

aircraft components. During a covertly recorded meeting in May 2012, and in subsequent 

recorded conversations and e-mails with the CS, he described in detail his plans for procuring the 

SAMs and aircraft parts and then smuggling them over land into Iran, from Afghanistan or 

another neighboring country. Olangian's 2012 negotiations included his participation in a 

videoconference with the CS, during which Olangian remotely inspected a bona fide SAM, which 

the CS presented as a sample of the larger quantity of SAMs that Olangian sought to purchase. 

After inspecting the SAM and inquiring about its specifications, Olangian stated that he would 

want "at least 200...minimum 200" of such SAMs. In his communications with the CS, Olangian 

also indicated that he was arranging for a missile expert to inspect and test the SAMs. In October 

2012, Olangian traveled to Estonia, where he was arrested. Following his arrest, Olangian stated, 

among other things, that he had been working with Iranian government officials; that the SAMs 

he had arranged to purchase were being obtained for the Iranian government; and that the aircraft 
31

parts he attempted to acquire were to be used in Iranian military aircraft. This investigation was 

conducted by the DEA, DOJ's Office of International Affairs, and NSD.

Military Weapons Parts and Accessories Overseas - On October 10, 2013, Christopher M. Gray 

was sentenced in the District of Columbia to 36 months imprisonment. Gray was also ordered to 

pay $6,990 in restitution and a $100,000 fine. On June 17, 2013, Gray pleaded guilty to one 

count of unlawfully exporting and attempting to export ACOG Riflescopes from the United 

States to Thailand, in violation of the Arms Export Control Act. The operator of an online 

business in Buffalo called "Hidden Treasures," Gray made his initial appearance on April 15, 

2013 pursuant to a federal indictment charging him with 12 counts of illegally exporting defense 

articles abroad. Gray allegedly exported a variety of combat optical gun sights, tactical sights, 

scopes and other military items to the following locations -- Hong Kong, Thailand, Ukraine, 

Turkey, South Korea, Spain, France, New Zealand and Canada -- without the required State 

Department licenses. 

Components for IEDs to Iran and Iraq - On September 20, 2013, in the District of Columbia, 

defendants Lim Kow Seng and Hia Soo Gan Benson were sentenced to 37 months and 34 months 

imprisonment, respectively. Previously, on June 26, 2013, Seng and Benson pleaded guilty for 

their roles in a conspiracy to defraud the United States. Seng and Benson made their initial court 

appearances in the District of Columbia on December 21, 2012, after being extradited from 

Singapore. Prosecutors in the District of Columbia unsealed a September 15, 2010 indictment 

which charged four individuals in Singapore, another individual in Iran, and four companies with 

various violations, including conspiracy to defraud the United States, smuggling, illegal export of 

goods to Iran, illegal export of defense articles, false statements and obstruction of justice. 

Among other things, the indictment alleged that the defendants participated in conspiracies to 

defraud the United States, including a conspiracy that allegedly caused 6,000 radio frequency 

modules to be illegally exported from the United States to Iran via Singapore, at least 16 of which 

were later found in Improvised Explosive Devices (IEDs) in Iraq. The defendants were Iranian 

national Hossein Larijani, and his companies Paya Electronics Complex, based in Iran, and Opto 

Electronics Pte, Ltd., based in Singapore. Also charged was Wong Yuh Lan, an agent of Opto 

Electronics who was allegedly supervised by Larijani from Iran. The indictment also charges 

NEL Electronics Pte. Ltd., a company in Singapore, along with NEL's owner and director, Lim 

Yong Nam. Finally, the indictment charges Corezing International Pte. Ltd., a company in 

Singapore that maintained offices in China, as well as Seng, an agent of Corezing, and Benson, a 

manager, director and agent of Corezing. On October 24, 2011, authorities in Singapore arrested 

Wong, Nam, Seng and Benson pursuant to a U.S. extradition request. Larijani remains a fugitive 

in Iran. The indictment alleges that, between June 2007 and February 2008, the defendants 

fraudulently purchased and caused 6,000 modules to be illegally exported from a Minnesota 

company through Singapore, and later to Iran, in five shipments, knowing that the export of U.S.-

origin goods to Iran was a violation of U.S. law. The defendants allegedly told the Minnesota 

firm and the U.S. government that a telecommunications project in Singapore was the final

destination of the goods. The alleged recipient of all 6,000 modules in Iran was Larijani. The 

indictment alleges that, in May 2008, December 2008, April 2009, and July 2010, Coalition 

forces found no less than 16 of these 6,000 modules in Iraq where they were being used as part of 

the remote detonation devices of unexploded IEDs. The indictment further charges Seng, 

Benson, and Corezing with a separate fraud conspiracy involving the illegal export of two types 

of military antenna from the United States. The indictment alleges that these defendants 

conspired to defraud the United States by causing a total of 55 cavity-backed spiral antennas and 

biconical antennas to be illegally exported from a Massachusetts company to Singapore and Hong 

Kong without the required State Department license. Larijani was also charged with false 

statements in connection with his alleged business dealings with Majid Kakavand, an accused 
32

Iranian procurement agent who has been indicted in the United States for illegally exporting 

goods to Iran, including to military entities in Iran involved in that nation's nuclear and ballistic 

missile programs. In coordination with the criminal actions by the Justice Department, the 

Commerce Department announced on October 25, 2011 the addition of 15 persons located in 

China, Hong Kong, Iran and Singapore to the Commerce Department's Entity List in connection 

with this procurement network. Among others, Action Global, Amaze International and OEM 

Hub Co., Ltd., all Hong Kong entities, were added to the Commerce entity list based on 

information indicating that they served as front companies and were related to the other entities 

named in this procurement network, including Corezing International. Furthermore, Luo Jie, 

director of Corezing International, Action Global and Amaze International, was added to the 

entity list on the basis of information indicating that she was specifically involved in the 

procurement and attempted procurement of U.S. power amplifiers intended for end-users in 

China, as well as in the diversion of various U.S.-origin goods through Hong Kong to Iran. 

Similarly, Zhou Zhenyong, director of Corezing International, was added to the Commerce list 

based on information that he was involved in the procurement of U.S.-origin items, including 

U.S.-origin munitions items destined for end-users in China and/or Iran. On February 10, 2012, a 

Singapore court ruled that the four individuals held in Singapore could be extradited to the United 

States to face prosecution for their alleged roles. In August 2012, another court in Singapore 

found that only Seng and Benson could be extradited to the United States to stand trial on charges 

related to the illegal export of military antennas. This investigation was conducted by ICE, FBI 

and Department of Commerce's BIS.

Acoustic Transducer and Other Technology Through U.A.E. to Iran – On September 13, 2013, 

Omidreza Khademi, an Iranian national who resides in the United Arab Emirates, was sentenced 

in the District of Columbia to 29 months in a federal prison, $100 special assessment, and ordered 

to forfeit $4,400. Previously, on May 28, 2013, Khademi pleaded guilty to his role in a 

conspiracy to violate the International Emergency Economic Powers Act and the Iranian 

Transaction Regulations. Khademi was the owner and managing director of Omid General 

Trading Company LLC, which is located in Dubai, U.A.E. Through Omid General Trading 

Company, Khademi conspired to transfer U.S.-origin goods through third countries to Iran on 

behalf of Iranian procurement companies on at least four occasions between February 2010 and 

September 2011. Khademi worked with co-conspirators Companies A and B, who were both 

Iranian supply companies operated by Iranian citizens, Individuals A and B. In his plea 

agreement, Khademi admitted to shipping U.S.-origin goods, to include a PCI Express Analog 

Input Board and related breakout board and cables, laptop computers, a side scan system and an 

underwater acoustic transducer from the U.S. through other countries to Iran without first 

obtaining a license from the Department of the Treasury, Office of Foreign Assets Control to 

export U.S.-origin goods from the United States to Iran.

Manhattan Office Building Secretly Owned and Controlled by Government of Iran - On 

September 17, 2013, in the Southern District of New York, a decision was issued granting 

summary judgment in favor of the United States' claims for forfeiture of the 36-story Midtown 

Manhattan office building located at 650 Fifth Avenue, New York, New York ("the Building"), 

as the result of violations of the Iranian Transactions Regulations promulgated under the 

International Emergency Economic Powers Act ("IEEPA"), and the federal money laundering 

statutes. The Court found that the partners of the Building's owner, the Alavi Foundation and 

Assa Corp., committed the IEEPA violations and money laundering offenses. According to the 

amended civil forfeiture Complaint and the oral and written opinions issued by Judge Forrest in 

this case: The Alavi Foundation has been providing numerous services to the Iranian 

Government, including managing the Building for the Iranian Government, running a charitable 

organization for the Iranian Government, and transferring funds from 650 Fifth Avenue Company 
33

to Bank Melli Iran ("Bank Melli"), a bank wholly owned and controlled by the Government of 

Iran. Likewise, Assa Corporation and Assa Company Limited ("Assa Co. Ltd.") have been 

providing numerous services to Bank Melli in contravention of IEEPA and the Iranian 

Transactions Regulations promulgated thereunder, including transferring rental income generated 

from 650 Fifth Avenue Company to Bank Melli, following Bank Melli's instructions with regard 

to Assa Corporation's affairs, reporting back to Bank Melli on Assa Corporation's financial 

situation and business dealings, and managing the affairs of Assa Corporation for the benefit of 

Bank Melli. The Alavi Foundation owns 60 percent of 650 Fifth Avenue Company, and Bank 

Melli owns 40 percent of 650 Fifth Avenue Company, through Assa Corp. and Assa Co. Ltd. On 

December 17, 2008, a civil Complaint was filed seeking forfeiture of the 40 percent interest held 

by Assa Corporation in 650 Fifth Avenue Company. In the Amended Complaint, the United 

States seeks to forfeit all right, title and interest in 650 Fifth Avenue Company, including the 

Alavi Foundation's 60 percent interest in the company. The United States also seeks to forfeit the 

contents of bank accounts held by 650 Fifth Avenue Company, the Alavi Foundation, and Assa 

Corporation, as well as other real properties owned by the Alavi Foundation. Claims against the 

building in this consolidated action by private parties holding judgments against the Government 

of Iran remain pending. The investigation was conducted by the FBI, IRS, CID, and the Joint 

Terrorism Task Force.

Spacecraft Navigation and Control Technology to Iran - On September 16, 2013, Aurel Fratila, 

a Romanian citizen and aeronautical engineer, was sentenced in the Southern District of 

California to 18 months in prison after pleading guilty on June 25, 2013. Fratila was extradited to 

the United States on February 8, 2013 from Romania to stand trial on charges of conspiracy to 

violate the Arms Export Control Act and to smuggle goods from the United States; conspiracy to 

launder money; money laundering and aiding and abetting stemming from an alleged plot to 

supply Iran with U.S.-origin military accelerometers and other defense articles. On October 17, 

2006, Fratila and co-defendant Jamshid Ghassemi, an Iranian national, were charged in an 

indictment in connection with their alleged efforts to illegally obtain 12 Honeywell military 

accelerometers, as well as Honeywell gyroscopes, from an individual in the U.S., and arrange for 

them to be smuggled to Romania so they could then be transshipped to Iran. The accelerometers 

are used for spacecraft navigation and control systems and classified as defense articles requiring 

a State Department license for export. According to the charges, Ghassemi and Fratila caused 

$70,000 to be wire transferred from a bank in Romania to San Diego for the devices, which were 

to be sent to Bucharest. On November 13, 2006, Ghassemi was arrested by Thai police in 

Bangkok pursuant to a U.S. provisional arrest warrant after he agreed to meet with a U.S. 

confidential source there. During the subsequent extradition proceeding in Thailand, Ghassemi's 

attorney filed a motion with the Thai court citing letters from Iran's Ambassador to Thailand 

confirming that Ghassemi was a "high-ranking officer of the Iranian Air Force" who was merely 

carrying out orders by the Iranian Air Force to obtain accelerometers and that the money for the 

accelerometers came from the Iranian government. On July 2, 2007, a lower court in Thailand 

ruled against the U.S. extradition request, finding that Ghassemi's actions were military in nature. 

The ruling was appealed by Thai prosecutors on July 27, 2007, who argued that a person's 

military status does not entitle that person to commit crimes. The Thai appeals court denied the 

appeal and Ghassemi was released from Thai custody in late September 2008. Ghassemi remains 

a fugitive. The investigation was conducted by ICE and DCIS.

Computer Components to Iran - On August 27, 2013, Business Machinery World Wide, an 

Iranian corporation based in Tehran, Iran, and two of its subsidiaries, Servex DWC, LLC and 

Ariana General Trading, pleaded guilty to conspiring to violate the International Emergency 

Economic Powers Act, and were each sentenced to 5 years of probation and a $50,000 fine. On 

March 7, 2013, a superseding indictment filed in the Eastern District of Virginia against an 
34

Iranian corporation, its subsidiaries and several of its officers and business partners alleged that 

they illegally exported more than $30 million in computer goods from U.S. companies to Iran. 

Those charged include Business Machinery World Wide, an Iranian corporation based in Tehran, 

Iran; three of its subsidiary companies located in Dubai, United Arab Emirates; and nine officers 

and individuals. They were accused of conspiring to defraud the United States and conspiring to 

violate the International Emergency Economic Powers Act. The original indictment and criminal 

complaint were made public on December 19, 2012, after two alleged conspirators - Alireza 

Beshcari and Mikaeil Ghahramani - were arrested in Los Angeles, Calif. According to the 

charges, beginning in 2008, BMWW began soliciting and receiving computer goods from the 

United States knowing that this conduct was prohibited under U.S. law. To avoid detection and 

to facilitate the shipment of goods from the United States to Iran, BMWW directed the U.S. 

goods to be shipped to its subsidiary companies in the United Arab Emirates. These subsidiaries 

were created solely to illicitly transship the U.S. goods to Iran and evade the export embargo. 

Those charged include the following: BMWW, aka Jahan Gostar Co., the parent company 

operating in Iran; BMWW DWC LLC, which later changed its name to Servex DWC, LLC, a 

subsidiary of BMWW based in Dubai that allegedly received $2.8 million in U.S.-origin goods 

for transshipment to Iran; Ariana General Trading, a subsidiary of BMWW based in Dubai that 

allegedly received more than $28 million in U.S.-origin goods for transshipment to Iran; Alireza

Faraj Tabrizy, aka Ali Faraji, a citizen of Iran and the managing director of BMWW, Ariana and 

Servex; Siyavash Aliakbar Yazdanfar, a citizen of Iran and the international affairs manager for 

BMWW; Ayoub Ali Ahmadi, the former lead manager at Ariana and current lead manager for 

Servex allegedly responsible for coordinating transshipment of U.S.-origin goods from Dubai to 

Iran; Michelle Liboon Diaz, the former front-line manager at Ariana and current front-line 

manager at Servex allegedly responsible for coordinating transshipment of U.S.-origin goods 

from Dubai to Iran; Esmaeil Ghahremani, an Iranian citizen with ties to the United States who 

allegedly relies on BMWW to unlawfully export U.S.-origin goods to Iran through Duba; Ehsan 

Mahmoud Ghorbanali Barati, an Iranian citizen who allegedly relies on BMWW to unlawfully 

export U.S.-origin goods to Iran through Dubai; Amir Mazlomian, a naturalized U.S. citizen of 

Iranian descent living in Newport Coast, Calif., and an officer with D&A Trading Corp., which 

has allegedly shipped nearly $300,000 in computer-related goods to Iran through BMWW and 

Ariana; Alirez Beshcari, a citizen of the Netherlands and a legal permanent resident in the U.S. 

living in Laguna Niguel, Calif., who owns ATA Trade Co., which has allegedly shipped nearly 

$800,000 in electronic goods to Iran through BMWW and Ariana; and Mikaeil Ghahramani, of 

Santa Ana, Calif., who owns Notebook Spectrum, which has allegedly shipped nearly $2 million 

in electronic equipment to Iran through BMWW and Ariana. On August 27, 2013, the 

superseding indictment was dismissed against Alireza Beshcari, Mikaeil Ghahramani, Alireza 

Faraj Tabrizy, Siyavash Aliakbar Yazdanfar, Ayouo Ali Ahmadi, Michelle Liboon Diaz, Esmaeil 

Ghahremani, and Ehsan Mahmoud Ghorbanali Barati. This investigation was conducted by ICE 

and Commerce's BIS.

Thermal Imaging Scopes and Cameras to Belarus - August 21, 2013, Ernest Chornoletskyy was 

sentenced in the Eastern District of Pennsylvania to 15 months in prison for conspiring to export 

military-grade night vision devices to Belarus in violation of the Arms Export Control Act and 

the International Emergency Economic Powers Act (IEEPA). On August 10, 2011, an indictment 

was returned charging Chornoletskyy, as well as Vitali Tsishuk, Yahor Osin, Aliaksandr Belski, 

Aliaksandr Stashynski, and Volha Dubouskaya with conspiracy to export defense articles without 

a license and conspiracy to violate IEEPA. Osin, Belski and Tsishuk were further charged with 

conspiracy to launder monetary instruments. According to the indictment, from January 2008, to 

early August 2011, the defendants conspired to illegally export to Belarus numerous defense 

articles, including ThOR 2 Thermal Imaging Scopes, AN/PAS-23 Mini Thermal Monoculars, and 

Thermal-Eye Renegade-320s without State Department licenses. During this period, they also 
35

allegedly conspired to illegal export Commerce-controlled items to Belarus, including L-3 x 

200xp Handheld Thermal Imaging Cameras without a Commerce Department license. Belski 

was sentenced on July 19, 2013 to 57 months in prison after pleading guilty on December 6, 

2012. Dubouskaya was sentenced to 6 months in prison on February 6, 2013 after pleading guilty 

on November 7, 2012. Stashynski was sentenced to 6 months in prison on November 28, 2012 

after pleading guilty on February 28, 2013. Tsishuk was sentenced to 24 months in prison on 

February 14, 2013 after pleading guilty on October 28, 2011. Osin pleaded guilty on February 

29, 2012.

Satellite Technology to Iran - On August 16, 2013, Seyed Amin Ghorashi Sarvestani, an Iranian 

national, was sentenced in the Southern District of New York to 30 months in prison, a fine of 

$100,000 and the forfeiture of $54,000 for conspiring to export goods, including satellite 

technology and hardware, from the United States to Iran, in violation the International Emergency 

Economic Powers Act. Ghorashi was arrested on October 3, 2012, and pleaded guilty on May 8, 

2013. According to the Complaint, Ghorashi was an owner of, and served as a managing director 

and director of, two related companies based in the United Arab Emirates. In that capacity, he 

worked with others to export electronic equipment used for satellite communications and data 

transfer, as well as other goods, from the U.S. to Iran, without the requisite approval from OFAC. 

Ghorashi and others conspired to acquire satellite technology and hardware from a supplier based 

in the U.S., for shipment to Iran. To conceal the true destination of the goods from the U.S. 

supplier, Ghorashi and his co-conspirators arranged for the items to be shipped first to the United 

Arab Emirates and subsequently shipped to Iran. This case was investigated by the FBI, ICE, 

DCIS, BIS, OEE, and CBP.

Inertial Navigation Units to the UAE & Turkey - On August 14, 2013, Junaid Peerani, a resident 

of Broward County, Fla., and the owner of AEROTEK 2000, INC., was sentenced to 46 months 

in prison and a $10,000 fine for knowingly and willfully attempting to export and cause to be 

exported from the United States to Turkey two Inertial Navigation Unit LTN-72's, without first 

having obtained the required authorization from the United States Department of Commerce. 

Peerani was indicted in the Southern District of Florida on December 11, 2012 and pleaded guilty 

on April 2, 2013 for violations of the International Emergency Economic Powers Act. According 

to the Indictment, in March 2011, Peerani attempted to export to the United Arab Emirates an 

inertial navigation unit that is controlled for export by the Commerce Department for missile 

technology and anti-terrorism reasons. The item, which is a laser gyro replacement for the 

mechanical inertial navigation system used on many military transport and commercial aircraft, 

was seized by U.S. border authorities before departing the United States. Peerani also allegedly 

attempted to export two additional inertial navigation units to Turkey in September 2012 without 

obtaining the requisite Commerce Department export license. This investigation was conducted 

by ICE.

Military Night Vision Equipment to New Zealand - On July 11, 2013, in the District of 

Maryland, Anthony Torresi was sentenced to 18 months in prison followed by 3 years of 

supervised release for unlawfully exporting military grade night vision equipment. According to

his plea agreement on February 28, 2013, Torresi listed night vision goggles and night vision 

monoculars for sale on eBay. The items were designed to enable military ground troop personnel 

to conduct night operations. A license from the U.S. Department of State is required to export the 

items. Selling such items overseas without a license is a violation of the Arms Export Control 

Act. On January 21, 2011, Torresi sold two of the night vision goggles for $7,039.99 to an 

undercover agent he believed to be located in New Zealand, but who was in fact located in 

Baltimore. Torresi exported the goggles on February 11, 2011 from Miami, Florida to New 

Zealand. The shipping label signed by Torresi falsely showed the contents as a "gift" described 
36

as a "Rangefinder" valued at $70. Torresi never applied for a license to export these items. 

Similarly, on March 29, 2011, Torresi sold a 6015-4 night vision monocular to the undercover 

agent he believed to be located in New Zealand for $6,099.89. On April 29, 2011, Torresi also 

exported from Miami to New Zealand what he falsely represented to the customers as a 6015-4 

night vision monocular. He sold the monocular for $6,099.98. The monocular shipped by 

Torresi was lower grade and purchased by Torresi for $266. This investigation was conducted by 

ICE. 

Firearms to Liberia - On June 20, 2013, McHarding Degan Galimah was sentenced in the 

District of Minnesota to 30 months in prison for smuggling firearms from the United States to his 

home country of Liberia. Galimah was indicted on August 22, 2012, and convicted on February 

14, 2013. The evidence presented at trial proved that Galimah purchased 12 firearms from a 

federally licensed firearms dealer, including seven Hi-Point, nine-millimeter handguns. In 

November 2010 and July 2011, he exported those weapons to Liberia and then made several trips 

to that country to take possession of the firearms for resale at a profit. At no time did he possess a 

license to transport the firearms, as required by federal law. Moreover, federal regulations 

prohibit the export of firearms to Liberia. This case was investigated by ICE and ATF. 

Firearms to Colombia –On June 13, 2013, Patrick Brewer Regan was sentenced in the Southern 

District of Texas to over 8 years imprisonment. His codefendant, Nicolas Ryan Alig was 

sentenced to 2 years of probation. Pursuant to an indictment dated April 6, 2011, Regan and Alig 

both pleaded guilty on January 19, 2012, to their respective roles in a conspiracy to provide false 

written statements in connection with obtaining firearms licenses. Regan also pleaded guilty to 

acting as a firearms dealer without having the proper federal license to do so, possession of 

firearms with obliterated serial numbers, and possession of an unregistered firearm. On March 8, 

2011, Regan, and his Colombian-born wife, Ximena del Pilar Echeverry Arias were arrested on a 

criminal complaint charging the couple with conspiracy, smuggling goods from the United States 

and possession of a firearm with an obliterated serial number. In December 2010, agents saw 

Regan and Arias ship numerous boxes addressed to recipients in Colombia. An examination of 

those boxes resulted in a determination that the name of the addressee was fictitious, the shipping 

address was an abandoned residence in Colombia, the shipper's name and address was fictitious 

and the contents falsely described. The boxes contained 16 firearms and each had its serial 

number obliterated. Agents intercepted two subsequent firearms shipments allegedly made by 

Regan to Colombian addresses. Records obtained during the investigation showed Arias, while 

living in Colombia, had allegedly signed for 12 of the 67 similarly suspicious packages addressed 

to her home and wire transferred more than $39,000 from a bank in Colombia to Regan's account 

in the United States. At the time of the arrests, agents seized 50 lower and 13 upper receivers for 

AR-15 style semi-automatic rifles, an unregistered fully assembled short-barrel AR-15 rifle, two 

pieces of metal working machinery and 13 AR-15 style lower receivers. The Colombian National 

Police arrested three individuals in Colombia and dismantled a workshop where firearms were 

being assembled from the lower receivers Regan and Arias allegedly supplied and other essential 

components. On March 9, 2012, the indictment against Arias was dismissed. This investigation 

was conducted by ATF and ICE.

Prohibited Exports to Iran - On June 12, 2013, Markos Baghdasarian was sentenced in the 

District of South Carolina to 36 months in prison. Previously, on December 4, 2012, 

Baghdasarian pleaded guilty to conspiracy to violate the International Emergency Economic 

Powers Act and to defraud the United States, violating the Iranian embargo and making false 

statements. On May 19, 2012, Baghdasarian was arrested in Atlanta prior to boarding a flight to 

the United Arab Emirates (UAE). Baghdasarian was charged by criminal complaint in the 

District of South Carolina with exporting goods from the United States to Iran without the 
37

required licenses and with making false statements. He was later indicted on June 14, 2012. 

According to the charges, Baghdasarian served as the manager of Delfin Group USA, a Russianowned producer of synthetic motor oils, located in North Charleston, South Carolina. From as 

early as June 13, 2010, until October 12, 2011, Baghdasarian is alleged to have engaged in 

prohibited transactions with customers in Iran, including Pars Oil, which is an oil company 

owned by the Government of Iran. He alleged exported to Iran aviation engine oils and polymers 

valued at $850,000 and allegedly concealed that Iranian customers were the true recipients of the 

shipment by falsely asserting that a business entity in the UAE was the ultimate consignee for the 

goods. The investigation was conducted by ICE and Department of Commerce.

Satellite Hardware and Technology to Iran - On December 20, 2013, Nader Modanlo, a 

naturalized U.S. citizen born in Iran was sentenced in the District of Maryland to 8 years in prison 

followed by 3 years of supervised release. Modanlo was also ordered to forfeit $10 million. 

Previously, on June 10, 2013, a federal jury convicted Nader Modanlo of charges arising from a 

conspiracy to illegally provide satellite related services to Iran, in violation of the International 

Emergency Economic Powers Act, money laundering and obstruction of bankruptcy proceedings. 

As a result of the conspiracy, an Iranian earth observation satellite equipped with a camera was 

launched into space from Russia on October 27, 2005. The launch was the first-ever Iranian 

satellite put into orbit. Previously, on June 2, 2010, a federal grand jury in the District of 

Maryland returned an indictment charging Modanlo and five Iranian citizens on charges of 

conspiring to illegally provide satellite hardware and technology to Iran, in violation of the 

International Emergency Economic Powers Act and money laundering. According to the 

indictment, from January 2000 through November 27, 2007, the defendants concocted a scheme 

to evade the Iran trade embargo, by using sham companies to conceal Iranian involvement in 

prohibited activities and transactions. The indictment notes that some $10 million was wired 

from an overseas account to the account of a defendant in the United States in consideration for 

his assistance to Iran and the Iranians in brokering a satellite agreement with Russia and for his 

New York company providing telecommunications services in support of that agreement. 

Charged in the indictment are: Modanlo, of Potomac, Maryland; Hamid Malmirian; Reza 

Heidari; Mohammad Modares; Abdol Reza Mehrdad; and Sirous Naseri, all Iranian nationals. 

Modanlo was arrested on June 8, 2010 in Maryland. The indictment was dismissed against the 

remaining defendants on December 30, 2013. The investigation was conducted by ICE and the 

IRS.

Military Accelerometers to China – On November 18, 2013, Bin Yang aka “Raymond Yang”, a 

citizen and resident of China, was sentenced in the Southern District of California to 27 months 

imprisonment, 3 years of supervised release and $100 special assessment. Previously, on January 

10, 2013, Yang pled guilty to count one of the Indictment charging the defendant with smuggling 

goods from the United States and conspiracy to export to China defense articles -- specifically 

accelerometers used in aircraft, missiles, "smart" munitions and in measuring explosions. Yang 

was first charged in a criminal complaint on December 7, 2011 and later arrested on January 4, 

2012, by Bulgarian authorities in Sofia, Bulgaria, pursuant to a U.S. provisional arrest warrant. 

According to the complaint, Yang, operating out of Changsha Harsay Industry Co., Ltd. in 

Hunan, China, posted a request for Honeywell accelerometers in an online business-to-business 

forum in August 2010. An undercover federal agent responded to the request and agreed to 

supply the requested accelerometers. After nearly a year of negotiations, with no deal finalized, 

Yang allegedly asked for Endevco 7270-200K accelerometers, which are used for "smart" 

munitions, bunker-busting bombs and measuring ground motions caused by nuclear and chemical 

explosions, among other things. In August and October 2011, Yang allegedly caused two 

payments totaling $4,875 to be sent to the undercover agent as a down payment for the 

accelerometers. According to the complaint, Yang subsequently agreed to meet with the 
38

undercover agent in Bulgaria so the undercover agent could hand deliver two Endevco 

accelerometers to him. After his arrest in Bulgaria, Yang was charged on January 13, 2012 in a 

five-count indictment returned in the Southern District of California. In May 2012, a Bulgarian 

court signed a final order of extradition and Yang was extradited to the United States to face 

charges against him. On May 21, 2012, Yang was arraigned in the Southern District of 

California. This investigation was conducted by ICE.

Carbon Fiber to China – On May 29, 2013, Lisong Ma aka “Ma Li”, was sentenced in the 

Eastern District of New York to 46 months imprisonment after pleading guilty on May 30, 2013 

to an information charging him with attempting to illegally export one or more spools of Toray T800 carbon fiber from the United States to China without the required licenses from the 

Department of Commerce. According to a complaint filed on March 29, 2013, Ma reached out to 

undercover law enforcement officers in February 2013 seeking carbon fiber for export to China. 

Ma then traveled to the United States where he met with undercover agents about obtaining 

samples of carbon fiber. Ma paid $400 for a spool of T-800 carbon fiber and allegedly arranged 

for it to be shipped via Federal Express from the United States to China, falsely labeled as 

"clothing" and without a license. The package was intercepted before leaving the United States. 

According to the Information, Type T-800 carbon fiber is extremely high-grade and is used 

primarily in aerospace and military applications. It is controlled for export by the Department of 

Commerce for nuclear non-proliferation and national security reasons. This investigation was 

conducted by the Department of Commerce and ICE.

Military Night Vision Equipment to Ukraine - On May 22, 2013, in the Eastern District of New 

York, Ukrainian citizen Volodomyr Ponomarenko was sentenced to 24 months in prison after 

pleading guilty on February 22, 2013 to conspiring to violate the Arms Export Control Act by 

attempting to export military-grade night vision equipment from the U.S. to Ukraine. 

Ponomarenko was arrested attempting to enter the U.S. on March 23, 2011. He and others 

purchased military-grade night vision equipment, among other things, from dealers in the U.S. 

and attempted to export that equipment to Ukraine without the required State Department export 

licenses. As part of the scheme, Ponomarenko and his co-conspirators used straw purchasers in 

the U.S. to purchase the equipment. In exchange for a fee, the straw purchasers shipped the items 

to various freight forwarders for export to Ponomarenko in Ukraine. The night vision scopes 

were intercepted by law enforcement at John F. Kennedy International Airport. In their review of 

the shipping records, investigators learned that Ponomarenko and his co-conspirators caused the 

freight forwarding companies to inaccurately describe the items and to falsely state that no export 

license was required. The case was investigated by ICE and DCIS.

Industrial Supplies for Iranian Petrochemical Companies - On May 21, 2013, Iranian national 

Saeed Talebi was sentenced in the Southern District of New York to 12 months imprisonment.. 

Previously, on September 26, 2012, Talebi pleaded guilty to conspiring to violate the 

International Emergency Economic Powers Act (IEEPA) stemming from his work with others to 

ship to Iran parts and goods for use in industrial operations. The indictment against Talebi was 

first unsealed on July 12, 2012 and charged him with conspiring to violate IEEPA and conspiring 

to commit money laundering. Talebi worked to ship industrial goods and parts from U.S.-based 

firms to Dubai and that these goods were then to be sent to various petrochemical companies 

located in Iran. In the course of the scheme, Talebi allegedly caused funds to be wired to the 

United States, including more than $300,000 that was sent to a bank account in Manhattan. The 

investigation was conducted by BIS, with assistance from CBP.

Military Aircraft Engines to Venezuela - On May 14, 2013, Floyd D. Stilwell of Phoenix, AZ, 

was sentenced in the District of Arizona to 5 years of probation and was ordered to pay a fine of 
39

$250,000. Previously, on October 29, 2012, Stilwell pleaded guilty to conspiracy to violate the 

Arms Export Control Act. Stilwell and Marsh Aviation Company of Mesa, Arizona, were 

indicted on October 28, 2010, for violating the Arms Export Control Act and conspiracy. The 

indictment alleged that beginning in November 2005 through February 2008, Stilwell Marsh 

Aviation and others contributed to the export of T-76 military aircraft engines from the United 

States to Venezuela for use by the Venezuelan Air Force. The T-76 aircraft engine was designed 

for the OV-10 Bronco Aircraft which is a light armed reconnaissance aircraft specifically suited 

for counterinsurgency missions. The indictment also alleges that the defendants furnished 

assistance to members of the Venezuelan Air Force, including training in the assembly, testing, 

maintenance and use of the T-76 military aircraft engine without the required authorization from 

the State Department. The indictment against Marsh Aviation Company was dismissed on May 

14, 2013. The investigation was conducted by the FBI, ICE, and the DCIS.

Ammunition to Jordan - On May 3, 2013, Brian Keith Bishop, an employee of the U.S. Embassy 

in Jordan was sentenced in the Eastern District of Virginia to 2 years of probation and ordered to 

pay a fine of $25,000. On February 4, 2013, Bishop was convicted in a bench trial in the Eastern 

District of Virginia of violating the Arms Export Control Act. In August 2011, federal agents 

discovered that Bishop had placed approximately 9,446 rounds of ammunition, including 9mm, 

7.62 X 39mm, 45 caliber and 12 gauge shells in a cargo container of personal effects that he was 

shipping from the United States to Jordan through a U.S. government contract carrier. Bishop did 

not have a license to export defense articles from the United States and Jordanian law prohibits 

the possession of firearms on Jordanian territory without a permit issued by the Public Security 

Directorate. 

Fighter Jet Components to Iran - On April 26, 2013, Iranian citizen, Saeid Mohabat made his 

initial appearance in federal court in the Northern District of California after being extradited 

from Cyprus to face U.S. charges of conspiring to violate the Arms Export Control Act, 

conspiring to violate the International Emergency Economic Powers Act, and two counts of 

smuggling. Mohabat was charged in an indictment on December 11, 2012. According to the 

indictment, Mohabat sent an email in February 2012 to purchase Pitot Static Tubes, which are 

component parts of the F-5 fighter jets and classified as defense articles, for a total price of $52, 

442. He later indicated via e-mail that that the parts were destined for Iran, but noted that they 

could be transshipped through Tajikistan or China. He later sent an e-mail detailing how to ship 

one of the tubes by listing it as a "sample tube" on the invoice and covering it in glue for 

concealment purposes. In October 2012, Mohabat allegedly traveled to Cyprus, where he was 

arrested by authorities in Cyprus. This investigation was conducted by ICE.

GM Trade Secrets to China – On April 20, 2013, in the Eastern District of Michigan, a former 

General Motors engineer, Shanshan Du, was sentenced to 12 months and one day along with a 

$12,500 fine. Her husband, Yu Qin, was sentenced to 36 months on each count to be served 

concurrently along with a $25,000 fine. Both defendants were found guilty by a federal jury on 

November 30, 2012, for conspiring to steal hybrid technology trade secrets from GM with the 

intent to use them in a joint venture with an automotive competitor in China. Du and Qin were 

also convicted of unlawful possession of trade secrets after a month-long trial November 2012. 

Qin was also convicted of wire fraud and obstruction of justice. The evidence at trial showed that 

from December 2003 through May 2006, the defendants conspired to steal GM’s trade secret 

information. Du, while employed with GM’s hybrid vehicle technology group, provided GM 

trade secret information relating to hybrid vehicles to her husband, Qin, for the benefit of their 

private company, Millennium Technology International Inc. (MTI), which the defendants jointly 

owned and operated. Approximately five days after Du was offered a severance agreement by 

GM in January 2005, she copied more than 16,000 GM files, including trade secret documents, to 
40

an external computer hard drive used for MTI business. A few months later, Qin moved forward 

on a business venture to provide hybrid vehicle technology to Chery Automobile, an automotive 

manufacturer based in China and a competitor of GM. In May 2006, during the execution of a 

search warrant, the FBI recovered multiple computer devices containing GM trade secret 

ineinformation on several computer and electronic devices located in the defendants’ residence. 

Shortly after the FBI search team left the defendants’ residence, the defendants drove to a 

dumpster behind a grocery store, where defendant Qin discarded plastic bags containing shredded 

documents, including GM trade secret information, that were responsive to federal grand jury 

subpoenas seeking information relating to MTI and hybrid vehicles. Based on preliminary 

calculations, GM estimates that the value of the stolen GM documents is more than $40 million. 

This case was investigated by the FBI.

Military Gyroscopes to China - On April 17, 2013, Kevin Zhang, aka Zhao Wei Zhang was 

sentenced in the Southern District of California to time served and 3 years supervised release. 

Previously, on February 19, 2013, Zhang pleaded guilty for his role in a conspiracy to export 

defense articles from the United States to China without a license. On July 30, 2012, Zhang was 

arrested as he attempted to enter the United States from Canada at a port of entry in Washington 

state. Zhang had been charged on January 14, 2011 in a sealed indictment in the Southern 

District of California with one count of conspiracy to export defense articles (specifically G-200 

Dynamically Tuned Gyroscopes) from the United States to China without a license or approval 

from the State Department. According to the indictment, these particular gyroscopes may be used 

in tactical missile guidance and unmanned aircraft systems. Zhang allegedly instructed 

individuals in the United States to obtain and export defense articles, including the gyroscopes, to 

China and allegedly sought to use a courier to smuggle the gyroscopes out of the U.S. The 

indictment alleged that Zhang, acting on behalf of a client in China, sought to purchase three 

gyroscopes for $21,000 from an individual in the United States as a prelude to future purchases of 

gyroscopes. This investigation was conducted by ICE.

Carbon Fiber to Taiwan - On March 29, 2013, Yen Ling Chen, a citizen of Taiwan, was 

sentenced in the Eastern District of New York to 9 months in prison for violating the International 

Emergency Economic Powers Act (IEEPA) by attempting to export weapons-grade carbon fiber 

from the United States to Taiwan. According to court filings, Chen attempted to negotiate a longterm contract for the acquisition of 5 to 10 tons of carbon fiber while evading applicable export 

controls. Chen was arrested after traveling to the U.S. to meet with an undercover agent in an 

effort to obtain a sample of the specialized fiber, which has applications in the defense and 

aerospace industries and is regulated by the Department of Commerce. According to court 

documents, Chen was retained in the spring of 2012 by a coconspirator in Taiwan to use her 

English language skills to assist in the acquisition of large quantities of carbon fiber on behalf of 

a Taiwan-based company, which were to be transshipped to a third party. On April 25, 2012, 

Chen contacted an undercover agent in Brooklyn via the Internet and indicated that she and others 

were interested in purchasing several tons of high-grade carbon fiber. During this conversation, 

Chen discussed various methods to evade U.S. licensing controls, including mis-labeling the 

goods. Shortly thereafter, an accomplice wired $1,000 to a U.S. bank account, as a deposit on a 

sample of carbon fiber. In furtherance of the export scheme, and in an effort to secure a source of 

the controlled commodity, Chen traveled from Taiwan to the United States on July 5, 2012, to 

obtain a sample. During a secretly recorded meeting with an undercover agent the following day, 

the defendant and a coconspirator negotiated the deal and made arrangements for the delivery of 

the sample to Taiwan so that further testing could be performed to confirm its authenticity. Chen 

was indicted on September 4, 2012 and pleaded guilty on December 11, 2012 to attempting to 

violate IEEPA. The investigation was conducted by ICE and BIS.
41

Military Technical Data and Trade Secrets to China - On March 25, 2013, Sixing Liu, aka 

"Steve Liu," a native of China with a PhD in electrical engineering who worked as a senior staff 

engineer for Space & Navigation, a New Jersey-based division of L-3 Communications, was 

sentenced in the District of New Jersey to 70 months in prison for exporting sensitive U.S. 

military technology to China, stealing trade secrets and lying to federal agents. On September 26, 

2012, Liu was convicted of nine of 11 counts of an April 5, 2012 second superseding indictment, 

specifically six counts of violating the Arms Export Control Act, one count of possessing stolen 

trade secrets in violation of the Economic Espionage Act, one count of transporting stolen 

property, and one count of lying to federal agents. The jury acquitted Liu on two counts of lying 

to federal agents. According to documents filed in the case and evidence presented at trial, in 

2010, Liu stole thousands of electronic files from his employer, L-3 Communications, Space and 

Navigation Division. The stolen files detailed the performance and design of guidance systems 

for missiles, rockets, target locators, and unmanned aerial vehicles. Liu stole the files to position 

and prepare himself for future employment in China. As part of that plan, Liu delivered 

presentations about the technology at several Chinese universities, the Chinese Academy of 

Sciences, and conferences organized by Chinese government entities. However, Liu was not 

charged with any crimes related to those presentations. On November 12, 2010, Liu boarded a 

flight from Newark to China. Upon his return to the United States on November 29, 2010, agents 

found Liu in possession of a non-work-issued computer found to contain the stolen material. The 

following day, Liu lied to ICE agents about the extent of his work on U.S. defense technology. 

The State Department later verified that several of the stolen files on Liu's computer contained 

technical data that relates to defense items listed on the United States Munitions List. The jury 

also heard testimony that Liu's company trained him about the United States' export control laws 

and told him that most of the company's products were covered by those laws. Liu was first 

arrested on March 8, 201, in Chicago on a complaint in the District of New Jersey charging him 

with one count of exporting defense-related technical data without a license. The investigation 

was conducted by the FBI, ICE and CBP.

Computers to Iran - On March 7, 2013, in the Northern District of Texas, Borna Faizy, of Frisco, 

Texas, and Touraj Ghavidel, of Plano, Texas -- the corporate owners/operators of Signal 

Microsystems in Addison, Texas, a company that sold computers domestically and internationally 

-- were arrested on an indictment alleging that they illegally shipped $12 million worth of 

computer equipment to Iran through Dubai. The indictment, returned under seal in early March 

2013, charges each with one count of conspiracy to illegally export to Iran, nine substantive 

counts charging illegal export and attempted export of goods to Iran and one count of making 

false statements to a federal agency. Faizy and Ghavidel allegedly acquired computers from U.S. 

companies to supply to end-users in Iran and concealed from the U.S. that the computers were 

destined for Iran. Faizy and Ghavidel allegedly actively recruited Iranian customers by marketing 

their computer business to business owners and individuals in Iran, and, in 2008 or 2009, attended 

a computer trade show, known as "GITEX," in Dubai to recruit Iranian customers. The 

defendants allegedly used freight-forwarding companies in Dubai to ship the equipment to Iran 

and communicated with coconspirators using fictitious names and coded language to obscure the 

true identities and locations of the ultimate consignees and end-users. They also created invoices 

and export forms that falsely identified the ultimate consignees of the shipments as parties in 

Dubai. The investigation is being conducted by members of the North Texas Counterproliferation Task Force, which includes the FBI, ICE, the Department of Commerce and DCIS.

Aircraft and Aircraft Components to Iran - On March 4, 2013 in the Western District of 

Kentucky, Hamid Asefi, an Iranian citizen, and Behzad Karimian, a U.S. citizen with a valid 

Iranian passport living in Kentucky, were sentenced to 23 months in prison and 46 months in 

prison, respectively, for charges related to the illegal export of aircraft and aircraft parts from the 
42

U.S. to Iran. On December 3, 2012, both defendants pleaded guilty to conspiracy to violate and 

violating the International Emergency Economic Powers Act. Asefi was the principal officer of 

Aster Corp Ltd., an Iranian company with offices in Iran and the United Kingdom, while 

Karimian was employed as a Mesaba Airlines pilot. Beginning in August 2007 and continuing 

through April 2011, Asefi used the U.K. office of Aster to serve as a transshipment point to 

facilitate shipment of goods from the United States to Iran. Asefi sent requests on behalf of 

Iranian entities to Karimian for purchases of aircraft and aircraft parts in the U.S. or owned by 

U.S. persons. Karimian then made inquiries, placed orders and attempted to facilitate the 

purchase of aircraft and aircraft parts in the United States on behalf of Asefi and persons in Iran. 

Among other things, the defendants admitted from September 2009 through April 2010, they 

violated the embargo against Iran by exporting and causing the export of services related to the 

sale of a G.E. Aircraft Engine Model CF6-50C2, as well as attempting the procurement of 

helicopters manufactured by Bell Helicopter, from the United States to Iran. All of the aircraft 

and aircraft parts involved in this case were intended for civilian use. Asefi made his initial 

appearance in federal court in Louisville, Ky., on June 1, 2012, while Karimian was arrested and 

made his initial appearance in federal court in Louisville on June 6, 2012. This investigation was 

conducted by the FBI.

Ballistic Vests and Ammunition to Mexico - On February 27, 2013 in the Western District of 

Texas, Hector Ayala, former owner of Uniforms of Texas, was sentenced to 2 years in federal 

prison for his role in a scheme to smuggle ammunition and other prohibited items into the 

Republic of Mexico. Ayala was also ordered to pay a $200,000 monetary judgment as well as 

forfeit to the Government 8,600 rounds of ammunition, $103,000 in U.S. Currency as well as 

approximately $1 million worth of military and law enforcement equipment seized by authorities 

during this investigation. In December 2012, Ayala pleaded guilty to one count of facilitating the 

smuggling of goods from the United States. Ayala admitted that from September 1, 2009, to 

December 3, 2011, he concealed and facilitated the transportation of multiple calibers and 

quantities of ammunition; approximately 300 high capacity ammunition magazines and drums; 

and, approximately 800 ballistic vests with ceramic plates knowing that the items were intended 

to be exported from the United States into Mexico. This investigation was conducted by ICE and 

ATF.

Trade Secrets to China - On January 25, 2013, Ji Li Huang, a Chinese business owner and his 

employee, Xiao Guang Qi, pleaded guilty and were sentenced in the Western District of Missouri 

for conspiring to steal trade secrets from Pittsburgh Corning Corporation, that produces 

FOAMGLAS® insulation. Huang is the CEO of Ningbo Oriental Crafts Ltd., which employs 

200 factory workers to manufacture promotional products for export to the United States and 

Europe. Qi was his employee. Huang was sentenced to 18 months in prison and ordered to pay a 

fine of $250,000. Qi was sentenced to time served and ordered to pay a fine of $20,000. 

Pittsburgh Corning, headquartered in Pittsburgh, Penn., manufactures various grades or densities 

of cellular glass insulation sold under the trade name FOAMGLAS®. That material is used to 

insulate buildings, industrial piping systems and liquefied natural gas storage tank bases. 

Pittsburgh Corning considers the product formula and manufacturing process for FOAMGLAS® 

proprietary and trade secrets. By pleading guilty, Huang and Qi admitted that they attempted to 

illegally purchase trade secrets of Pittsburgh Corning for the purpose of opening a plant in China 

to compete with Pittsburgh Corning. The court ruled that the intended loss to Pittsburgh Corning 

exceeded $7 million, based on the company's investment of time and resources to research, 

develop and protect the proprietary information the defendants attempted to steal. Huang and Qi 

were arrested when they met with an individual they believed to be an employee of Pittsburgh 

Corning who had stolen documents that contained trade secret information and was willing to sell 

it to them for $100,000. That employee, however, was cooperating with law enforcement and the 
43

meetings in Kansas City were a sting operation that led to their arrests on September 2, 2012. 

The case was investigated by the FBI. 

Military Lasers to Canada - On January 23, 2013, Joel Stone was sentenced in the Western 

District of Texas to 24 months imprisonment. Stone previously pleaded guilty on March 22, 

2012, to receiving stolen property, illegal export of defense articles and money laundering. Stone 

illegally exported to Canada three stolen U.S. Military Advanced Target Pointer Illuminating 

Aiming Lasers, which are defense articles on the U.S. Munitions List. Stone was arrested on 

February 2, 2012 after being charged in a sealed criminal information on January 12, 2012.

Sensitive Microwave Amplifiers to China and India - On January 17, 2013, Timothy Gormley 

was sentenced to 42 months in prison, three years supervised release and a $1,000 fine in Eastern 

District of Pennsylvania for five counts of violating the International Emergency Economic 

Powers Act (IEEPA). On October 17, 2012, Gormley, the former export control manager of AR 

Worldwide/Amplifier Research in Souderton, PA, pleaded guilty in connection with the illegal 

export of over 57 microwave amplifiers, which are controlled for National Security reasons due 

to their applications in military systems, including radar jamming and weapons guidance systems. 

The August 9, 2012, information alleged that between 2007 and 2011, Gormley failed to obtain 

the required licenses on behalf of the company for shipments sent to destinations requiring such 

licenses for the shipment of these goods. The information cited specific shipments of amplifiers 

from the United States to customers in India and China that Gormley caused without the required 

export license. This investigation was conducted by the Department of Commerce.

Controlled Microelectronics to Russian Military and Intelligence Agencies - On January 10, 

2013, defendants Lyudmila Bagdikian and Viktoria Klebanova pleaded guilty in the Eastern 

District of New York to their roles in exporting goods from the United States to Russian end 

users. On October 3, 2012, an indictment was unsealed in the Eastern District of New York 

charging 11 members of a Russian procurement network operating in the United States and 

Russia, as well as a Houston-based export company, Arc Electronics Inc., and a Moscow-based 

procurement firm, Apex System L.L.C. ,with illegally exporting high-tech microelectronics from 

the United States to Russian military and intelligence agencies. Alexander Fishenko, an owner 

and executive of both the American and Russian companies, is also charged with operating as an 

unregistered agent of the Russian government inside the U.S. by illegally procuring the 

microelectronics on behalf of the Russian government. The microelectronics allegedly exported 

to Russia are subject to U.S. controls due to their potential use in a wide range of military 

systems, including radar and surveillance systems, weapons guidance systems and detonation 

triggers. In conjunction with the unsealing of these charges, the Department of Commerce added 

165 foreign persons and companies who received, transshipped, or otherwise facilitated the 

export of controlled commodities by the defendants to its "Entity List." As alleged in the 

indictment, between October 2008 and the present, Fishenko and the other defendants engaged in 

a conspiracy to obtain advanced microelectronics from manufacturers and suppliers located in the 

United States and to export those high-tech goods to Russia, while evading the government 

export licensing system. The microelectronics shipped to Russia included analog-to-digital 

converters, static random access memory chips, microcontrollers and microprocessors. The 

defendants allegedly exported many of these goods, frequently through intermediary procurement 

firms, to Russian end users, including Russian military and intelligence agencies, and went to 

great lengths to conceal their procurement activities. The investigation uncovered a Russian 

Ministry of Defense document designating an Apex subsidiary as a company "certified" to 

procure and deliver military equipment and electronics. The FBI recovered a letter sent by a 

specialized electronics laboratory of Russia's Federal Security Service (FSB), Russia's primary 

domestic intelligence agency, to an Apex affiliate regarding certain microchips obtained for the 
44

FSB by Arc. The defendants' principal port of export for these goods was John F. Kennedy 

International Airport in New York. In addition to Fishenko, Arc and Apex, the indictment also 

charges Shavkat Abdullaev, Lyudmila Bagdikian, Anastasia Diatlova, Viktoria Klebanova, 

Alexander Posobilov, Sevinj Taghiyeva, and Svetalina Zagon, who were arrested in Houston on 

October 2 and Oct 3, 2012. Three others charged in the indictment, Sergey Klinov, Yuri Savin, 

and Dimitriy Shegurov, were based overseas and were not arrested. The investigation was 

conducted by the FBI, Department of Commerce (BIS), Naval Criminal Investigative Service 

(NCIS) and the IRS.

Hawk Air Defense Missile Batteries to Iran - On January 9, 2013, British businessman 

Christopher Tappin was sentenced in the Western District of Texas to serve 33 months in prison 

and ordered to pay a fine of $11, 357 for aiding and abetting the illegal export of defense articles 

in connection with his efforts to export to Iran special components of the Hawk Air Defense 

Missile. Tappin pleaded guilty on November 1, 2012, admitting that from December 2005 to 

January 2007, he aided and abetted others, including his Cyprus-based business associate Robert 

Gibson, and Robert Caldwell, of Portland, Ore., in an attempt to export Zinc/Silver Oxide 

Reserve Batteries to Iran. These particular batteries, a special component of the Hawk Air 

Defense Missile, are on the U.S. Munitions List and require a license for export from the United 

States. In October 2006, Tappin wired some $25,000 from a London financial institution to an 

account in the United States as payment for five of the batteries. Using false shipping 

documentation, Tappin arranged for the transfer of the batteries to the United Kingdom without 

an export license through his specifically-designated freight forwarders in violation of export 

control regulations. During the investigation, Tappin agreed to reimburse the undercover agent 

for $5,000 in fines purportedly being assessed against him by U.S. Customs authorities after they 

had seized the shipment of batteries. Tappin also caused Caldwell to travel to San Antonio in 

January 2007 to take delivery of the batteries, ensure that they were shipped to him and to pay the 

undercover agent $5,000 for the current fines. Tappin was first charged in a federal indictment on 

February 7, 2007. He was extradited from the United Kingdom to the United States for 

prosecution on February 24, 2012. On November 9, 2007, his co-defendant Robert Caldwell was 

sentenced in the Western District of Texas to 20 months in prison for his role in the scheme. 

Robert Gibson was sentenced on August 24, 2007 to a two-year prison term for his role in the 

scheme. The case was investigated by ICE.

Dual-Use Programmable Logic Devices to China - On December 18, 2012, federal prosecutors 

in the District of Oregon unsealed a 12-count indictment charging Wan Li Yuan, aka "Nicholas 

Bush," a resident of China, and another Chinese resident known as "Jason Jiang," with export and 

money laundering violations in connection with their alleged efforts to obtain dual-use 

programmable logic devices (PLDs) from the United States for export to China. According to the 

indictment, while operating from China, Yuan and Jiang created a sophisticated scheme to 

conceal their true identity and location in order to mislead U.S. companies into believing they 

were dealing with American customers so they could procure and send sensitive technologies to 

China without the required export licenses. Yuan and Jiang allegedly sought to procure PLDs 

made by Lattice Semiconductor Corporation in Oregon, which are designed to operate at extreme 

temperature ranges and which can have military applications such as in missiles and radar 

systems. To further his efforts, the indictment alleges that Yuan created a fake website and email 

addresses using the name of a legitimate New York-based company. Yuan requested U.S. 

companies to ship the desired parts to the address of a freight forwarder in New York, which he 

also falsely represented as being associated with the New York company whose business name 

Yuan had stolen. Through the investigation and use of an undercover operation, the FBI and 

Department of Commerce were able to seize approximately $414,000 in funds sent by Yuan as 
45

down payments for the Lattice PLDs. Lattice Semiconductor cooperated with the government in 

the investigation, which was conducted by the FBI and Department of Commerce's BIS.

Specialty Coatings to Pakistani Nuclear Facility - On December 11, 2012, in the District of 

Columbia, China Nuclear Industry Huaxing Construction Co., Ltd. (Huaxing), a corporate entity 

owned by the People's Republic of China (PRC) was sentenced to the maximum criminal fine of 

$2 million, $1 million of which was stayed pending its successful completion of five years of 

corporate probation. Previously, on December 3, 2012, Huaxing pleaded guilty to conspiracy to 

violate the International Emergency Economic Powers Act (IEEPA) and three unlawful exports 

of high performance coatings to a nuclear reactor in Pakistan. The plea marked the first time that 

a PRC corporate entity has entered a plea of guilty in a U.S. criminal export matter. The terms of 

Huaxing's probation require it to implement an export compliance and training program that 

recognizes Huaxing's obligation to comply with U.S. export laws. In both the criminal and 

administrative case, Huaxing was accused of conspiring to export, re-export, and transship highperformance epoxy coatings to the Chashma II Nuclear Power Plant in Pakistan, a nuclear reactor 

owned by the Pakistan Atomic Energy Commission (PAEC), an entity on the Department of 

Commerce's Entity List. The Huaxing guilty plea was related to the December 21, 2010, guilty 

plea of PPG Paints Trading Co., Ltd. to a four-count information in the District of Columbia. 

Together, PPG Paints Trading and its parent company, PPG Industries, Inc., paid $3,750,000 in 

criminal and administrative fines and over $32,000 in restitution. The Huaxing guilty plea was 

also related to the November 15, 2011, guilty plea by Xun Wang to conspiracy to violate IEEPA. 

Wang also reached a settlement with the Commerce Department on November 15, 2011, in which 

she agreed to pay a civil penalty of $200,000, with another $50,000 payment suspended, and to be 

placed on the Commerce Department's Denied Persons List for five years, with an additional five 

years suspended. Wang, a former Managing Director of PPG Paints Trading, was the senior most 

PPG Paints Trading employee responsible for the unlawful export scheme. Wang, a Chinese 

national and lawful permanent resident of the United States, was arrested on June 16, 2011, in 

Atlanta. On June 7, 2011, a grand jury in the District of Columbia returned a sealed indictment 

against her. Wang was ultimately sentenced on December 20, 2012, to one year and one day in 

prison in connection with the scheme. According to Huaxing's plea documents, in January 2006, 

PPG Industries sought an export license for the shipments of coatings to Chashma II. In June 

2006, the Department of Commerce denied that license application. Following that denial, 

Huaxing and its co-conspirators agreed upon a scheme to export, re-export and transship the highperformance epoxy coatings from the U.S. to Chashma II, via a third-party distributor in China, 

without first having obtained the required export license from the Department of Commerce. 

From June 2006 through around March 2007, members of the conspiracy falsely stated that the 

coatings were to be used at a nuclear power plant in China, the export of goods to which would 

not require a Commerce license. Through these means, Huaxing and its co-conspirators 

unlawfully exported three shipments of coatings from the U.S. to Chashma II worth 

approximately $32,000. The investigation was conducted by BIS.

Night Vision Technology Overseas - On December 3, 2012, Sean Elias Sayegh, a retired Marine 

Corps staff sergeant who previously worked in the Marine Aviation Supply Office at Edwards Air 

Force Base in California, was sentenced in the Central District of California to 1 year of 

probation. Sayegh, who pleaded guilty on August 27, 2012, was arrested in March 2012 for 

allegedly lying to the government in connection with a scheme to illegally export military night 

vision technology overseas. Sayegh, who retired from the Marine Corps in December 2011, was 

charged in a March 2, 2012 indictment in the Central District of California with four counts of 

making false statements on customs declaration forms, stating that packages he was shipping 

contained camera lenses and other camera equipment, when the items were actually laser light 

interference filters (LIFs). The alleged violations, which occurred between December 2009 and 
46

February 2010, involved the shipment of more than 100 LIFs. LIFs, which are used with military 

night vision goggles, are on the U.S. Munitions List and cannot legally be exported without a 

license issued by the Department of State. This investigation was conducted by ICE, NCIS, 

DCIS, the U.S. Postal Inspection Service (USPIS) and U.S. Customs and Border Protection.

TOW Missile Components to Iran – On November 30, 2012, Andro Telemi, a naturalized U.S. 

citizen from Iran who resided in California, sentenced in the Northern District of Illinois to five 

years probation with 6 months home confinement and electronic monitoring and a $10,000 fine. 

Previously, on July 26, 2012, Telemi pleaded guilty to one count of attempting to illegally export 

defense articles in connection with his efforts to export TOW and TOW2 missile components to 

Iran. Telemi was indicted in December 2009, along with Davoud Baniameri, an Iranian citizen 

who lived in Woodland Hills, Calif. A superseding indictment returned in July 2010 charged 

Telemi, Baniameri and Syed Majid Mousavi, an Iranian citizen living in Iran. According to court 

documents, sometime before October 2008, Mousavi, based in Iran, contacted Baniameri in 

California and requested that he purchase Marconi radio test sets for illegal export from the 

United States to Iran via Dubai. Baniameri purchased these sets from an Illinois company and 

later exported them to Iran via Dubai. Mousavi also requested that Baniameri purchase and 

export to Iran, via Dubai, ten connector adaptors for the TOW and TOW2 missile system, which 

are used on the U.S. Army's Bradley fighting vehicle and the U.S. Marine Corp's AH-1W Cobra 

attack helicopter. Baniameri later negotiated the purchase of these items from an Illinois 

company for $9,450 and directed Telemi to assist him in this effort and to take possession of the 

items. To facilitate the export of these goods, Baniameri arranged to fly to Iran, but he was 

arrested before leaving the country. Baniameri conducted business via Pacific Green Valley, a 

firm in California, while Telemi conducted business as Oceanic Import Cars, Inc., a firm in 

California. On May 31, 2011, Baniameri pleaded guilty to conspiracy to illegally export goods 

and technology to Iran and to attempt to illegally export defense articles in connection with the 

TOW missile components and radio test sets. Baniameri was sentenced on August 12, 2011 to 51 

months in prison. Mousavi remains a fugitive. This investigation was conducted by ICE, DCIS, 

BIS, and IRS. 

Military Antennas to Iran - On November 20, 2012, an indictment in the District of Columbia 

charging Amin Ravan and his Iranian company, IC Market Iran (IMI), with conspiracy to defraud 

the United States, smuggling and violating the Arms Export Control Act, was unsealed. Ravan 

was arrested by authorities in Malaysia on October 10, 2012 and the United States is seeking his 

extradition. According to the indictment, which was returned under seal on November 16, 2011, 

Ravan was based in Iran and, at various times, acted as an agent of IMI in Iran and an agent of 

Corezing International, Pte, Ltd, a company based Singapore that also maintained offices in Hong 

Kong and China. In late 2006 and early 2007, Ravan allegedly attempted to procure for shipment 

to Iran export-controlled antennas made by a company in Massachusetts, through an intermediary 

in Iran. The antennas sought by Ravan were cavity-backed spiral antennas as well as biconical 

antennas. After this first attempt was unsuccessful, Ravan joined with two co-conspirators at 

Corezing in Singapore so that Corezing would contact the Massachusetts company and obtain the 

antennas on behalf of Ravan for shipment to Iran. When Corezing was unable to purchase the 

antennas from the Massachusetts firm, Corezing then contacted another individual in the United 

States who was ultimately able to obtain these items from the Massachusetts firm by slightly 

altering the frequency range of the antennas to avoid detection by the company's export 

compliance officer. Ultimately, between July and September 2007, a total of 50 cavity-backed 

spiral antennas and five biconical antennas were exported from the United States to Corezing in 

Singapore and Hong Kong. No party to these transactions -- including Ravan or IMI -- ever 

applied for or received a license from the State to export any of these antennas from the United 

States to Singapore or Hong Kong. This investigation was conducted by ICE, FBI and BIS.
47

Military Aircraft Parts to Iran - On November 15, 2012, Alireza Moazami Goudarzi, an Iranian 

national, was charged in an indictment in the Southern District of New York in connection with a 

plot to illegally export military and civilian aircraft components from the United States to Iran. 

Goudarzi was arrested in Malaysia on October 24, 2012 and the United States is seeking his 

extradition. According to the indictment, in 2010, Goudarzi contacted a U.S. supplier seeking to 

buy certain civilian aircraft parts for shipment to Iran, and, as an incentive, offered to pay more 

than market value because of the embargo on sending these parts to Iran. After the supplier 

referred the solicitation to investigating agents, an undercover agent began corresponding with 

Goudarzi regarding the proposed purchase, as well as other purchases of aircraft parts that he 

sought. Those purchases included rotor blades for a particular model of attack helicopter, and 

most recently, jet engine parts listed on the U.S. Munitions List. Goudarzi met with the UC in 

person to purchase those parts and made payments to the UC towards their purchase. The 

indictment charges Goudarzi with conspiracy, money laundering and violations of the Arms 

Export Control Act and the International Emergency Economic Powers Act. The investigation 

was conducted by ICE and DCIS

Stolen Tactical Laser Illuminators Overseas - On October 30, 2012, Fidel Ignacio Cisneros was 

sentenced in the Middle District of Florida to 46 months in prison followed by two years 

supervised release for violating the Arms Export Control Act. Cisneros, a former master sergeant 

in the U.S. Army pleaded guilty to the charge on July 31, 2012. According to court documents, 

from 2007 to 2010, Cisneros served as a soldier in the U.S. Army, where he performed various 

missions in that capacity, in Iraq and elsewhere. During his deployment, Cisneros stole three 

Acquired Tactical Illuminating Laser Aimers (Atilla 200 lasers), an ACOG rifle scope, and other 

items. He brought all of the items back to Orlando without first obtaining permission from the 

Department of Defense. Using his eBay account, Cisneros auctioned one of the Atilla 200 lasers 

to the highest bidder. Cisneros shipped the Atilla-200 laser from Orlando to a Japanese national 

in Tokyo, in exchange for $3,200. The Atilla 200 laser requires a State Department license to be 

exported out of the United States, which Cisneros did not have. In March 2010, Cisneros also 

auctioned a PEQ AN/PEQ-14 night vision pointer illuminator, which was shipped to California; a 

Thuraya Hughes 7101 Satellite phone GSM+GPS, which was shipped to Kuwait; a Thuraya 

Satellite phone docker FDU 2500, which was shipped to California; and a PEQ/Atilla 200 rail 

mounted laser, which was shipped to Nevada. On January 26, 2011, Cisneros admitted to ICE 

agents that he knew it was probably wrong to sell the items and that civilians probably were not 

allowed to possess the items. That same day, agents recovered the remaining Atilla 200 lasers 

that Cisneros stole from the Army. Federal law enforcement agents in the United States and in 

Japan subsequently recovered all of the items Cisneros sold. Cisneros was charged in a May 16, 

2012 indictment. This investigation was conducted by ICE and DCIS.

Restricted Microwave Amplifier Technology to China - On October 29, 2012, Fu-Tain Lu was 

sentenced in the Northern District of California to 15 months in prison, 3 years supervised release 

$100 special assessment and a $5,000 fine. Previously, on November 17, 2011, Lu pleaded guilty 

to selling sensitive microwave amplifiers to the People's Republic of China without the required 

license. Lu was the owner and founder of Fushine Technology, Inc., corporation formerly located 

in Cupertino, Calif. Fushine was an exporter of electronic components used in communications, 

radar and other applications. At the time of the offense, Fushine had a sales representative 

agreement with Miteq Components, Inc., a New York-based manufacturer of microwave and 

satellite communications components and subsystems. Lu admitted that, on March 1, 2004, 

Fushine submitted a purchase order to Miteq for one microwave amplifier and requested that 

Miteq notify Fushine immediately if an export license was required. Miteq responded that the 

part was controlled for export to China. Nonetheless, on April 2, 2004, Fushine exported the 
48

amplifier to co-defendant Everjet Science and Technology Corporation (Everjet), located in 

China, without a license from the Department of Commerce. Lu further admitted that the 

amplifier he shipped was restricted for export to China for reasons of national security. Lu, along 

with the two corporate defendants, Fushine and Everjet, were first indicted on April 1, 2009. A 

superseding indictment was returned on February 17, 2010. In addition to the count of 

conviction, the indictment also charged him with conspiring to violate U.S. export regulations, 

and lying to federal agents who were investigating that conduct. The superseding indictment 

quoted from an internal company e-mail in which an Everjet employee told a Fushine employee, 

"Since these products are a little bit sensitive, in case the maker ask [sic] you where the location 

of the end user is, please do not mention it is in China." As part of the plea agreement, Lu also 

agreed to forfeit 36 additional microwave amplifiers seized on March 24, 2010, but that were not 

included in the superseding indictment. On October 29, 2012, the government moved to dismiss 

all charges against co-defendant Fushine Technology. This investigation was conducted by the 

Department of Commerce (BIS), the FBI, ICE, and U.S. Customs and Border Protection.

Military Aircraft Engines and Components to Venezuelan Air Force - On October 29, 2012, 

Kirk Drellich, the owner of SkyHigh Accessories, Inc., an aircraft parts company in Florida, was 

sentenced in the Southern District of Florida to one year and one day in prison and was fined 

$50,000, after pleading guilty earlier in the year to conspiracy to violate the Arms Export Control 

Act (AECA). On July 30, 2012, Victor Brown, an aircraft parts broker in Florida, pleaded guilty 

in the Southern District of Florida to conspiracy to violate the AECA. On July 27, 2012, Freddy 

Arguelles, a former Venezuelan Air Force pilot living in the U.S., pleaded guilty to conspiracy to 

violate the AECA. On July 13, 2012, Alberto Pichardo, an officer of the Venezuelan Air Force 

who was responsible for control of the Venezuelan Military Acquisitions Office in Doral, Fla., 

pleaded guilty to conspiracy to violate the AECA. Each of these four defendants was charged on 

June 25, 2012, with conspiring to violate the AECA in connection with their efforts to export to

Venezuela U.S.-origin military aircraft engines and components from November 2008 through 

August 2010. According to the charges, co-conspirators residing in Venezuela and Spain advised 

the defendants and other members of the conspiracy of specific defense articles that the 

Venezuelan Air Force wanted to purchase. Some of the co-conspirators, including Pichardo and 

Brown, also met with officials of the Venezuelan Air Force regarding these defense articles. The 

defendants allegedly purchased and obtained the requested defense articles from various U.S. 

suppliers. The defendants then made arrangements for the shipment of the defense articles to 

Venezuela. These items included T56 military aircraft engines and components for other military 

aircraft, including the F-16 fighter jet. Co-conspirators residing in foreign countries paid the 

defendants and other co-conspirators for their assistance in obtaining the defense articles. This 

investigation was conducted by the FBI.

Military-Sensitive Parts to Iran - On October 29, 2012, Susan Yip, a citizen of Taiwan, was 

sentenced in the Western District of Texas to two years in federal prison for her role in a 

conspiracy to obtain and illegally export dual-use parts with military applications to Iran. A 17-

count indictment, returned on June 15, 2012 and later unsealed, charged Yip, Mehrdad Foomanie 

of Iran, and Merdad Ansari of the United Arab Emirates, with conspiracy to violate the Iranian 

Trade Regulations, conspiracy to launder money and conspiracy to commit wire fraud. On July 

20, 2012, Yip pleaded guilty to one count of conspiracy to violate the Iranian Trade Regulations. 

By pleading guilty, Yip admitted that from 2007 to 2011, she acted as a broker and conduit for 

Foomanie to buy items in the United States and have them unlawfully shipped to Iran. According 

to the indictment, Foomanie bought or attempted to buy items in the United States and arranged 

to have them unlawfully shipped to Iran through his companies in Iran, Hong Kong and China. 

Ansari allegedly attempted to transship and transshipped cargo obtained from the United States 

by Yip and Foohmanie using Ansari's company in Dubai. Foohmanie and Ansari remain 
49

fugitives. In her plea, Yip admitted to primarily using her companies in Taiwan and in Hong

Kong to carry out the fraudulent scheme. The parts Yip obtained and attempted to obtain for Iran 

were worth millions of dollars, and could be used in such military systems as nuclear weaponry, 

missile guidance and development, secure tactical radio communication, offensive electronic 

warfare, military electronic countermeasures and radar warning and surveillance systems. From 

October 9, 2007, to June 15, 2011, the defendants obtained or attempted to obtain from 

companies worldwide over 105,000 parts valued at some $2,630,800 involving more than 1,250 

transactions. The defendants conducted 599 transactions with 63 different U.S. companies where 

they obtained or attempted to obtain parts from U.S. companies without notifying these 

companies the parts were being shipped to Iran or getting the required U.S. licenses to ship these 

parts to Iran. The case was investigated by ICE, FBI, DCIS and the Department of Commerce.

Military Flight Helmets and Night Vision Goggles to Panama - On October 23, 2012, Martyn 

Caulfield, a British national illegally present in the United States, was sentenced in the Northern 

District of Florida to two years in prison after pleading guilty on June 27, 2012 to a five-count 

information charging him with illegally exporting defense articles, being an alien in possession of 

a firearm, and money laundering. Caulfield purchased new and used military equipment, 

including military flight helmets and advanced night vision goggles, and then resold these 

restricted defense articles over an eBay auction site for export without the required State 

Department licenses. During online discussions with undercover law enforcement agents, 

Caulfield agreed to export military flight helmets and night vision goggles to agents posing as 

buyers from Panama. The shipments were intercepted before they departed the United States. 

More than $81,000 was seized and forfeited from Caulfied in connection with the investigation. 

This investigation was conducted by ICE.

Sensitive Military Encryption Technology to China – On October 19, 2012, Chi Tong Kuok, a 

resident of Macau, China, was sentenced in the Southern District of California to time served. 

Previously, on July 31, 2012, Kuok pleaded guilty to one count of conspiracy to illegally export 

defense articles and to smuggle goods from the United States. According to the plea agreement, 

Kuok and others conspired to purchase and export from the United States defense articles, 

including communication, precision location and cryptographic equipment, without a license 

from the State Department. Kuok also caused $1,700 to be sent to the United States for the 

purchase and unlicensed export of a KG-175 Taclane Encryptor. According to court documents, 

the KG-175 Taclane Encryptor was developed by General Dynamics under a contract with the 

National Security Agency for use by the U.S. military to encrypt Internet Protocol 

communications. Kuok was first arrested on June 17, 2009 in Atlanta, Ga., after he arrived from 

Paris to catch a connecting flight to Panama in order to meet with undercover federal agents to 

take possession of controlled U.S. technology. A criminal complaint was filed on June 23, 2009 

and an indictment returned on July 7, 2009. On May 11, 2010, Kuok was convicted at trial of 

conspiracy to export defense articles without a license and smuggling goods to Macau and Hong 

Kong, China; smuggling goods; attempting to export defense articles without a license; and 

money laundering. On September 13, 2010, Kuok was sentenced to 96 months in prison. Kuok 

appealed and on July 2, 2012, the 9th U.S. Circuit Court of Appeals vacated Kuok's convictions 

on counts three and four and remanded to the district court for a new trial on counts one and two. 

The appeals court ruled that Kuok should have been allowed to put on a defense that he was 

forced into trying to procure the equipment by the Chinese government. Kuok pleaded guilty 

prior to the second trial. This investigation was conducted by ICE and DCIS.

Computers and Related Equipment to Iran - On October 18, 2012, in the Middle District of 

Florida, Mohammad Reza Hajian, a resident of Tampa, was sentenced to four years in prison and 

ordered to forfeit $10 million for conspiracy to violate the Iranian Transaction Regulations. On 
50

July 11, 2012, Hajian pleaded guilty to conspiracy to export roughly $10 million worth of 

computers and related equipment from the United States to Iran through the United Arab 

Emirates without first obtaining an export license from the Treasury Department. Additionally, 

Hajian as Chief Executive Officer of his computer companies, Nexiant LLC, RH International 

LLC, and P & P Computers LLC, pleaded guilty on behalf of the companies to count two of the 

information, charging these companies with conspiracy to export computers and related 

equipment to Iran without first obtaining an export license from the Treasury Department. On 

October 18, 2012, Nexiant LLC, P&P Computers, and RH International LLC each received a 

sentence of 24 months probation. The case was investigated by ICE and the Department of 

Commerce.

Trade Secrets to South Korea - On October 18, 2012, prosecutors in the Eastern District of 

Virginia unsealed an August 21, 2012 indictment charging South Korean-based Kolon Industries 

Inc. and several of its executives and employees with allegedly engaging in a multi-year 

campaign to steal trade secrets related to DuPont's Kevlar para-aramid fiber and Teijin Limited's 

Twaron para-aramid fiber. The indictment seeks forfeiture of at least $225 million in proceeds 

from the alleged theft of trade secrets from Kolon's competitors and charges Kolon with one 

count of conspiring to convert trade secrets, four counts of theft of trade secrets and one count of 

obstruction of justice. Kolon makes a product called Heracron, which is a recent entrant into the 

para-aramid fiber market as a competitor to products called Kevlar and Twaron. Para-aramid 

fibers are used to make, for example, body armor, fiber optic cables and automotive and industrial 

products. Kevlar is produced by E. I. du Pont de Nemours and Company (DuPont), one of the 

largest chemical companies in the United States. For decades, Kevlar has competed against 

Twaron, a para-aramid fiber product produced by Teijin Limited, one of the largest chemical 

companies in Japan. According to the indictment, from July 2002 through February 2009, Kolon 

allegedly sought to improve its Heracron product by targeting current and former employees at 

DuPont and Teijin and hiring them to serve as consultants, then asking these consultants to reveal 

information that was confidential and proprietary. The indictment alleges that in July 2002, Kolon 

obtained confidential information related to an aspect of DuPont's manufacturing process for 

Kevlar, and within three years Kolon had replicated it. This successful misappropriation of 

DuPont's confidential information, the indictment alleges, spurred Kolon leadership to develop a 

multi-phase plan in November 2005 to secure additional trade secret information from its 

competitors, by targeting people with knowledge of both pre-1990 para-aramid technology and 

post-1990 technologies. Kolon is alleged to have retained at least five former DuPont employees 

as consultants. Kolon allegedly met with these people individually on multiple occasions from 

2006 through 2008 to solicit and obtain sensitive, proprietary information that included details 

about DuPont's manufacturing processes for Kevlar, experiment results, blueprints and designs, 

prices paid to suppliers and new fiber technology. This investigation was conducted by the FBI.

Theft of Trade Secrets for Potential Use in China - On September 19, 2012, Chunlai Yang, a 

former senior software engineer for Chicago-based CME Group, Inc., pleaded guilty in the 

Northern District of Illinois to two counts of theft of trade secrets for stealing source code and 

other proprietary information while at the same time pursuing plans to improve an electronic 

trading exchange in China. Yang admitted that he downloaded more than 10,000 files containing 

CME computer source code that made up a substantial part of the operating systems for the 

Globex electronic trading platform. The government maintains that the potential loss was 

between $50 million and $100 million. Yang began working for CME Group in 2000 and was a 

senior software engineer at the time of his arrest. Between late 2010, and June 30, 2011, Yang 

downloaded more than 10,000 computer files containing CME computer source code from CME's 

secure internal computer system to his CME-issued work computer. He then transferred many of 

these files from his work computer to his personal USB flash drives, and then transferred many of 
51

these files from his flash drives to his personal computers and hard drives at his home. Yang also 

admitted that he downloaded thousands of others CME files. Yang admitted that he and two 

unnamed business partners developed plans to form a business referred to as the Tongmei 

(Gateway to America) Futures Exchange Software Technology Company (Gateway), whose 

purpose was to increase the trading volume at the Zhangjiagang, China, chemical electronic 

trading exchange (the Zhangjiagang Exchange.) The Zhangjiagang Exchange was to become a 

transfer station to China for advanced technologies companies around the world. Yang expected 

that Gateway would provide the exchange with technology through written source code to allow 

for high trading volume, high trading speeds, and multiple trading functions. Yang was indicted 

on September 28, 2011. This investigation was conducted by the FBI.

Motorola Trade Secrets to China - On August 29, 2012, Hanjuan Jin, a former software engineer 

for Motorola, was sentenced in the Northern District of Illinois to four years in prison for stealing 

trade secrets from Motorola, specifically Motorola's proprietary iDEN telecommunications 

technology, for herself and for Sun Kaisens, a company that developed products for the Chinese 

military. According to court documents filed in the case, Motorola spent more than $400 million 

researching and developing iDEN technology in just a matter of years. On February 8, 2012, Jin 

was found guilty of three counts of stealing trade secrets. Jin, a naturalized U.S. citizen born in 

China, possessed more than 1,000 electronic and paper Motorola proprietary documents when she 

was stopped by U.S. authorities at Chicago's O'Hare International Airport as she attempted to 

travel to China on February 28, 2007. The judge presiding over the case found her not guilty of 

three counts of economic espionage for the benefit of the government of China and its military. 

According to the evidence at trial, Jin began working for Motorola in 1998, and took medical 

leave in February 2006. Between June and November 2006, while still on sick leave, Jin pursued 

employment in China with Sun Kaisens, a Chinese telecommunications firm that developed 

products for the Chinese military. Between November 2006 and February 2007, Jin returned to 

China and did work for Sun Kaisens on projects for the Chinese military. On February 15, 2007, 

Jin returned to the United States from China and reserved a flight to China scheduled to depart on 

February 28, 2007. Jin advised Motorola that she was ready to return to work at Motorola, 

without informing Motorola that she planned to return to China to work for Sun Kaisens. On 

February 26, 2007, she returned to Motorola, and accessed hundreds of technical documents 

belonging to Motorola on its secure internal computer network. As she attempted to depart from 

Chicago to China, authorities seized numerous materials, some of which provided a description of 

communication feature that Motorola incorporates into its telecommunications products. 

Authorities also recovered classified Chinese documents describing telecommunication projects 

for the Chinese military. Jin was charged with theft of trade secrets in an April 1, 2008 

indictment. A superseding indictment returned on December 9, 2008 charged her with economic 

espionage. The investigation was conducted by the FBI, with assistance from U.S Customs and 

Border Protection. 

Firearms to Haiti - On August 23, 2012, Jean Gordy Gedeon, a national of Haiti, was sentenced 

in the Middle District of Florida to 46 months imprisonment. Previously, on June 5, 2012, 

Gedeon pleaded guilty to a criminal information which charged the defendant with attempting to 

purchase and smuggle firearms from the United States to Haiti. Gedeon arranged with an 

undercover agent to purchase eleven firearms that he said he intended to smuggle to Haiti. He 

was arrested on May 30, 2012 after paying $1,100 to the undercover agent for four pistols and a 

machine gun. The case was investigated by ATF.

Anti-Aircraft Missile, Anti-Tank Weapons and Machine Guns to Mexican Drug Cartel - On 

August 22, 2012, Mexican national David Diaz-Sosa was sentenced in the District of Arizona to 

25 years in prison after pleading guilty on April 19, 2011, to several violations related to his 
52

efforts to acquire military-grade weaponry in the United States for export to Mexico for use by a 

Mexican drug trafficking organization. Diaz-Sosa pleaded guilty to conspiracy to acquire and 

export an anti-aircraft missile, conspiracy to possess machine guns and transfer guns for use in a 

drug trafficking crime as well as methamphetamine violations. In 2009, Diaz-Sosa began 

negotiating with undercover agents for the purchase of weapons for the Sinaloan Drug Cartel in 

Mexico, including a Stinger missile, several anti-tank weapons, grenade launchers, grenades, and 

machine guns. Diaz-Sosa and his associates agreed to exchange cash and methamphetamine as 

payment for the weapons. On February 17, 2010, Diaz-Sosa and Jorge DeJesus-Casteneda were 

arrested as they sought to finalize the weapons exchange with undercover agents. Diaz-Sosa, 

DeJesus-Castaneda, and an additional defendant, Emilia Palomino-Robles, were charged in a 

sealed indictment on March 16, 2010. Palomino-Robles pleaded guilty on April 13, 2011 to one 

drug violation, stemming from her role as a money and drug courier in the weapons-for-drugs 

transaction. On April 27, 2011, DeJesus-Casteneda was convicted of one count of possession 

with intent to distribute over 500 grams of methamphetamine, but was acquitted of other charges. 

DeJesus-Casteneda was sentenced on August 3, 2011 to 146 months in prison and five years 

supervised release. Palomino-Robles was sentenced on March 5, 2012 to 10 years in prison and 5 

years supervised release for her role in the scheme. This investigation was conducted by the ATF 

and the DEA. 

Defense Services, Training, Technical Data, Body Armor and Ammunition to Foreign Nations

- On August 7, 2012, a criminal information was unsealed in the Eastern District of North 

Carolina charging Academi LLC, formerly known as Blackwater Worldwide and Xe Services, 

LLC, with violating the Arms Export Control Act, the International Emergency Economic Powers 

Act (IEEPA), as well as federal firearms laws and other violations. A deferred prosecution 

agreement (DPA) was also unsealed on the same day, in which the company admitted to certain 

facts set forth in the bill of information and agreed to pay $7.5 million a fine. The DPA also 

acknowledged and referenced a $42 million settlement between the company and the State 

Department to settle civil violations of the Arms Export Control Act. The criminal information 

alleged the company violated IEEPA by exporting satellite phones to the Sudan in November 

2005 without a license from the Treasury Department. The information also alleged that the 

company violated arms export laws by proposing to provide security services and a threat 

assessment to the government of the Sudan; by providing military training to Canadian military 

and law enforcement officials between 2006 and 2008; by providing technical data related to the 

construction of armored personnel carriers to individuals from Sweden and Denmark between 

2006 and 2008; and by exporting ammunition and body armor to Iraq and Afghanistan between 

2004 and 2006 - all without the required State Department export licenses. The information also 

alleged that Academi possessed automatic weapons without registration or permission and that it 

falsely represented to the ATF that five firearms were owned by certain individuals, when the 

weapons had been given as a gift to the King of Jordan and his traveling entourage in June 2005. 

This case was investigated by the FBI, IRS, ATF, DCIS and ICE.

Tactical SUVs Armed with M 134 Mini-guns to Turkmenistan – On Jul. 31, 2012, in the District 

of Arizona, Victor Dobrogaiev was sentenced to 21 months imprisonment (time served), three 

years supervised release, and $100 special assessment after his plea of guilty on Apr. 24, 2012 to 

conspiracy to violate the Arms Export Control Act. Previously, on Feb. 4, 2011, his codefendant, 

Ruslan Gilchenko, was sentenced to 18 months in prison and three years supervised release after 

his plea of guilty on Sept. 29, 2010 for his role in the conspiracy. Both defendants were ordered 

to forfeit any interest in the $610,000 paid in furtherance of the conspiracy. A Feb. 24, 2010 

indictment charged Gilchenko and Victor Dobrogaiev with conspiracy to violate the Arms Export 

Control Act, money laundering and fraud charges. According to the charges, Gilchenko and 

Dobrogaiev attempted to obtain three sport utility vehicles outfitted with M134 Mini-guns, which 
53

are fully automatic defense suppression weapons that fire at a rate of 3,000 rounds per minute, for 

illegal export to Turkmenistan. As part of the conspiracy, the defendants allegedly agreed to pay 

$1.2 million to purchase three armed vehicles and forwarded $340,000 to sellers in the U.S. as a 

down payment. In connection with the transaction, Gilchenko, who represents a company in 

Slovenia called MG CZ Group, allegedly sought to defraud the government of Turkmenistan of 

by causing the price of the transaction to be inflated. Gilchenko pleaded guilty to the conspiracy 

count on September 29, 2010. The investigation was conducted by ICE.

Military-Grade Riflescopes Overseas - On July 13, 2012, Geoffrey Roose was sentenced in the 

Western District of Washington to 10 months in prison and two years supervised release for his 

efforts to sell military-grade riflescopes overseas via eBay. Roose was arrested on a complaint on 

December 6, 2011, indicted on February 22, 2012 and pleaded guilty March 28, 2012 to 

attempting to violate the Arms Export Control Act. Federal agents learned that Roose had sold 

export-restricted rifle scopes to individuals overseas without the required license and warned him 

that such exports were restricted. Despite the warning, Roose continued to offer the items for sale 

on eBay with no limitation on their export. He later sold one of the military scopes to an 

undercover agent who requested that it be sent to Europe. This case was investigated by ICE.

Materials for Gas Centrifuges and Other Nuclear-Related Goods to Iran - On July 12, 2012, a 

grand jury in the District of Columbia returned a superseding indictment charging Parviz Khaki, a 

citizen of Iran, and Zongcheng Yi, a resident of China, for their alleged efforts to obtain and 

illegally export to Iran U.S.-origin materials used to construct, operate and maintain gas 

centrifuges to enrich uranium, including maraging steel, aluminum alloys, mass spectrometers, 

vacuum pumps and other items. Khaki was also accused of conspiring to procure radioactive 

source materials from the United States for customers in Iran. The indictment charges Khaki and 

Yi each with conspiracy to violate the International Emergency Economic Powers Act (IEEPA), 

conspiracy to defraud the United States, smuggling, illegally exporting U.S. goods to Iran in 

violation of IEEPA; and conspiracy to commit money laundering. Khaki was arrested on May 

24, 2012, by authorities in the Philippines in connection with a U.S. provisional arrest request 

stemming from a March 8, 2012 indictment in the District of Columbia. Yi, who is purported to 

be the managing director of Monalila Co. LTD, a toy company in Guangzhou City, China, 

remains at large. From around October 2008 through January 2011, Khaki, Yi and others 

allegedly conspired to cause the export of goods from the United States to Iran without a Treasury 

Department license. In carrying out the conspiracy, Khaki directed Yi and others to contact U.S. 

companies about purchasing U.S.-origin goods. Yi and other conspirators then purchased goods 

from various U.S. companies and had the goods exported from the United States through China 

and Hong Kong to Khaki and others in Iran. Yi and others made false statements to U.S. 

companies on behalf of Khaki to conceal that Iran was the final destination and end-user of the 

goods. For example, the indictment alleges that Khaki reached out to an individual in China, as 

well as to Yi, and to an undercover agent in the United States to obtain 20 tons of C-350 

maraging steel from the United States for Khaki's customer in Iran. In late 2008, Khaki also 

reached out to an individual in China about procuring 20 tons of 7075-O aluminum alloy 80mm 

rods and 20 tons of 7075-T6 aluminum alloy 150 mm rods from the United States or Europe. 

Khaki also allegedly sought to obtain mass spectrometers from the United States, including a 

magnetic mass spectrometer for the isotopic analysis of gaseous uranium hexafluoride, which is 

used in the gas centrifuge process to enrich uranium. Khaki and Yi also conspired to obtain other 

items from U.S. companies that can be used for gas centrifuges, including measuring instruments, 

MKS Baratron pressure transducers, vacuum pumps and other accessories, according to the 

charge. Khaki also allegedly sought to obtain radioactive source materials from the United 

States, including barium-133 source, europium-152 source, cobalt-57 source, and cadmium-109 

source. Finally, the indictment alleges the defendants were able to successfully cause the illegal 
54

export of two Twister Speed Lathes as well as nickel alloy 120 wire from the U.S. through China 

to Iran. This investigation was conducted by ICE. 

Carbon Fiber Material to Iran - On June 21, 2012, Richard Phillips, a resident of the Bronx, 

N.Y. was sentenced in the Eastern District of New York to 92 months in prison for attempting to 

export carbon fiber material to Iran in violation of the International Emergency Economic Powers 

Act. Phillips pleaded guilty to this charge on January 18, 2012. According to court filings, in 

October 2011, Phillips offered his services and expertise in exporting a spool of carbon fiber to 

Tehran, Iran, via the Philippines. The two main applications of carbon fiber in specialized 

technology, including aerospace and nuclear technology, and in general engineering and 

transportation. After a series of communications with an undercover federal agent in which he 

was warned of the law regarding exports of carbon fiber to Iran, Phillips insisted on moving 

forward with the export. He took possession of a spool of carbon fiber which was placed into a 

shipping container and affixed a label to the contained addressed to the Philippines, where it was 

to be forwarded to Iran. Phillips was first charged by criminal complaint on October 21, 2011. 

This investigation was conducted by ICE and the DCIS.

$619 Million Fine Against ING Bank for Transactions with Iran and Cuba - On June 12, 2012, 

ING Bank, N.V., a global bank based in Amsterdam, agreed to forfeit $619 million to the Justice 

Department and the New York County District Attorney's Office for conspiring to violate U.S. 

sanctions on Iran and Cuba as well as New York state laws by illegally moving more than $2 

billion (via more than 20,000 transactions) through the U.S. financial system on behalf of 

sanctioned entities in Iran and Cuba. This conduct caused unaffiliated U.S. banks to unwittingly 

process transactions that should have been blocked or stopped pursuant to Treasury Department 

regulations. On June 12, 2012, a criminal information was filed in the District of Columbia 

charging ING Bank with one count of conspiring to violate the International Emergency 

Economic Powers Act and the Trading with the Enemy Act. ING Bank waived the federal 

indictment, agreed to the filing of the information, accepted responsibility for its criminal conduct 

and that of its employees, and agreed to pay $619 million to the Justice Department and the New 

York County District Attorney's office under deferred prosecution agreements with each. The 

fine represented the largest against a financial institution in connection with an investigation into 

U.S. sanctions and related offenses. The Justice Department's case against ING Bank arose out of 

ongoing investigations by the National Security Division and U.S. Attorney's Office for the 

District of Columbia into the illegal export of goods from the United States to sanctioned 

countries, including Iran. For instance, ING processed payments on behalf of one customer, 

Aviation Services International B.V. (ASI), a Dutch aviation company which was the subject of a 

U.S. Commerce Department-initiated criminal investigation, through the United States for trade 

services relating to the procurement by ASI of dual-use U.S. aviation parts for ASI's Iranian 

clients. The ING Bank investigation also resulted in part from a criminal referral from OFAC, 

which was conducting its own probe of ING Bank. The ING Bank investigation was conducted 

by the FBI, IRS, with assistance from OFAC and the Commerce Department.

Trade Secrets to India – On June 3, 2013, Prabhu Prasad Mohapatra, an Indian citizen with a 

work visa and an alien registration card, was sentenced in the District of Utah to time served, 30 

days supervised release, $100 SPA and $3,435.25 in restitution. Previously, on April 11, 2012, 

Mohapatra was charged in a 26 count Superseding Indictment with theft of trade secrets, wire 

fraud and attempt, and computer-related fraud. On May 11, 2012, Mohapatra pleaded guilty to 

one count of unlawful access to a protected computer. The remaining 25 counts of the 

Superseding Indictment were dismissed on the government’s motion. On November 14, 2011, 

Mohapatra was arrested on a criminal complaint in the District of Utah (filed on November 10, 

2011) charging him with stealing proprietary information from his employer, Frontier Scientific, 
55

Inc., a Utah scientific company, and providing it to a relative in India who was starting up a 

competing company. According to the charges, Mohapatra worked as a senior scientist for 

Frontier Scientific, Inc., a company that makes large pure quantities of an organic chemical, 2,2'-

dipyrromethane, that has several applications, including as an ingredient in new drugs, as well as 

in solar cells and batteries. The complaint alleged that Mohapatra emailed proprietary 

information from Frontier Scientific about the chemical to his brother-in-law in India, who was 

setting up an unregistered, competing company called Medchemblox. The complaint further 

alleged that Mohapatra had a financial interest in Medchemblox. This investigation was 

conducted by FBI.

Aircraft Components and Other Materials to Iran - On May 15, 2012, Ulrich Davis, a former 

manager of a Netherlands-based freight forwarding company, was sentenced in the District of 

New Jersey to six months in prison after pleading guilty on February 6, 2012 to conspiracy to 

defraud the United States by facilitating the illegal export of goods to Iran. Davis was first 

arrested on August 6, 2011. In October 2007, the Commerce Department issued a Temporary 

Denial Order (TDO) denying export privileges to the company of a co-conspirator of Davis. The 

TDO prohibited any person, including Davis, from directly or indirectly exporting or re-exporting 

to or on behalf of the co-conspirator. The co-conspirator located in another country, purchased 

U.S. origin goods from a New Jersey firm for businesses and governmental agencies of Iran. The 

New Jersey firm was in the business of reselling chemicals, lubricants, sealants and other 

products used in the aircraft industry. As part of the conspiracy, Davis and his coconspirator 

directed a New York freight forwarding company to arrange for a trucking company to pick up 

commodities from the New Jersey company and transport them to New York on behalf of the 

coconspirator's company. Davis admitted that in November 2007, he completed an air waybill 

that represented certain acrylic adhesives and spray paint coatings obtained from a New Jersey 

company were to be forwarded on behalf of the co-conspirator's company to Iran after issuance of 

the TDO. Davis acknowledged that at no time was any relief, exception, or other authorization 

sought from the TDO. The investigation was conducted by BIS, ICE, and DCIS.

Laboratory and Radiation Detection Equipment to Iran – On May 15, 2012, Majid Saboni was 

sentenced in the Southern District of California to 12 months and 1 day in prison and $100 

special assessment. Previously, on December 15, 2011, Majid Saboni pleaded guilty to a onecount information charging him with conspiracy to export laboratory equipment, radiation 

detection equipment, and radon detection equipment from the United States to Iran in violation of 

the embargo on Iran. Saboni was first charged in a criminal complaint on October 14, 2011 and 

was later arrested on October 24, 2011. The information against him was filed on November 21, 

2011. This investigation was conducted by ICE. 

Military-Grade Thermal Weapon Sight and Rifle Scopes to Eastern Europe – On May 11, 

2012, Igor Bobel of Brooklyn, N.Y. was sentenced in the Eastern District of Pennsylvania to 30 

months imprisonment, 3 years supervised release, and $200 special assessment stemming from 

his plea of guilty on February 1, 2012 to a two count criminal information. The criminal 

information, dated December 22, 2011, charged the defendant with one count of smuggling and 

one count of attempting to illegally export defense articles. Bobel attempted to export a thermal 

weapon sight and two rifle scopes -- which are classified as defense articles -- to an Eastern 

European nation on May 16, 2011, without the required export license from the State Department. 

Bobel was first arrested on a sealed criminal complaint on July 1, 2011. This investigation was 

conducted by ICE. 

Trade Secrets to U.S. Subsidiary of Chinese Company – On May 7, 2012, Yuan Li, a former 

research chemist with the global pharmaceutical company Sanofi-Aventis, was sentenced in the 
56

District of New Jersey to 18 months imprisonment, 2 years of supervised release, $100 special 

assessment and restitution in the amount of $131,000. Previously, on January 17, 2012, Li 

pleaded guilty to stealing Sanofi's trade secrets and making them available for sale through Abby 

Pharmatech, Inc., the U.S. subsidiary of a Chinese chemicals company. According to court 

documents, Li worked at Sanofi headquarters in Bridgewater, N.J., from August 2006 through 

June 2011, where she assisted in the development of several compounds (trade secrets) that 

Sanofi viewed as potential building blocks for future drugs. While employed at Sanofi, Li was a 

50 percent partner in Abby, which sells and distributes pharmaceuticals. Li admitted that 

between October 2008 and June 2011, she accessed internal Sanofi databases and downloaded 

information on Sanofi compounds and transferred this information to her personal home 

computer. She also admitted that she made the stolen compounds available for sale on Abby's 

website. This investigation was conducted by the FBI.

Thermal Imaging Cameras to China - On May 7, 2012, Hing Shing Lau, also known as Victor 

Lau, a foreign national living in Hong Kong, Peoples Republic of China, was sentenced in the 

Southern District of Ohio to 10 months in prison followed by 2 years supervised release. 

Previously, on May 3, 2012, Lau pleaded guilty to two counts of violating export control laws. 

On June 9, 2009, a federal grand jury in the Southern District of Ohio indicted Lau on charges of 

trying to buy 12 infrared thermal imaging cameras from a Dayton-area company in order to 

illegally export the cameras to Hong Kong and China. The indictment alleges that Lau tried to 

buy 12 thermal imaging cameras manufactured in Texas by contacting a company in the Dayton 

area. On three occasions, he wire transferred a total of $39,514 from Hong Kong to the U.S. as 

partial payment for the cameras. The indictment charges Lau with two counts of violating export 

control laws and four counts of money laundering. Canadian authorities arrested Lau on June 3, 

2009, at the Toronto International Airport pursuant to a provisional arrest warrant issued by U.S. 

authorities. The investigation was conducted by the FBI, and BIS, with the assistance of the U.S. 

Department of State. 

Firearms to Nigeria - On May 3, 2012, Olamide Ogunyale was sentenced in the Northern 

District of Georgia to 8 months in prison, followed by two years of supervised release, for 

attempting to smuggle firearms to Nigeria. Ogunyale pleaded guilty on December 1, 2012. 

According to court documents, in April 2011, Ogunyale agreed to help an individual ship 12 

firearms and vehicles from the Port of Savannah, Ga., to Nigeria and completed export paperwork 

without declaring the hidden shipment of weapons. The case was investigated by the ATF and 

ICE.

Thermal Imaging Cameras to China - On April 23, 2012, Jason Jian Liang, the owner and 

operator of Sanwave International Corporation in Huntington Beach, Calif., was sentenced to 46 

months in prison and three years supervised release after pleading guilty on July 18, 2011, in the 

Central District of California to violations stemming from his illegal exports of thermal imaging 

cameras to Hong Kong and China. Lian was first indicted on June 2, 2010. An August 18, 2010 

superseding indictment charged Liang with illegally exporting more thermal imaging cameras to 

China without first having obtained the required licenses. The cameras in question were 

manufactured by L-3 Communications Infrared Products and were designated by the Commerce 

Department as an export-controlled item that could not be exported to China for national security 

and regional stability reasons. Ultimately Lian admitted making seven illegal exports of 300-D 

thermal imaging cameras over a 31-month period. All told, he exported 63 cameras.

Ammunition and Night Vision Devices to Mexico - On April 10, 2012, Enrique Gustavo 

Gonzalez was sentenced in the Southern District of Texas to 36 months in prison and two years 

supervised release after pleading guilty on September 8, 2010 to arms export violations. In June 
57

2010, officers with the Roma, TX, police department conducted a traffic stop of Gonzalez, where 

a search of his car revealed 7,260 rounds of ammunition, military night vision goggles, military 

night vision rifle scopes, infrared illuminators, as well as two .30-06 rifles - all of which are on 

the U.S. Munitions List. Gonzalez later admitted he was taking the materials to a ranch along the 

border, where the items would be crossed into Mexico. The investigation was conducted by ICE.

Arms to Colombian Terrorists to Kill Americans - On April 5, 2012, international arms dealer 

Viktor Bout was sentenced in the Southern District of New York to 25 years in prison, five years 

of supervised release and ordered to forfeit $15 million after being convicted on November 2, 

2011 of conspiracy to kill U.S. nationals; conspiracy to kill U.S. officers and employees; 

conspiracy to acquire and use an anti-aircraft missile; and conspiracy to provide material support 

to the Revolutionary Armed Forces of Colombia (FARC), a designated terrorist organization. 

Bout was first arrested on March 5, 2008 by Thai authorities in Bangkok, Thailand. On 

November 17, 2010, after more than two years of legal proceedings in Thailand, Bout was 

extradited from Thailand to the United States to stand trial on the charges. According to court 

documents and evidence introduced at trial, between November 2007 and March 2008, Bout 

agreed to sell to the FARC millions of dollars' worth of weapons - including 700 - 800 surface-toair missiles (SAMs), more than 20,000 AK-47 firearms, 10 million rounds of ammunition, five 

tons of C-4 plastic explosives, "ultralight" airplanes outfitted with grenade launchers, and 

unmanned aerial vehicles. Bout agreed to sell the weapons to two confidential sources working 

with the DEA (the "CSs"), who represented that they were acquiring them for the FARC, with the 

specific understanding that the weapons were to be used to attack U.S. helicopters in Colombia. 

During a covertly recorded meeting in Thailand in 2008, Bout stated to the CSs that he could 

arrange to airdrop the arms to the FARC in Colombia, and offered to sell two cargo planes to the 

FARC that could be used for arms deliveries. Bout said that he understood that the CSs wanted 

the arms to use against American personnel in Colombia, and advised that, "we have the same 

enemy," referring to the United States. During the meeting, he also offered to provide people to 

train the FARC in the use of the arms. The investigation was conducted by the DEA.

$4 Million Arms Shipment to Cote d'Ivoire - On March 26, 2012, Michael Barry Shor, of 

Alexandria, Va., was sentenced in the Northern District of California to 18 months in prison, after 

pleading guilty on August 1, 2010 to one count of conspiracy to violate the Arms Export Control 

Act. In pleading guilty, Shor admitted that, beginning in July 2009 until about April 21, 2010, he 

conspired with others to illegally export 4,000 Glock 9mm handguns, 200,000 rounds of 

ammunition, and 50,000 tear gas grenades from the United States to the Cote d' Ivoire on behalf 

of the Cote d' Ivoire Defense Ministry, purportedly for use in the 2010 elections in that country. 

According to court documents filed in the case, federal agents learned in 2009 that Shor, located 

in the United States, was working to broker the export of arms and ammunition to Cote d'Ivoire. 

During investigation that ensued, Shor revealed to undercover agents that he was brokering the 

deal on behalf of the Defense Minister of Cote d' Ivoire. In April 2010, officials in Cote d' Ivoire 

wire transferred $1.9 million from a bank in New York to an undercover bank account in San 

Jose, Calif., as a 50 percent down payment for the shipment of arms and ammunition. Shor was 

then arrested by ICE agents. After his arrest, ICE agents were provided with information on the 

identity of several individuals from the Cote d'Ivoire who were assigned to conduct an inspection 

of a sample of the weapons to be shipped from the United States. On August 31, 2010, Nguessan 

Yao, a citizen of the Cote d'Ivoire and other co-conspirators were picked up from a location in 

New York City and were shown 500 9mm pistols, 1,000 tear gas grenades and 100,000 rounds of 

9mm ammunition by the agents at a location in New Jersey. A few days later, these conspirators 

arranged for another $1.9 million to be wire transferred to a government controlled bank account. 

Yao was subsequently arrested. On September 22, 2010, both Shor and Yao were charged in a 

superseding indictment in the Northern District of California with one count of conspiracy to 
58

export arms in violation of a United Nations Security Council Arms Embargo, and in violation of 

a U.S. law and regulation; and one count of attempting to export defense articles. Yao pleaded 

guilty on October 4, 2011 to conspiracy to violate the Arms Export Control Act and was 

sentenced on November 22, 2011 to one year and one day in prison. The investigation was 

conducted by ICE.

Military Gyroscopes and Other Technology to Iran - On February 29, 2012, a federal grand jury 

in the District of Columbia returned an indictment charging David Levick, an Australian national, 

and his company, ICM Components Inc., located in Thorleigh, Australia, with conspiring to 

export sensitive military and other technology from the United States to Iran, including 

components with applications in missiles, drones, torpedoes and helicopters. The indictment 

charged Levick and ICM each with one count of conspiracy to defraud the United States and to 

violate the International Emergency Economic Powers Act (IEEPA) and the Arms Export Control 

Act; as well as four counts of illegally exporting goods to an embargoed nation in violation of 

IEEPA; and forfeiture of at least $199,227.41. Levick and ICM allegedly solicited orders from an 

Iranian representative of a trading company in Iran. Levick and ICM then placed orders with 

U.S. companies on behalf of the Iranian representative for U.S. aircraft parts and other goods. 

Among the items they allegedly sought to procure from the United States were military-grade 

VG-34 Series Miniature Vertical Gyroscopes - which are used in applications such as helicopter 

flight systems, target drones, missiles, torpedoes and remotely piloted vehicles -- as well as 

military-grade K2000 Series Servo Actuators designed for use on aircraft. The defendants also 

sought precision pressure transducers, emergency floatation system kits -- for use on helicopters -

and shock mounted light assemblies. Levick and ICM often used a broker in Florida to place 

orders for these goods and allegedly concealed the final end-use and end-users of the goods from 

the U.S. In addition to the conspiracy allegations, the indictment charges the defendants with 

exporting to Iran four specific shipments involving shock mounted lighted assemblies, precision 

pressure transducers and an emergency floatation system kit. Levick remains at large. The 

investigation was conducted by BIS, FBI, DCIS and ICE.

Defense Items to the United Arab Emirates - On February 24, 2012, Andrew Silcox was 

sentenced to 24 months in prison after pleading guilty on December 15, 2011 in the Western 

District of Texas to one count of violating the Arms Export Control Act. Silcox was in the 

business of purchasing surplus Defense Department equipment and reselling it. According to 

court documents, Silcox sold a Naval Radar Control Unit part (also known as a Sensitivity time 

Control Generator Assembly) and attempted to sell three others to an undercover agent posing as 

a broker for a purchaser in the United Arab Emirates. The units Silcox attempted to sell are 

defense articles that require a State Department license for export. Silcox was arrested in San 

Antonio on October 21, 2011. This investigation was conducted by ICE and DCIS.

Computer-Related Technology to Iran - On February 17, 2012, Jeng "Jay" Shih, was sentenced 

in the District of Columbia to 18 months in prison, while his Queens, N.Y., company, Sunrise 

Technologies and Trading Corporation, was sentenced to 24 months corporate probation for 

conspiracy to illegally export U.S.-origin computers from the United States to Iran through the 

United Arab Emirates (UAE). Both Shih and his company were also ordered to forfeit $1.25 

million, for which they are jointly liable. Shih and Sunrise pleaded guilty on October 7, 2011. 

Three related defendants have also pleaded guilty in the case. On February 16, 2012, Massoud 

Habibion and his Costa Mesa, Calif., company, Online Micro LLC, pleaded guilty in the District 

of Columbia to conspiracy to illegally export computers from the United States to Iran through 

the (UAE). Mohsen Motamedian, a co-owner of Online Micro, pleaded guilty to obstruction of 

justice. Under the terms of the plea and related civil settlements with BIS and OFAC, Habibion 

and his company agreed to forfeit $1.9 million, while Motamedian separately agreed to a $50,000 
59

monetary penalty. On May 16, 2012, Habibion was sentenced to 13 months in prison, while 

Motamedian was sentenced to three years supervised release. On April 21, 2011, two separate 

indictments were returned in the District of Columbia charging Shih and Sunrise, as well as 

Habibion, Motamedian and Online Micro. The indictments alleged that each of the defendants 

sold millions worth of laptop computers to a company in Dubai, knowing full well that the 

computers were ultimately destined for Iran. According to court documents, Shih exported 

roughly $700,000 worth of computers per month to Iran through Dubai, while Habibion and 

Motamedian exported roughly $300,000 worth of computers per month to Iran through Dubai, by 

using fake invoices and other concealment techniques. The investigation was conducted by ICE, 

with assistance from the Department of Commerce and U.S. Customs and Border Protection.

Radiation-Hardened Circuits to China - On December 18, 2013, Chinese citizen and former 

California Department of Transportation (Caltrans) engineer Philip Chaohui He was sentenced in 

the District of Colorado for exporting radiation-hardened integrated circuits from the United 

States to China, in violation of the Arms Export Control Act, 22 U.S.C. § 2778. He was 

sentenced to 36 months imprisonment followed by 3 years of supervised release. He pleaded 

guilty on September 3, 2013. According to documents filed in the case, He was arrested as he 

was attempting to deliver the circuits onto a Chinese ship at the Long Beach, California port. 

Upon a search of He's vehicle, agents located more than 300 space-qualified and radiationhardened computer circuits concealed inside plastic infant formula containers. The circuits are 

used in satellite communications and had a total value of nearly $550,000. He did not have a 

State Department license. A December 15, 2011 indictment charged He with conspiracy to 

violate the Arms Export Control Act (AECA) and to smuggle goods; attempted violation of 

AECA; and smuggling. According to the charges, He, the only employee of an Oakland 

company called Sierra Electronic Instruments, arranged for the purchase of more than 300 

radiation-hardened circuits from Aeroflex, a Colorado manufacturer, in May 2011. He arranged 

for the purchase after a co-conspirator sent him wire transfers totaling nearly $490,000 from a 

bank in China. He then provided false certification to Aeroflex that the items would remain in the 

United States. He received the first shipment of 112 circuits from Aeroflex in July 2011 and later 

traveled from Mexico to Shanghai in September. In October 2011, he received a second 

shipment of 200 circuits from Aeroflex. He drove to the Port of Long Beach in December 2011 

and met with two men in front of a docked Chinese-flagged ship that was registered to a 

subsidiary of a China state-owned corporation. The ship had recently arrived from Shanghai and 

was scheduled to return on December 15, 2011. He had allegedly concealed the 200 circuits in 

infant formula containers within boxes labeled "milk powder" in the trunk of his vehicle. He was 

arrested on December 11, 2011 at the Port. This investigation was conducted by ICE and DCIS 

and Defense Security Service.

Military Antennae to Hong Kong & Singapore - On January 20, 2012, Rudolf L. Cheung, the 

head of research and development at a company in Massachusetts that manufactures antennae, 

pleaded guilty in the District of Columbia to one count of conspiracy to violate the Arms Export 

Control Act in connection with the illegal export of 55 military antennae from the United States 

to Hong Kong and Singapore. Cheung was charged in a criminal information on December 2, 

2011. According to court documents, Cheung's company received a query in 2006 from a firm in 

Singapore seeking two types of military antennae. After the Singapore firm refused to fill out the 

necessary end-user forms, the export compliance officer at Cheung's company stopped the 

transaction. Cheung then conspired with an associate at another U.S. company to bypass the 

export compliance officer at Cheung's company by having the associate purchase the antennae 

from Cheung's firm and then export them separately to Singapore without a State Department 

license. The conspiracy resulted in the illegal export, between July and September 2007 of 55 

military antennae from the United States to the Hong Kong and Singapore addresses of a 
60

company called Corezing International. Corezing, based in Singapore, has been charged in a 

separate indictment for its role in this particular antennae transaction. Corezing has also been 

charged for its role in a separate conspiracy involving the illegal export of radio frequency 

modules from the U.S. to Iran, some of which later ended up in Improvised Explosive Devices in 

Iraq. This investigation was conducted by ICE, FBI and BIS

Dow Trade Secrets to China - On January 12, 2012, Wen Chyu Liu, aka David W. Liou, a 

former research scientist at Dow Chemical Company in Louisiana, was sentenced in the Middle 

District of Louisiana to 60 months in prison, two years supervised release, a $25,000 fine and was 

ordered to pay $600,000 in restitution. Liu was convicted on February 7, 2011 of one count of 

conspiracy to commit trade secret theft for stealing trade secrets from Dow and selling them to 

companies in China, and he was also convicted of one count of perjury. According to the 

evidence presented in court, Liu came to the United States from China for graduate work. He 

began working for Dow in 1965 and retired in 1992. Dow is a leading producer of the 

elastomeric polymer, chlorinated polyethylene (CPE). Dow's Tyrin CPE is used in a number of 

applications worldwide, such as automotive and industrial hoses, electrical cable jackets and vinyl 

siding. While employed at Dow, Liu worked as a research scientist on various aspects of the 

development and manufacture of Dow elastomers, including Tyrin CPE. The evidence at trial 

established that Liu conspired with at least four current and former employees of Dow's facilities 

in Plaquemine, Louisiana, and in Stade, Germany, who had worked in Tyrin CPE production, to 

misappropriate those trade secrets in an effort to develop and market CPE process design 

packages to Chinese companies. Liou traveled throughout China to market the stolen 

information, and he paid current and former Dow employees for Dow's CPE-related material and 

information. In one instance, Liou bribed a then-employee at the Plaquemine facility with 

$50,000 in cash to provide Dow's process manual and other CPE-related information. The 

investigation was conducted by the FBI.

Handguns to the United Kingdom - On January 10, 2012, Steven Neal Greenoe was sentenced in 

the Eastern District of North Carolina to serve 10 years in prison in connection with the illegal 

export or firearms from the United States to the United Kingdom, after pleading guilty on March 

2, 2011. Greenoe was first charged by criminal complaint with Arms Export Control Act 

violations and other charges on July 26, 2010. A 50-count superseding indictment returned on 

February 2, 2011, alleged that Greenoe, and at least two other individuals he recruited obtained 

pistol purchase permits, completed the necessary ATF forms and purchased firearms. Greenoe 

then took the firearms apart and concealed them in his checked luggage. On nine occasions, from 

February 22, 2010, to July 25, 2010, he allegedly concealed a total of 63 pistols in his checked 

luggage and traveled from Raleigh, N.C., to the United Kingdom. In total, Greenoe smuggled at 

least 79 firearms to co-conspirators in the United Kingdom. According to court documents in the 

case, firearms purchased by Greenoe in the United States and illegally smuggled to the United 

Kingdom were used in a shooting in Manchester, England, in October 2010; as well as in the 

murder of Ian Langford, a father of four children, in Scotland on April 29, 2011; and in an 

attempted shooting of a cab driver near Liverpool. The investigation was conducted by ICE and 

ATF, with assistance from the Northwest Regional Organized Crime Unit from Liverpool.

U.S. Technology to Pakistani Nuclear Facilities - On January 6, 2012, Nadeem Akhtar, a 

Pakistan citizen and U.S. lawful permanent resident, was sentenced in the District of Maryland to 

37 months in prison followed by 2 years of supervised release. Previously, on September 9, 

2011, Akhtar pleaded guilty to conspiring to commit export violations and to defraud the United 

States in connection with a scheme to illegally export nuclear-related materials to Pakistan. 

Akhtar, who owned a company called Computer Communication USA (CC-USA), was originally 

indicted on March 11, 2010. According to his plea agreement, from October 2005 through March 
61

11, 2010, Akhtar and his conspirators used CC-USA to obtain or attempt to obtain radiation 

detection devices; resins for coolant water purification; calibration and switching equipment; 

attenuators; and surface refinishing abrasives for export to several restricted nuclear entities in 

Pakistan. Other items that Akhtar unlawfully procured or exported, or attempted to procure or 

export, to restricted entities in Pakistan include mechanical and electrical valves, cranes and 

scissor lifts. The total value of all of these items exceeded $400,000. The restricted entities in 

Pakistan included: Pakistan's Space and Upper Atmosphere Research Commission; and the 

Pakistan Atomic Energy Commission (PAEC) and its subordinate entities, such as the Chasma 

Nuclear Power Plant I in Kundian, Pakistan, and the research reactor maintained by the Pakistan 

Institute of Engineering and Applied Sciences, a constituent institution of the PAEC in Nilare, 

Pakistan, specializing in nuclear-related research and development. Akhtar attempted to evade 

export regulations and licensing requirements by: undervaluing and falsely describing the items 

being exported; failing to reveal the true end-user by using third parties and/or real and fake 

business entities/locations in Pakistan, Dubai and the United States; using individuals in Illinois 

and California to procure items for him under false pretenses; shipping items to his residences in 

Maryland so it would appear as though his company was the actual purchaser/end-user of the 

items; and transshipping the items from the U.S. through the United Arab Emirates (UAE). 

Akhtar took direction from the owner of a trading company located in Karachi, Pakistan, who had 

business relationships with governmental entities in Pakistan. This individual would obtain 

orders for nuclear-related and other commodities from Pakistani government entities identified 

above, and then direct Akhtar as to what commodities to purchase in the United States for export 

to Pakistan. Akhtar would then negotiate prices with manufacturers and suppliers of commodities 

sought in the U.S. and arrange for shipment of the commodities. Akhtar's co-conspirators 

included individuals in Pakistan, Dubai, UAE and New York associated with the owner of the 

Pakistani trading company. The owner usually paid Akhtar a commission of five to seven and a 

half percent of the cost of each item Akhtar obtained for export from the U.S. This investigation 

was conducted by BIS and FBI.

Wire Fraud in Trade Secrets Case Involving China - On January 5, 2012, Yan Zhu, a Chinese 

citizen in the U.S. on a work visa, was sentenced in the District of New Jersey to 3 years of 

probation and a special assessment of $700. Previously, on April 6, 2011, Zhu was convicted in 

the District of New Jersey on 7 counts of wire fraud in connection with his scheme to steal 

confidential and proprietary business information relating to computer systems and software with 

environmental applications from his New Jersey employer. He was acquitted on the charge of 

conspiracy to steal trade secrets and two counts of unauthorized transmission of trade secrets in 

interstate or foreign commerce. On April 10, 2009, Zhu was arrested on charges of theft of trade 

secrets, conspiracy, wire fraud, and theft of honest services fraud in connection with a plot to 

steal software from his former U.S. employer and sell a modified version to the Chinese 

government after he was fired. Zhu was employed as a senior environmental engineer from May 

of 2006 until his termination in July of 2008. Zhu worked for a comprehensive multi-media 

environmental information management portal that developed a proprietary software program for 

the Chinese market which allows users to manage air emissions, ambient water quality, and 

ground water quality. This investigation was conducted by the FBI

Dow and Cargill Trade Secrets to China - On December 21, 2011, in the Southern District of 

Indiana, Kexue Huang, a Chinese national and former resident of Indiana, was sentenced to 87 

months imprisonment and three years supervised release stemming from his plea of guilty on 

October 18, 2011 to charges of economic espionage to benefit a foreign university tied to the 

People's Republic of China (PRC) and theft of trade secrets. Huang also pleaded guilty on 

September 19, 2011 to one count of an indictment filed in the District of Minnesota for stealing a 

trade secret from a second company, Cargill Inc. Previously, on June 16, 2010, Huang was 
62

charged in the Southern District of Indiana with misappropriating and transporting trade secrets to 

the PRC while working as a research scientist at Dow AgroSciences LLC. On October 18, 2011, 

a separate indictment in the District of Minnesota charging Huang with stealing a trade secret 

from company, Cargill Inc., was unsealed. According to court documents, from January 2003 

until February 2008, Huang was employed as a research scientist at Dow. In 2005, he became a 

research leader for Dow in strain development related to unique, proprietary organic insecticides 

marketed worldwide. Huang admitted that during his employment at Dow, he misappropriated 

several Dow trade secrets. According to plea documents, from 2007 to 2010, Huang transferred 

and delivered the stolen Dow trade secrets to individuals in Germany and the PRC. With the 

assistance of these individuals, Huang used the stolen materials to conduct unauthorized research 

to benefit foreign universities tied to the PRC. Huang also admitted that he pursued steps to 

develop and produce the misappropriated Dow trade secrets in the PRC. After Huang left Dow, 

he was hired in March 2008 by Cargill, an international producer and marketer of food, 

agricultural, financial and industrial products and services. Huang worked as a biotechnologist for 

Cargill until July 2009. Huang admitted that during his employment with Cargill, he stole one of 

the company's trade secrets - a key component in the manufacture of a new food product, which 

he later disseminated to another person, specifically a student at Hunan Normal University in the 

PRC. According to the plea agreement, the aggregated loss from Huang's conduct exceeds $7 

million but is less than $20 million. On December 27, 2011, Huang received a sentence in the

District of Minnesota case of 87 months imprisonment and three years, to be served concurrently 

with the term imposed in the defendant’s case in the Southern District of Indiana. This 

investigation was conducted by the FBI.

Infrared Military Technology to South Korea - On December 20, 2011, EO System Company, 

Ltd, located in Inchon, South Korea, and defendants Seok Hwan Lee, Tae Young Kim and Won 

Seung Lee, all citizens and residents of South Korea, were indicted in the Northern District of 

Ohio on five counts of illegally exporting defense articles to South Korea. According to the 

indictment, on November 4, 2005, the defendants caused to be exported five infrared focal plan 

array detectors and infrared camera engines, which are classified as defense articles on the U.S. 

munitions list, from the United States to South Korea without the required State Department 

license. As part of the same investigation, on January 20, 2011, Kue Sang Chun, a former 

longtime employee at the NASA Glenn Research Center in Ohio and resident of Avon Lake, 

Ohio, pleaded guilty in the Northern District of Ohio to one count of violating the Arms Export 

Control Act and one count of filing false tax returns. Chun was sentenced on November 10, 2011 

to 14 months in prison. Chun was charged in a criminal information on January 10, 2011. 

According to court documents, while working as an electrical engineer for NASA, Chun also 

operated a business out of his home through which he illegally exported U.S. munitions to the 

South Korea and performed consulting services for Korean businesses. Chun illegally exported 

several infrared focal plane array detectors and infrared camera engines to South Korea for use in 

Korean government projects between March 2000 and November 2005. Chun entered into a 

contract with a Korean company to design, build and text electronics to support the items he was 

exporting. On occasion, Chung used his NASA e-mail address to order sensitive items from U.S. 

manufacturers, falsely asserting that they would be used for NASA projects in the United States, 

when in fact, they were to be exported to South Korea. The investigation was conducted by the 

FBI and IRS.

Trade Secrets to Foreign Government - On December 19, 2011, Elliot Doxer, of Brookline, 

Mass., was sentenced in the District of Massachusetts to 6 months in prison and 2 years 

supervised release. Previously, on August 30, 2011, Doxer pleaded guilty to one count of foreign 

economic espionage for providing trade secrets over an 18-month period to an undercover FBI 

agent posing as an Israeli intelligence officer. Neither the government of Israel nor anyone acting 
63

on its behalf committed any offense under U.S. laws in this case. Doxer was a former employee 

of Akamai Technologies, Inc., who in June 2006 sent an e-mail to the Israeli consulate in Boston 

stating that he worked in Akamai's finance department and was willing to provide information 

that might help Israel. In September 2007, an undercover FBI agent posing as an Israeli 

intelligence officer spoke to Doxer and established a "dead drop" where the agent and Doxer 

could exchange information. From September 2007 through March 2009, Doxer visited the dead 

drop at least 62 times to leave information, retrieve communications or check for new 

communications. Doxer provided the undercover agent with Akamai customer lists, employee 

lists, contract information and other trade secrets. He was arrested on October 6, 2010 on a 

complaint charging him with wire fraud. That charge was dismissed as part of the plea 

agreement. The case was investigated by the FBI.

Fighter Jet Engines to Iran - On December 16, 2011, defendants Amparo Echeverri and Carlos 

Alfredo Pantoja-Coral were both sentenced in the Southern District of Florida to 24 months in 

prison; 2 years supervised release and $100 special assessment. On September 2, 2011, these two 

defendants pleaded guilty to one count each of conspiring with others to fraudulently attempt to 

export J-85 fighter jet engines from the United States to Iran. Their co-defendant Diego M. 

Echeverri pleaded guilty to the same charge on August 3, 2011 and was later sentenced on 

October 24, 2011 to 24 months in prison and two years supervised release. On March 22, 2011, 

Pantoja-Coral, Amparo Echeverri, Diego Echeverri and an additional family member, Felipe 

Echeverry, were charged in an indictment with conspiring to illegally export to Iran 22 J-85 jet 

engines, which are primarily used in the F-5 fighter jet aircraft. All the defendants except Felipe 

Echeverry were arrested. According to the indictment and a March 9, 2011 criminal complaint, 

undercover ICE agents responded to an ad on the Internet that was listing the engines for sale. In 

subsequent conversations, Felipe Echeverry allegedly told undercover agents he had 22 of the 

engines stored at a warehouse in Miami and allowed undercover agents to inspect the engines as 

part of a potential sale. Undercover agents indicated that they were purchasing the engines on 

behalf of customers in Iran. Ultimately, in March 2011, several of the defendants met with the 

ICE undercover agents to sign the sales document and accept a 50 percent down payment for the 

22 engines. The defendants allegedly plotted to ship the items to Panama, knowing that they 

were ultimately bound for Iran. Felipe Echeverry remains a fugitive. The investigation was 

conducted by ICE and DCIS. 

Defense Items to the Philippines - On December 13, 2011, John Dennis Tan Ong was sentenced 

in the Northern District of Georgia to 21 months in prison for conspiracy to violate the Arms 

Export Control Act in connection with the illegal export of M-4 rifle parts and accessories. On 

May 5, 2011, Ong pleaded guilty to this violation. Ong was first indicted on August 17, 2010 on 

charges of conspiracy to violate and attempt to violate the Arms Export Control Act. According 

to court documents, Ong agreed to ship the rifle parts to the Philippines, wired funds to 

undercover agents in connection with items, and provided undercover agents with instructions on 

how to ship the items in manner to avoid detection. The investigation was conducted by ICE

Stolen U.S. Military Night Vision & Optics to China and England - On November 4, 2011, in 

the Southern District of California, Phillip Andro Jamison, a former Gunner's Mate Petty Officer 

First Class in the U.S. Navy stationed aboard Naval Amphibious Base Coronado, was sentenced 

to serve 30 months in prison for violating the Arms Export Control Act. Jamison pleaded guilty 

on April 28, 2011. On September 9, 2010, he was indicted for trafficking in stolen government 

property, interstate transportation of stolen goods and exporting defense articles without a license. 

The indictment alleged that Jamison, while assigned to work at his unit's armory, stole more than 

280 items from the U.S. Navy between October 2008 and September 2009 and then sold these 

items to customers via eBay, an Internet auction and shopping website. The indictment further 
64

alleged that Jameson illegally exported to Hong Kong and England combat-grade night vision 

devices, riflescopes and laser aiming devices without first obtaining the required export licenses 

from the State Department. Jamison admitted stealing the items and illegally exporting some of 

the technology to Hong Kong. The investigation was conducted by ICE and NCIS.

Radiation-Hardened Defense and Aerospace Technology to China - On October 27, 2011, Lian 

Yang, a resident of Woodinville, Washington, was sentenced in the Western District of 

Washington to 18 months in prison and a $10,000 fine. On March 24, 2011, Yang pleaded guilty 

to conspiring to violate the Arms Export Control Act by trying to sell radiation hardened military 

and aerospace technology to China. Yang was arrested on December 3, 2010, pursuant to a 

criminal complaint filed charging him with conspiracy to violate the Arms Export Control Act. 

According to the complaint, Yang attempted to purchase and export from the United States to 

China 300 radiation-hardened, programmable semiconductor devices that are used in satellites 

and are also classified as defense articles under the U.S. Munitions List. The complaint alleges 

that Yang contemplated creating a shell company in the United States that would appear to be 

purchasing the parts, concealing the fact that the parts were to be shipped to China. Yang 

allegedly planned that false purchasing orders would be created indicating that parts that could be 

legally exported were being purchased, not restricted parts. Yang and his co-conspirators 

allegedly wire-transferred $60,000 to undercover agents as partial payment for a sample of five 

devices. As part of the conspiracy, Yang allegedly negotiated a payment schedule with the 

undercover agents for the purchase and delivery of the remaining 300 devices in exchange for a 

total of $620,000. This investigation was conducted by the FBI, ICE and CBP.

Military Night Vision Scopes to Russia - On October 24, 2011, Anna Fermanova was sentenced 

in the Eastern District of New York to four months in prison, three years supervised release and a 

$1,000 fine. Fermanova pleaded guilty on January 14, 2011 to one count of violating the Arms 

Export Control Act. In March 2010, U.S. Customs and Border Protection officers searched 

Fermanova's checked luggage in New York as she was preparing to board a flight to Moscow and 

identified three night vision items they suspected of being export controlled. ICE agents detained 

the items and permitted Fermanova to board her flight to Moscow. ICE agents later determined 

that the items consisted of a Raptor night vision weapon sight and two advanced rifle sights, 

which are designated as defense articles. On July 15, 2010, Fermanova was arrested (pursuant to 

a July 9, 2010 complaint) at JFK upon her return from Russia and she was charged with 

attempting to export the military night vision scopes. This investigation was conducted by ICE. 

Radiation-Hardened Aerospace Technology to China - On September 30, 2011, defendants 

Hong Wei Xian, aka "Harry Zan," and Li Li, aka "Lea Li," were sentenced in the Eastern District 

of Virginia to 24 months in prison for conspiracy to violate the Arms Export Control Act and 

conspiracy to smuggle goods unlawfully from the United States, in connection with their efforts 

to export to China radiation-hardened microchips that are used in satellite systems and are 

classified as defense articles. Both defendants pleaded guilty to the charges on June 1, 2011. The 

defendants were arrested on September 1, 2010 in Budapest by Hungarian authorities pursuant to 

a U.S. provisional arrest warrant. On April 4, 2011, they made their initial court appearances in 

federal court in the Eastern District of Virginia after being extradited from Hungary. According to 

court documents, Zan and Li operated a company in China called Beijing Starcreates Space 

Science and Technology Development Company Limited. This firm was allegedly in the 

business of selling technology to China Aerospace and Technology Corporation, a Chinese 

government-controlled entity involved in the production and design of missile systems and launch 

vehicles. According to court documents, from April 2009 to September 1, 2010, the defendants 

contacted a Virginia company seeking to purchase and export thousands of Programmable ReadOnly Microchips (PROMs). The defendants ultimately attempted to purchase 40 PROMs from 
65

the Virginia firm and indicated to undercover agents that the PROMs were intended for China 

Aerospace and Technology Corporation. The investigation was conducted by ICE and DCIS.

Military Flight Simulation Technology to Iran - On September 26, 2011, Chan Hok Shek was 

sentenced in the District of Massachusetts to 3 1⁄2 years in prison for conspiring to obtain 

components for C-130 military flight simulators from the United States for delivery to Iran. On 

March 25, 2010, an indictment was unsealed in federal court charging Shek and two Malaysian 

nationals, Wong Fook Loy and Ngo Tek Chai, with conspiring to and attempting to illegally 

export munitions without the required licenses. According to the October 2008 indictment, Shek, 

a Hong Kong citizen, conspired with Loy and Chai, and others to cause the export of 10 

indicators servo tachometers used in C-130 military flight simulators from the United States for

use in Iran. Shek was extradited from Hong Kong to face the charges against him in Boston. The 

case was investigated by ICE, BIS, and DCIS.

Outsourced Manufacture of Military Items to China - On September 13, 2011, Staff Gasket 

Manufacturing Corporation, a defense contracting company in New Jersey, was sentenced in the 

District of New Jersey to five years probation and ordered to pay $751,091 in restitution and an 

$800 special assessment. Eric Helf, Staff Gasket's president was sentenced to three years 

probation, a $500 fine and a final order of forfeiture was entered for $49,926. On April 19, 2011, 

Staff Gasket pleaded guilty to Arms Export Control Act and wire fraud violations, while Helf 

pleaded guilty to one count of wire fraud. From August 2004 to March 2006, Staff Gasket 

entered into contracts with the Department of Defense to provide replacement parts for use in 

military operations. Many of the parts to be supplied were critical application items and were 

thus required to be manufactured in the United States. Nonetheless, Staff Gasket contracted with 

foreign manufacturers, including in China, and many of the parts ultimately supplied to the 

Defense Department, including lock pins for helicopters, were made overseas, substandard, and 

failed in the field. As a result, Staff Gasket caused the Defense Department to sustain losses of 

some $751,091 in connection with the fraudulent contracts. This investigation was conducted by 

DCIS and ICE.

F-5 Fighter Jet and Other Military Items to Iran - On September 12, 2011, Marc Knapp, of 

Simi Valley, California, was sentenced in the District of Delaware to 46 months in prison for 

plotting to illegally export fighter jet components and other materials to Iran. Knapp pleaded 

guilty on January 13, 2011, to a two-count information charging him with violating the Arms 

Export Control Act and the International Emergency Economic Powers Act. The information, 

filed on November 22, 2010, charged that Knapp engaged in a seven-month course of criminal 

conduct involving illegal exports to Hungary and attempted exports to Iran during negotiations 

with undercover agents posing as Iranian purchasers. Among other things, Knapp attempted to 

export a complete F-5 Tiger II fighter jet, as well as F-14 flight ejection seats, anti-gravity flight 

suits, search and rescue beacons and emergency manuals for U.S. fighter jets. On two occasions, 

Knapp illegally exported items, including anti-gravity flight suits, to Hungary believing they were 

destined for Iran. The investigation was conducted by ICE and DCIS.

Military Night Vision Overseas - On August 24, 2011, in the District of Maryland, Connor 

Kraegel was sentenced to 8 months imprisonment and three years supervised release. On July 8, 

2011, Kraegel plead guilty to one count of unlawful export of a defense article. According to 

documents filed in the case, Kraegel sold and exported a set of Aviator's Night Vision Imaging 

System (AN/AVS-6) goggles to a conspirator located outside the United States without first 

having obtained a license from the U.S. Department of State, Directorate of Defense Trade 

Controls. This case was investigated by ICE.
66

Fighter Jet Parts to Singapore - On August 22, 2011, Russell Marshall were sentenced in the 

Southern District of Florida to three years probation, while his Boynton Beach, Fla., company, 

Universal Industries Limited, Inc., was sentenced to one year probation and a $1,000 fine in 

connection with an effort to illegally export J-85 engine blades for F-5 fighter jets to Singapore. 

Both defendants pleaded guilty on June 3, 2011. On April 21, 2011, a criminal information was 

filed charging Marshall and Universal Industries Limited, Inc., with making false statements and 

violating the Arms Export Control Act. According to court documents, Marshall illegally 

attempted to export 200 J-85 engine blades for F-5 fighter jets to Singapore. Marshall allegedly 

failed to obtain the required State Department license for such exports and recorded the value of 

the parts as $2,000 in invoices, when in fact the shipment of military parts was valued at more 

than $105,000. This investigation was conducted by ICE. 

Automatic Rifles and Plastic Explosives to the FARC - On August 5, 2011, Hector Antonio 

Guillen-Martinez of El Salvador, was sentenced in the Eastern District of Virginia to 31 years in 

prison after pleading guilty on May 11, 2011 to one count of attempting to provide material 

support to the Revolutionary Armed Forces of Colombia (FARC), a designated terrorist 

organization, and one count of carrying an explosive during a commission of a crime. On 

February 24, 2011, Guillen-Martinez was indicted on charges of attempting to provide material 

support to the FARC, carrying an explosive during the commission of a felony, transferring 

explosive materials knowing that they will be used to commit a crime of violence, carrying a 

destructive device in relation to a crime of violence, and a drug violation. Guillen-Martinez sold 

several automatic rifles, more than 20 pounds of plastic explosives, and other explosives to an 

individual whom he believed to be a member of the FARC. Guillen-Martinez believed that these 

weapons and explosives were to be used by the FARC in Colombia to eradicate Americans from 

Colombia, dead or alive. Guillen-Martinez was apprehended in the Eastern District of Virginia 

when he traveled to the District in order to transfer a load of 20 kilograms of cocaine to New 

York City on behalf of the FARC. This case was investigated by the DEA.

Holographic Weapons Sights and Firearms Parts to China and Japan - On August 3, 2011, 

Andrew Vincent ODonnell, of Georgia, was sentenced in the Northern District of Georgia to 37 

months in prison, three years supervised release and ordered to pay a fine of $2500 for his roll in 

a conspiracy to violate and violating the Arms Export Control Act and possessing short barrel 

rifles. ODonnell pleaded guilty on February 25, 2011. ODonnell operated an eBay online store 

called "LRA Tactical Gear" through which he sold various weapons parts and accessories, 

including military holographic weapons sights and gun parts. ODonnell sold more than 50 

export-controlled military holographic weapons sights to a customer in Hong Kong without the 

required export license, falsely labeling the shipments as toys. He also sold gun parts used to 

assemble an AR15 / M16 / M4 rifle to a customer in Japan after routing the parts through a third 

country to conceal the illegal nature of the exports. Co-defendant Ho Yueng Barry Tang remains 

a fugitive. This investigation was conducted by ICE.

Export/Import of Unmanned Aerial Vehicle - On July 28, 2011 in the Middle District of Florida, 

Henson Chua, a citizen of the Philippines, pleaded guilty to one count of causing the temporary 

import of a defense article, specifically, an unmanned aerial vehicle (UAV), without 

authorization, in violation of the Arms Export Control Act. He was sentenced on November 8, 

2011 to time served. Hua was first charged on February 10, 2011, by criminal complaint with 

illegally conspiring to temporarily import into the U.S. and then to export a defense article. 

According to court documents, ICE agents were contacted by the U.S. military in May 2010 

about a "Raven" UAV that was posted for sale on eBay.com. The Raven is a U.S.-made UAV 

manufactured by AeroVironment Inc. for the U.S. Army. Chua was attempting to sell the UAV 

for $13,000 on eBay. Undercover ICE agents posing as buyers were able to identify the UAV 
67

and confirm that it was U.S. government property. Agents purchased the nose cone for the UAV 

from Chua and then later arrested Chua on February 10, 2011 after he arrived at the Los Angeles 

airport. He was later indicted on March 10, 2011, on charges of smuggling and Arms Export 

Control Act violations. The investigation was conducted by ICE.

Machine Gun Specifications and Components to China - On July 12, 2011, Swiss Technology 

(Swiss Tech), Inc., a company in Clifton, N.J. that makes equipment for the U.S. military, 

pleaded guilty in the District of New Jersey to a one count criminal information charging the firm 

with conspiracy to violate the Arms Export Control Act from August 2004 to about July 2009. 

On November 15, 2011, Swiss Tech was sentenced to two years probation and ordered to pay 

restitution in the amount of $1.1 million to the Defense Department in connection with fraudulent 

contracts. Swiss Tech was under contract with the Department of Defense to manufacture 

components for the M249 machine gun. In order to lower its manufacturing costs, Swiss Tech 

sent defense articles, including specification drawings and parts samples, to a company in the 

People's Republic of China so that the Chinese company could make these machine gun 

components for Swiss Tech. Swiss Tech did not have the required State Department license for 

exports of these munitions to China. After receiving the components from the Chinese company, 

Swiss Tech then shipped the defense articles and other parts to the Department of Defense, 

purporting that the defense articles were made by Swiss Tech in conformance with its contract. 

Among other things, Swiss Tech illegally exported to China specifications for the production of 

M249 machine gun parts, as well as components for the M249 machine gun, and M16 or M4 

rifle. This investigation was conducted by DCIS and ICE.

Firearms to Nigeria - On July 11, 2011, Boniface Ibe was sentenced in the District of Maryland 

to five months in prison followed by 10 months of supervised release for illegally exporting 

shotguns, a handgun and ammunition to Nigeria without a license, and for delivering a firearm to 

a common carrier without notice. Ibe attempted to export these items to Nigeria concealed in a 

vehicle that was in a shipping container. The container and weapons were intercepted at the Port 

of Baltimore on September 22, 2010. The investigation was conducted by ICE, CBP, and ATF.

Vacuum Pumps With Potential Sensitive Applications to Iran - On July 6, 2011, in the Central 

District of California, Jirair Avanessian, of Glendale, California, was sentenced to serve 18 

months in prison in connection with his role in a conspiracy to violate International Emergency 

Economic Powers Act and the Iranian trade embargo, including smuggling, money laundering 

and other crimes. Avanessian also must pay a $10,000 fine and forfeit the proceeds of his 

criminal activity. Avanessian was indicted on December 30, 2009 and arrested in January 2010. 

He pled guilty in July 2010. Another individual involved in the conspiracy, Amirhossein Sairafi, 

of Iran, was arrested in January 2010 in Frankfurt, Germany by German law enforcement 

authorities based on a provisional arrest warrant from the United States. Sairafi was later 

extradited to the United States in September 2010, pled guilty on November 30, 2010, and was 

sentenced to 41 months in March of this year in connection with the scheme. Sairafi was first 

charged in a January 4, 2010 criminal complaint. Avanessian, who was born in Iran, is the owner

and operator of XVAC, a company located in California. Avanessian corresponded with Sairafi 

and another individual in Iran, Farhad Masoumian, via e-mail over several years to arrange the 

export of high-dollar vacuum pumps and pump-related equipment to Iran through a free trade 

zone located in the United Arab Emirates. The vacuum pumps and related equipment at issue 

have a number of applications, including in the enrichment of uranium. Avanessian purchased 

and arranged to ship the goods ordered by Masoumian to the United Arab Emirates, making it 

appear that the U.A.E. was the ultimate destination. Sairafi would then send the same goods from 

the location in the U.A.E. to Iran. As part of the conspiracy, Masoumian, Avanessian and Sairafi 

re-labeled and undervalued the contents of the shipments in order to mask the true contents and to 
68

avoid interception by U.S. officials. In most cases, Avanessian prepared air waybills indicating 

his shipments contained "spare parts" and that no shipper's export declaration was needed. 

Between December 2007 and November 2008, there were at least seven shipments containing 

vacuum pump equipment purchased and exported by Avanessian at Masoumian's request. The 

investigation continues as Masoumian remains at large and is believed to be in Iran. This case 

was the product of an investigation by the Export and Anti-proliferation Global Law Enforcement 

(EAGLE) Task Force in the Central District of California, which includes the FBI, ICE, BIS, 

CBP, Diplomatic Security Service and the Transportation Security Administration. 

Military Aircraft Components to Iran - On June 23, 2011, federal prosecutors in the Middle 

District of Georgia announced charges against 12 defendants (seven individuals and five 

corporate entities) based in the U.S., France, the United Arab Emirates and Iran for their alleged 

roles in a conspiracy to illegally export military components for F-4 and F-5 fighter jets and AH-1 

and UH-1 Huey attack helicopters from the United States to Iran. Prosecutors unsealed a June 16, 

2011 superseding indictment charging the eight foreign defendants with conspiring to violate and 

violating the Arms Export Control Act and the International Emergency Economic Powers Act, 

as well as conspiracy to defraud the United States, money laundering and false statement 

violations. Charges against four other defendants, who are based in the United States and have 

pleaded guilty in the case, were contained in the original indictment filed in 2010. The U.S.-

based defendants are The Parts Guys LLC, and its president, Michael Edward Todd, as well as 

Galaxy Aviation Services and its president, Hamid Seifi, also known as Hank Seifi. Todd and his 

company pleaded guilty to conspiracy to violate the AECA on May 9, 2011. Todd was sentenced 

on October 26, 2011 to 46 months in prison, a $10,000 fine and ordered to forfeit $160,362. He 

was resentenced on October 24, 2012 decreasing his time in prison to 35 months. Seifi and his 

company pleaded guilty on February 24, 2011, to conspiracy to violate the AECA and violating 

the IEEPA. On June 22, 2011, Seifi was sentenced to 56 months in prison followed by three 

years of supervised release, a fine of $12,500 and forfeiture of $153,950, while Galaxy Aviation, 

which is now defunct, received a $400 special assessment. Three defendants based in France 

have also been indicted as part of the investigation. They are Aerotechnic, a company in 

Pinsaguel, France, and its president, Philippe Sanchez, as well as Luc Teuly, the sales manager of 

Aerotechnic. Each of these defendants remains a fugitive. Two defendants based in the U.A.E. 

have also been indicted in the case. They are Aletra General Trading, a company in Dubai doing 

business as "Erman & Sultan Trading Co," and Syed Amir Ahmed Najfi, a purchaser for Aletra. 

Najfi remains a fugitive. Three defendants based in Iran have also been charged in the case. They 

are Sabanican Company, a company in Tehran, and its president, Hassan Seifi as well as Reza 

Seifi, the managing director of Sabanican Company. Each of these defendants remains at large. 

As part of the U.S. government's coordinated action against this procurement network, the 

Commerce Department announced on June 23, 2011 that it would add the eight defendants in 

France, Iran and the U.A.E. to its "Entity List." The investigation was conducted by ICE, FBI, 

and BIS.

Centrifuge and Dual-Use Scientific Technology to Iran - On June 3, 2011, Mohammad Reza 

Vaghari was sentenced in the Eastern District of Pennsylvania to 33 months in prison for his 

participation in illegal business transactions with Iran between 2002 and 2005 involving scientific 

research equipment and computer software. Vaghari was convicted on February 24, 2011 of one 

count of conspiracy to violate the International Emergency Economic Powers Act (IEEPA); two 

substantive counts of violating IEEPA; and one count of naturalization fraud stemming from his 

attempt to procure U.S. citizenship. Vaghari's co-conspirator, Mir Hossein Ghaemi, pleaded 

guilty on November 30, 2010. Ghaemi was sentenced on June 14, 2011 to time served, 6 months 

supervised release, $25 special assessment and ordered to pay $680.80 in restitution. Vaghari 

operated in the U.S. through a Pennsylvania corporation called Saamen Company, purchasing 
69

items from American companies and illegally exporting them to Iran through the United Arab 

Emirates. Among the items Vaghari caused to be delivered or attempted to deliver to Iran were a 

centrifuge, computers, fuel cell systems, ultrasonic liquid processors, ultrasound machines, and 

other laboratory equipment. Among the recipients of some of these goods was the Pasteur 

Institute of Iran, which has been listed as an entity of concern for biological and chemical 

weapons development by several foreign governments. Agents unraveled Vaghari's efforts in 

2005 after receiving a complaint from a vendor at Beckman-Coulter, a nationwide manufacturer 

of medical equipment, asserting that Vaghari was attempting to purchase a $100,000 centrifuge 

from the company, which weighed some 1,000 pounds, for delivery to his apartment and that 

Vaghari was seeking to pay in cash and did not request a warranty or installation. The 

investigation was conducted by FBI, BIS, and ICE.

Anti-Aircraft Missiles and Machine Guns to Syria - On May 20, 2011, Dani Nemr Tarraf 

pleaded guilty in the Eastern District of Pennsylvania. On September 16, 2010, Hussein Ali 

Asfour also pleaded guilty. Previously, on November 24, 2009, a grand jury returned an 

indictment charging Dani Nemr Tarraf and Douri Nemr Tarraf, with conspiring to illegally export 

anti-aircraft missiles (FIM-92 Stingers) machine guns (approximately 10,000 Colt M4 Carbines), 

as well as M72 Light anti-armor weapons, Glock pistols, as well night vision equipment, from 

Philadelphia to the Port of Latakia, Syria. In addition, these two defendants and Hassan 

Mohamad Komeiha, and Hussein Ali Asfour - were charged with conspiring to transport stolen 

goods. Dani Nemr Tarraf and Ali Fadel Yahfoufi were also charged with conspiring to commit 

passport fraud. According to a criminal complaint filed in the case, in or about mid-June 2009, 

Dani Tarraf asked whether an undercover law enforcement official (UC) could supply guided 

missiles and told the UC that he (Tarraf) wanted the UC to export approximately 10,000 

"commando" machine guns [Colt M4 Carbines with short barrels] from the United States. On or 

about July 28, 2009, in Philadelphia, Tarraf paid the UC a deposit of approximately $20,000 

toward the cost of purchasing FIM-92 Stinger missiles and approximately 10,000 Colt M4 

Carbines and shipping these items outside the United States to the Port of Latakia, Syria. Dani 

Tarraf was arrested on November 21, 2009. The investigation was conducted by the FBI's Joint 

Terrorism Task Force, ICE, IRS, Secret Service, DCIS, ATF, and other law enforcement 

agencies.

U.S. Aircraft Components to Iran - On May 17, 2011, a grand jury in the Southern District of 

California returned a superseding indictment charging Belgian citizens Willy A.E. De Greef and 

Frederic Depelchin, as well as their Belgium-based companies, Meca Airways LTD and Meca 

Overseas Airways LTD, with 15 felony counts arising from the smuggling of helicopter and 

fixed-wing aircraft components from the United States to Iran. De Greef was also charged with 

two counts of making false statements to the U.S. government concerning the smuggling ring. 

DeGreef was arrested in the United Kingdom pursuant to a March 18, 2011 prior indictment in 

the Southern District of California charging he and his co-defendants with fraudulently procuring 

millions of dollars-worth of helicopter and airplane components from U.S. suppliers by indicating 

to the suppliers that the destination of the parts was Belgium or another non-prohibited location. 

After the parts were exported from the United States to Belgium, De Greef and Depelchin 

allegedly promptly transshipped them to Iran, typically via France, the indictment alleges. This 

investigation was conducted by ICE and DCIS.

Controlled Technology to Libya – On May 16, 2011, Mohammed El-Gamal was sentenced in the 

District of Columbia to 24 months probation, $5,000 fine, and $100 special assessment stemming 

from his plea of guilty on February 9, 2011 to a superseding information charging him with 

making a false statement to a federal agent. Previously, on May 13, 2010, El-Gamal, was 

indicted and subsequently arrested on federal charges of illegally exporting controlled technology 
70

to Libya. The indictment charged El-Gamal with three counts of violating the International 

Emergency Economic Powers Act and one count of making a material false statement. According 

to the indictment, El-Gamal did business as Applied Technology Inc. ("ATI") located in 

Kenansville, North Carolina. El-Gamal held himself out to be ATI's President and CEO. The 

indictment alleges that several times in 2006, the defendant exported or attempted to export 

various computer equipment, including items controlled for national security and antiterrorism 

reasons, to Libya. In one instance, El-Gamal attempted to export integrated circuit boards 

containing strong encryption software by allegedly instructing an employee to smuggle them in 

his suitcase. According to the indictment, the defendant did not obtain any export licenses for any 

of the shipments to Libya. This case was investigated by the Department of Commerce.

Military Technical Data to South Korea - On May 16, 2011, Young Su Kim, a former Vice 

President at Rocky Mountain Instrument Company (RMI), based in Colorado, pleaded guilty in 

the District of Colorado to violating the Arms Export Control Act. Kim was first charged on 

April 21, 2011. Kim caused the illegal export to South Korea of technical data related to prisms 

that are useful in guidance or targeting systems in Unmanned Aerial Vehicles, AC-130 gunships, 

tanks and missile systems. On August 17, 2011, Kim was sentenced to five years probation and 

ordered to pay a $36,000 civil forfeiture judgment. RMI, the company, pleaded guilty on June 

22, 2010, to one count of violating the Arms Export Control Act and was immediately sentenced 

to five years probation and ordered to forfeit $1 million. The case was investigated by ICE and 

DCIS.

Ford Motor Company Trade Secrets to China - On April 13, 2011, Xiang Dong Yu, aka Mike 

Yu, was sentenced in the Eastern District of Michigan to 70 months in prison. Previously, on 

November 17, 2010, Dong, a product engineer with Ford Motor Company pleaded guilty in the 

Eastern District of Michigan to 2 counts of theft of trade secrets. According to the plea 

agreement, Yu was a Product Engineer for Ford from 1997 to 2007 and had access to Ford trade 

secrets, including Ford design documents. In December 2006, Yu accepted a job at the China 

branch of a U.S. company. On the eve of his departure from Ford and before he told Ford of his 

new job, Yu copied some 4,000 Ford documents onto an external hard drive, including sensitive 

Ford design documents. Ford spent millions of dollars and decades on research, development, 

and testing to develop and improve the design specifications set forth in these documents. On 

December 20, 2006, Yu traveled to the location of his new employer in Shenzhen, China, taking 

the Ford trade secrets with him. On January 2, 2007, Yu emailed his Ford supervisor from China 

and informed him that he was leaving Ford's employ. In November 2008, Yu began working for 

Beijing Automotive Company, a direct competitor of Ford. On October 19, 2009, Yu returned to 

the U.S. Upon his arrival, he was arrested. At that time, Yu had in his possession his Beijing 

Automotive Company laptop computer. During an examination of that computer, the FBI 

discovered that 41 Ford system design specifications documents had been copied to the 

defendant's Beijing Automotive Company work computer. The FBI also discovered that each of 

those design documents had been accessed by Yu during the time of his employment with Beijing 

Automotive Company. This case was investigated by the FBI.

Military Night Vision Technology to China, Singapore & U.K. - On March 27, 2007, ITT 

Corporation pleaded guilty in the Western District of Virginia to two criminal counts of violating 

the Arms Export Control act stemming from its illegal exports of restricted military night vision 

data to China, Singapore, and the United Kingdom and omission of statements of material fact in 

required arms exports reports. As part of the plea agreement, ITT Corporation agreed to invest 

$50 million toward the development of the most advanced night vision systems in the world for 

the U.S. Armed Forces. On April 12, 2011, the Justice Department announced that a government 

motion to dismiss the remaining deferred criminal charge against ITT Corporation, the leading 
71

manufacturer of military night vision equipment for the U.S. Armed Forces, was granted by the 

court. The Justice Department agreed to dismiss the remaining criminal charge against ITT 

Corporation after ITT Corporation implemented an extensive remedial plan overseen by an 

independent monitor to prevent future Arms Export Control Act violations. ITT Corporation and 

the Justice Department will continue to work together to utilize resources set aside by the 

deferred prosecution agreement to further the development and fielding of the most advanced 

night vision technology. This investigation was conducted by DCIS and ICE. 

Firearms Components to the United Kingdom - On March 28, 2011, defendants Charles 

Shearon, Elmer Hill, Michael Curlett and Arnold See, Jr., pleaded guilty in the Middle District of 

Tennessee to conspiracy and violations of the Arms Export Control Act. On February 8, 2011, a 

grand jury an indictment charging these defendants, another individual and a Nashville, Tenn., 

arms manufacturer with conspiracy to violate the Arms Export Control Act and other offenses in 

connection with the illegal export and import of firearms and firearms components. The 

indictment charged Guy Savage, of the United Kingdom, Sabre Defence Industries, LLC, a 

Nashville-based arms manufacturing company owned by Savage, as well as four officers of 

Sabre: Charles Shearon, Elmer Hill, Michael Curlett, and Arnold See, Jr. The indictment alleged 

that the defendants conspired to cause firearm components on the U.S. Munitions List to be 

exported from the United States without first obtaining authorization from the Department of 

State, by falsifying shipping records, concealing components in false bottoms of shipping cartons, 

and mislabeling and undervaluing shipments of firearm components. Sentencing hearings for 

Shearon, Hill, See and Curlett are scheduled for June 2015. The investigation was conducted by 

the ATF and ICE.

Assault Rifles and Explosives For Export - On March 22, 2011, Yanny Aguila Urbay was 

sentenced in the Southern District of Florida to 60 months in prison and his co-defendant, 

Abdalaziz Aziz Hamayel, was sentenced to 48 months in prison. On January 27, 2011, Urbay

was convicted of conspiracy to possess stolen, fully-automatic M-16s, AK-47s and silencers, and 

receiving grenades and improvised explosive devices. On December 16, 2010 Hamayel, pleaded 

guilty to conspiracy to possess stolen machine guns and to transport grenades and improvised 

explosive devices. Urbay and Hamayel were first charged by complaint on August 31, 2010. 

The charges resulted from an undercover operation in which Hamayel and Urbay met with an 

undercover agent and discussed the purchase price of between 200-300 stolen automatic assault 

rifles, 150 grenades and remotely detonated explosives. According to the court documents, 

Hamayel indicated that the arms would be destined for abroad. During negotiations, the 

defendants were shown two M-16s, an AK-47, two grenades, and two improvised explosive 

devices for an unknown purchaser. Hamayel later requested a picture of the weapons to show his 

money supplier as proof that the weapons and explosives were available. Hamayel then traveled 

to the West Bank. Hamayel was arrested upon his return to Miami from Jordan on August 30, 

2010. Urbay was arrested on September 6, 2010 in Miami. The investigation was conducted by 

the FBI.

Fighter Jet Components to Iran - On March 11, 2011, Omid Khalili a.k.a. Saeid Kamyari, an 

Iranian national, was sentenced in the Southern District of Alabama to 30 months in prison. 

Previously, on June 17, 2010, Khalili pleaded guilty to attempting to illegally export U.S. fighter 

jet parts from the United States to Iran. Khalili, along with defendant "Masun," whose last name 

is unknown, were charged in a nine-count indictment on January 28, 2010, with conspiracy, 

money laundering, smuggling, as well as violations of the Arms Export Control Act and the 

International Emergency Economic Powers Act. Khalili was arrested by federal agents in March 

2010 upon his arrival in Miami. Khalili and Masun have been actively working with the Iranian 

government to procure military items for the Iranian government. In November 2009, Khalili
72

reached out to an undercover federal agent requesting pricing for a list of military aircraft parts to 

be sent to Iran. Thereafter, he sent four separate payments totaling more than $70,000 to a bank in 

Alabama as a down payment for the parts. The investigation was conducted by ICE and DCIS.

Specialized Metals For Iranian Missile Program - On February 1, 2011, an indictment returned 

on July 21, 2010, was unsealed in the District of Columbia charging Milad Jafari, an Iranian 

citizen and resident, with illegally exporting and attempting to export specialized metals from the 

United States through companies in Turkey to several entities in Iran -- including entities that 

have been sanctioned for their involvement in Iran's ballistic missile activities. The Treasury 

Department also designated Jafari, several of his family members, associates, and corporate 

entities in Iran and Turkey, under Executive Order 13382, which targets for sanctions the 

proliferators of weapons of mass destruction and their supporters - thereby isolating them from 

the U.S. financial and commercial systems. According to the Treasury designation, Jafari and his 

associates operate a procurement network that provides direct support to Iran's missile program 

by securing metal products, including steel and aluminum alloys, for subordinates of Iran's 

Aerospace Industries Organization (AIO). The indictment alleges that Jafari and others operated 

Macpar and STEP, businesses with locations in Istanbul and Tehran. From February 2004 

through August 2007, Jafari and his conspirators solicited orders from customers in Iran and 

purchased goods from U.S. companies on behalf of these Iranian customers. Jafari and others 

allegedly wired money to the U.S. companies as payment, concealed from the U.S. companies the 

end-use of the goods, and caused the goods to be shipped to Turkey and later to Iran. For 

instance, the indictment alleges that in July 2006, Sanam Industrial Group - an entity in Iran that 

is controlled by Iran's AIO and has since been sanctioned by the U.S. and United Nations for 

involvement in nuclear and ballistic missile activities -- issued to Jafari's company, STEP, a 

request for quote for 660 pounds of a specialized steel welding wire with aerospace applications 

in rocket/missile casings. Jafari caused an order to be placed for 660 pounds of this welding wire 

with a Nevada company. The following month, the Nevada firm received more than $38,000 

from Jafari's company, Macpar. According to the indictment, Jafari made arrangements for the 

welding wire to be picked up from the Nevada company. In response to questions from the 

Nevada company about the end-use of the welding wire, Jafari told the company that the 

materials "will not be exported from Turkey and will not be used for any nuclear, missile or 

chemical/biological weapons related applications," the indictment alleges. The shipment was 

detained by the Commerce Department in 2007 before it left the country. The indictment alleges 

that Jafari and his conspirators were successful in causing several shipments of other materials to 

be exported from the United States to Iran via Turkey, including: three kilograms of custom-made 

brazing alloy, 1,366 pounds of commercial bronze bars, electronic testing equipment, U.S. fiberoptic equipment and aerosol generators for fire suppression systems. The investigation was 

conducted by BIS and FBI.

Stealth Missile Exhaust Designs and Military Technical Data to China - On January 24, 2011, a 

federal judge in the District of Hawaii sentenced Noshir Gowadia, 66, of Maui to 32 years in 

prison for communicating classified national defense information to the People's Republic of 

China (PRC), illegally exporting military technical data, as well as money laundering, filing false 

tax returns and other offenses. On August 9, 2010, a federal jury in the District of Hawaii found 

Gowadia guilty of 14 criminal violations after six days of deliberation and a 40-day trial. These 

included five criminal offenses relating to his design for the PRC of a low-signature cruise 

missile exhaust system capable of rendering a PRC cruise missile resistant to detection by 

infrared missiles. The jury also convicted Gowadia of three counts of illegally communicating 

classified information regarding lock-on range for infrared missiles against the U.S. B-2 bomber 

to persons not authorized to receive such information. Gowadia was also convicted of unlawfully 

exporting classified information about the B-2, illegally retaining information related to U.S. 
73

national defense at his home, money laundering and filing false tax returns for the years 2001 and 

2002. Gowadia was an engineer with Northrop Grumman Corporation from 1968 to 1986, during 

which time he contributed to the development of the unique propulsion system and low 

observable capabilities of the B-2 bomber. Gowadia continued to work on classified matters as a 

contractor with the U.S. government until 1997, when his security clearance was terminated. 

Evidence at trial revealed that from July 2003 to June 2005, Gowadia took six trips to the PRC to 

provide defense services in the form of design, test support and test data analysis of technologies 

for the purpose of assisting the PRC with its cruise missile system by developing a stealthy 

exhaust nozzle and was paid at least $110,000 by the PRC. The jury convicted Gowadia of two 

specific transmissions of classified information: a PowerPoint presentation on the exhaust nozzle 

of a PRC cruise missile project and an evaluation of the effectiveness of a redesigned nozzle, and 

a computer file providing his signature prediction of a PRC cruise missile outfitted with his 

modified exhaust nozzle and associated predictions in relation to a U.S. air-to-air missile. The 

prosecution also produced evidence which documented Gowadia's use of three foreign entities he 

controlled, including a Liechtenstein charity purportedly for the benefit of children, to disguise 

the income he received from foreign countries. This case was investigated by FBI, the U.S. Air 

Force Office of Special Investigations, the IRS, U.S. Customs and Border Protection, and ICE.

Ammunition Primers to Jamaica - On January 24, 2011, Orville Andrew Braham, of Brockton, 

Mass., was indicted in the Southern District of Florida in connection with the transportation in his 

luggage of ammunition primers, which caused an explosion at the Miami International Airport on 

December 28, 2010. Braham boarded a flight in Boston ultimately bound for Jamaica with 

hundreds of .45 caliber ammunition primers concealed in his luggage. The primers exploded 

when a baggage handler at the Miami airport placed the luggage on the ground. On February 22, 

2011, Braham pleaded guilty to charges in the case. He was later sentenced on May 10, 2011 to 

six months in prison followed by 6 months supervised release, but later received an amended 

sentence changing his supervised release to three years. The investigation was conducted by FBI, 

ATF and Department of Transportation. 

AK-47s Assault Rifles to Somalia - On January 17, 2011, Chanoch Miller, an Israeli national, 

was sentenced to 18 months in prison and 36 months supervised release, while his co-defendant 

Joseph O'Toole, a former U.S. Air Force Colonel F-4 fighter pilot, was sentenced on December 

14, 2010 to 12 months and a day in prison followed by 24 months of supervised release. On 

October 5, 2010, Miller and O'Toole pleaded guilty in the Southern District of Florida to charges 

of knowingly and willfully conspiring to export AK-47 assault rifles from the U.S. to Somalia 

without a license from the Department of State. According to the indictment and statements 

made during the plea hearing, beginning in April 2010, Miller contacted O'Toole to arrange for 

the transportation of approximately 6,000 fully automatic AK-47 assault rifles from Bosnia to 

Somalia. To facilitate the transportation of the AK-47 assault rifles, O'Toole contacted an 

individual who, unbeknownst to O'Toole, was working undercover for ICE and the DCIS. Miller 

agreed to purchase 700 fully automatic AK-47 assault rifles from the undercover individual. 

These assault rifles were to be shipped from the United States through Panama and then to 

Somalia. Miller paid $116,000 to the undercover individual as partial payment of the 

transportation costs and commissions to O'Toole for the shipment of the 700 assault rifles. Both 

defendants were charged in a June 17, 2010 indictment with conspiring and attempting to 

illegally export defense articles, money laundering and money laundering conspiracy. The 

investigation was conducted by ICE and DCIS.

Bullet-Proof Vest Inserts to Colombia - On January 13, 2011, Jerome Stewart Pendzich, of 

Hampton, Tenn., pleaded guilty in the Eastern District of Tennessee to violating the Arms Export 

Control Act. According to court documents, ICE agents became aware that Pendzich was 
74

attempting to sell a bullet-proof vest on E-bay. In May and June 2009, Pendzich attempted to 

export military-grade, small-arms protective inserts to purchasers in Colombia, who were 

undercover agents. Pendzich was sentenced to 46 months in prison and three years supervised 

release on October 12, 2011. The investigation was conducted by ICE.

Iran Embargo Violations - On January 10, 2011, the Child Foundation, a charity in Oregon, and 

its founder and CEO, Mehrdad Yasrebi, pleaded guilty in the District of Oregon to conspiracy to 

defraud the United States by concealing violations of the U.S.-embargo on Iran. Yasrebi and the 

charity admitted that they used several different methods to facilitate money transfers to Iran 

through the Child Foundation. Using a series of money transmitters and the Swiss bank account 

of a related charity, the defendants arranged for claimed embargo-exempt food commodities 

transactions from Dubai designed to disguise what were, in reality, significant cash transfers to 

Iran. On March 6, 2012, Yasrebi was sentenced to five years probation with a year of home 

detention, and a $50,000 fine. In addition, the Child Foundation was sentenced to two years 

probation on the condition that it receives OFAC approval for any continuing activities, on their 

behalf, involving cash or in kind goods transfers into Iran. Child Foundation was also ordered to 

pay a $50,000 fine. This investigation was conducted by the FBI, IRS, and ICE. 

U.S. Military Equipment to Yemen - On January 7, 2011, Amen Ahmed Ali was sentenced in the 

Eastern District of California to five years in prison followed by three years supervised release for 

conspiracy to act as an illegal agent of a foreign government, to possess stolen government 

property, and to unlawfully export defense materials. Ali pleaded guilty to these violations on 

October 7, 2010. Beginning in 1987, Ali conspired with others to act as an unregistered agent of 

the Government of Yemen, and received instructions and acted on behalf of the Armed Forces 

Department of the Republic of Yemen. Ali admitted that he took official actions on behalf of the 

Yemeni Government and that, among other things, he issued documents in 2002 ordering the 

arrest of a person upon his return to Yemen. Ali also admitted that in 2003 he had conspired with 

another person to cause various defense articles to be exported to Yemen without a license, 

including bullet proof vests and chemical protective suits. Finally, Ali admitted in his plea 

agreement that in late 2005 and early 2006, he negotiated with an undercover FBI agent to obtain 

and ship to Yemen materials that he believed were stolen U.S. military equipment, including 

night vision goggles, satellite telephones and laptop computers. On February 2, 2011, codefendant Ibrahim A. Omer received a judgment of acquittal for his alleged role in the 

conspiracy. Co-defendant Mohamed Al-Rahimi remains a fugitive. The investigation was 

conducted by the Joint Terrorism Task Force, including FBI and ICE.

Weapons and Ammunition to Nigeria - On January 3, 2011, Emenike Charles Nwankwoala, of 

Laurel, Md., was sentenced in the District of Maryland to 37 months in prison followed by two 

years supervised release in connection with a scheme to export guns, including shotguns and 

pistols, and ammunition to Nigeria. According to the charges, Nwankwoala illegally shipped 

weapons and ammunition to Nigeria for a decade, while employed as a state probation officer. 

He concealed the weapons and ammunition in shipping containers and lied about the contents and 

destination of these items. The investigation was conducted by ICE, ATF, and BIS.

Arms Exports to Russia - On December 13, 2010, in the Middle District of Pennsylvania, Sergey 

Korznikov, a Russian citizen, pleaded guilty to a superseding information charging him with 

conspiracy to smuggle military articles from the United States to Russia. Korznikov was later 

sentenced to 6 months in prison and two years supervised release on July 21, 2011. On July 29, 

2010, Korznikov's co-defendant Mark Komoroski was sentenced to 32 months in prison and 

ordered to pay $10,000 after pleading guilty to conspiring to smuggle military equipment to 

Russia. Komoroski, of Nanticoke, Pa.; Korznikov, of Moscow, and two companies, D&R Sports 
75

Center and Tactica Limited, were charged in a 2008 superseding indictment with conspiring to 

smuggle military equipment, including rifle scopes, magazines for firearms, face shields, and 

other military equipment from the United States to Russian to be resold to unknown persons. The

government later dismissed the charges against the corporate defendants, D&R Sports Center and 

Tactica Limited. The case was investigated by ICE, IRS, ATF, U.S. Postal Service, Department 

of Commerce and DCIS.

Valspar Trade Secrets to China - On December 8, 2010, David Yen Lee, a former chemist for 

Valspar Corporation, a Chicago paint manufacturing company, was sentenced in the Northern 

District of Illinois to 15 months in prison for stealing trade secrets involving numerous formulas 

and other proprietary information valued up to $20 million as he prepared to go to work for a 

competitor in China. Lee, formerly a technical director in Valspar Corp's architectural coatings 

group since 2006, pleaded guilty in September 2010 to using his access to Valspar's secure 

internal computer network to download approximately 160 original batch tickets, or secret 

formulas for paints and coatings. Lee also obtained raw materials information, chemical formulas 

and calculations, sales and cost data, and other internal memoranda, product research, marketing 

data, and other materials from Valspar. Lee admitted that between September 2008 and February 

2009, he had negotiated employment with Nippon Paint, in Shanghai, China and accepted 

employment with Nippon as vice president of technology and administrator of research and 

development. Lee was scheduled to fly from Chicago to Shanghai on March 27, 2009. He did not 

inform Valspar that he had accepted a job at Nippon until he resigned on March 16, 2009. 

Between November 2008 and March 2009, Lee downloaded technical documents and materials 

belonging to Valspar, including the paint formula batch tickets. He further copied certain 

downloaded files to external thumb drives to store the data, knowing that he intended to use the 

confidential information belong to Valspar for his own benefit. There was no evidence that he 

actually disclosed any of the stolen trade secrets. This investigation was conducted by the FBI.

Digital Microwave Radios to Iran - On November 23, 2010, Vikramaditya Singh, a resident of 

Fountain Hills, Arizona, and the owner of Orion Telecom Networks, Inc., pleaded guilty in the 

District of Delaware to a one count information alleging that he caused and attempted to cause the 

illegal export of digital microwave radios to Iran between September 2008 and May 2010. On 

March 3, 2011, he was sentenced to a fine of $100,000 and three years probation. This case was 

investigated by ICE. 

Firearms to Kosovo & Austria - On November 5, 2010, Ramadan Rama, a native of Kosovo, was 

charged by criminal complaint in the Eastern District of North Carolina with unlawfully shipping 

firearms on a common carrier and illegally exporting firearms. Rama allegedly transported two 

semi-automatic pistols on a flight from North Carolina to Kosovo and later transported a semiautomatic pistol on a flight from North Carolina to Austria. He was later indicted in December 

2010 on charges that included violations of the Arms Export Control Act. Rama pleaded guilty 

on March 9, 2011 to failure to notify a commercial carrier of a firearm and exporting defense 

articles without a license. He was sentenced on July 21, 2011 to 18 months in prison. This 

investigation was conducted by ICE.

DuPont Trade Secrets to China - On October 26, 2010, Hong Meng, a former research chemist 

for DuPont, was sentenced in the District of Delaware to 14 months in prison and $58,621 in 

restitution for theft of trade secrets. Meng pleaded guilty on June 8, 2010. Meng was involved in 

researching Organic Light Emitting Diodes (OLED) during his tenure at DuPont. In early 2009, 

DuPont's OLED research efforts resulted in the development of a breakthrough chemical process 

(trade secret) that increased the performance and longevity of OLED displays. In the Spring of 

2009, while still employed at DuPont and without DuPont's permission or knowledge, Meng 
76

accepted employment as a faculty member at Peking University (PKU) College of Engineering, 

Department of Nanotechnology in Beijing, China, and thereafter began soliciting funding to 

commercialize his OLED research at PKU. In June 2009, he emailed to his PKU account the 

protected chemical process from DuPont. He also downloaded the chemical process from his 

DuPont work computer to a thumb drive which he uploaded to his personal computer. In August 

2009, he mailed a package containing 109 samples of DuPont intermediate chemical compounds 

to a colleague at Northwestern University and instructed his colleague at Northwestern to forward 

the materials to Meng's office at PKU. Eight of the 109 samples were trade secret chemical 

compounds. Meng also made false statements to the FBI when questioned about these samples. 

This investigation was conducted by the FBI.

Rocket Propulsion Systems, Engines and Technology to South Korea - On October 20, 2010, 

Juwhan Yun, a.k.a. JW Yun, a naturalized U.S. citizen of Korean origin, was sentenced in the 

Southern District of Florida to 57 months in prison and 3 years supervised release. On May 14, 

2010, Yun pleaded guilty to attempting to illegally export defense articles to South Korea, 

including components for a 20 mm gun, known as the M61Vulcan; components for a SU-27 

Russian fighter jet; and RD-180 rocket propulsion systems, and related technology without the 

required State Department licenses. Yun was arrested on April 15, 2009, in Fort Lauderdale, Fla., 

and subsequently indicted on April 29, 2009 for attempting to purchase rocket materials for a 

company working on the Korean Satellite Launch Vehicle project and which was previously 

involved in developing Korea's KOMPSAT-1 satellite. Yun was previously convicted in May 

1989 of conspiracy to violate the Arms Export Control Act in connection with an effort to export 

500 quarter-ton bombs of sarin nerve gas to Iran. None of the bombs ultimately made it to Iran. 

He was sentenced to 39 months in federal prison in 1989. He was released from federal prison in 

March 1991 and was debarred by the State Department as a result of his conviction. This 

investigation was conducted by ICE and DCIS.

Missiles, Grenade Launchers & Other Weapons to Sri Lankan Terrorists - On October 18, 

2010, a federal jury in the District of Maryland convicted Balraj Naidu, a citizen of Singapore, of 

conspiracy to provide material support to a foreign terrorist organization stemming from his 

efforts to supply the Liberation Tigers of Tamil Eelam (Tamil Tigers) with advanced American 

weaponry. He was later sentenced to 57 months in prison on December 16, 2010. Beginning in 

February 2006, Naidu and his co-conspirators attempted to purchase state of the art weaponry 

from China, Thailand, North Korea, the Phillipines and Indonesia for the Tamil Tigers operating 

within Sri Lanka, to be used to fight against Sri Lankan government forces. Several arms 

merchants refused to supply the Tamil Tigers with weaponry once the destination for the arms 

had been disclosed by Naidu and his associates. In April 2006, Naidu's Indonesian sources for 

weapons unwittingly introduced Naidu and his associates to an agent for an undercover business 

in Maryland that purported to sell military weapons. In the subsequent months, the conspirators' 

negotiations with the undercover agent centered on the acquisition of American made weaponry. 

Terms of the sale included delivery of the weapons to locations in international waters off the 

coast of Sri Lanka. The weaponry was to be off-loaded by the Sea Tigers, the naval branch of the 

Tamil Tigers. Charged under a separate indictment, co-conspirator Haniffa Bin Osman visited 

Baltimore in the summer of 2006, where he examined and test-fired much of the weaponry. As a 

result of the trip, Tamil Tiger representatives wire transferred $250,000 into the undercover 

business' accounts as down payment on a $900,000 weapons deal. Approximately 28 tons of 

weapons and ammunition, which the conspirators believed they were purchasing, was air-lifted to 

the U.S. territory of Guam. On September 29, 2006, after inspecting the weapons and 

transferring an additional $450,000 into the undercover business' accounts, co-conspirators 

Osman, Haji Subandi, Erick Wotulo and Thirunavukarasu Varatharasa were arrested and indicted. 

The investigation continued and led to the indictment of Naidu and an alleged Tamil Tigers 
77

financier, Thulasitharan Santhirajah, on charges of conspiracy to provide material support to the 

Tamil Tigers and related offenses. Varatharasa, a citizen of the Democratic Socialist Republic of 

Sri Lanka; Subandi and retired Indonesian Marine Corps General Wotulo, both citizens of the 

Republic of Indonesia; and Osman, a citizen of the Republic of Singapore, pleaded guilty to their 

participation in the conspiracy and were sentenced to 57 months, 37 months, 30 months and 37 

months in prison, respectively, in 2007 and 2008. Santhirajah remains a fugitive. Three

additional defendants charged under a separate indictment, Haji Subandi, Reinehard Rusli and 

Helmi Soedirdja, pleaded guilty to export and money laundering violations in January 2007 for 

their participation in a related plot to provide military night vision devices to the Indonesian 

military. Rusli and Soedirdja were both sentenced in April 2007 to 12 months and 1 day in 

prison. Subandi was later sentenced in December 2007 to 37 months in prison. The case was 

investigated by ICE, FBI, and DCIS.

U.S. Fighter Jet Engines and Parts to Iran - On Sept 22, 2010, Jacques Monsieur, a Belgian 

national and resident of France suspected of international arms dealing for decades, was 

sentenced by a judge in the Southern District of Alabama to 23 months imprisonment. On 

November 23, 2009, Monsieur pleaded guilty to conspiracy to illegally export F-5 fighter jet 

engines and parts from the Untied States to Iran. He and co-conspirator Dara Fatouhi were first 

charged by indictment on August 27, 2009, with conspiring to illegally export F-5 fighter jet 

engines and parts from the United States to Iran, as well as money laundering, smuggling, and 

Iran embargo violations. Monsieur was arrested on August 28, 2009 after arriving in New York 

aboard a flight from Panama. Fatouhi, an Iranian national living in France who allegedly worked 

with the Iranian government to procure military items, remains at large. During a series of emails and meetings in Paris and London with undercover federal agents, Monsieur requested 

engines and parts for the F-5 fighter jet for export to Iran. Monsieur requested that the items be 

routed through Colombia and the United Arab Emirates on their way to Iran. He also arranged 

for a wire transfer of $110,000 as payment for F-5 fighter jet parts and indicated to undercover 

agents that a deposit of $300,000 would be forthcoming as payment for two F-5 fighter jet 

engines. The investigation was conducted by ICE and DCIS.

Nuclear-Related Equipment to Iran - On July 29, 2010, Mahmoud Yadegari was sentenced in a 

Canadian court in Toronto to four years and three months in prison for attempting to export 

pressure transducers that he had purchased in the United States to Iran, via Canada. Yadegari 

purchased pressure transducers from a company in Massachusetts and transported them to 

Canada. From there, he attempted to export the items to the United Arab Emirates, and 

ultimately to Iran in March 2009. Pressure transducers have applications in the production of 

enriched uranium. The Massachusetts company alerted ICE to the purchases, which, in turn 

worked with Canadian authorities. Yadegari was found guilty on July 6, 2010 of nine charges, 

including the Customs Act, the United Nations Act, the Export Import Permits Act, and the 

Nuclear Safety and Control Act. He was originally arrested by Canadian authorities in 2009 after 

a joint investigation by BIS, ICE and Canadian authorities.

Combat Riflescopes Overseas - On July 29, 2010, Chou-Fu Ho pleaded guilty in the Southern 

District of California to Arms Export Control Act violations and other charges. He was later 

sentenced on September 20, 2011 to five years supervised release and a $10,000 fine. Chou-Fu 

Ho was arrested on June 25, 2010, after being indicted on charges of smuggling and illegally 

exporting military night vision systems to various locations overseas without the required State 

Department licenses. According to the indictment, Ho illegally exported to Hong Kong and Japan 

combat riflescopes listed on the U.S. Munitions List without obtaining the required export 

licenses. Ho also allegedly attempted to illegally export combat riflescopes to Ireland, Austria and 

the United Arab Emirates. The investigation was conducted by ICE and DCIS.
78

F-5 Fighter Jet Components to Iran - On July 7, 2010, a superseding indictment was returned in 

the District of Columbia charging Mac Aviation Group, an Irish trading company, and its officers 

Thomas and Sean McGuinn of Sligo, Ireland, with purchasing F-5 fighter aircraft parts from U.S. 

firms and illegally exporting them to Iran. The defendants were previously charged in July 2008 

in connection with illegally exporting helicopter engines and other aircraft components to Iran. 

The new charges allege that, from 2005 and continuing until 2006, the defendants caused canopy 

panels designed for the F-5 fighter jet, valued at $44,500 to be exported from the United States to 

Iran and that the defendants falsely stated that the end-user for the panels was Nigeria. The 

transaction with Iran was allegedly arranged through the Iran Aircraft Manufacturing Industrial 

Company, known as HESA, which has been designated by the United States as an entity involved 

weapons mass destruction proliferation. The investigation was conducted by ICE and DCIS.

Oil Field Equipment to the Sudan - On June 22, 2010, Agar Corporation Inc., a company in 

Houston, pleaded guilty in the Southern District of Texas to violating the International 

Emergency Economic Powers Act and agreed to pay $2 million in criminal fines and forfeiture as 

well as civil penalties to the U.S. Treasury's Office of Foreign Assets Control. The company was 

sentenced two days later to four years probation and a $760,000 fine. Agar Corporation illegally 

facilitated the export of multi-phase flow meters by an affiliate in Venezuela to the Sudan for use 

in the Melut Basin oilfield in violation of the embargo on the Sudan. The investigation was 

conducted by ICE.

Military Optics Technology to China, Russia, Turkey and South Korea - On June 22, 2010, in 

U.S. District Court for the District of Colorado, Rocky Mountain Instrument Company (RMI), a 

Colorado corporation located in Lafayette, Colorado, pled guilty to one count of knowingly and 

willfully exporting defense articles without a license in violation of the Arms Export Control Act. 

The company was then immediately sentenced to five years of probation and ordered to forfeit 

$1,000,000. Between April 2005 and October 2007, RMI exported from the United States to 

Turkey, South Korea, the People's Republic of China, and Russia, prisms and technical data 

related to various optics used in military applications, which were designated as defense articles 

on the U.S. Munitions List, without having first obtained the required export licenses. The 

military technology that RMI illegally exported consisted of guidance or targeting systems used 

in such military items as unmanned aerial vehicles, AC-130 gunships, Abrams tanks, TOW 

missile systems, and Bradley fighting vehicles. RMI was originally charged by criminal 

information on March 17, 2010. The case was investigated by ICE and DCIS.

Illegal Oil Transaction with Iraq - On June 21, 2010, Muthanna Al-Hanooti pleaded guilty in the 

Eastern District of Michigan to one count of violating the International Emergency Economic 

Powers Act (IEEPA) for unlawfully accepting an allocation of two million barrels of Iraqi oil 

from the Government of Iraq in December 2002 without the required U.S. government license. 

Al-Hanooti was previously charged in a February 13, 2008, indictment with conspiracy to act as 

an unregistered agent of the Government of Iraq, an IEEPA violation, and making false 

statements in connection with his alleged work on behalf of the Iraqi Intelligence Service. In 

March 2011, Al-Hanooti was sentenced to one year and one day in prison. This investigation was 

conducted by the FBI. 

Thermal Imaging Cameras to China - On May 14, 2010, Sam Ching Sheng Lee, part-owner and 

chief operations manager of Multimillion Business Associate Corporation ("MBA"), pleaded 

guilty in the Central District of California to conspiracy to violate the International Emergency 

Economic Powers for illegally exporting national security-controlled thermal imaging cameras to 

China. His nephew, Charles Yu Hsu Lee, pleaded guilty the same day to misprision of a felony 
79

for the same activity. Sam Lee was sentenced on February 18, 2011 to 12 months in prison and a 

$10,000 fine, while Charles Lee was sentenced on December 15, 2010 to 6 days in prison and a 

$3,000 fine. The Lees were arrested on December 30, 2008 in Hacienda Heights, Ca, pursuant to 

a December 16, 2008 indictment charging them with conspiracy to export and exporting national 

security-controlled items without a license in violation of the IEEPA. The indictment alleged that 

the defendants, doing business as MBA, an import/export business located in Hacienda Heights, 

assisted persons in China illegally procure export controlled thermal-imaging cameras. During 

the period between April 2002 and July 2007, defendants allegedly exported a total of ten 

thermal-imaging cameras to China in circumvention of export laws. After being advised of strict 

export restrictions, Charles Lee allegedly purchased the cameras from U.S. suppliers for 

approximately $9,500 a piece by withholding the fact that the devices were destined to China. His 

uncle, Sam Lee, then received the devices and, through his company, arranged for their shipment 

to Shanghai, China without obtaining proper licenses. One of the recipients is alleged to be an 

employee of a company in Shanghai engaged in the development of infrared technology. The 

thermal-imaging cameras are controlled for export to China by the Department of Commerce for 

national security and regional stability reasons because of their use in a wide variety of military 

and civilian applications. This investigation was conducted by the EAGLE Task Force in the 

Central District of California. 

U.S. Missile Components to Iran - On August 27, 2010, in the Southern District of Florida, YiLan Chen, aka Kevin Chen, of Taiwan, was sentenced to 42 months in prison, while his Taiwan 

corporation, Landstar Tech Company Limited, was sentenced to 1 year probation. On September 

9, 2011, an amended sentence was issued for Yi-Lan Chan, sentencing him to time served, 2 

years supervised release and a $300 special assessment. Previously, on May 13, 2010, Chen and 

Landstar Tech Company Limited, pleaded guilty to a 3-count criminal information charging them 

with illegally exporting dual-use commodities to Iran that have potential military applications. 

Chen was arrested in Guam on February 3, 2010. According to court documents in the case, 

customers in Iran affiliated with that nation's missile program sent orders by e-mail to Chen for 

specific goods. Chen then requested quotes, usually by e-mail, from U.S. businesses and made 

arrangements for the sale or shipment of the goods to one of several freight forwarders in Hong 

Kong and Taiwan. Once in Hong Kong or Taiwan, the goods were then shipped to Iran. Among 

the customers in Iran were buyers for Electro SANAM Industries, which serves as a front 

company for Aerospace Industries Organization in Iran and has been linked to Iranian ballistic 

missile programs. Another Iranian customer was the owner of the Noavaran Sooyab Sanat, Co., 

which is a division of Jahad Engineering Research Center. Jahad Engineering Research Center 

has been linked to chemical research and development facilities and has been listed as an entity of 

concern by the British government for the procurement of weapons of mass destruction. In one email with an Iranian customer, Chen stated, "As you know we cannot tell USA this connector is 

for you. So we have to tell a white lie to USA that this is for our factory in Hong Kong." Among 

the dual-use items that Chen caused to be shipped to Iran were 120 circular hermetic connectors 

and 8,500 glass-to- metal seals. While the goods have commercial applications, they also can 

make a significant contribution to the military or nuclear potential of other nations. Agents 

learned of Chen's efforts after he attempted to obtain and export to Iran some 2,000 detonators 

from a California company. The investigation was conducted by BIS and ICE.

Commercial 747 Aircraft to Iran - On May 11, 2010, Balli Aviation Ltd., a subsidiary of the 

U.K.-based Balli Group PLC, was sentenced in the District of Columbia to pay a $2 million fine 

and to serve a five-year corporate period of probation after pleading guilty on February 5, 2010, 

to a two-count criminal information in connection with its illegal export of commercial Boeing 

747 aircraft from the United States to Iran. The $2 million fine, combined with a related $15 

million civil settlement among Balli Group PLC, Balli Aviation Ltd., the U.S. Department of 
80

Commerce's Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury's 

Office of Foreign Assets Control (OFAC), represented one of the largest fines for an export 

violation in BIS history. Balli Aviation Ltd. conspired to export three 747 aircraft from the U.S. 

to Iran without the required export licenses. According to the criminal information, Balli 

Aviation Ltd., through its subsidiaries, the Blue Sky Companies, purchased U.S.-origin aircraft 

with financing obtained from an Iranian airline and caused these aircraft to be exported to Iran 

without obtaining the required U.S. government licenses. Further, Balli Aviation Ltd. entered 

into lease arrangements that permitted the Iranian airline to use the U.S.-origin aircraft for flights 

in and out of Iran. In addition, Balli Aviation Ltd. violated a Temporary Denial Order issued by 

BIS that prohibited the company from conducting any transaction involving any item subject to 

the Export Administration Regulations. The investigation was conducted by BIS and OFAC.

$500 Million Forfeiture for Iran Embargo Violations and Other Charges - On May, 10, 2010, 

the former ABN AMRO Bank N.V., now named the Royal Bank of Scotland N.V., agreed to 

forfeit $500 million in connection with a conspiracy to defraud the United States, to violate the 

International Emergency Economic Powers Act and to violate the Trading with the Enemy Act, 

as well as a violation of the Bank Secrecy Act. A criminal information was filed in the District of 

Columbia. The bank waived indictment, agreed to the filing of the information, and accepted and 

acknowledged responsibility for its conduct. ABN AMRO agreed to forfeit $500 million as part 

of a deferred prosecution agreement. From 1995 through December 2005, ABN AMRO assisted 

sanctioned countries and entities in Iran, Libya, Sudan, Cuba and elsewhere in evading U.S. laws 

by facilitating hundreds of millions of U.S. dollar transactions. The IEEPA and TWEA violations 

relate to ABN AMRO conspiring to facilitate illegal dollar transactions on behalf of financial 

institutions, including Bank Markazi and Bank Melli of Iran as well as other customers from Iran, 

Libya, the Sudan, Cuba and other sanctioned nations. ABN AMRO Bank offices and employees 

in the Netherlands, the UAE, Saudi Arabia, and elsewhere stripped mention of Iranian and 

Sudanese banks from international funds transfer instructions sent to the New York branch of the 

bank thereby causing and facilitating financial transactions for the benefit of the Iranian and 

Sudanese financial institutions. The investigation was conducted by the IRS and FBI. 

Russian Attack Helicopters to Zimbabwe - On March 19, 2010, Peter Spitz, a resident of 

Hallandale, Fla., and the owner of Russian Aircraft Services LLC, received an amended sentence 

in the Southern District of Florida, of 42 months in prison followed by 2 years of supervised 

release. Previously, on April 8, 2008, Spitz was arrested in Miami pursuant to a criminal 

complaint alleging that he conspired to sell seven MI-24 Russian attack helicopters and three MI8T Russian military transport helicopters to undercover law enforcement officials who 

represented that the helicopters would be going to a Cabinet member of the government of 

Zimbabwe. On August 14, 2008, Spitz was charged by a superseding indictment with illegal 

arms brokering activities. Spitz pleaded guilty to count one of the superseding indictment on 

September 12, 2008. The investigation was conducted by ICE and DCIS.

U.S. - Origin Tools to Libya - On March 9, 2010, Uni-Arab Engineering and Oil Field Services, a 

firm incorporated in the United Arab Emirates and operated in part by two naturalized U.S. 

citizens, Jaime Radi Mustafa and Nureddin Shariff Sehweil, pleaded guilty in the Eastern District 

of Louisiana to a superseding information changing the firm with violating U.S. sanctions against 

Libya and was sentenced to one year inactive probation, a $60,000 fine, and $400 special 

assessment. According to the plea agreement, Uni-Arab caused goods to be shipped from Texas 

to the Netherlands in 2001 and 2002, where they were repackaged and illegally shipped to Libya. 

The government dismissed the indictment against Mustafa and Sehweil.
81

BAE Systems PLC Pleads Guilty and Ordered to Pay $400 Million - On March 1, 2010, BAE 

Systems PLC (BAES), a multinational defense contractor with headquarters in the United 

Kingdom, pleaded guilty in the District of Columbia to conspiracy to defraud the United States, 

conspiracy to make false statements about its Foreign Corrupt Practices Act compliance program, 

and conspiracy to violate the Arms Export Control Act (AECA) and International Traffic in Arms 

Regulations (ITAR). BAES was sentenced on March 1, 2010 to a $400 million fine, 36 months 

probation, and a $400 assessment. With respect to the conspiracy to violate AECA, BAES 

admitted to making false statements and failing to make required disclosures to the U.S. 

government in connection with the administration of certain regulatory functions, including 

statements and disclosures related to applications for arms export licenses, as required by the 

AECA and ITAR. As part of the licensing scheme, applicants are required to identify associated 

commissions to the State Department- whether they are legitimate commissions or bribes - paid to 

anyone who helps secure the sales of defense materials. BAES admitted that, as part of the 

conspiracy, it knowingly and willfully failed to identify commissions paid to third parties for 

assistance in soliciting, promoting or otherwise securing sales of defense items in violation of the 

AECA and ITAR. In one instance, BAES caused the filing of false applications for export 

licenses for Gripen fighter jets to the Czech Republic and Hungary by failing to tell the export 

license applicant or the State Department of £19 million BAES paid to an intermediary with the 

high probability that it would be used to influence that tender process to favor BAES. The case 

was investigated by the FBI and ICE, with assistance by DCIS and the General Services 

Administration, Office of Inspector General.

Semi-Automatic Pistols to Cayman Islands - On February 23, 2010, a grand jury in the Southern 

District of Florida returned an indictment charging Junior Estiven with conspiracy to smuggle 

firearms, making false statements in connection with the acquisition of firearms, and possession 

of firearms with obliterated serial numbers. On June 15, 2010, Estiven pled guilty to conspiracy 

to smuggle firearms and was sentenced on August 25, 2010 to 30 months imprisonment, 3 years 

supervised release and $100 special assessment. Estiven and others allegedly conspired to 

smuggle semi-automatic pistols to the Cayman Islands. Several other individuals were charged 

and previously pleaded guilty in connection with the scheme. David Gilbert Lyons, Anthony 

Mitchell Brown and Brittanio Jermie Walton were all indicted in the Southern District of Florida 

on May 5, 2009 in connection with the attempted illegal export of firearms to the Cayman Islands 

and other charges. Lyons was sentenced to 57 months in prison, while Brown was sentenced to 

37 months in prison, and Walton was sentenced to 51 months in prison. In addition, Sheila 

Caraballo Madrigal was charged on September 14, 2009 with conspiracy to smuggle firearms, 

conceal shipment of firearms and acquire firearms by making false statements. She later pleaded 

guilty and was sentenced to three years probation. The investigation was conducted by ICE and 

ATF.

Electronics to Designated Terror Entity in Paraguay - On February 19, 2010, federal authorities 

in the Southern District of Florida announced the indictment of four individuals and three Miami 

businesses on charges involving the illegal export of electronics to a U.S. designated terrorist 

entity in Paraguay. The defendants charged were Samer Mehdi, of Paraguay, Khaled T. Safadi, 

of Miami, Ulises Talavera, of Miami, Emilio Jacinto Gonzalez-Neira, of Paraguay, Cedar 

Distributors, Inc. (Cedar), a Miami-based firm owned by defendant Safadi, Transamerica Express 

of Miami, Inc. (Transamerica), a Miami-based firm owned by defendant Talavera, and Jumbo 

Cargo, Inc. (Jumbo), a Miami-based firm owned by defendant Gonzalez-Neira. All were indicted 

on charges of conspiracy, violating the International Emergency Economic Powers Act and 

smuggling electronic goods from the United States to Paraguay. According to the indictment, 

from March 2007 through January 2008, freight-forwarders Talavera, through Transamerica, and 

Gonzalez-Neira, through Jumbo, exported Sony brand electronics, including Play station 2 
82

consoles and digital cameras, to Samer Mehdi, owner of Jomana Import Export, an electronics 

business located within the Galeria Page, a shopping center in Ciudad del Este, Paraguay. Safadi, 

through Cedar, was a distributor of the electronics to the freight-forwarders. Since December 6, 

2006, the shopping center known as Galeria Page in Ciudad del Este, Paraguay, has been 

designated as a Specially Designated Global Terrorist entity by the U.S. Treasury Department, on 

grounds that it serves as a source of fundraising for Hizballah in the Tri-Border Area and is 

managed and owned by Hizballah members in the Tri-Border Area. Consequently, any 

transaction or dealing by a U.S. person with Galeria Page is prohibited. The OFAC designation 

banned trade with Galeria Page and all tenants located therein. Gonzalez-Neira and Jumbo 

Cargo, Inc. pleaded guilty on September 15, 2010 to conspiracy violations and were later 

sentenced to 1 year probation and 1 year non-reporting probation, respectively. Defendants 

Safadi and Cedar Distributors, Inc. pleaded guilty on October 1, 2010 to conspiracy violations. 

Talavera and Transamerica Express of Miami pleaded guilty to conspiracy violations on October 

20, 2010. On January 24, 2011, Safadi, Cedar Distributors, Inc., Talavera and Transamerica 

Express of Miami were each sentenced. Safadi was sentenced to 6 months probation. Talavera 

was sentenced to 1 year probation. Cedar Distributors and Transamerica Express were each 

sentenced to 3 years probation. Mehdi pleaded guilty to conspiracy violations on August 19, 

2014 and was sentenced the next day to 1 year of probation. The investigation was conducted by 

ICE FBI, CBP, BIS, OFAC, and U.S. Secret Service.

Economic Espionage / Theft of Space Shuttle and Rocket Secrets for China - On February 11, 

2010 former Rockwell and Boeing engineer Dongfan "Greg" Chung was sentenced to 188 

months imprisonment and three years supervised release after his July 16, 2009 conviction in the 

Central District of California. Chung was convicted of charges of economic espionage and acting 

as an illegal agent of the People's Republic of China (PRC), for whom he stole restricted 

technology and Boeing trade secrets, including information related to the Space Shuttle program 

and the Delta IV rocket. According to the judge's ruling, Chung served as an illegal agent of 

China for more than 30 years and kept more than 300,000 pages of documents reflecting Boeing 

trade secrets stashed in his home as part of his mission of steal aerospace and military trade 

secrets from Boeing to assist the Chinese government. Chung sent Boeing trade secrets to the 

PRC via the mail, via sea freight, via the Chinese consulate in San Francisco, and via a Chinese 

agent named Chi Mak. On several occasions, Chung also used the trade secrets that he 

misappropriated from Boeing to prepare detailed briefings that he later presented to Chinese 

officials in the PRC. Chung was originally arrested on February 11, 2008, in Southern California 

after being indicted on eight counts of economic espionage, one count of conspiracy to commit 

economic espionage, one count of acting as an unregistered foreign agent, one count of 

obstruction of justice, and three counts of making false statements to the FBI. The investigation 

was conducted by the FBI and NASA.

Chemical Purchasing Software to Iran - On January 11, 2010, Ali Amirnazmi, of Berwyn, PA, 

was sentenced in the Eastern District of Pennsylvania to 48 months in prison for his February 13, 

2009 conviction on one count of conspiracy to violate the International Emergency Economic 

Powers Act (IEEPA); three counts of violating IEEPA, three counts of making false statements; 

and three counts of bank fraud. Amirnazmi was also ordered to forfeit $64,000 and to pay 

$17,277 restitution to Penn Liberty Bank. Amirnazmi, the owner of Trantech Consultants, Inc., 

in Pa., was charged by superseding indictment in October 2008 with crimes relating to his 

participation from 1996 to July 2008 in illegal business transactions and investments with 

companies located in Iran, including companies controlled in whole or in part by the government 

of Iran, as well as lying to federal officials about those transactions, and bank fraud. Evidence at 

trial revealed that Amirnazmi worked at the express direction of the highest echelons of the 

Iranian government, specifically President Mahmoud Ahmadinejad and his close advisors, to 
83

advance the Iranian petrochemical industry. Amirnazmi is a chemical engineer who, among other 

things, licensed to Iranian companies the use of a proprietary database and software system that 

he had developed. The software was designed to help buyers around the globe locate the best 

prices for various chemicals. Amirnazmi, a citizen of both the United States and Iran, was first 

indicted on July 25, 2008. The case was investigated by the FBI and IRS.

Military Equipment to Yemen, Libya & Other Locations - On January 7, 2010, Ioannis 

Papathanassiou, of Vienna, Va., entered a guilty plea on behalf of his company, Taipan 

Enterprises, Ltd., in the Eastern District of Virginia for attempting to illegally broker the sale of 

weapons, night vision goggles and other military equipment to purchasers in Yemen, Libya, Chile 

and other nations. Taipan Enterprises was ordered to pay a fine of $15,000. Court records indicate 

that Papathanassiou attempted to arrange the sale of Swiss-made machine pistols to a purchaser in

Yemen, attempted to arrange the sale of Canadian night vision technology from Canada to Libya, 

attempted to arrange the sale of Canadian armored vehicles to the Chilean marine corps, 

attempted to arrange the sale of M4 rifles, gas grenades, armored vehicles and other military 

equipment to Chile, and attempted to arrange the sale of a number of military armored vehicles 

from a Belgian defense manufacturer to a Missouri-based company for final use in Vietnam. The 

investigation was conducted by ICE and CBP.

Firearms to Canada - On December 18, 2009, Ugur Yildiz, a former suburban Chicago gun shop 

owner, was sentenced in the Northern District of Illinois to 71⁄2 years in prison for illegally 

exporting more than 200 firearms to Canada -- some of which were later used in violent crimes in 

Canada. Yildiz, of Park Ridge, Illinois, owned the Chicagoland Bells gun store. He was arrested 

and charged with violations of the Arms Export Control Act in a criminal complaint on June 19, 

2009. According to court documents filed in the case, since 2006, Canadian law enforcement 

recovered 25 firearms in Canada that were registered to Yildiz, and all but one of these guns were 

recovered during the execution of search warrants in connection with investigations of drug and 

violent crimes. Two guns registered to Yildiz were traced to attempted homicides in Canada, 

according to court documents, including a .45 caliber Glock recovered on September 22, 2006 

pursuant to a shooting in Toronto. This case was investigated by ICE, ATF and DEA.

Restricted Components to Iran - On December 17, 2009, James Larrison, of Avondale, AZ, 

pleaded guilty in the District of Delaware to a one-count criminal information charging him with 

violating the International Emergency Economic Powers Act. From August 2008, through 

February 2009, Larrison attempted to illegally export from the United States to Iran Hitachi JUZ2 Junction Units (camera control box, 8-port multiple television camera control delegation 

switch). The charges result from an investigation launched after the seizure in October 2007 of a 

laptop computer from convicted Iranian procurement agent Amir Hossein Ardebili. Larrison was 

sentenced to probation on June 23, 2011 after providing substantial assistance to the government 

in its investigation of his former employer Aegis Electronic Group Inc, which entered into a 

deferred prosecution agreement with the government and paid a fine to the Treasury Department. 

This case was investigated by ICE. 

Military Electronics for Radar, Fighter Jets, and Missiles to Iran - On December 2, 2009, 

criminal indictments were unsealed in the Districts of Delaware and Massachusetts relating to the 

prosecution of Iranian arms procurement agent Amir Hossein Ardebili. Defendant Ardebili pled 

guilty to these indictments on May 19, 2008. Ardebili pleaded guilty to multiple violations of the 

Arms Export Control Act, International Emergency Economic Powers Act, smuggling, 

conspiracy and money laundering. The charges result from a three year international undercover 

investigation which exposed Ardebili's role as a prolific arms acquisitions agent for the 

government of Iran. During the investigation, Ardebili negotiated the purchase and illegal export 
84

of a number of military components, including: QRS-11 Gyro Chip Sensors, which are used in 

numerous advanced aircraft, missile, space and commercial applications; MAPCGM0003 Phase 

Shifters, which perform a key function in electronically steered antennae and have many 

applications including phased array radar, which is used in military target acquisition and missile 

guidance; and Digital Air Data Computer, which is a replacement for the computer installed on 

the U.S. F-4 fighter aircraft used by Iran that calculates flight parameters including altitude, air 

speed, static pressure, mach number, and true angle of attack. Ardebili's negotiations with 

undercover agents culminated in a face-to-face meeting in the Republic of Georgia in October of 

2007, after which Ardebili was arrested and extradited to the United States in January 2008. On 

December 14, 2009, Ardebili was sentenced to five years in prison, with credit for time served. 

He completed his prison term in February 2012 and was deported to Iran on March 14, 2012. The 

investigation was conducted by ICE and DCIS.

Military & Commercial Aircraft Components to Iran - On November 5, 2009, Laura WangWoodford, a U.S. citizen who served as a director of Monarch Aviation Pte Ltd., a Singapore 

company that imported and exported military and commercial aircraft components for more than 

20 years, was sentenced in the Eastern District of New York to 46 months in prison and ordered 

to forfeit $500,000 for conspiring to violate the U.S. trade embargo by exporting controlled 

aircraft components to Iran. On March 13, 2009, Wang-Woodford pled guilty to the charges. She 

was arrested on December 23, 2007, at San Francisco International Airport after arriving on a 

flight from Hong Kong. She and her husband, Brian D. Woodford, a U.K. citizen who served as 

chairman and managing director of Monarch, were originally charged in a 20-count indictment on 

January 15, 2003. Brian Woodford remains a fugitive. A superseding indictment charging 

Wang-Woodford with operating Jungda International Pte. Ltd ("Jungda"), a Singapore-based 

successor to Monarch, was returned on May 22, 2008. According to the superseding indictment, 

the defendants exported controlled U.S. aircraft parts from the U.S. to Monarch and Jungda in 

Singapore and Malaysia and then re-exported those items to companies in Tehran, Iran, without 

obtaining the required U.S. government licenses. The defendants also falsely listed Monarch and 

Jungda as the ultimate recipients of the parts on export documents filed with the U.S. 

government. The aircraft parts illegally exported to Iran include aircraft shields, shears, "o" rings, 

and switch assemblies, as well as U.S. military aircraft components, designed for use in Chinook 

military helicopters. At the time of her arrest, Wang-Woodford possessed catalogues from a 

Chinese company, the China National Precision Machinery Import and Export Corporation 

("CPMIEC"), containing advertisements for surface-to-air missile systems and rocket launchers. 

CPMIEC has been sanctioned by the Treasury Department as a specially designated Weapons of 

Mass Destruction proliferator, based, in part, on CPMIEC's history of selling military hardware to 

Iran. The investigation was conducted by BIS and ICE.

Carbon-Fiber Material with Rocket & Spacecraft Applications to China - On October 8, 2009, 

three individuals were sentenced in the District of Minnesota for illegally exporting highmodulus, carbon fiber material to the China Academy of Space Technology. Jian Wei Ding was 

sentenced to 46 months in prison. Kok Tong Lim was sentenced to just over one year of 

confinement because of his cooperation in the case, while Ping Cheng was sentenced to one year 

probation due to his cooperation. On March 20, 2009, Ding pleaded guilty to one count of 

conspiracy to violate the Export Administration Regulations. Cheng entered his plea on February 

13, 2009 and Lim entered his plea on March 9, 2009. All three men were indicted on October 28, 

2008 for conspiring to illegally export to China controlled carbon-fiber material with applications 

in aircraft, rockets, spacecraft, and uranium enrichment process. The intended destination for 

some of the materials was the China Academy of Space Technology, which oversees research 

institutes working on spacecraft systems for the PRC government. For national security, nuclear 

proliferation and antiterrorism reasons, the U.S. government requires a license to export these 
85

carbon-fiber materials. Jian Wei Ding was a resident of Singapore and owned or was a affiliated 

with various Singaporean import/export companies, including Jowa Globaltech Pte Ltd, 

FirmSpace Pte Ltd, and Far Eastron Co. Pte Ltd. Kok Tong Lim was a resident of Singapore and 

once was affiliated with FirmSpace, Pte Ltd. Ping Cheng was a resident of New York and the sole 

shareholder of Prime Technology Corporation. This investigation was conducted by ICE and BIS.

Sensitive Aircraft Components to Iran - On September 24, 2009, Aviation Services International 

(ASI), a Netherlands-based aviation services company, its owner, Robert Kraaipoel, and his son 

Robert Neils Kraaipoel, pleaded guilty in the District of Columbia to a one-count criminal 

information alleging conspiracy to violate the International Emergency Economic Powers Act 

(IEEPA) and the Iranian Transactions Regulations. From about October 2005 to about October 

2007, the defendants received orders from customers in Iran for U.S.-origin goods, including 

various aircraft components that were restricted from being transshipped into Iran. The 

defendants then contacted companies in the United States and negotiated purchases of materials 

on behalf of Iranian customers. The defendants provided false end-user certificates to certain U.S. 

companies to conceal that customers in Iran would be the true recipients of the goods. The goods 

were routed to Iran through the Netherlands, the United Arab Emirates, and Cyprus. In 2006 

alone, Aviation Services obtained some 290 aircraft-related components from the U.S. and caused 

them to be shipped to Iran. Many of these U.S.-origin goods were sent to Iranian government 

agencies, Iranian procurement agencies or companies doing business in Iran. ASI agreed to pay a 

$100,000 fine and corporate probation for five years. On June 12, 2012, the Kraaipoels were both 

sentenced to probation as a result of their cooperation in a number of investigations. The 

investigation was conducted by BIS, ICE, DCIS and FBI. 

Sighting Devices to Afghanistan and Taiwan - On September 21, 2009, Aaron Henderson, doing 

business as Vahalla Tactical Supply, was sentenced to time served and two years supervised 

release following his plea of guilty on September 18, 2009 to a criminal information in the 

Southern District of Iowa. Henderson pleaded guilty to his illegal export of restricted sighting 

devices to Taiwan and Afghanistan without the required export licenses. The investigation was 

conducted by BIS, ICE and the Bureau of Alcohol, Tobacco, Firearms and Explosives.

Electronics and IED Components to Iran – On August 31, 2009, in the Southern District of 

Florida, Farshid Gillardian, an Iranian national who is a naturalized British citizen, was sentenced 

in the Southern District of Florida to 1 year of probation and $100 special assessment. On August 

24, 2009, defendant Gillardian pleaded guilty to a superseding information charging him with 

making false statements. Previously, on September 18, 2008, a 13-count superseding indictment 

was unsealed in the Southern District of Florida charging eight individuals and eight companies 

with conspiracy, violations of the International Emergency Economic Powers Act, the U.S. Iran 

embargo, and false statements in connection with their participation in conspiracies to illegally 

export electronics, Global Positioning Systems (GPS) systems, and other dual-use commodities to 

Iran. All the items had potential military applications, including in the construction of Improvised 

Explosive Devices (IEDs). Among other things, the indictment alleges the defendants illegally 

exported to Iran 345 GPS systems and 12,000 Microchip brand microcontrollers. These specific 

types of microcontrollers have been found in IEDs in Iraq. The businesses charged are: Mayrow 

General Trading, Atlinx Electronics, Micatic General Trading, Madjico Micro Electronics, and 

Al-Faris, all Dubai-based businesses; Neda Industrial Group, an Iran-based business; and Eco 

Biochem Sdn BHD and Vast Solution Sdn BHD, Malaysian businesses. The individuals charged 

are charged are: Ali Akbar Yahya and Gillardian, both Iranian nationals who are naturalized 

British citizens; F.N. Yaghmaei, Bahman Ghandi, Ahmad Rahzad, all Iranian nationals; Kaam 

Chee Mun, a resident of Malaysia; Djamshid Nezhad, a resident of Germany; and Majid Seif, an 

Iranian national residing in Malaysia. As part of the enforcement action, the Department of 
86

Commerce added 75 individuals and companies affiliated with this Iranian procurement network 

to its Entities list. This investigation was conducted by Commerce BIS, DCIS, ICE, and the 

Treasury Department's Office of Foreign Assets Control (OFAC).

Restricted Integrated Circuits with Military Applications to China - On August 3, 2009, William 

Chai-Wai Tsu, an employee of a Beijing-based military contracting company called Dimigit 

Science & Technology Co. Ltd, and the vice president of a Hacienda Heights, CA, front company 

called Cheerway, Inc., was sentenced in the Central District of California to 40 months in prison. 

Tsu illegally exported more than 400 restricted integrated circuits with applications in military 

radar systems to China over a 10-month period, according to court documents. These dual-use 

items are restricted for export for national security reasons. Tsu purchased many of the items 

from U.S.-distributors after falsely telling these U.S. companies that he was not exporting the 

circuits abroad. According to court documents, Tsu supplied restricted U.S. technology to several 

customers in China, including the "704 Research Institute," which is known as the "Aerospace 

Long March Rocket Technology Company" and is affiliated with the state-owned China 

Aerospace Science & Technology Corporation. Tsu's employer in China, Dimigit, boasted in 

brochures that its mission was "providing the motherland with safe, reliable and advanced 

electronic technical support in the revitalization of our national military industry." Tsu was 

indicted in the Central District of California on February 6, 2009 on charges of violating the 

International Emergency Economic Powers Act. He later pleaded guilty to two federal counts of 

the indictment on March 13, 2009. This case was the product of an investigation by the Export 

and Anti-proliferation Global Law Enforcement (EAGLE) Task Force in the Central District of 

California, which includes BIS, ICE, FBI, CBP, Diplomatic Security Service and the 

Transportation Security Administration. 

Restricted Thermal Imaging Technology to China - On July 27, 2009, Zhi Yong Guo, a resident 

of Beijing, was sentenced in the Central District of California to 60 months in prison, while Tah 

Wei Chao, also a resident of Beijing, was sentenced to 20 months in prison. Both were sentenced 

in connection with a plot to procure and illegally export thermal-imaging cameras to the People's 

Republic of China without obtaining the required export licenses. Guo and Chao were indicted 

on federal charges on July 17, 2008. Chao pleaded guilty to three federal counts in July 2008. On 

February 23, 2009, following a one-week trial, Guo was convicted of two federal counts. The 

case related to ten cameras concealed in luggage destined for China in April 2008. The export of 

these thermal-imaging cameras to China are controlled by the Department of Commerce for 

national security and regional stability reasons because of their use in a wide variety of civilian 

and military applications. In March 2008, Chao ordered 10 thermal-imaging cameras from FLIR 

Systems, Inc. for $53,000. Representatives from FLIR Systems repeatedly warned Chao that the 

cameras could not be exported without a license. Both Chao and Guo were arrested at Los 

Angeles International Airport in April 2008 after authorities recovered the ten cameras that had 

been hidden in their suitcases. In addition to the 10 cameras intercepted by federal authorities, 

Chao admitted that, acting at the behest of Guo, he shipped three cameras to China in October 

2007. The evidence at trial showed that Guo, an engineer and a managing director of a technology 

development company in Beijing, directed Chao to obtain the cameras for Guo's clients, the 

Chinese Special Police and the Special Armed Police. This case was the product of an 

investigation by the Export and Anti-proliferation Global Law Enforcement (EAGLE) Task Force 

in the Central District of California, including BIS, ICE, FBI, CBP, DSS, and TSA.

Military Technical Data on Unmanned Aerial Vehicles to China - On July 1, 2009, Dr. John 

Reece Roth was sentenced in the Eastern District of Tennessee to 48 months in prison, two years 

supervised release and a $1,700 assessment for illegally exporting sensitive military technical 

data related to a U.S. Air Force contract. Roth, a former Professor Emeritus at the University of 
87

Tennessee, was convicted on September 2, 2008 of 15 counts of violating the Arms Export 

Control Act, one count of conspiracy, and one count of wire fraud. Roth had illegally exported 

military technical data relating to plasma technology designed to be deployed on the wings of 

Unmanned Aerial Vehicles (UAVs) or "drones" operating as a weapons or surveillance systems. 

The illegal exports involved technical data related to an Air Force research contract that Roth 

provided to foreign nationals from China and Iran. In addition, Roth carried multiple documents 

containing controlled military data with him on a trip to China and caused other controlled 

military data to be e-mailed to an individual in China. On August 20, 2008, Atmospheric Glow 

Technologies, Inc (AGT), a privately-held plasma technology company in Tennessee, also 

pleaded guilty to charges of illegally exporting U.S. military data about drones to a citizen of 

China in violation of the Arms Export Control Act. AGT was sentenced on February 12, 2010 to 

a $4,000 assessment and a $25,000 fine. Roth and AGT were first charged on May 20, 2008. In a 

related case, on April 15, 2008, Daniel Max Sherman, a physicist who formerly worked at AGT, 

pleaded guilty to an information charging him with conspiracy to violate the Arms Export Control 

Act in connection with this investigation. Sherman was later sentenced to 14 months in prison on 

August 10, 2009 after cooperating in the investigation. The investigation was conducted by the 

FBI, ICE, U.S. Air Force Office of Special Investigations, DCIS and BIS. 

Missiles & Other Arms to Colombian Terror Organization - On July 1, 2009, Palestinian born 

businessman Tareq Mousa al-Ghazi was sentenced in the Southern District of New York to 25 

years in prison after his March 17, 2009 conviction for conspiring with Syrian arms dealer, 

Monzer Al-Kassar, and others in a plot to sell surface-to-air missiles, 4,000 grenades, and nearly 

9,000 assault rifles to the Fuerzas Armadas Revolucionarias de Colombia, or FARC, a designated 

terrorist organization in Colombia. Al-Ghazi was found guilty of conspiracy to murder U.S. 

officers and employees, conspiracy to acquire and export anti-aircraft missiles, and conspiracy to 

provide material support to terrorists. Al-Ghazi's co-defendants, Monzer al-Kassar and Luis 

Felipe Moreno Godoy, were both convicted at trial on November 20, 2008 in connection with the 

same conspiracy and were sentenced on February 24, 2009 to 30 years imprisonment and 25 

years imprisonment, respectively. In June 2007, Al Kassar was arrested in Spain, while Moreno 

and El Ghazi were arrested in Romania pursuant to a May 29, 2007 indictment alleging that they 

agreed to sell millions of dollars worth of surface-to-air missiles, rocket-propelled grenade 

launchers, ammunition, and machine guns to the FARC, between February 2006 and May 2007. 

Al Kassar also offered to send 1,000 men to fight with the FARC against U.S. military officers in 

Colombia. On June 13, 2008, Al Kassar arrived in New York after being extradited from Spain. 

Since the early 1970s, Al Kassar has been a source of weapons and military equipment for armed

factions engaged in violent conflicts around the world. Some of these factions have included 

known terrorist organizations, such as the Palestinian Liberation Front, the goals of which 

included attacking United States interests and United States nationals. The investigation was 

conducted by the Drug Enforcement Administration, Spanish National Police and Romanian 

Border Police

Military Night Vision Technology to China - On July 1, 2009, Bing Xu, of Nanjing, China, was 

sentenced in the District of New Jersey to 22 months in prison followed by two years of 

supervised release after pleading guilty on February 24, 2009, to conspiracy to illegally export 

military-grade night vision technology to China. Xu, a manager at Everbright Science and 

Technology, Ltd, a company in Nanjing, China, admitted that he conspired with others at 

Everbright to purchase certain night-vision technology from a company in the United States, 

which required a license from the State Department for export. Xu admitted that he and others at 

Everbright first attempted to obtain the necessary export license for the night-vision equipment. 

When the license application was denied by the Department of State, Xu agreed with others at 

Everbright to take steps to export the night-vision optical equipment illegally. Xu has been in 
88

custody since his arrest in on October 2007 pursuant to a criminal complaint. Xu arrived in New 

York on October 26, 2007 from China a day after his Chinese employer wire transferred $14,080 

to agents as payment for the purchase of the equipment. The investigation was conducted by ICE 

and the DCIS.

Restricted Nuclear Materials to Foreign Government - On June 18, 2009, Roy Lynn Oakley, of 

Harriman, Tenn., was sentenced in the Eastern District of Tennessee to six years in prison for 

unlawful disclosure of restricted data under the Atomic Energy Act in connection with his efforts 

to sell materials used in the production of highly enriched uranium to a foreign government. 

Oakley pleaded guilty to this offense on January 26, 2009. Oakley had worked as a contract 

employee at the East Tennessee Technology Park (ETTP), in Oak Ridge, Tenn., which was 

previously a Department of Energy facility that produced highly enriched uranium. While 

employed at ETTP, Oakley stole restricted nuclear materials from the facility and offered them 

for sale to the French government. The French government officials did not pursue the purchase 

of these items. The FBI launched an undercover investigation posing as an agent of the foreign 

government and arrested Oakley after he offered them the nuclear materials in exchange for 

$200,000 cash. The materials involved were pieces of equipment known as "barrier" and 

associated hardware items that play a crucial role in the production of highly enriched uranium. 

The investigation was conducted by the FBI and Department of Energy.

Fighter Jet and Military Helicopter Components to Iran - On June 11, 2009, Traian Bujduveanu 

was sentenced in the Southern District of Florida to 35 months in prison followed by three years 

supervised release for his role in a conspiracy to illegally export military and dual-use aircraft 

parts to Iran. Bujduveanu appeared on behalf of himself and his now defunct corporation, Orion 

Aviation Corp., in federal court to announce his guilty plea on April 2, 2009. Bujduveanu's codefendant, Hassan Keshari, and his corporation, Kesh Air International, pleaded guilty in January 

2009 to charges of conspiring to illegally export military and commercial aircraft components to 

Iran. Keshari was sentenced to 17 months in prison on May 14, 2009. On July 3, 2008, Keshari, 

Kesh Air International, as well as Bujduveanu, and his company Orion Aviation, were indicted 

for their participation in a conspiracy to export U.S.-made military and dual-use aircraft parts to 

Iran. In June 2008, agents arrested Keshari at Miami International Airport as he walked off a 

flight from Atlanta. Bujduveanu was arrested at his Plantation, Florida, home on June 21, 2008. 

Since August 2006, Keshari and Bujduveanu have allegedly procured U.S.-made military aircraft 

parts for buyers in Iran and have illegally shipped the parts to a company in Dubai, UAE, for 

shipment to buyers in Iran. Keshari allegedly received the orders for specific parts by e-mail from 

buyers in Iran. Keshari then requested quotes, usually by e-mail, from Bujduveanu and made 

arrangements with Bujduveanu for the sale and shipment of the parts to a company in Dubai. 

From Dubai, the parts were then shipped on to Iran. Keshari and Bujduveanu are alleged to have 

obtained and illegally shipped to buyers in Iran parts for the CH-53 military helicopter, the F-14 

Tomcat fighter jet, and the AH-1 attack helicopter. Keshari is also alleged to have requested 

quotes for other parts for other military aircraft, including F-4 Phantom aircraft. This 

investigation was conducted by BIS, ICE, and DCIS.

Stolen Military Optics Sold to Hong Kong, Taiwan and Japan via Internet - On June 1, 2009, in 

the Southern District of West Virginia, former U.S. Marines Timothy Oldani and Joseph Oldani 

were ordered to serve five months in prison and pay $52,872 in restitution, and 21 months in 

prison and $72,013 in restitution, respectively, for conspiring to steal military night vision optics 

and illegally export them from the United States. On February 2, 2009, the Oldani brothers 

pleaded guilty. Joseph admitted that while on active duty with the Marines, he stole military 

optics from his station in Georgia and transported them to his brother Timothy in West Virginia, 

where Timothy sold the stolen items to overseas purchasers on the Internet, primarily via eBay. 
89

The pair sold miniature night vision sights and target pointer illuminators via the Internet to 

purchasers in Hong Kong, Taiwan, and Japan. The investigation was conducted by DCIS and

ICE.

Amplifiers & Missile Target Acquisition Technology to China - On May 14, 2009, Joseph 

Piquet, the owner and President of AlphaTronX, a company in Port St. Lucie, Fla., that produces 

electronic components, was sentenced in the Southern District of Florida to 60 months in prison 

followed by two years supervised release. On March 5, 2009, he was convicted of seven counts 

arising from a conspiracy to purchase military electronic components from Northrop Grumman 

Corporation, and to ship them to Hong Kong and the People's Republic of China without first 

obtaining required export licenses under the Arms Export Control Act and the International 

Emergency Economic Powers Act. Among those items involved in the conspiracy were highpower amplifiers designed for use by the U.S. military in early warning radar and missile target 

acquisition systems, as well as low noise amplifiers that have both commercial and military use. 

Piquet was first indicted on June 5, 2008, along with his company, AlphaTronX, Inc, as well as 

Thompson Tam, and Ontime Electronics Technology Limited. Tam is a director of Ontime 

Electronics, an electronics company in China. On March 2, 2009, the Court ordered the dismissal 

of the indictment against AlphaTronX. Tam and Ontime Electronics Technology Limited are 

fugitives. This investigation was conducted by BIS and ICE.

Military Night Vision Goggles to Italy - On May 12, 2009, Rigel Optics, Inc. was sentenced in 

the Southern District of Iowa to pay a $90,000 fine and a $400 special assessment for illegally 

exporting military night vision goggles to Italy. Rigel's owner, Donald Wayne Hatch, was 

sentenced to two years probation and ordered to pay a $5,000 fine for making false statements in 

connection with the illegal export. On July 31, 2008, the defendants pleaded guilty to these 

violations. The defendants were indicted on June 24, 2008 for illegally exporting military night 

vision systems. The case was investigated by ICE and BIS.

Rocket / Space Launch Technical Data to China - On April 7, 2009, Shu Quan-Sheng, a native 

of China, naturalized U.S. citizen and PhD physicist, was sentenced to 51 months in prison for 

illegally exporting space launch technical data and defense services to the People's Republic of 

China (PRC) and offering bribes to Chinese government officials. Shu pleaded guilty on 

November 17, 2008, in the Eastern District of Virginia to a three-count criminal information. He 

was arrested on September 24, 2008. He was the President, Secretary and Treasurer of AMAC 

International, a high-tech company located in Newport News, Va., and with an office in Beijing, 

China. Shu provided the PRC with assistance in the design and development of a cryogenic 

fueling system for space launch vehicles to be used at the heavy payload launch facility located in 

the southern island province of Hainan, PRC. The Hainan facility will house launch vehicles 

designed to send space stations and satellites into orbit, as well as provide support for manned 

space flight and future lunar missions. Shu also illegally exported to the PRC technical data 

related to the design and manufacture of a "Standard 100 M3 Liquid Hydrogen (LH) 2 Tank. In 

addition, Shu offered approximately $189,300 in bribes to government officials with the PRC's 

101 Institute to induce the award of a hydrogen liquefier project to a French company he 

represented. In January 2007, the $4 million hydrogen liquefier project was awarded to the 

French company that Shu represented. This investigation was conducted by the FBI, ICE, BIS 

and DCIS.

Military Aircraft Components to Iran - On April 2, 2009, eleven defendants were indicted in the 

Southern District of Florida on charges of participating in a conspiracy to export U.S.-made 

military aircraft parts to Iran. On April 3, 2009, federal agents arrested defendant Baktash 

Fattahi, an Iranian national and legal U.S. resident, at his residence in Lancaster, Calif. The other 
90

ten defendants charged in the indictment are Amir Hosein Atabaki, an Iranian national; 

Mohammad Javad Mohammad Esmaeil, an Iranian national; Abbas Haider, an Indian citizen 

residing in Dubai; Mohammed Javid Yahya Saboni, an Iranian national residing in Dubai; Reza 

Zahedi Pour, an Iranian national; Mahdi Electronic Trading Co, an Iranian business; Planet 

Commercial Brokerage, a Dubai business; Raht Aseman Co, Ltd, an Iranian business; Sahab 

Phase, an Iranian business; and Sea Speed UAE, a Dubai business. According to the indictment, 

the defendants conspired to and did export 13 different types of military aircraft parts to Iran by 

way of Dubai, United Arab Emirates. Among the aircraft parts the defendants are alleged to have 

obtained and illegally shipped to buyers in Iran are parts for the F-5 ("Tiger") Fighter Jet, the Bell 

AH-1 ("Cobra") Attack Helicopter, the CH-53 Military Helicopter, the F-14 ("Tomcat") Fighter 

Jet, and the UH-1 ("Huey") Military Helicopter. According to the Indictment, defendants in Iran 

sent orders by email to a co-conspirator in Novato, Calif., for specific aircraft parts. The coconspirator in Calif. then requested quotes, usually by e-mail, from another co-conspirator in 

Plantation, Fla., and made arrangements with that co-conspirator in Plantation for the sale and 

shipment of the parts to one of several defendants in Dubai. From Dubai, the parts were then 

shipped on to Iran. On March 10, 2010, Baktash Fattahi pleaded guilty to conspiracy to violate 

the International Emergency Economic Powers Act by exporting military and commercial aircraft 

parts to Iran and was sentenced to 35 months in prison on July 20, 2010. This investigation was 

conducted by ICE, DCIS, Diplomatic Security Service, with assistance from OFAC and State 

Department's Directorate of Defense Trade Controls.

Military Aircraft Parts to Israel - On April 2, 2009, Stuart Wax pleaded guilty in the District of 

Connecticut to a one-count criminal information charging him with making a false statement in 

an export control document. Wax entered the plea both for himself and on behalf of his company, 

M.M.M. Wheels, Inc. In 2003, Wax exported parts used in the F-4 fighter jet to be sent to a 

company in Israel without the required license from State Department. Wax indicated on the 

shipping documents that the box contained "plumbing parts for repair," although he knew the 

contents actually were parts for military aircraft. On September 10, 2009, Wax and M.M.M. 

Wheels, Inc., were each sentenced to one year probation. This investigation was conducted by 

ICE, DCIS, and BIS agents.

Thermal Imaging Cameras to South Korea - On March 25, 2009, David Lee plead guilty in the 

Northern District of Illinois to a one count indictment charging that he illegally exported thermal 

imaging cameras to South Korea without obtaining the required export license. Lee, the owner of 

Lucena Technology, Inc., an export company in Park Ridge, Ill., exported seven thermal imaging 

cameras to South Korea in June 2007 without obtaining the required U.S. Department of 

Commerce export license. Under the terms of the plea agreement, Lee agreed to forfeit $59,500 

which represents the proceeds from the sale of the cameras. Lee was originally indicted on 

December 16, 2008. On June 29, 2009, Lee was sentenced to two years probation and a $3,000 

fine. The investigation was conducted by BIS and U.S. Customs and Border Protection.

Sensitive U.S. Technology to Iranian Missile & Nuclear Entities - On March 20, 2009, Iranian 

national and resident Majid Kakavand was arrested in France pursuant to a provisional U.S. arrest 

warrant issued in the Northern District of California. An April 7, 2009 indictment charges 

Kakavand and two co-defendants, Amir Gasemi and Alex Ramzi, with overseeing an 

international network that allegedly purchased thousands of military and commercial items from 

U.S. companies and illegally exported these goods to Iran via Malaysia. The alleged recipients of 

these goods included two Iranian military entities designated by the United States for their role in 

Iran's nuclear and ballistic missile program. According to court documents, Kakavand served as 

a director of a company in Malaysia called Evertop Services Sdn Bhd, that he and others created 

to procure goods from the United States and Europe for export to Iran. Gasemi was also a 
91

director of Evertop Services, while Ramzi served as the purchasing supervisor. Evertop Services' 

primary customers in Iran were two Iranian military entities, Iran Electronics Industry (IEI), and 

Iran Communication Industries (ICI), both of which were designated in 2008 by the United States 

for their role in Iran's nuclear and ballistic missile programs. Furthermore, IEI was listed by the 

European Union as an entity linked to Iran's proliferation-sensitive nuclear activities or Iran's 

development of nuclear weapon delivery systems. Using Evertop Services, Kakavand and his-codefendants allegedly purchased products for Iran from U.S. companies in several states, including 

California, Alabama, Florida, Washington, and New Jersey. Kakavand has allegedly exported 

more than 30 shipments of goods from the United States to Iran since February 2006. These 

shipments contained electronic and avionic components, including capacitors, spectrometers, 

resistors, sensors, connectors, and airborne antennae. Kakavand allegedly concealed from the 

U.S. companies that the ultimate end-users of these products were in Iran, and at no time did he 

have a license to export or re-export goods to Iran. For example, in one transaction, Kakavand 

allegedly purchased 41,900 radiall connectors from a company in California and, in January 

2008, wired $51,425 to the firm as payment for the goods. The affidavit indicates that these 

goods were exported from the United States to Evertop Services in Malaysia, then re-exported to 

ICI in Iran. In other transactions spelled out in the affidavit, Kakavand used similar techniques to 

illegally export sensors, inductors and other materials to Iran. On May 5, 2010, the U.S. 

extradition request for Kakavand was denied by a French court. Kakavand was released by 

French authorities and returned to Iran. This investigation was conducted by BIS and ICE.

Aircraft Engines and Advanced Surveillance Cameras to Iranian Military - On March 14, 

2009, Hossein Ali Khoshnevisrad, the general manager of Ariasa, AG in Tehran, Iran, and 

Skylife Worldwide Sdn. Bhd, in Kuala Lumpur, Malaysia, was arrested in San Francisco pursuant 

to a sealed criminal complaint charging him with purchasing helicopter engines and advanced 

aerial cameras for fighter bombers from U.S. firms and illegally exporting them to Iran using 

companies in Malaysia, Ireland and the Netherlands. Among the alleged recipients of these U.S. 

goods was an Iranian military firm that has since been designated by the United States for being 

owned or controlled by entities involved in Iran's nuclear and ballistic missile program. The 

criminal complaint, which was filed under seal in the District of Columbia on August 1, 2008, 

charged Khoshnevisrad with two counts of unlawfully exporting U.S. goods to Iran and two 

counts of conspiracy to unlawfully export U.S. goods to Iran in violation of the International 

Emergency Economic Powers Act. According to court documents, from January 2007 through 

December 2007, Khoshnevisrad and Ariasa caused Mac Aviation Group, a trading company in 

Ireland, to purchase 17 model 250 turbo-shaft helicopter engines from Rolls-Royce Corp. in 

Indiana for $4.27 million. Mac Aviation allegedly concealed from Rolls-Royce the end user of 

the engines, and ultimately 15 of these engines were exported from the U.S. to Iran via Malaysia 

or Germany. Among the recipients in Iran was the Iran Aircraft Manufacturing Industrial 

Company, known as HESA, which was designated by the United States for being controlled by 

Iran's Ministry of Defense and Armed Forces Logistics and providing support to the Iranian 

Revolutionary Guard Corps. According to the complaint, Khoshnevisrad and Ariasa also caused 

to be exported to Iran 10 aerial panorama cameras from the United States. These cameras were 

designed for the U.S. Air Force for use on bombers, fighters and surveillance aircraft, including 

the F-4E Phantom fighter bomber, which is currently used by the Iranian military. According to 

the affidavit, in 2006, Khoshnevisrad instructed Aviation Services International, B.V., (ASI) a 

Dutch aviation parts company, to place an order for 10 of these cameras with a U.S. company 

located in Pennsylvania and to ship them to an address in Iran. According to the affidavit, ASI 

ordered the aerial panorama cameras from the Pennsylvania firm, falsely stating that the 

Netherlands would be the final destination for the cameras. Khoshnevisrad ultimately pleaded 

guilty on July 1, 2009, to a two-count information charging him with conspiracy to export goods 

(the Rolls Royce engines) to an embargoed nation and illegally exporting defense articles (aerial 
92

panorama cameras) to Iran. On June 2, 2010, he was sentenced to 15 months in prison for each 

count, to run concurrently. This investigation was conducted by BIS, FBI, ICE and DCIS.

Miniature Unmanned Aerial Vehicle Components to China - On March 12, 2009, a federal 

grand jury in the District of Columbia returned an indictment charging Yaming Nina Qi Hanson, 

her husband Harold Dewitt Hanson (an employee at Walter Reed Army Medical Center), and a 

Maryland company, Arc International, LLC, with illegally exporting miniature Unmanned Aerial 

Vehicle (UAV) Autopilots to a company in the People's Republic of China. The UAV 

components are controlled for export to China for national security reasons. According to court 

documents, beginning in 2007, the Hansons began attempting to acquire the autopilots from a 

Canadian manufacturer in order to re-export them to Xi'an Xiangyu Aviation Technical Group in 

China. Qi Hanson initially represented that the autopilots would be used for a model airplane 

civilian flying club in China. When Canadian company officials questioned the utility of 

autopilots - designed for use on unmanned aircraft - for flying club hobbyists, Qi Hanson claimed 

that autopilots would be used on US aircraft to record thunderstorm and tornado developments 

and ice-pack melting rates in the arctic. On or about August 7, 2008, after having fraudulently 

taken delivery of 20 of these autopilots (valued at $90,000), Qi Hanson boarded a plane in the 

United States bound for Shanghai, and hand-delivered the items to Xi'an Xiangyu Aviation 

Technical Group in China. The Hansons ultimately pleaded guilty on November 13, 2009 to 

felony false statement violations. On February 3, 2010, Harold Dewitt Hanson was sentenced to 

24 months imprisonment, while his wife, Yaming Nina Qi Hanson was sentenced to time served. 

The indictment against Arc International, LLC was dismissed. The investigation was conducted 

by BIS and FBI.

3,500 Military Night Vision Goggles to Iranian Military - On March 6, 2009, Shahrazad Mir 

Gholikhan was sentenced in the Southern District of Florida to 63 months in prison for brokering 

defense articles to Iran and other export violations in connection with an effort by she and her 

husband, Mahmoud Seif, to illegally procure 3,500 sets of Generation III military night vision

goggles from the United States for Iran's military and police forces. Gholikhan was convicted of 

the charges on December 19, 2008. Gholikhan and her husband were first arrested in 2004 in 

Vienna, Austria, after a meeting with undercover law enforcement officials in which they 

received the first sample shipment of U.S. night vision goggles destined for Iran. After her arrest, 

Gholikhan told authorities that she and her husband were not allowed to transport the items from 

Austria to Iran, but that the Iranian Embassy in Austria was to organize the shipment of night 

vision goggles to Iran. Austrian authorities subsequently released the couple and they returned to 

Iran. Seif remains a fugitive. Gholikhan was arrested by U.S. authorities in December 2007 upon 

her arrival in the United States. She later pleaded guilty to one count of conspiracy. However, she 

subsequently withdrew the plea after a dispute over her sentence and represented herself at a new 

trial in 2008, where she was convicted of three of six counts. This investigation was conducted by 

ICE, DCIS, and Austrian law enforcement.

Pump Components to Iran - On February 5, 2009, two German nationals and a German company 

were indicted in the District of Massachusetts for conspiring to illegally export pump parts worth 

more than $200,000 to Iran in violation of the International Emergency Economic Powers Act. 

According to the indictment, Hans Schneider and Christof Schneider conspired with an individual 

in Jordan to obtain pump parts from a U.S. company for centrifugal sulphuric acid and sulphur 

pumps located in Iran. The pump parts would be delivered to Germany and re-exported to Iran by 

the defendants via their company, Schneider Gmbh. The defendants remain fugitives. The case 

was investigated ICE and BIS.
93

Restricted Electronic Components to China - On January 20, 2009, Michael Ming Zhang and 

Policarpo Coronado Gamboa were arrested pursuant to indictments in the Central District of 

California charging them with separate schemes involving the illegal export of controlled U.S. 

electronic items to China and the illegal trafficking of counterfeit electronic components from 

China into the United States. Zhang was the president of J.J. Electronics, a Rancho Cucamonga, 

CA, business, while Gamboa owned and operated Sereton Technology, Inc., a Foothill Ranch, 

CA, business. Zhang allegedly exported to China dual-use electronic items that have uses in U.S. 

Army battle tanks. He also allegedly imported and sold in the United States roughly 4,300 Cisco 

electronic components bearing counterfeit marks from China. Gamboa is charged with conspiring 

with Zhang to import Sony electronic components with counterfeit marks from China for 

distribution in the United States. On July 9, 2009, Gamboa pleaded guilty to one count of the

indictment and was later sentenced to 5 years probation and was ordered to pay $13,600 

restitution to Sony Electronics. On July 6, 2009, Zhang pleaded guilty to count one in each of the 

indictments. He was sentenced on May 17, 2010 to 18 months in prison, 3 years supervised 

release, $200 special assessment and was ordered to pay Sony Electronics $226,072 and Cisco 

Systems, Inc. $5,451. The case was investigated by the FBI, BIS, DCIS, ICE, the U.S. Postal 

Inspection Service, and the Orange County Sheriff's Department, in conjunction with the EAGLE 

Task Force in the Central District of California.

Night Vision Technology to Singapore - On January 15, 2009, Thomas J. Loretz was indicted in 

the District of Massachusetts for illegally exporting defense articles and making false statements 

in connection with the illegal export of sophisticated night vision technology to Singapore. 

Specifically, Loretz was charged with illegally exporting to Singapore hundreds of Imaging 

Grade Micro-Channel Plates and Premium Grade Micro-Channel Plates, which are used for 

military night vision optics. Loretz allegedly submitted false shipper's export documents to the 

government stating that the plates were commercial. Loretz pleaded guilty to four counts of the 

indictment on March 8, 2010. He was sentenced on October 28, 2010 to 2 years probation, 

$20,000 fine and $400 special assessment. The investigation was conducted by ICE.

###