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June 2016 NSD 

WWW.JUSTICE.GOV (202) 514-2007

 

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

TRADE SECRET AND EMBARGO-RELATED CRIMINAL CASES

(January 2010 to the present: updated June 27, 2016)

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 2010. 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.

Firearm Parts to the Republic of Turkey – On June 24, 2016, the Court in the Eastern District of 

Virginia issued Findings of Fact and Conclusions of Law finding Hamza Kolsuz, a citizen of the 

Republic of Turkey, guilty of all three counts in the indictment pending against him. The Court’s 

ruling followed a two-day bench trial on May 18-19, 2016. On March 2, 2016, after having 

previously been charged in a Criminal Complaint, a grand jury in the Eastern District of Virginia 

returned a three-count indictment against Kolsuz, charging him with: (1) conspiring to violate the 

Arms Export Control Act (the “AECA”) and 18 U.S.C. § 554(a), in violation of 18 U.S.C. § 371; 

(2) attempting to export defense articles on the United States Munitions List (“USML”) without a 

license or other written authorization from the United States Department of State’s Directorate of 

Defense Trade Controls (the “DDTC”), in violation of the AECA; and (3) attempting to smuggle 

goods out of the United States, in violation of 18 U.S.C. § 554(a). The charges stemmed from 

Kolsuz’s attempt to export firearms parts—specifically, eighteen handgun barrels, twenty-two 

9mm handgun magazines, four .45 caliber handgun magazines, one .357 caliber handgun 

magazine and one .22 caliber Glock caliber conversion kit—to the Republic of Turkey, and his 

involvement in a years-long conspiracy to export firearms parts to the Republic of 

Turkey. Kolsuz arrived in the United States at Miami International Airport on January 25, 2016 

on a B-2 visitor’s visa. While in Florida, Kolsuz and one of his co-conspirators visited gun stores 

and a gun show where they purchased firearms parts. On February 2, 2016, Kolsuz began his 

return trip to Istanbul, Republic of Turkey by checking in at Miami International Airport for a 

flight that took him to Cleveland Hopkins International Airport. He then checked in for a flight 

that was to take him and his checked luggage through Cleveland Hopkins International Airport 

and Washington Dulles International Airport before embarking for Istanbul, Republic of Turkey 

on Turkish Airlines. When Kolsuz arrived at Dulles, his luggage was searched and the firearms 

parts were discovered. The eighteen handgun barrels, twenty-two 9mm handgun magazines, four 

.45 caliber handgun magazines, one .357 caliber handgun magazine, and one .22 caliber Glock 

caliber conversion kit were and are each defense articles listed on the USML, and a license or 

other written authorization from the DDTC was and is therefore required for the firearms parts to 
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be lawfully exported from the United States. However, Kolsuz and his co-conspirators have 

never registered with the DDTC, or applied to register with the DDTC, to export defense articles 

from the United States, and they have never applied for and have never received any licenses or 

other written authorization from the DDTC to export defense articles from the United States. A 

bench trial was held on May 18, 2016 and May 19, 2016, but a verdict has not yet been 

rendered. This case was investigated by the Department of Homeland Security, Immigration and 

Customs Enforcement, Homeland Security Investigations.

High-Tech Material Used in Missile Production and Nuclear Applications to Iran – On June 14, 

2016, in the Eastern District of New York, Erdal Kuyumcu, the CEO of Global Metallurgy LLC, 

a company based in Woodside, New York, pleaded guilty to one count of conspiring to violate 

the International Emergency Economic Powers Act, in connection with the export of specialty 

metals from the United States to Iran. As detailed in the criminal information to which he 

pleaded guilty and other court filings, Kuyumcu, a U.S. citizen, conspired to export from the 

United States to Iran a metallic powder composed of cobalt and nickel, without having obtained 

the required license from the U.S. Treasury Department’s Office of Foreign Assets Control 

(OFAC). The metallic powder can be used to coat gas turbine components, including turbine 

blades, and can be used in aerospace, missile production and nuclear applications. Such 

specialized metals are closely regulated by the U.S. Department of Commerce to combat nuclear 

proliferation and protect national security, and exporting them without an OFAC license is illegal. 

Kuyumcu and others conspired to obtain over 1,000 pounds of the metallic powder from a U.S.-

based supplier for export to Iran. To hide the true destination of the goods from the U.S. supplier, 

Kuyumcu and a co-conspirator arranged for the metallic powder to be shipped first to Turkey and 

then to Iran. At sentencing, Kuyumcu faces up to 20 years in prison and a $1 million fine. This 

case was investigated by the Commerce Department and the FBI.

Theft Of Valuable Source Code – On June 14, 2016, Jiaqiang Xu was charged in the Southern 

District of New York in a six-count superseding indictment with economic espionage and theft of 

trade secrets, in connection with Xu’s theft of proprietary source code from his former employer, 

with the intent to benefit the National Health and Family Planning Commission of the People’s 

Republic of China. Xu was initially arrested by the FBI on Dec. 7, 2015, and was previously 

charged on Jan. 6, 2016 by indictment with one count of theft of trade secrets. According to court 

documents, from November 2010 to May 2014, Xu worked as a developer for a particular U.S. 

company (the “Victim Company”). As a developer, Xu enjoyed access to certain proprietary 

software (the “Proprietary Software”), as well as that software’s underlying source code (the 

“Proprietary Source Code”). The Proprietary Software is a clustered file system developed and 

marketed by the Victim Company in the U.S. and other countries. A clustered file system 

facilitates faster computer performance by coordinating work among multiple servers. The 

Victim Company takes significant precautions to protect the Proprietary Source Code as a trade 

secret. Among other things, the Proprietary Source Code is stored behind a company firewall and 

can only be accessed by a small subset of the Victim Company’s employees. Before receiving 

Proprietary Source Code access, Victim Company employees must first request and receive 

approval from a particular Victim Company official. Victim Company employees must also 

agree in writing at both the outset and the conclusion of their employment that they will maintain 

the confidentiality of any proprietary information. The Victim Company takes these and other 

precautions in part because the Proprietary Software and the Proprietary Source Code are 

economically valuable, which value depends in part on the Proprietary Source Code’s secrecy. In 

May 2014, Xu voluntarily resigned from the Victim Company. Xu subsequently communicated 

with one undercover law enforcement officer (“UC-1”), who posed as a financial investor aiming 

to start a large-data storage technology company, and another undercover law enforcement officer 

(“UC-2”), who posed as a project manager, working for UC-1. In these communications, Xu 
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discussed his past experience with the Victim Company and indicated that he had experience with 

the Proprietary Software and the Proprietary Source Code. On March 6, 2015, Xu sent UC-1 and 

UC-2 a code, which Xu stated was a sample of Xu’s prior work with the Victim Company. A 

Victim Company employee (“Employee-1”) later confirmed that the code sent by Xu included 

proprietary Victim Company material that related to the Proprietary Source Code. Xu 

subsequently informed UC-2 that Xu was willing to consider providing UC-2’s company with the 

Proprietary Source Code as a platform for UC-2’s company to facilitate the development of UC2’s company’s own data storage system. Xu informed UC-2 that if UC-2 set up several 

computers as a small network, then Xu would remotely install the Proprietary Software so that 

UC-1 and UC-2 could test it and confirm its functionality. In or around early August 2015, the 

FBI arranged for a computer network to be set up, consistent with Xu’s specifications. Files were 

then remotely uploaded to the FBI-arranged computer network (the “Xu Upload”). Thereafter, on 

or about August 26, 2015, Xu and UC-2 confirmed that UC-2 had received the Xu Upload. In 

September 2015, the FBI made the Xu Upload available to a Victim Company employee who has 

expertise regarding the Proprietary Software and the Proprietary Source Code (“Employee-2”). 

Based on Employee-2’s analysis of technical features of the Xu Upload, it appeared to Employee2 that the Xu Upload contained a functioning copy of the Proprietary Software. It further 

appeared to Employee-2 that the Xu Upload had been built by someone with access to the 

Proprietary Source Code who was not working within the Victim Company or otherwise at the 

Victim Company’s direction. On December 7, 2015, Xu met with UC-2 at a hotel in White 

Plains, New York (the “Hotel”). Xu stated, in sum and substance, that Xu had used the 

Proprietary Source Code to make software to sell to customers, that Xu knew the Proprietary 

Source Code to be the product of decades of work on the part of the Victim Company, and that 

Xu had used the Proprietary Source Code to build a copy of the Proprietary Software, which Xu 

had uploaded and installed on the UC Network (i.e., the Xu Upload). Xu also indicated that Xu 

knew the copy of the Proprietary Software that Xu had installed on the UC Network contained 

information identifying the Proprietary Software as the Victim Company’s property, which could 

reveal the fact that the Proprietary Software had been built with the Proprietary Source Code 

without the Victim Company’s authorization. Xu told UC-2 that Xu could take steps to prevent 

detection of the Proprietary Software’s origins – i.e., that it had been built with stolen Proprietary 

Source Code – including writing computer scripts that would modify the Proprietary Source Code 

to conceal its origins. Later on December 7, 2015, Xu met with UC-1 and UC-2 at the Hotel. 

During that meeting, Xu showed UC-2 a copy of what Xu represented to be the Proprietary 

Source Code on Xu’s laptop. Xu noted to UC-2 a portion of the code that indicated it originated 

with the Victim Company as well as the date on which it had been copyrighted. Xu also stated 

that Xu had previously modified the Proprietary Source Code’s command interface to conceal the 

fact that the Proprietary Source Code originated with the Victim Company and identified multiple 

specific customers to whom Xu had previously provided the Proprietary Software using Xu’s 

stolen copy of the Proprietary Source Code. This case was investigated by the FBI.

Tactical Equipment to Insurgent Groups in Syria – On June 10, 2016, in the Eastern District of 

Virginia, Amin al-Baroudi, a Syrian-born naturalized U.S. citizen, formerly of Irvine, California, 

was sentenced to 32 months in prison for conspiring to export U.S.-origin goods from the United 

States to Syria in violation of sanctions imposed on Syria by the U.S. government. Baroudi 

pleaded guilty on Jan. 15, 2016. According to court documents, Baroudi admitted that from at 

least December 2011 through March 2013, he and his co-conspirators exported U.S. tactical 

equipment to Syria for the purpose of supplying and arming Ahrar al-Sham and other insurgent 

groups in Syria whose stated goal is to overthrow the Assad government and install an Islamic 

state. Ahrar al-Sham frequently fights alongside Jabhat al-Nusrah, which has been designated by 

the U.S. State Department as a foreign terrorist organization and operates as al-Qaeda’s official 

branch in Syria. According to court documents, Baroudi and his co-conspirators purchased tens 
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of thousands of dollars-worth of goods from companies and vendors in the United States, 

consisting largely of tactical equipment such as sniper rifle scopes, night vision rifle scopes, night 

vision goggles, laser bore sighters, speed loaders and bullet proof vests. Baroudi and his coconspirators traveled with the goods aboard commercial flights to Turkey and then transported 

the goods into Syria or provided them to others for transport. Baroudi made two such trips in 

February and March of 2013. This case was investigated by the FBI, DOC OEE, ICE HSI, 

California Highway Patrol; the Irvine Police Department; the Orange County, California, 

Sheriff’s Department; and the Regional Computer Forensics Laboratory in Orange County 

provided significant assistance.

Systems and Components for Marine Submersible Vehicles to China – On Jun. 10, 2016, Amin 

Yu pleaded guilty in the Middle District of Florida to acting in the United States as an illegal 

agent of a foreign government without prior notification to the Attorney General and conspiring 

to commit international money laundering. According to the plea agreement, from at least 2002 

until February 2014, at the direction of co-conspirators working for Harbin Engineering 

University (HEU), a state-owned entity in the People’s Republic of China, Yu obtained systems 

and components for marine submersible vehicles from companies in the United States. She then 

illegally exported those items to the PRC for use by her co-conspirators in the development of 

marine submersible vehicles – unmanned underwater vehicles, remotely operated vehicles and 

autonomous underwater vehicles – for HEU and other state-controlled entities. Yu illegally 

exported items by failing to file electronic export information (EEI), as required by U.S. law, and 

by filing false EEI. In particular, Yu completed and caused the completion of export-related 

documents in which she significantly undervalued the items that she had exported and provided 

false end user information for those items. Previously, on Apr. 21, 2016, an 18-count superseding 

indictment was unsealed in the Middle District of Florida charging Yu with acting as an illegal 

agent of a foreign government in the United States without prior notification to the Attorney 

General, conspiring to defraud the United States and to commit offenses against the United 

States, committing unlawful export information activities, smuggling goods from the United 

States, conspiring to and committing international money laundering and making false statements 

to the U.S. Citizenship and Immigration Services. This case was investigated by the FBI, U.S. 

Immigration and Customs Enforcement’s Homeland Security Investigations, the Internal Revenue 

Service-Criminal Investigation and the Naval Criminal Investigative Service. 

Unmanned Aerial Vehicle to China – On June 10, 2016, Wenxia Man, aka Wency Man of San 

Diego, was convicted by a federal jury in the Southern District of Florida of conspiring to export 

and cause the export of fighter jet engines, an unmanned aerial vehicle – commonly known as a 

drone – and related technical data to the People’s Republic of China, in violation of the Arms 

Export Control Act. According to evidence presented at trial, between approximately March 

2011 and June 2013, Man conspired with Xinsheng Zhang, who was located in China, to illegally 

acquire and export to China defense articles including: Pratt & Whitney F135-PW-100 engines 

used in the F-35 Joint Strike Fighter; Pratt & Whitney F119-PW-100 turbofan engines used in the 

F-22 Raptor fighter jet; General Electric F110-GE-132 engines designed for the F-16 fighter jet; 

the General Atomics MQ-9 Reaper/Predator B Unmanned Aerial Vehicle, capable of firing 

Hellfire Missiles; and technical data for each of these defense articles. During the course of the 

investigation, when talking to an HSI undercover agent, Man referred to Zhang, as a “technology 

spy” who worked on behalf of the Chinese military to copy items obtained from other countries 

and stated that he was particularly interested in stealth technology. Man faces a statutory 

maximum penalty of 20 years in prison. Zhang remains in China and has yet to be arrested. The 

investigation was conducted by ICE-HSI and DCIS.
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High-Tech Electronic Components to Iran – On May 23, 2016, in the Southern District of New 

York, Ali Reza Parsa, a Canadian-Iranian dual citizen and resident of Canada, was sentenced to 

three years in prison for his participation in a conspiracy to violate the International Emergency 

Economic Powers Act (IEEPA) and the Iranian Transactions and Sanctions Regulations 

(ITSR). Parsa was arrested in October 2014 following an investigation by the FBI and U.S. 

Department of Commerce’s Bureau of Industry and Security (BIS). He pleaded guilty on Jan. 20, 

2016. According to court documents, between approximately 2009 and 2015, Parsa conspired to 

obtain high-tech electronic components from American companies for transshipment to Iran and 

other countries for clients of Parsa’s procurement company in Iran, Tavan Payesh Mad, in 

violation of U.S. economic sanctions. To accomplish this, Parsa used his Canadian company, 

Metal PM, to place orders with U.S. suppliers and typically had the parts shipped to him in 

Canada or to a freight forwarder located in the United Arab Emirates, and then shipped from 

these locations to Iran or to the location of his Iranian company’s client. Parsa provided the U.S. 

companies with false destination and end-user information about the components in order to 

conceal the illegality of these transactions. Parsa’s criminal scheme targeted numerous American 

technology companies. The components that Parsa attempted to procure included cryogenic 

accelerometers, which are sensitive components that measure acceleration at very low 

temperatures. Cryogenic accelerators have both commercial and military uses, including in 

applications related to ballistic missile propellants and in aerospace components such as liquidfuel rocket engines. In addition, following his arrest and while incarcerated, Parsa continued to 

violate the IEEPA and the ITSR by conducting business for Metal PM and Tavan Payesh Mad, 

including by ordering parts from German and Brazilian companies for Iranian customers. Parsa 

subsequently directed a relative to delete email evidence of his ongoing business transactions 

while in jail and emphasized the need for secrecy in their dealings. Neither Parsa nor any other 

individual or entity involved in transactions that gave rise to his conviction applied for or 

obtained a license from the U.S. Department of the Treasury’s Office of Foreign Assets Control 

for the transactions. This case was investigated by the FBI and Department of Commerce BIS.

Production and Development of Nuclear Material for China – On April 14, 2016, in the Eastern 

District of Tennessee, a two-count indictment was unsealed charging Szuhsiung Ho, aka Allen 

Ho, a citizen of the United States; China General Nuclear Power Company (CGNPC), formerly 

known as the China Guangdong Nuclear Power Company and Energy Technology International 

(ETI), for conspiracy to unlawfully engage and participate in the production and development of 

special nuclear material outside the United States, without the required authorization from the 

U.S. Department of Energy. This authorization is required by U.S. law and is robustly observed 

through frequent legal U.S.-China civil nuclear cooperation. Ho was also charged with conspiracy 

to act in the United States as an agent of a foreign government. According to the indictment, Ho 

is a nuclear engineer employed by CGNPC as a senior advisor and is also the owner and president 

of ETI. Born in China, he is a naturalized U.S. citizen with dual residency in Delaware and China. 

CGNPC, which is owned by China’s State-Owned Assets Supervision and Administration 

Commission of the State Council, is the largest nuclear power company in China and specializes 

in the development and manufacture of nuclear reactors. ETI is a Delaware corporation 

headquartered in Ho’s home in Wilmington, Delaware. According to allegations in the 

indictment, which was returned on April 5, 2016, beginning in 1997 and continuing through April 

2016, Ho, CGNPC and ETI allegedly conspired with others to engage and participate in the 

development and production of special nuclear material in China, with the intent to secure an 

advantage to China and without specific authorization to do so from the U.S. Secretary of Energy, 

as required by law. In particular, the defendants allegedly sought technical assistance related to, 

among other things, CGNPC's Small Modular Reactor Program; CGNPC's Advanced Fuel 

Assembly Program; CGNPC's Fixed In-Core Detector System; and verification and validation of 

nuclear reactor-related computer codes. The indictment further alleges that Ho, under the 
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direction of CGNPC, identified, recruited and executed contracts with U.S.-based experts from 

the civil nuclear industry who provided technical assistance related to the development and 

production of special nuclear material for CGNPC in China. Ho and CGNPC also allegedly 

facilitated the travel to China and payments to the U.S.-based experts in exchange for their 

services. The indictment further alleges that during this same period of time, Ho conspired with 

others to knowingly act as an agent of China without prior notification to the Attorney General, as 

required by law. On or about Oct. 4, 2009, Ho allegedly told experts who he was attempting to 

recruit that, “China has the budget to spend,” and that he needed assistance so that, “China will be 

able to design their Nuclear Instrumentation System independently and manufactur[e] them 

independently after the project is complete.” In further correspondence with nuclear experts in the 

United States, Ho made clear that he was charged with obtaining necessary expertise from the 

United States at the direction of the CGNPC and the China Nuclear Power Technology Research 

Institute, a subsidiary of CGNPC, and that he was to do so surreptitiously. If convicted, the 

charge of conspiracy to unlawfully engage and participate in the production and development of 

special nuclear material outside the United States carries a maximum sentence of life in prison 

and a $250,000 fine. The charge of conspiring to act in the United States as an agent of a foreign 

government carries a maximum sentence of 10 years in prison along with fines and supervised 

release. The case was investigated by the FBI, the Tennessee Valley Authority-Office of the 

Inspector General, the Department of Energy-National Nuclear Security Administration and the 

U.S. Immigration and Customs Enforcement Homeland Security Investigations, with assistance 

from other agencies.

Defense Materials to India – On Apr. 14, 2016 in the District of New Jersey, Hannah Robert, the 

owner of two New Jersey defense contracting businesses, was sentenced to 57 months in prison 

for conspiring to send sensitive military technical data to India. Previously, on Apr. 1, 2015, 

Robert pleaded guilty to one count of conspiracy to violate the Arms Export Control Act (22 

U.S.C. § 2778). On Oct. 28, 2013, Robert was arraigned for allegedly transmitting military 

technical drawings to India without first obtaining a license from the U.S. Department of State, in 

violation of U.S. export laws. She was indicted by a federal grand jury on Oct. 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 Sep. 2012, Robert 

opened a second defense-contracting 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 defense hardware items and 

spare parts in India. From Jun. 2010 to Dec. 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 
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State for this conduct. On Aug. 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 Oct. 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., 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 Jun. 25, 2012, R.P. emailed 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. This 

case was investigated by DoD, DCIS, DHS HSI, Counter Proliferation Investigations.

High-Grade Carbon Fiber to China – On Apr. 13, 2016, Fuyi Sun, a/k/a “Frank,” a citizen of the 

People’s Republic of China, was arrested in the Southern District of New York in connection 

with a scheme to illegally export to China, without a license, high-grade carbon fiber that is used 

primarily in aerospace and military applications. Sun was arrested after traveling to New York to 

meet with undercover agents (UCs) in an effort to obtain the specialized fiber, which – due to its 

military and aerospace applications – requires an export license for export to China. The three 

count Complaint that was filed on Apr. 13, 2016, charges Sun with: Count One – attempt to 

violate the International Emergency Economic Powers Act (“IEEPA”); Count Two – conspiracy 

to violate IEEPA; and Count Three – attempt to smuggle goods from the United 

States. According to the allegations in the Complaint, Sun attempted for years to acquire highgrade carbon fiber for illegal export to China. After traveling to New York from China to finalize 

the deal, Sun allegedly told the UCs that the carbon fiber he sought was headed to the Chinese 

military. He then paid tens of thousands of dollars in cash to purchase two cases of it. To avoid 

law enforcement detection, Sun allegedly directed the UCs to ship the carbon fiber in unmarked 

boxes and to falsify the shipping documents regarding the contents of the boxes. According to 

the Complaint, since approximately 2011, Sun has attempted to acquire extremely high-grade 

carbon fiber, including Toray type M60JB-3000-50B carbon fiber (“M60 Carbon Fiber”). M60 

Carbon Fiber has applications in aerospace technologies, unmanned aerial vehicles (commonly 

known as “drones”) and other government defense applications. Accordingly, M60 Carbon Fiber 

is strictly controlled – including that it requires a license for export to China – for nuclear nonproliferation and anti-terrorism reasons. In furtherance of his attempts to illegally export M60 

Carbon Fiber from the United States to China without a license, Sun contacted what he believed 

was a distributor of carbon fiber – but which was, in fact, an undercover entity created by HSI 

and “staffed” by HSI UCs. Sun inquired about purchasing the M60 Carbon Fiber without the 

required license. In the course of his years-long communications with the UCs and the UC 

Company, Sun repeatedly suggested various security measures that he believed would protect 

them from “U.S. intelligence.” Among other such measures, at one point, Sun instructed the UCs 

to use the term “banana” instead of “carbon fiber” in their communications. Consequently, soon 

thereafter he inquired about purchasing 450 kilograms of “banana” for more than $62,000. In 

order to avoid detection, Sun also suggested removing the identifying barcodes for the M60 

Carbon Fiber, prior to transshipment, and further suggested that they identify the M60 Carbon 
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Fiber as “acrylic fiber” in customs documents. On or about Apr. 11, 2016, Sun traveled from 

China to New York for the purpose of purchasing M60 Carbon Fiber from the UC 

Company. During meetings with the UCs, on or about Apr. 11 and 12, 2016, among other things, 

Sun repeatedly suggested that the Chinese military was the ultimate end-user for the M60 Carbon 

Fiber he sought to acquire from the UC Company. Sun claimed to have personally worked in the 

Chinese missile program. Sun also asserted that he maintained a close relationship with the 

Chinese military, had a sophisticated understanding of the Chinese military’s need for carbon 

fiber, and suggested that he would be supplying the M60 Carbon Fiber to the Chinese military or 

to institutions closely associated with it. On or about Apr. 12, 2016, Sun agreed to purchase two 

cases of M60 Carbon Fiber from the UC Company. Sun paid the UCs $23,000 in cash for the 

carbon fiber. He also paid an additional $2,000 to the UCs as compensation for the risk he 

believed they were taking to illegally export the carbon fiber to China without a license. This 

investigation was conducted by DOC, HSI, and DCIS.

Components for IEDs to Iran and Iraq – On Apr. 4, 2016, Lim Yong Nam aka Steven Lim, a 

citizen of Singapore, made his initial court appearance in the District of Columbia after being 

extradited from Indonesia to stand trial on charges of taking part in a conspiracy that allegedly 

caused thousands of radio frequency modules to be illegally exported from the United States to 

Iran. Lim had been detained in Indonesia since Oct. 2014 in connection with a U.S. request for 

extradition. Prosecutors in the District of Columbia unsealed a Sep. 15, 2010 superseding 

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 Oct. 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 Jun. 2007 and Feb. 

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, Dec. 2008, Apr. 2009, and Jul. 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 Iranian 

procurement agent who has been indicted in the United States for illegally exporting goods to 
9

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 Oct. 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 Feb. 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 Aug. 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. On Dec. 21, 2012, Seng and Benson made their initial court appearances in the 

District of Columbia after being extradited from Singapore. On Jun. 26, 2013, Seng and Benson 

pleaded guilty for their roles in a conspiracy to defraud the United States and were sentenced on

Sep. 20, 2013, to 37 months and 34 months imprisonment, respectively. This investigation was 

conducted by ICE, FBI and Department of Commerce's BIS.

Sensitive Military and Export Controlled Data to China – On Mar. 23, 2016, in the Central 

District of California, a Chinese national and resident of the People’s Republic of China, pleaded 

guilty to participating in a years-long conspiracy to hack into the computer networks of major 

U.S. defense contractors, steal sensitive military and export-controlled data and send the stolen 

data to China. A criminal complaint filed in 2014 and subsequent indictments filed in Los 

Angeles charged Su Bin, also known as Stephen Su and Stephen Subin, a China-based 

businessman in the aviation and aerospace fields, for his role in the criminal conspiracy to steal 

military technical data, including data relating to the C-17 strategic transport aircraft and certain 

fighter jets produced for the U.S. military. Su was initially arrested in Canada in Jul. 2014 on a

warrant issued in relation to this case. Su ultimately waived extradition and consented to be 

conveyed to the United States in Feb. 2016. In the plea agreement, Su admitted to conspiring 

with two persons in China from Oct. 2008 to Mar. 2014 to gain unauthorized access to protected 

computer networks in the United States, including computers belonging to the Boeing Company 

in Orange County, California, to obtain sensitive military information and to export that 

information illegally from the United States to China. As part of the conspiracy, Su would e-mail 

the co-conspirators with guidance regarding what persons, companies and technologies to target 

during their computer intrusions. One of Su’s co-conspirators would then gain access to 

information residing on computers of U.S. companies and email Su directory file listings and 

folders showing the data that the co-conspirator had been able to access. Su then directed his coconspirator as to which files and folders his co-conspirator should steal. Once the co-conspirator 

stole the data, including by using techniques to avoid detection when hacking the victim 

computers, Su translated the contents of certain stolen data from English into Chinese. In 

addition, Su and his co-conspirators each wrote, revised and emailed reports about the 

information and technology they had acquired by their hacking activities, including its value, to 

the final beneficiaries of their hacking activities. Su’s plea agreement makes clear that the 

information he and his co-conspirators intentionally stole included data listed on the U.S. 

Munitions List contained in the International Traffic in Arms Regulations. Su also admitted that 
10

he engaged in the crime for the purpose of financial gain and specifically sought to profit from 

selling the data the he and his co-conspirators illegally acquired. This case was investigated by 

the FBI, U.S. Air Force’s Office of Special Investigations, OIA and NSD CES.

Sanctions Violations to Aid the Government of Iran – On Mar. 21, 2016, an indictment was 

unsealed in the Southern District of New York against Reza Zarrab, aka Riza Sarraf, a resident of 

Turkey and dual citizen of Turkey and Iran; Camelia Jamshidy, aka Kamelia Jamshidy, a citizen 

of Iran; and Hossein Najafzadeh, a citizen of Iran, for engaging in hundreds of millions of dollarsworth of transactions on behalf of the government of Iran and other Iranian entities, which were 

barred by U.S. sanctions, laundering the proceeds of those illegal transactions and defrauding 

several financial institutions by concealing the true nature of these transactions. Zarrab was 

arrested on Mar. 19, 2016, and had his initial court appearance in Miami, Florida, on Mar. 21, 

2016. Jamshidy and Najafzadeh remain at large. According to the allegations contained in the 

indictment, beginning in 1979, the U.S. President found that the situation in Iran constituted an 

unusual and extraordinary threat to the national security, foreign policy and economy of the 

United States and declared a national emergency to deal with the threat. Consistent with that 

designation, the United States has instituted a host of economic sanctions against Iran and Iranian 

entities pursuant to the International Emergency Economic Powers Act (IEEPA). This sanctions 

regime prohibits, among other things, financial transactions involving the United States or United 

States persons that are intended for the government or Iran, or specified Iranian-related entities. 

According to court documents, between 2010 and 2015, Zarrab, Jamshidy and Najafzadeh 

conspired to conduct international financial transactions on behalf of and for the benefit of, 

among others, Iranian businesses, the Iranian government and entities owned or controlled by the 

Iranian government. Among the beneficiaries of these schemes were: Bank Mellat, an Iranian 

government-owned bank designated, during the time of the charged offenses, by the U.S. 

Department of the Treasury’s Office of Foreign Assets Control (OFAC) as a Specially 

Designated National (SDN) under the Iranian Transactions and Sanctions Regulations, the Iranian 

Financial Sanctions Regulations and the Weapons of Mass Destruction Proliferators Sanctions 

Regulations; Mellat Exchange, an Iranian money services business owned and controlled by Bank 

Mellat; the National Iranian Oil Company (NIOC), identified during the time of the charged 

offenses by OFAC as an agent or affiliate of Iran’s Islamic Revolutionary Guard Corp (IRGC); 

the Naftiran Intertrade Company Ltd. (NICO), Naftiran Intertrade Company Sarl (NICO Sarl) and 

Hong Kong Intertrade Company (KHICO), companies located in the United Kingdom, 

Switzerland and Hong Kong, respectively, that were acting on behalf of NIOC; and the MAPNA 

Group, an Iranian construction and power plant company. Bank Mellat, NIOC, NICO Sarl, 

NICO and HKICO are no longer designated as SDNs and NIOC is no longer identified as an 

agent or affiliate of the IRGC, though these entities remain “blocked parties,” with whom U.S. 

persons continue to be prohibited generally from engaging in unlicensed transactions or dealings. 

The scheme was part of an intentional effort to assist the government of Iran in evading the 

effects of United States and international economic sanctions. For example, on or about Dec. 3, 

2011, Zarrab and Najafzadeh received a draft letter in Farsi prepared for Zarrab’s signature and 

addressed to the general manager of the Central Bank of Iran. The letter stated, in part, that “[t]he 

role of the Supreme Leader and the esteemed officials and employees of Markazi Bank [the 

Central Bank of Iran] play against the sanctions, wisely neutralizes the sanctions and even turns 

them into opportunities by using specialized methods.” The letter goes on to state, in part, “[i]t is 

not secret that the trend is moving towards intensifying and increasing the sanctions, and since the 

wise leader of the Islamic Revolution of Iran has announced this to be the year of the Economic 

Jihad, the Zarrab family, which has had a half a century of experience in foreign exchange, . . . 

considers it to be our national and moral duty to declare our willingness to participate in any kind 

of cooperation in order to implement monetary and foreign exchange anti-sanction policies . . . .” 

Zarrab, Jamshidy, Najafzadeh and their co-conspirators used an international network of 
11

companies located in Iran, Turkey and elsewhere to conceal from U.S. banks, OFAC and others 

that the transactions were on behalf of and for the benefit of Iranian entities. This network of 

companies includes Royal Holding A.S., a holding company in Turkey; Durak Doviz Exchange, a 

money services business in Turkey; Al Nafees Exchange, a money services business; Royal 

Emerald Investments; Asi Kiymetli Madenler Turizm Otom, a company located in Turkey; ECB 

Kuyumculuk Ic Vedis Sanayi Ticaret Limited Sirketi, a company located in Turkey; and Gunes 

General Trading LLC; and others. As a result of this scheme, the co-conspirators induced U.S. 

banks to unknowingly process international financial transactions in violation of the IEEPA. The 

case was investigated by the FBI.

Sanctions Violations to Aid Iran – On March 3, 2016, the Ahmad Sheikhzadeh, a naturalized 

U.S. citizen who was born in Iran, was arrested in New York, NY pursuant to an arrest warrant 

issued upon a superseding indictment charging him with (a) five counts of aiding and assisting in 

the preparation of false individual income tax returns, in violation of 26 U.S.C. § 7206(2); (b) one 

count of conspiracy to violate the International Emergency Economic Powers Act (IEEPA), in 

violation of 50, U.S.C. § 1705; and (c) one count of money laundering, in violation of 18 U.S.C. 

§ 1957(a), et seq. Sheikhzadeh has worked as a long-term consultant to the Government of 

Iran’s Permanent Mission to the United Nations (IMUN) and has received a cash salary from the 

IMUN. The tax charges relate to under-reporting of the defendant’s IMUN income on his 

personal income tax returns. Distinct from his work at the IMUN, Sheikhzadeh was charged with 

conducting money remitting services for two co-conspirators to facilitate their desire to make 

investments in Iran, without obtaining any license from the Department of Treasury’s Office of 

Foreign Assets Control (OFAC) for such activity, in violation of the Iranian Transactions and 

Sanctions Regulations (ITSR), 31 C.F.R. Part 560 and IEEPA. Sheikhzadeh is also charged with 

laundering the proceeds of his IEEPA conspiracy. This case was investigated by the FBI.

Technology Equipment to China – On Mar. 2, 2016, Louis Brothers was sentenced in the 

Eastern District of Kentucky to 93 months in prison for illegally exporting sophisticated 

technology equipment to the People’s Republic of China (PRC) and concealing the unlawful 

proceeds. The sentence also includes a monetary judgment of $1.1 million. Brothers, a former 

president and CEO of Valley Forge Composite Technologies, pleaded guilty to the offenses in 

Jul. 2015. He admitted that from 2009 until 2013, he unlawfully exported microcircuits to the 

PRC. Under federal law, anyone exporting a defense article, including microcircuits, to the PRC 

must obtain the permission of the Department of State for the purposes of maintaining national 

security. According to his plea agreement, Brothers intentionally avoided notifying the 

Department of State about his activity and labeled his shipments as “computer parts” in order to 

conceal the true identity of the items. Brothers further admitted that he falsified paperwork to 

make it appear that the proceeds he received from his business with the PRC were actually profits 

from a business he owned in Kentucky. The investigation was conducted by the FBI and ICE 

HSI.

Night Vision Devices to China – On Feb. 29, 2016, Song Il Kim, aka Kim Song Il was sentenced 

in the District of Utah to 40 months imprisonment, 36 months supervised release and $100 special 

assessment after pleading guilty on Dec. 9, 2015 to violating the Arms Export Control Act. Kim 

attempted to export from the United States to China night vision devices without first obtaining a 

license from the State Department.

U.S. Military Technology to China – On February 22, 2016, in the District of Connecticut, Jiang 

Yan, 33, of Shenzen, China, pleaded guilty to charges stemming from his having attempted to 
12

conduct a purchase and unlicensed export to China, of sophisticated, export-restricted integrated 

circuits used in military applications. According to court documents and statements made in 

court, Yan operated a business in China that had sold refurbished integrated circuits (“ICs”) to a 

U.S. source. In the summer of 2015, a customer in China asked Yan to locate and purchase 

several advanced ICs made by Xilinx Corp., which had military applications, including radiation 

tolerance for uses in space. Yan then asked the U.S. source to locate the Xilinx ICs. The U.S. 

source explained that the ICs cannot be shipped outside the U.S. without an export license, but 

Yan still wished to make the purchase. When the U.S. source expressed concern that the desired 

ICs would have to be stolen from military inventory, Yan proposed to supply the U.S. source with 

“fake” ICs that “look the same,” to replace the ones to be stolen from the military. In November 

2015, a company affiliated with a second individual shipped from China to the U.S. source, two 

packages containing a total of eight counterfeit ICs, each bearing a counterfeit Xilinx brand label. 

After further discussions between Yan and the U.S. source, Yan, the second individual, and a 

third individual flew together from China to the U.S. in early December 2015 to complete the 

Xilinx ICs purchase. On December 10, 2015, Yan and the two individuals drove to a location 

near Route 95 in Milford, Connecticut, where they planned to meet the U.S. source, make 

payment, and take custody of the Xilinx ICs. Federal investigating agents arrested all three at the 

meeting location. Yan pled guilty both to conspiracy to traffic in counterfeit military equipment, 

and to attempted, unlicensed export of advanced, export-restricted electronic equipment. This 

investigation was conducted by Defense Criminal Investigative Service, the Department of 

Homeland Security, the Department of Commerce, the Federal Bureau of Investigation, and the 

Air Force Office of Special Investigations. 

Firearms and Ammunition to Ghana – On Feb. 16, 2016, in the Western District of North 

Carolina, a nine count indictment was returned against Richmond Akoto Attah charging him with 

one count of violating the Arms Export Control Act (AECA), one count of illegal firearms 

dealing, two counts of smuggling goods from the United States and four counts of making false 

statements to a firearms dealer. According to allegations contained in the indictment, beginning 

in at least 2013 and continuing to the present, Attah purchased numerous firearms and 

ammunition he intended to smuggle and illegally export to Ghana, West Africa. The indictment 

alleges that Attah obtained the firearms by misstating on the required federal forms that he was 

the actual buyer and transferee of the firearms. According to the indictment, Attah is not a 

federally licensed firearms dealer and does not possess a license to export firearms or ammunition 

to Ghana or any other country. According to allegations in the indictment, from on or about Sep.

2013 to Dec. 2015, Attah purchased approximately 63 firearms and 3,500 rounds of ammunition 

from various stores, Internet vendors and at gun shows. On or about Sep. 4, 2015, Attah travelled 

from Charlotte to Ghana, returning on Oct. 10, 2015. According to the charges, during his return 

trip Attah hid $30,100 dollars in his luggage, falsely declaring on his customs paperwork that he 

was only bringing $350 back into the United States. The indictment also alleges that from on or 

about Nov. 2015 to Dec. 13, 2015, Attah purchased approximately 22 firearms and ammunition 

from dealers in North Carolina and online. Attah then hid 27 firearms, including semi-automatic 

pistols and revolvers, inside a washing machine and a dryer, and 3,500 rounds of ammunition 

inside a barrel. The indictment alleges that Attah placed the washer, dryer, and barrel inside a 

shipping container and attempted to have it shipped from Charlotte to Ghana. The indictment 

alleges that U.S. Customs officers recovered the firearms and ammunition before it was shipped 

outside the United States. This case was investigated by ATF, FBI, ICE HSI and CBP.

Theft of Trade Secrets of Inbred Corn Seeds to China – On Jan. 27, 2016, Mo Hailong, aka 

Robert Mo, 46, pleaded guilty in the Southern District of Iowa to conspiracy to steal trade secrets. 

According to the plea agreement, Hailong admitted to participating in a long-term conspiracy to 

steal trade secrets from DuPont Pioneer and Monsanto. Hailong further admitted to participating 
13

in the theft of inbred – or parent – corn seeds from fields in the Southern District of Iowa for the 

purpose of transporting those seeds to China. The stolen inbred seeds constitute the valuable 

intellectual property of DuPont Pioneer and Monsanto. During the conspiracy, Hailong was 

employed as director of international business of the Beijing Dabeinong Technology Group 

Company, a Chinese conglomerate with a corn seed subsidiary company, Kings Nower 

Seed. Hailong is a Chinese national who became a lawful permanent resident of the United 

States pursuant to an H-1B visa. The remaining codefendants include Li Shaoming, Wang Lei, 

Wang Hong Wei, Ye Jian, Lin Yong, and Mo Yun. The investigation was initiated when DuPont 

Pioneer security staff detected suspicious activity and alerted the FBI. DuPont Pioneer and 

Monsanto have fully cooperated throughout the investigation. The case is being investigated by 

the FBI.

Pressure Transducers to Iran – On Jan. 27, 2016, Sihai Cheng, a citizen of the People’s 

Republic of China (PRC), was sentenced in the District of Massachusetts to nine years 

imprisonment and $600 special assessment after pleading guilty on Dec. 18, 2015, to two counts 

of conspiring to commit export violations and smuggle goods from the U.S. to Iran and four 

counts of illegally exporting U.S. manufactured pressure transducers to Iran. Previously, on Dec. 

5, 2014, Cheng 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 Nov. 2005 and 2012, Cheng supplied thousands of parts that have 

nuclear applications, including U.S.-origin goods, to Eyvaz, an Iranian company 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 Feb. 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) 
14

Homeland Security Investigations (HSI) and the Department of Commerce's Office of Export 

Enforcement.

Military Aircraft Components to UAE, Thailand – On Jan. 15, 2016, John Nakkashian was 

sentenced in the Central District of California to 2 years’ probation, $100 special assessment, and 

a fine of $1,000 after previously pleading guilty on Aug. 28, 2014 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 in the 

Central District of California on Jul. 15, 2008. The company was sentenced on Jul. 17, 2008 and 

ordered 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 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 a military gyroscope to Thailand. Nakkashian was arrested on Jun.

16, 2014 after fleeing the country during the investigation. The investigation was conducted by 

DCIS and ICE. 

Theft of Trade Secrets – On Dec. 9, 2015 in the Middle District of North Carolina, Dr. Lin 

Cheng, an American citizen, pled guilty to Count 7 of a Superseding Indictment charging Dr. 

Cheng with possession of a stolen trade secret. Dr. Cheng was employed by Cree, Inc. from Nov. 

2008 to Oct. 2014 as a Scientist. Specifically, Dr. Cheng was the engineering manager for Cree’s 

fourth generation of MOSFET technology. On Sep. 4, 2014, Cree informed the FBI that on Aug. 

27, 2014, Dr. Cheng emailed a file containing Cree’s proprietary information from her work 

email at Cree to a Gmail account. The file contained the step-by-step process Cree uses to 

manufacture MOSFET technology. Cree determined that the proprietary and confidential files 

which were removed by Dr. Cheng from the control of Cree would cause both financial damage 

and technological loss to Cree. Cree estimated that the development cost for information 

contained in the file would exceed approximately 61 million dollars. Dr. Cheng also signed a 

contract to provide consulting services to another company interested in developing silicon 

carbide MOSFETs without consulting with the Cree’s legal department. The Gmail account that 

Dr. Cheng forwarded Cree files to was an email account used by Dr. Cheng as a repository for 

Cree proprietary information forwarded from Dr. Cheng’s work email account and used to 

communicate with the company that she provided consulting services. This case was investigated 

by FBI and Department of Energy, Office of Inspector General.

Military Technical Drawings Downloaded/Exported Outside of the U.S. – On Dec. 8, 2015, in 

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

Jersey defense contracting businesses was sentenced to time served, Special Assessment of $100, 

and Restitution in the amount of $347,240, after pleading guilty on Aug. 27, 2015 to a one-count 

Information charging him with committing mail fraud. Previously, on Sep. 13, 2014, Calik 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 
15

United States without prior approval from the U.S. Department of State. According to the 

complaint, starting in Nov. 2009, Calik was the co-owner 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 defense-contracting 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 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 exportcontrolled 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.

 

Sniper Rifles to Belarus – On Dec. 2, 2015, in the District of Utah, a federal grand jury returned 

an indictment charging Kolar Rahman Anees Ur Rahman, age 44, who was born in India and 

lives in the United Arab Emirates, with violations of federal law in connection with alleged 

efforts to purchase 89 Sako .308 caliber sniper rifles and have them exported from the United 

States to Belarus. The charges in the four-count indictment include conspiracy to commit an 

offense against the United States, a violation of the Arms Export Control Act, smuggling goods 

from the United States, and money laundering. Rahman was arrested in early Nov. in Chicago on 

a complaint filed in Utah. Following a removal proceeding in Chicago, he is being transferred to 

Salt Lake City by the U.S. Marshals Service. According to the indictment, the Arms Export 

Control Act authorizes the President of the United States to control the export of defense articles 

and defense services from the United States. Unless a specific exception applies, the Act provides 

that no defense articles or defense services may be exported without a license for such export. It 

is the policy of the United States to deny licenses and other approvals for the export of defense 

articles and defense services destined for Belarus, as well as other countries subject to an arms 

embargo. According to the indictment, in Nov. 2013, a firearms manufacturer in Salt Lake City 

was contacted through email by someone identified as Individual A in the indictment regarding 

the purchase of 50 sniper rifles to be shipped to Belarus. The firearms manufacturer notified 

Individual A that the purchase and delivery would be impossible due to current trade sanctions 

and embargoes against Belarus. The firearms manufacturer subsequently informed a special 

agent with U.S. Immigration and Customs Enforcement’s Homeland Security Investigations 

(HSI) about the suspicious inquiry. An HSI Salt Lake City undercover agent contacted Individual 

A by email. In those communications, Individual A reiterated his desire to procure sniper rifles in 

the United States for delivery to Belarus. From Nov. 2013 through May 2015, negotiations 
16

between the undercover agent and Individual A did not result in a purchase. However, in May 

2015, Individual A introduced the undercover agent to Rahman, designating Rahman as the 

principal broker for the procurement of the sniper rifles. The indictment alleges that from May 

2015 until Nov. 2015, the defendant engaged in a conspiracy to purchase 89 sniper rifles in the 

United States and have them exported to Belarus without first obtaining licenses as required. In 

Aug. 2015, Rahman and an undercover agent agreed that Rahman would make a first purchase of 

10 sniper rifles and ammunition for approximately $66,285. No party to the transaction obtained 

export licenses for the rifles. In Sep. 2015, according to the indictment, Rahman informed the 

undercover agent that the final contract with Belarus had been completed and sent the undercover 

agent a down payment of approximately $13,257 for 10 sniper rifles. Rahman agreed to pay the 

remaining balance once the rifles arrived in Belarus. He told the undercover agent not to include 

U.S. invoices with the shipment. Rahman requested that the sniper rifles be shipped by the most 

direct route possible to Belarus. According to the indictment, the undercover agent informed 

Rahman that the shipment route would be from the United States to South Africa, to Turkey and 

then to Belarus. On Nov. 4, 2015, two undercover HSI agents met with an individual who 

identified himself as Kolar Rahman Anees Ur Rahman at a hotel near Chicago, according to the 

indictment. Rahman confirmed he was the same individual the agents had been negotiating with 

since May. Rahman, the indictment alleges, informed the agents that he understood the risk of 

illegally obtaining and shipping the sniper rifles to Belarus and that he desired to complete their 

business transaction as planned. Rahman and the agents discussed future purchases and shipments 

of the .308 caliber rifles to Belarus. Rahman was arrested by the agents in Chicago later that 

day.

Theft of Military Trade Secrets to Iran – On Oct. 27, 2015, Mozaffar Khazaee, also known as 

“Arash Khazaie”, was sentenced in the District of Connecticut to 97 months imprisonment, 3 

years supervised release, $100 special assessment and $50,000 fine. Previously, on Feb. 25, 

2015, Khazaee pled guilty to a one-count information charging him with unlawful export and 

attempted export of defense articles from the United States, in violation of the Arms Export

Control Act. On Jan. 21, 2014, a federal grand jury returned an indictment charging Khazaee

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 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 Nov. 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 Aug.

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 Jan. 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 was 

investigated by HSI, CBP, the U.S. Air Force’s Office of Special Investigations, DCIS, and the 

FBI.
17

Controlled Microelectronics to Russian Military and Intelligence Agencies – On Oct. 26, 2015, 

in the Eastern District of New York, Alexander Posobilov, Shavkat Abdullaev and Anastasia 

Diatlova were convicted of all counts of an indictment which included charges for conspiring to 

export, and illegally exporting, controlled microelectronics to Russia. Posobilov was also 

convicted of money laundering conspiracy. On Sep. 9, 2015, Alexander Fishenko, a dual citizen 

of the United States and Russia, pleaded guilty to acting as an agent of the Russian government 

within the United States without prior notification to the Attorney General, conspiring to export 

and illegally exporting controlled microelectronics to Russia, conspiring to launder money and 

obstruction of justice. On Jan. 10, 2013, defendants Lyudmila Bagdikian and Viktoria Klebanova 

pleaded guilty for their roles in exporting goods from the United States to Russian end users. 

Previously, on Oct. 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. Fishenko, an owner and 

executive of both the American and Russian companies, was 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 Oct. 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 

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, Apex, Posobilov, Abdullaev 

and Diatlova, the indictment also charges Sevinj Taghiyeva and Svetalina Zagon, who were 

arrested in Houston on Oct. 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.

Schematics of the Navy’s Nuclear Aircraft Carrier to Egypt – On Oct. 15, 2015, Navy Engineer 

Mostafa Ahmed Awwad was sentenced in the Eastern District of Virginia to 11 years of 

incarceration after having earlier plead guilty to attempted espionage. Awwad was originally 

arrested on Dec. 5, 2014, 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 Dec. 3, 2014 and charged with two 

counts of attempted exportation of defense articles and technical data. According to court 
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documents, Awwad began working for the Department of the Navy in Feb. 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 Sep. 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 Oct. 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 

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 Oct. 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 

Nov. 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. Awwad plead guilty to the 

espionage charge on Jun. 15, 2015. This case was investigated by the FBI’s Norfolk Field Office 

and the Naval Criminal Investigative Service, in cooperation with the Department of Navy.

Firearm Parts to the Philippines – On Oct. 7, 2015, Kirby Santos, 38, of the Republic of the 

Philippines, pleaded guilty in the District of New Jersey to an information charging him with one 

count of conspiracy to violate the Arms Export Control Act and U.S. anti-smuggling laws. 

According to the documents filed in this case, other cases and statements made in court: Santos 

admitted that from 2008 through Oct. 2013, he and conspirators he met in the Philippines or 

through an online forum agreed to ship firearms parts from the United States to the Philippines. 

Santos and others used credit cards and other forms of payment to purchase firearms parts from 

suppliers in the United States. Knowing that they would not ship to the Philippines, Santos 

arranged for the suppliers to send the firearms parts to the addresses of conspirators in Toms 

River, New Jersey, and Lynwood, Washington, in order to make the purchases appear as 

domestic sales. At the direction of Santos, the conspirators, including Abelardo Delmundo, 53, of 

Toms River, New Jersey, would then repackage the firearms parts, falsely label the contents of 

the package and export the firearms parts to the Philippines for ultimate delivery to Santos. To 

disguise their role in the conspiracy, the conspirators used aliases when sending the packages 

containing prohibited items. Upon receiving the firearms parts, Santos paid Delmundo and other 

conspirators in the form of cash or wire transfers to others at their direction. During the course of 
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the nearly five-year long conspiracy, Santos and others purchased and directed the unlawful 

exportation of more than $200,000 worth of defense articles from the United States to the 

Philippines without the required export license. Santos made his initial appearance in federal 

court on Apr. 22, 2015, after being charged by criminal complaint with one count of conspiracy 

to violate the Arms Export Control Act and U.S. anti-smuggling laws. The Arms Export Control 

Act prohibits the export of defense articles and defense services without first obtaining a license 

from the U.S. Department of State and is one of the principal export control laws in the United 

States. Santos was arrested in Guam on Mar. 31, 2015, by special agents of the U.S. Department 

of Homeland Security-Homeland Security Investigations (DHS-HSI) and the Bureau of Alcohol, 

Tobacco, Firearms, and Explosives (ATF). Delmundo, charged in the District of New Jersey 

under a separate information, pleaded guilty to his role in the conspiracy on Apr. 30, 2015. This 

investigation was conducted by DHS-HIS, ATF.

Gyroscope to Iran – On Aug. 27, 2015, Ali Mohammadi, a United States citizen, was sentenced 

in the Northern District of Illinois to 5 years’ probation, a $2,000 fine and $100 special 

assessment. Previously, on Feb. 26, 2015, pled guilty to conspiracy to violate the International 

Emergency Economic Powers Act (IEEPA) and the U.S. sanctions against Iran. Mohammadi was 

the sole owner and operator of Modir Trading, an export business. According to court 

documents, Mohammadi, Modir Trading and Ebrahim Hallaji, an Iranian national, conspired to 

export one Series 446 Rate Integrating Gyroscope, a component of the TOW missile, from the 

United States to Iran. Hallaji contacted Mohammadi by email in Feb. 2010, requesting that 

Mohammadi obtain certain gyroscope models to sell and export to Iran for Hallaji, who claimed 

to conduct import and export business in the United Arab Emirates. Hallaji informed 

Mohammadi that the items were prohibited to be sold directly to Iran. Mohammadi contacted a 

salesperson for gyroscopes and was told that he would need an export license to export the 

gyroscope internationally. The salesperson was an undercover agent. Mohammadi falsely 

informed the agent that the gyroscopes would be used as models in California. Mohammadi, 

Modir Trading, and Hallaji were indicted on Jul. 31, 2012. Hallaji remains a fugitive.

Sensitive U.S. Technology to Iran – On Aug. 27, 2015, Arash Ghahreman, a naturalized U.S. 

citizen and former Iranian national, was sentenced in the Southern District of California to 78 

months imprisonment, 3 years supervised release, and $100 special assessment. Previously, on 

Apr. 23, 2015, a federal jury convicted Ghahreman of violations of U.S. export and money 

laundering laws, arising from his involvement in a scheme to purchase marine navigation 

equipment and military electronic equipment for illegal export to, and end-use in, Iran. 

Ghahreman was convicted of attempted export to Iran, and conspiracy to do the same, in violation 

of the Iran Trade Embargo (formerly known as the Iranian Transactions and Sanctions 

Regulations); smuggling goods from the U.S., and conspiracy to do the same; and aiding and 

abetting the transfer of money from Dubai, United Arab Emirates (UAE), to the U.S., in support 

of an illegal export activity, and conspiracy to do the same. After a seven-day jury trial, the jury 

returned a guilty verdict on seven counts of a nine-count superseding indictment after only one 

day of deliberation. The jury was unable to reach a verdict on two of the counts involving the 

attempted exportation and smuggling of a fiber optic gyrocompass, used in both military and 

civilian marine navigation applications. The evidence presented at trial showed that Ghahreman 

acted as an agent of an Iranian procurement network which used a front company in Dubai to 

acquire U.S. goods and technologies for illegal transshipment to, and end-use in, Iran. Codefendant Koorush Taherkhani, an Iranian national and resident, was the managing director and 

founder of that front company, co-defendant TIG Marine Engineering Services. Because of his 

German nationality, co-defendant Ergun Yildiz, 35, a resident of UAE, was hired by Taherkhani 

to be the “face” of the front company, as the president/CEO of TIG Marine. Before Ghahreman 

immigrated to the U.S. in 2007, Ghahreman and Taherkhani had been friends and dorm mates at 
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an Iranian university, where each received a degree in marine engineering. Upon graduation, 

both Ghahreman and Taherkhani worked as engineers for various Iranian shipping companies, 

including the Islamic Republic of Iran Shipping Lines and its subsidiaries. After immigrating to 

the U.S., Ghahreman was employed by various shipyards in the U.S., and became a naturalized 

U.S. citizen. Because of his employment and citizenship status, Ghahreman was well placed to 

act as an agent of the illegal procurement network. From Dec. 2012 through Jun. 17, 2013, 

Ghahreman and his co-defendants negotiated via email, text, telephone and meetings with U.S. 

Immigration Customs and Enforcement’s Homeland Security Investigations (ICE-HSI) and the 

Defense Criminal Investigative Service (DCIS) undercover agents to purchase marine navigation 

components (fiber optic gyrocompasses), military electronic components (electron tubes) and 

other U.S. technology for illegal export to, and/or end-use in, Iran. The undercover agents were 

posing as brokers of U.S. goods and technology, willing to sell U.S. goods to the defendants for 

end-use in Iran. Ultimately, as a result of these negotiations, Ghahreman and his co-defendants 

agreed to purchase four Navigat-2100 fiber optic gyrocompasses and 50 Y-690 units (electron 

tubes). Pursuant to that agreement, Ghahreman and his co-defendants wired approximately 

$60,000 in partial payment for the gyrocompasses and electron tubes from a bank in Dubai to the 

undercover agents’ bank account. Ultimately, on Jun. 17, 2013, ICE-HSI agents arrested 

Ghahreman and Yildiz after they traveled to the U.S. and took partial delivery of one 

gyrocompass and two electron tubes and attempted to ship the items indirectly to Iran, via third 

countries. On Oct. 9, 2014, Yildiz pleaded guilty to conspiracy to export to Iran. He was 

sentenced on May 8, 2015 to time served, 2 years supervised release, and $100 special 

assessment. On Jan. 21, 2016, the Court dismissed with prejudice the superseding indictment 

against Taherkhani and Tig Marine Engineering Services. This case was investigated by ICE-HSI 

and DCIS. 

Accelerometers to China – On Aug. 25, 2015, Yue Wu, a.k.a. David Wu, a Chinese national, was 

sentenced in the Western District of Washington to 18 months imprisonment, $100 special 

assessment, and deportation after completion of his sentence following a plea of guilty on May 

26, 2015 to conspiracy to violate the Arms Export Control Act. Previously, on Oct. 22, 2014, Wu

was indicted for violating the Arms Export Control Act. According to court documents, between 

Dec. 2011 and Oct. 2014, Wu directed others to contact a United States manufacturer and request 

the purchase of QA3000 accelerometers for export to China without first obtaining a license from 

the United States Department of State. Wu and another person met with an undercover agent in 

San Francisco, CA, in an effort to order 30 accelerometers from the undercover agent. Wu 

explained that he was attempting to acquire the accelerometers on behalf of a customer in China. 

He requested that the accelerometers be concealed in housing to evade United States export 

restrictions, providing the agent with schematics for the construction of the housing. Court 

documents further show that Wu suggested that the agent ship the accelerometers to Wu’s 

associate in Switzerland, who, in turn, would trans-ship the accelerometers into China. 

Firearms Parts and Accessories to Lebanon – On Aug. 12, 12015 in the District of Maryland, Sam 

Rafic Ghanem was sentenced to 18 months in prison followed by three years of supervised 

release for attempting to illegally export firearms parts and accessories to Lebanon, and for 

smuggling goods from the United States. Ghanem was ordered by the Court to pay a fine of 

$70,734.24. Ghanem, a naturalized U.S. citizen born in Lebanon, owned and operated 

Washington Movers International, also known as Washington Movers, Inc., a freight forwarding 

business located in District Heights, Maryland. According to evidence presented at his five day 

trial, beginning Oct. 3, 2013, Ghanem sought to export guns and accessories to Lebanon through 

his shipping company that were provided to him by an FBI source. Ghanem knew that the 

weapons and accessories were designated as defense articles and required an export license, 

which Ghanem never sought or obtained. In addition, those items were prohibited from export to 
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Lebanon. Specifically, Ghanem attempted to export seven 9mm semi-automatic pistols; three .40 

caliber semi-automatic pistols; 10 AR-15 .223 caliber semi-automatic rifles; and 18 advanced 

combat optic gun sights. According to trial evidence, on Nov. 21, 2013, Ghanem told the source 

to pay him $3,000 for the cost of purchasing salvaged vehicles which would be used to export the 

firearms and accessories. Ghanem texted the source his bank account number and at the direction 

of law enforcement, the source deposited $3,000 into Ghanem’s account. Ghanem purchased the 

salvaged vehicles and arranged for them to be cut up. Ghanem concealed the weapons and other 

items within the doors and cut-up parts of the salvaged vehicles, which were then loaded into a 

shipping container. Ghanem advised the source that the shipping container would be loaded with 

the remaining car parts and transported to the Port of Baltimore for shipment to Lebanon on Dec.

23, 2013. Ghanem was subsequently arrested. This investigation was conducted by the FBI and 

ICE HSI.

Thermal Imaging Camera to Pakistan – On Jun. 30, 2015, in the Northern District of Illinois, 

Bilal Ahmed was sentenced to 24 months imprisonment, $100 special assessment, $1,000 fine, 

and 2 years supervised release after previously pleading guilty on Oct. 2, 2014 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 HRC-U thermal imaging camera from his 

company in Schaumburg to a company in Pakistan without first 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 Mar. 14, 2014. 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 Nov. 2013 

and Feb. 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 Feb. 2014. Ahmed took delivery of the camera on Feb. 27, 2014 at a 

commercial shipping store in Bolingbrook, IL. On Mar. 7, 2014, 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 HRCU thermal imaging camera from the U.S. to Pakistan. 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.

Theft of Trade Secrets by Chinese Professors for Technology to China - On May 16, 2015, 

Tianjin University Professor Hao Zhang was arrested upon entry into the U.S. from the People’s 

Republic of China (PRC) in connection with a recent superseding indictment in the Northern 

District of California. The 32-count indictment, which had previously been sealed, charges a 

total of six individuals with economic espionage and theft of trade secrets for their roles in a longrunning effort to obtain U.S. trade secrets for the benefit of universities and companies controlled 

by the PRC government. According to the indictment, PRC nationals Wei Pang and Zhang met at 

a U.S. university in Southern California during their doctoral studies in electrical 

engineering. While there, Pang and Zhang conducted research and development on thin-film 

bulk acoustic resonator (FBAR) technology under funding from U.S. Defense Advanced 

Research Projects Agency (DARPA). After earning their doctorate in approximately 2005, Pang 
22

accepted employment as an FBAR engineer with Avago Technologies (Avago) in Colorado and 

Zhang accepted employment as an FBAR engineer with Skyworks Solutions Inc. (Skyworks) in 

Massachusetts. The stolen trade secrets alleged in the indictment belong to Avago or Skyworks. 

Avago is a designer, developer and global supplier of FBAR technology, which is a specific type 

of radio frequency (RF) filter. Throughout Zhang’s employment, Skyworks was also a designer 

and developer of FBAR technology. FBAR technology is primarily used in mobile devices like 

cellular telephones, tablets and GPS devices. FBAR technology filters incoming and outgoing 

wireless signals so that a user only receives and transmits the specific communications intended 

by the user. Apart from consumer applications, FBAR technology has numerous applications for 

a variety of military and defense communications technologies. According to the indictment, in 

2006 and 2007, Pang, Zhang and other co-conspirators prepared a business plan and began 

soliciting PRC universities and others, seeking opportunities to start manufacturing FBAR 

technology in China. Through efforts outlined in the superseding indictment, Pang, Zhang and 

others established relationships with officials from Tianjin University. Tianjin University is a 

leading PRC Ministry of Education University located in the PRC and one of the oldest 

universities in China. As set forth in the indictment, in 2008, officials from Tianjin University 

flew to San Jose, CA, to meet with Pang, Zhang and other co-conspirators. Shortly thereafter, 

Tianjin University agreed to support Pang, Zhang and others in establishing an FBAR fabrication 

facility in the PRC. Pang and Zhang continued to work for Avago and Skyworks in close 

coordination with Tianjin University. In mid-2009, both Pang and Zhang simultaneously 

resigned from the U.S. companies and accepted positions as full professors at Tianjin 

University. Tianjin University later formed a joint venture with Pang, Zhang and others under the 

company name ROFS Microsystem intending to mass produce FBARs. The indictment alleges 

that Pang, Zhang and other co-conspirators stole recipes, source code, specifications, 

presentations, design layouts and other documents marked as confidential and proprietary from 

the victim companies and shared the information with one another and with individuals working 

for Tianjin University. According to the indictment, the stolen trade secrets enabled Tianjin 

University to construct and equip a state-of-the-art FBAR fabrication facility, to open ROFS 

Microsystems, a joint venture located in PRC state-sponsored Tianjin Economic Development 

Area (TEDA), and to obtain contracts for providing FBARs to commercial and military entities. 

The remaining indicted defendants are all citizens of the PRC and include: Jinping Chen, a 

professor at Tianjin University and a member of the board of directors for ROFS Microsystems; 

Huisui Zhang (Huisui) studied with Pang and Zhang at a U.S. university in Southern California 

and received a Master’s Degree in Electrical Engineering in 2006; Chong Zhou, a Tianjin 

University graduate student and a design engineer at ROFS Microsystem. Zhou studied under 

Pang and Zhang; Zhao Gang, the General Manager of ROFS Microsystems. This investigation 

was conducted by the FBI.

Illegal Trade with Iran and Sudan – On May 6, 2015, in the District of Columbia, Schlumberger 

Oilfield Holdings Ltd. (SOHL), a wholly-owned subsidiary of Schlumberger Ltd., entered into a 

formal judgment memorializing the sentence requiring SOHL to pay a $232,708,356 penalty to 

the U.S. for conspiring to violate the International Emergency Economic Powers Act (IEEPA) by 

willfully facilitating illegal transactions and engaging in trade with Iran and Sudan. At a hearing 

on Apr. 30, 2015, the Court accepted the company’s guilty plea and sentenced the company to the 

proposed sentence articulated in the plea agreement, which called for the fine and other terms of 

corporate probation. The court recognized the seriousness of SOHL’s criminal conduct, which 

posed a threat to our national security. In addition, the court noted that the scope of criminal 

conduct justified the large monetary penalty imposed. Finally, the court concluded that the terms 

of probation provided adequate deterrence to SOHL as well as other companies. The Court 

entered the written judgment confirming the sentence imposed on Apr. 30, 2015. Previously, on 

Mar. 25, 2015, a criminal information was filed in the District of Columbia charging SOHL with 
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one count of knowingly and willfully conspiring to violate IEEPA. SOHL waived the 

requirement of being charged by way of federal Indictment, agreed to the filing of the 

information, and accepted responsibility for its criminal conduct and that of its employees by 

entering into a plea agreement with the government. The plea agreement requires that SOHL pay 

the U.S. government $232,708,356 and enter into a three-year period of corporate 

probation. SOHL’s monetary penalty includes a $77,569,452 criminal forfeiture and an 

additional $155,138,904 criminal fine. The criminal fine represents the largest criminal fine in 

connection with an IEEPA prosecution. In addition to SOHL’s agreement to continue its 

cooperation with U.S. authorities throughout the three-year period of probation and not to engage 

in any felony violation of U.S. federal law, SOHL’s parent company, Schlumberger Ltd., also has 

agreed to continue its cooperation with U.S. authorities during the three-year period of probation, 

and hire an independent consultant who will review the parent company’s internal sanctions 

policies, procedures and company-generated sanctions audit reports. According to court 

documents, starting in or about early 2004 and continuing through Jun. 2010, Drilling & 

Measurements (D&M), a United States-based Schlumberger business segment, provided oilfield 

services to Schlumberger customers in Iran and Sudan through non-U.S. subsidiaries of 

SOHL. Although SOHL, as a subsidiary of Schlumberger Ltd., had policies and procedures 

designed to ensure that D&M did not violate U.S. sanctions, SOHL failed to train its employees 

adequately to ensure that all U.S. persons, including non-U.S. citizens who resided in the United 

States while employed at D&M, complied with Schlumberger Ltd.’s sanctions policies and 

compliance procedures. As a result of D&M’s lack of adherence to U.S. sanctions combined with 

SOHL’s failure to train properly U.S. persons and to enforce fully its policies and procedures, 

D&M, through the acts of employees residing in the United States, violated U.S. sanctions against 

Iran and Sudan by: (1) approving and disguising the company’s capital expenditure requests from 

Iran and Sudan for the manufacture of new oilfield drilling tools and for the spending of money 

for certain company purchases; (2) making and implementing business decisions specifically 

concerning Iran and Sudan; and (3) providing certain technical services and expertise in order to 

troubleshoot mechanical failures and to sustain expensive drilling tools and related equipment in 

Iran and Sudan. In 2009, in consultation with the U.S. Department of State, Schlumberger agreed 

to no longer pursue new oilfield contracts in Iran. In 2011, Schlumberger voluntarily decided to 

cease providing oilfield services in Iran and the Republic of the Sudan (North Sudan). As of Jun.

30, 2013, Schlumberger ceased providing oilfield services in Iran. And presently, Schlumberger 

has ceased providing oilfield services in North Sudan as well. This case was investigated by the 

Department of Commerce – BIS.

Trade Secrets to South Korea - On April 30, 2015, in the Eastern District of Virginia, Kolon 

Industries Inc., a South Korean industrial company, pleaded guilty to conspiracy to steal trade 

secrets involving E.I. DuPont de Nemours & Co.’s (DuPont) Kevlar technology. The company 

was sentenced on May 1, 2015 to pay $85 million in criminal fines and $275 million in 

restitution. Kolon Industries Inc., appearing through two successor entities—Kolon Industries Inc. 

and Kolon Corporation (collectively, Kolon)—pleaded guilty in federal court to one count of 

conspiracy to convert trade secrets. According to the statement of facts filed with the plea 

agreement, from June 2006 to February 2009, Kolon conspired with former DuPont employees 

and others to steal DuPont’s trade secrets for making Kevlar, a high-strength, para-aramid 

synthetic fiber. Kevlar, a trademarked name, is one of DuPont's most well-known products and is 

used is a wide range of commercial applications such as body armor, fiber optic cables, and 

automotive and industrial products. Kolon admitted that it was attempting to improve the quality 

of its own para-aramid fiber known as Heracron. Kolon personnel met repeatedly with former 

DuPont employees, including Edward Schulz of Brownstown, PA, and Michael Mitchell, of 

Chesterfield, VA, to obtain confidential and proprietary DuPont information about 

Kevlar. Schulz pleaded guilty to conspiracy to steal trade secrets in September 2014 and was 
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sentenced in July 2015 to 2 years probation, 500 hours community service, $100 special 

assessment and $75,000 fine. Mitchell pleaded guilty to theft of trade secrets and obstruction of 

justice in December 2009 and was sentenced to 18 months in prison, 3 years supervised release, 

$200 special assessment, and $187,895.90 restitution. Kolon admitted that it obtained technical 

and business documents regarding Kevlar, including instructional materials that described 

DuPont’s “New Fiber Technology,” documents on polymerization, and a detailed breakdown of 

DuPont’s capabilities and costs for the full line of its Kevlar products and DuPont’s Kevlar 

customers. According to the statement of facts and Mitchell’s admissions at his guilty plea, 

Mitchell exchanged numerous telephone calls and emails with Kolon personnel. On more than 

one occasion, Mitchell advised Kolon personnel that some of the information they sought was 

proprietary and that DuPont considered such information to be trade secrets. Mitchell also 

coordinated a meeting at a hotel in Richmond, at which Kolon personnel were introduced to a 

cooperating witness who pretended to be a disgruntled scientist from DuPont. During the 

Richmond meeting, Kolon personnel indicated that they would only be comfortable 

communicating with the cooperating witness in a manner that was confidential and that would not

leave an evidentiary trail. In February 2009, DuPont filed a civil lawsuit against Kolon in the 

Eastern District of Virginia, alleging theft of trade secrets. Thereafter, certain Kolon personnel 

attempted to delete files and emails related to Mitchell, Schulz and outside consultants hired to 

improve Kolon’s para-aramid fiber, and urged other Kolon personnel to search for such materials 

and mark them for deletion. Kolon also admitted that certain employees approached a former 

employee of an American subsidiary of Teijin Ltd. – a Japanese company that makes the paraaramid fiber called Twaron—in an unsuccessful effort to obtain information about Twaron. This 

case represents the first time that foreign corporations with no direct presence in the United States 

were found to be successfully served with U.S. criminal process, over their objections, based on 

service pursuant to an international treaty. In December 2014, the district court found that both of 

the successor companies were properly served, and ordered them to appear for arraignment. In 

February 2015, the Fourth Circuit Court of Appeals denied Kolon’s petition for extraordinary 

relief seeking reversal of the district court’s order. Five former Kolon executives and employees, 

all of South Korea, were charged in an August 2012 indictment filed in the Eastern District of 

Virginia: Jong-Hyun Choi, a senior executive who oversaw the Heracron Business Team; In-Sik 

Han, who managed Kolon’s research and development related to Heracron; Kyeong-Hwan Rho, 

the head of the Heracron Technical Team; Young-Soo Seo, the general manager for the Heracron 

Business Team; and Ju-Wan Kim, a manager on the Heracron Business Team. The case was 

investigated by the FBI’s Richmond Division.

Fighter Jet Parts to Thailand and Pakistan - On Apr. 27, 2015, Russell Marshall and his 

company, Universal Industries Limited, Inc., were sentenced in the Southern District of Florida 

for violating the International Emergency Economic Powers Act. Marshall was sentenced to 

serve 41 months in prison and will be removed from the United States upon the completion of his 

sentence. In imposing the sentence, the Court found that the order denying export privileges 

issued by the Department of Commerce constituted a national security control, which subjected 

Marshall to an enhanced sentence. Universal Industries Limited Inc. was sentenced to a term of 

one year probation and a special assessment of $400 upon a finding that the corporation is 

currently listed as inactive by the Florida Division of Corporations as a result of Marshall’s arrest. 

Marshall and his company, Universal Industries Limited Inc., were previously convicted in a 

2011 case in the Southern District of Florida for violating the Arms Export Control Act, after 

which the Department of Commerce issued a denial order prohibiting Universal Industries 

Limited Inc. and its owners, agents and employees from participating in any transaction involving 

the export of any item subject to the Department of Commerce‘s Export Administration 

Regulations (EAR). Marshall and Universal Industries Limited Inc. violated IEEPA and the U.S. 

Department of Commerce’s denial order by attempting to send three temperature transmitters 
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used on F-16 fighter jets and a saddle part for the J-69 engine used on 737 military trainer aircraft 

to Thailand and Pakistan, respectively. According to court documents and information presented 

during the sentencing hearing, the DoD Inspector General received a hotline complaint 

concerning Marshall and Universal Industries Limited Inc. in Nov. 2012. The subsequent 

investigation revealed that the defendants brokered the sale of military aircraft parts which were 

subject to license controls by the Department of Commerce, and which the defendants knew were 

intended to be illegally exported to Thailand and Pakistan. On Feb. 6, 2015, Marshall and 

Universal Industries Limited Inc. entered guilty pleas to an information that charged them with 

knowingly and willfully engaging in negotiations concerning selling, delivering or otherwise 

servicing a transaction involving an item to be exported from the United States to Thailand and 

subject to the EAR. This case was investigated by DoD, DCIS, ICE-HSI and the U.S. 

Department of Commerce’s Office of Export Enforcement.

WMD Materials to North Korea –On Apr. 24, 2015, Yueh-Hsun Tsai, a.k.a. “Gary Tsai”, was 

sentenced in the Northern District of Illinois to 3 years of probation and a fine of $250. On Mar.

16, 2015, Hsien Tai Tsai, a.k.a. “Alex Tsai”, was sentenced to 2 years imprisonment and $100 

special assessment. Previously, on Oct. 10, 2014, Alex Tsai pleaded guilty 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. On Dec. 16, 2014, his son, 

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. 

On Jun. 6, 2013, Alex Tsai, who the U.S. government has linked to the supply of weapons 

machinery to North Korea, and 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 Apr. 19, 2013. Alex Tsai, who was believed to have resided in Taiwan, was 

arrested in Tallinn, Estonia, and later extradited to the United States. 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 were 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 Jan.

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 
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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. This 

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

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

2015, Bo Cai, a Chinese national, was sentenced in the District of New Mexico to 24 months 

imprisonment. On the same day, his cousin Wentong Cai, a Chinese national in the U.S. on a 

student Visa, was also sentenced to 18 months imprisonment. Both men are scheduled to be 

deported after completing their prison sentences. Bo Cai and Wentong Cai were charged in a 

three-count superseding indictment with a scheme to illegally export sensors primarily 

manufactured for sale to the U.S. 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. Previously, on Dec. 16, 2014, Wentong Cai, pleaded guilty to conspiring 

with Bo Cai to violate the Arms Export Control Act and the International Traffic Arms 

Regulations (ITAR). Bo Cai pleaded guilty on Jul. 23, 2014. Cai and Wentong Cai participated 

in a scheme to illegally export defense articles with military applications to the People’s Republic 

of China. According to court documents, in Mar. 2012, Bo Cai, was employed by a technology 

company in China. He embarked on an illegal scheme to smuggle sensors out of the U.S. to 

China for one of his customers despite 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

his cousin 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 Oct. 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 

Dec. 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 Dec. 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 Jan. 2014. This investigation was conducted by Homeland Security Investigations, USAF 

Office of Special Investigations, Defense Security Service, FBI.

High-Tech Microelectronics and Uninterruptible Power Supplies to Iran – On Apr. 17, 2015, in 

the Southern District of Texas, a 24-count indictment was unsealed charging four corporations 

and five individuals with facilitating the illegal export of high-tech microelectronics, 

uninterruptible power supplies and other commodities to Iran, in violation of the International 

Emergency Economic Powers Act (IEEPA). The indictment alleges that Houston-based company 

Smart Power Systems Inc. (SPS), Bahram Mechanic and Tooraj Faridi – both of Houston, and 

Khosrow Afghahi of Los Angeles, were all members of an Iranian procurement network 

operating in the United States. Also charged as part of the scheme are Arthur Shyu and the 

Hosoda Taiwan Limited Corporation in Taiwan, Matin Sadeghi and Golsad Istanbul Trading Ltd. 

in Turkey, and the Faratel Corporation co-owned by Mechanic and Afghahi in Iran. The 

indictment was returned under seal on Apr. 16, 2015, and unsealed as Mechanic and Faridi made 

their initial appearances. Afghahi was taken into custody and will make an initial appearance in 

the Central District of California. Sadeghi and Shyu are believed to be out of the country. 

Warrants remain outstanding for their arrests. In conjunction with the unsealing of these charges, 

the Department of Commerce is designating seven foreign nationals and companies, adding them 

to its Bureau of Industry and Security Entity List. Designation on the Entity List imposes a 

license requirement before any commodities can be exported from the United States to these 

persons or companies and establishes a presumption that no such license will be granted. 

According to the indictment, Mechanic and Afghahi are the co-owners of Iran-based Faratel and 

its Houston-based sister company SPS. Faratel, currently the vice president of SPS, designs and 
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builds uninterruptible power supplies for various Iranian entities, including Iranian government 

agencies such as the Iranian Ministry of Defense, the Atomic Energy Organization of Iran, and 

the Iranian Centrifuge Technology Company. Shyu is a senior manager at the Hosoda Taiwan

Limited Corporation, a trading company located in Taiwan, while Sadeghi is an employee of 

Golsad Istanbul Trading, a shipping company located in Turkey. The indictment alleges that 

between approximately Jul. 2010 and the present, Mechanic and the others engaged in a 

conspiracy to obtain various commodities, including controlled United States-origin 

microelectronics. They then allegedly exported these commodities to Iran, while carefully 

evading the government licensing system set up to control such exports. The microelectronics 

shipped to Iran allegedly included microcontrollers and digital signal processors. These 

commodities have various applications and are frequently used in a wide range of military 

systems, including surface-air and cruise missiles. Mechanic’s network allegedly sent at least $24 

million worth of commodities to Iran. Mechanic, assisted by Afghahi and Faridi, regularly 

received lists of commodities, including United States-origin microelectronics sought by Faratel 

in Iran, and would approve these orders and then send the orders to Shyu in Taiwan. Shyu would 

allegedly purchase the commodities utilizing Hosoda Taiwan Limited and then ship the 

commodities to Turkey, where Sadeghi would act as a false buyer via his company, Golsad 

Istanbul Trading Ltd. The indictment further alleges that Sadeghi would receive the commodities 

from Shyu and then ship them to Faratel in Iran. Mechanic required his co-conspirators to notify 

him and obtain his approval for each of the transactions completed by the network. The 

individual defendants each face up to 20 years in federal prison, while the corporate defendants 

face fines of up to $1 million for each of the IEEPA counts. Mechanic, Afghahi and Shyu are 

also charged with conspiring to commit money laundering and substantive money laundering 

violations, each charge carries a maximum federal prison term of 20 years. Mechanic further 

faces a charge of willful failure to file foreign bank and financial accounts for which he faces up 

to five years in federal prison. The charges also carry the possibility of substantial fines upon 

conviction. This case was investigated by the FBI, Department of Commerce, and the IRS.

Computers to Iran – On Apr. 6, 2015, 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 both sentenced to 2 years probation, $100 special assessment and $75,000 fine. Faizy and 

Ghavidel both pled guilty on Sept. 29, 2014 to making false statements to federal agents about the 

illegal export of computer equipment from the United States to Iran. Previously, on Mar. 7, 2013, 

Faizy and Ghavidel 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 Mar. 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 Counter-proliferation Task Force, which includes the FBI, ICE, the Department of 

Commerce and DCIS.
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Munitions to Egypt – On Apr. 1, 2015, in the Eastern District of New York, AMA United 

Group, Malak Neseem Swares Boulos and Amged Kamel Yonan Tawdraus pleaded guilty to 

violating U.S. export regulations in connection with the attempted shipment of munitions samples 

from New York City to Egypt. AMA United Group, an Egyptian procurement agent, entered a 

guilty plea to violating the Arms Export Control Act. Boulos and Tawdraus, Egyptian citizens 

and partners in AMA United Group, pleaded guilty to failing to file required export information 

relating to the international shipment of a landmine and multiple bomblet bodies. According to 

court filings and facts presented during the plea proceeding, Boulos and Tawdraus were arrested 

after attempting to close a deal to acquire and export the items, which were included on the U.S. 

Munitions List and regulated by the U.S. Department of State. Beginning in Feb. 2011, the 

defendants began trying to obtain munitions items on behalf of AMA United Group’s client, a 

factory in Cairo. The items the defendants sought included a landmine as well as bomblet bodies 

and “trumpet liners,” two components that are integral to manufacturing the housings for 

explosives in an aerial warhead. In Jul. 2011, the defendants traveled from Cairo to New York 

City to inspect the items. On Jul. 1, 2011, the three principals of AMA United Group attempted 

to ship samples to its client in Egypt. Boulos and Tawdraus failed to file any export information 

in connection with the attempted shipment. The requirement to file accurate information 

regarding the contents of international shipments is one layer of regulatory oversight pertaining to 

protecting the U.S. national security and diplomatic interests. This case was investigated by the 

U.S. Immigration and Customs Enforcement’s Homeland Security Investigations (ICE-HSI) and 

the Defense Criminal Investigative Service (DCIS).

High-Powered Military-Grade Weapons to the Philippines – On Mar. 27, 2015, in the Eastern 

District of New York, two law enforcement officers who used their positions to obtain highpowered military-grade weapons to smuggle to the Philippines, were sentenced to three years in 

prison, followed by three years of supervised release. According to court documents, former New 

York City Police Officer Rex Maralit and his brother Wilfredo Maralit, a U.S. Customs and 

Border Protection officer assigned to Los Angeles International Airport, pleaded guilty on Jun.

12, 2014, for their roles in an illegal scheme to smuggle high-powered assault rifles, sniper rifles, 

pistols, and firearms accessories from the United States to the Philippines, violating the Arms 

Export Control Act. A third brother, Ariel Maralit, resides in the Philippines and remains a 

fugitive. Court documents further alleges that between Jan. 2009 and Sep. 2013, the defendants 

exported a variety of military-style firearms, along with high-capacity magazines and accessories 

for those weapons, from the United States to the Philippines, where they were sold to overseas 

customers. Both Rex and Wilfredo Maralit used their official credentials and status to obtain and 

ship the weapons without first obtaining a license from the U.S. State Department. The firearms 

included the Barrett .50 caliber long-range semi-automatic rifle, the FN “SCAR” assault rifle, and 

high-capacity FN 5.7mm semi-automatic carbines and pistols which fire a cartridge that was 

specifically designed to penetrate body armor. The Arms Export Control Act requires exporters 

of firearms to first obtain the approval of the U.S. State Department before shipping weapons 

overseas. Similarly, dealing in firearms is regulated by the ATF, which requires gun dealers to 

first obtain a federal firearms license before engaging in such a business. This case was 

investigated by U.S. Immigration and Customs Enforcement’s (ICE) Homeland Security 

Investigations (HSI), Defense Criminal Investigative Service (DCIS), Bureau of Alcohol, 

Tobacco, Firearms, and Explosives (ATF), and New York City Police Department (NYPD).

Aluminum Tubes to Iran – On Mar. 4, 2015, Nicholas Kaiga of Brussels and London, was 

sentenced in the Northern District of Illinois to 27 months imprisonment, two years supervised 

release, and $100 special assessment after a plea of guilty on Dec. 4, 2014 to one count of 

attempting to violate the export control regulations. Previously, on Oct. 24, 2013, a federal grand 

jury returned a three -count indictment charging Kaiga with one count of violating the 
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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 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 Dec. 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 Nov. 2009 and 

Feb. 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 Nov. 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 Dec. 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.

Oilfield Service Equipment to Iran – On Feb. 24, 2015, Patrick Jean Zuber, a lawful permanent 

resident of the U.S., was sentenced in the Southern District of Texas to one year of probation, 

$100 special assessment and a $15,000 fine. Previously, on Sep. 24, 2014, Zuber pled guilty to a 

Criminal Information charging him 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) East where he oversaw the operations in India, Saudi Arabia, Yemen, Oman, Qatar, 

Turkmenistan, and Pakistan for Weatherford Oil Tool Middle East Limited (WOTME), a wholly 

owned subsidiary of Weatherford International, Ltd. (Weatherford), one of the world’s largest 

oilfield service companies. According to court documents, in Jan. 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.

Military Articles to China – On Feb. 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 

Jan. 14, 2015. Defendant 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, than 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 Nov. 2006 and Mar. 2014, the 
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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 

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

location of the 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 AECA and the 

ITAR, one count of conspiracy to defraud the United States, and one count of violating the 

AECA. 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 Feb. 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 Feb. 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 Sep. 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 Oct. 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 Feb. 2, 2015, in the District of Maryland, Ali Saboonchi, a U.S. 

citizen, was sentenced to 2 years in prison, 1 year supervised release, and $800 special 

assessment. Previously, on Aug. 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 Mar. 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 Mar. 4, 2013, and unsealed upon Saboonchi's arrest. From Nov.

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

Military-Grade Thermal and Night Vision Goggles to the United Kingdom – On Jan. 28, 2014, 

Martin Gula a.k.a. Mark Welder, was charged by indictment in the Central District of California 

and on Dec. 12, 2013 by complaint in the District of Connecticut for violations of U.S. export 

control laws. According to court documents, between 2006 and 2013, Gula, a former member of 

the Slovakian Military Special Forces, used numerous fictitious names and an international 

network of suppliers, freight forwarders, mail forwarding companies, and bank accounts, to 

illegally export United States defense articles, including but not limited to military-grade thermal 

and night-vision goggles and scopes from the United States to the United Kingdom and various

other European countries. On Dec. 18, 2013, the London Metropolitan Police Service arrested 

Gula in London, England, based upon a provisional arrest warrant in connection with Gula’s 

involvement in violating United States export control laws. After he was charged by indictment 

in the Central District of California, Gula fled from England prior to extradition to the United 

States. Gula is currently a fugitive. This investigation was conducted by ICE. 

Sanctions Violations to Aid Zimbabwean Government Officials – On Jan. 21, 2015, C. Gregory 

Turner, also known as Greg Turner, was sentenced in the Northern District of Illinois to 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 Oct. 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 Nov. 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. President Mugabe and his ruling ZANUPF party have governed Zimbabwe since its independence in 1980. The sanctions against 

President Mugabe and other specially designated individuals in Zimbabwe – for human rights 

abuses – 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 Nov. 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 President 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 Dec. 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 Nov. and Dec. 2008, 

and Jan. and Dec. 2009; attempted to have Gono and other Zimbabwean officials speak at an 
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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 Dec. 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. Ben Israel was sentenced on Aug. 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.

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

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

$12,560. On Oct. 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 Sep. 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 Sep. 2008 through Apr. 2009 without a license and brokered the sale and export of 

approximately $2 million in such aerospace parts between Jul. 2007 and Oct. 2009. This case 

was investigated by ICE/HSI and DCIS.

Drone, Missile and Stealth Technology to China – On Jan. 9, 2015, Hui Sheng Shen, a.k.a.

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

assessment. On Jan. 6, 2015, Huan Ling Chang, a.k.a. “Alice” was sentenced to time served and 

$200 special assessment. Previously, on Sep. 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 Apr. 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 Feb. 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 
33

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 Feb. 2012, the defendants allegedly examined a 

Raven RQ-11b UAV and manuals relating to the RQ-4 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 Dec. 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 in the District of Columbia 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 from the Treasury Department. Kim was the president and CEO of Karham 

Eng., Corp., a company located in Seoul, South Korea. Beginning in Dec. 2007 to Mar. 2010, 

Kim and Karham conspired with 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. Kim was transferred to the District of Columbia in Jan. 2015.

Trade Secrets to Competitors in China – On Dec. 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 Sep. 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 Jun. 2003 through Nov. 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 Aug. 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 Dec. 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 Dec. 5, 2014 for his role in illegally exporting firearm 

parts from the United States to Russia. An indictment was unsealed on Jun. 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 
34

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 Savannah-Chatham 

Metropolitan Police Department.

Embargo Violations by Alleged Arms Dealer – On Dec. 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 Jan.

2013, and then extradited to the U.S. in May 2013. On Dec. 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 Nov. 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 DEA-Special Operations 

Division.

Military-Grade Weapons Exported Outside of the U.S. – On Nov. 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, one year of supervised release and $125 special 

assessment. Previously, on Aug. 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 

Nov. 2009 through Jan. 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 Apr. 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 
35

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

performed a follow-up search in Jul. 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 Nov. 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 

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 Aug. 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 Aug. 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 Nov. 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.

Defense Articles Exported Outside of the U.S. – On Oct. 14, 2014 in the Middle District of 

Georgia, Robert J. Shubert, Sr., was sentenced to 78 months in prison following his earlier plea of 

guilty to one count each of conspiracy to violate and violation of the Arms Export Control Act as 

well as one count of possession of an unregistered firearm. The investigation in this case 

revealed that Mr. Shubert conspired with a foreign national between Jun. 2006 and Dec. 2011 to 
36

export defense articles to a foreign nation without the proper authority or license. He purchased 

the defense articles from various legitimate distributors and shipped them to a foreign nation at a 

considerable profit to himself. To facilitate the scheme he also prepared false documents 

regarding the contents to be exported to his foreign co-conspirator. These acts formed the basis of 

the Arms Export Control Act violations. Additionally, search warrants executed on homes owned 

by Mr. Shubert in Warner Robins, Georgia, and in Wisconsin revealed more than 80 unregistered 

destructive devices, better known as pipe bombs. These resulted in the possession of an 

unregistered firearm count. The Court also imposed a fine of $15,000.00 and ordered forfeiture 

of $147,892.00. The Court prohibited Shubert from leaving the U.S. and ordered his passport be 

surrendered to the State Department, as well. The case was investigated by the Federal Bureau of 

Investigation and Homeland Security Investigations.

High-Tech Night Vision Devices to Russia – On Oct. 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 after a plea of guilty on Jul. 10, 2013 to conspiracy to export high-tech military 

technology, in violation of the Arms Export Control Act (AECA) and the International Traffic in 

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

federal prison. Previously, at the request of the U.S. government, Ustinov was arrested in 

Vilnius, Lithuania after entering that country from Russia. On Aug. 23, 2013, Lithuania 

extradited Ustinov to the United States. According to court documents, between Jul. 2010 and 

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

export from the United States to Russia 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 of the United States. The defense articles 

at issue include the Insight Mini Thermal Monoculars, D-740 night vision scopes, and Flir Tau 

640 thermal imaging cameras, and 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 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.

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

Pennsylvania, Harold Rinko, the owner-operator of Global Parts Supply, pleaded guilty to 

conspiracy to illegally smuggle laboratory equipment, including items used to detect chemical 

warfare agents, from the U.S. to Syria. 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 
37

Kingdom, and thereafter transshipped to Syria. Previously, on Apr. 23, 2014, an indictment was 

unsealed charging three individuals, including Rinko, Ahmad Feras Diri of London, United 

Kingdom, 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. 

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. 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 

Mar. 14, 2013 and extradited to the United States by the United Kingdom on Nov. 12, 2015. He 

was arraigned in the Middle District of Pennsylvania on Nov. 13, 2015. 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.

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

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

assessment. Previously, on Jun. 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 Dec. 29, 2007 and Dec. 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 F-16 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 Dec. 29, 2007, and Dec. 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.

DuPont Trade Secrets to China – On Aug. 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 Jul. 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 
38

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 Mar. 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 

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 
39

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

On May 6, 2015, Christina Liew pled guilty to conspiracy to tamper with evidence and was 

sentenced on Oct. 10, 2015 to 3 years’ probation, $100 special assessment, $25,000 fine and 

$6,029,391 restitution. Chao, a former DuPont employee, pleaded guilty to conspiracy to commit 

economic espionage on Mar. 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 Aug. 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 Sep. 2009 and Aug. 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 F-14 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.

Electronics to UAE and Africa – On Aug. 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 Dec. 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 Jan. 2008 and Apr. 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.
40

Pressure Transducers with Nuclear Applications to China and Elsewhere – On Jul. 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 Oct. 16, 2013 for his role in a conspiracy scheme to export dual-use pressure 

transducers from the United States to China. Previously, on Jun. 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. 

Information Technology Services and Support to Iran – On Jul. 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 Feb. 28, 2014 

to a superseding indictment. On Apr. 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 Sep. 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 Sep. 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 Sep. 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 
41

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 Jul. 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 Oct. 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 Jul. 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 Jun. 28, 2012, PWC, a Canadian subsidiary of Connecticut-based defense 

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 Jun. 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 Sep.

4, 2013, Bajestani pleaded guilty to violating the International Emergency Economic Powers Act 
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and filing false tax returns. On Feb. 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 Apr. 30, 2014, Yufeng 

Wei, a Chinese national, was re-sentenced to 23 months in prison, 2 years of supervised released, 

and $1100 special assessment. Previously, on Sep. 10, 2013, Wei’s now ex-husband 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 resentenced 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 Mar. 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 re-sentencing hearings. Wei and 

Wu were originally sentenced in 2011. Wei was sentenced on Jan. 27, 2011 in the District of 

Massachusetts to 36 months in prison, while on Jan. 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 
43

delivered to the Chinese military and other end-users, was also indicted. On Feb. 9, 2011, 

Chitron-Shenzhen received a fine of $1.9 million for refusing to appear for trial. On Jul. 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 Apr. 29, 2014, Li Fangwei, who is more 

commonly known by his alias “Karl Lee,” was charged in the Southern District of New York 

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 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, Fangwei 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 Iran-based 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 Dec. 18, 2013, and Apr. 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 
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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 Apr. 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 Nov. 2005 and Feb. 2008 to refurbish 18 T76 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 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 Oct. 2010. Roby was arrested in Florida on Sep. 4, 2013. 

Menegazzo-Carrasquel, a Venezuelan air force colonel, was arrested in Sep. 2012 after he arrived 

in Houston on a flight from Caracas, using his Italian passport. On Jun. 3, 2013, MenegazzoCarrasquel pleaded guilty and on Aug. 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 Oct. 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 Apr. 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 Mar. 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 Mar. 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 
45

the Eastern District of New York to 24 months in federal prison, 3 years supervised release and 

$100 special assessment. On Oct. 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 Dec. 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 Jul. 1, 2006, and Aug.

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 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. Co-conspirators Sahilal Sabaratnam, Thiruthanikan 

Thanigasalam, and Nadarasa Yograrasa were each sentenced in Sep. 2011. Sabaratnam was 

sentenced on Sep. 23, 2011 to 25 years’ imprisonment, 5 years supervised release, and $400 

special assessment. Yograrasa was sentenced on Sep. 23, 2011 to 14 years’ imprisonment, three 

years supervised release, and $200 special assessment. Thanigasalam was sentenced on Sep. 26, 

2011 to 25 years imprisonment, 5 years supervised release and $400 special assessment. 

Sathajhan Sarachandran was sentenced on Sep. 26, 2011 to 26 months’ imprisonment, 5 years 

supervised release, and $500 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 Mar. 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 Oct. 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 Oct. 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 Mar. 20, 2014, in the Western District of 

Texas, Oliver Bres-Carranza was sentenced to 51 months in federal prison after pleading guilty 

in Oct. 2013 for his role in a scheme to smuggle defense articles into the Republic of Mexico. On 

Jan. 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 
46

Jun. 2012 indictment with multiple counts of aiding and abetting the smuggling of goods from the 

United States. According to the indictment, between Jun. 19, 2010 and Feb. 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 highcapacity 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.

High-Tech Material Used in Missile Production and Nuclear Applications to Iran – On 

Mar. 1, 2016, Erdal Kuyumcu was arrested on charges of illegally exporting a cobalt-nickel 

metallic powder from the United States to Iran, through an intermediary in Turkey. The 

complaint, filed in the Eastern District of New York, alleges that Kuyumcu, a U.S. citizen and the 

CEO of Global Metallurgy LLC, twice exported a specialized metallic powder used in aerospace, 

missile production and nuclear applications. Exporting this specialized powder to Iran without a 

license from the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) is 

illegal. As detailed in the complaint, Kuyumcu and others conspired to obtain over a thousand 

pounds of the metallic powder from a U.S.-based supplier for export to Iran, without the requisite 

approval from OFAC. To conceal the true destination of the goods from the U.S. supplier, 

Kuyumcu and a co-conspirator arranged for the items to be shipped first to Turkey and 

subsequently to Iran. As described in the complaint, Kuyumcu and a co-conspirator used coded 

language when discussing Iran, such as calling Iran the “Neighbor,” referring to the fact that 

Turkey shares a border with Iran. This investigation was conducted by the Commerce Department 

and the FBI.

Hazardous Materials to Saudi Arabia - On Feb. 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 Jul. 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 

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 Nov. 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 Jun. 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 
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indictment against defendant MEDCHEM Corporation was dismissed on Jun. 26, 2013. The 

investigation was conducted by the FBI, Department of Commerce, IRS and Federal Aviation 

Administration.

Firearms Parts to Thailand - On Jan. 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 Jun. 2013 in connection with a 

conspiracy to illegally ship firearms parts to Thailand. In their Oct. 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. In Dec. 2013, 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, was sentenced in 

Feb. 2014 to 7 months imprisonment. This investigation was conducted by ICE HSI and the 

USPIS. 

Assault Weapon Parts and Gun Sights to Philippines - On Jan. 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 Jun. 10, 2013, 

Reclusado pleaded guilty to conspiracy to violate the Arms Export Control Act and the 

International Emergency Economic Powers Act. On Feb. 7, 2011, in the District of Arizona, 

codefendant Mike Cabatingan also pleaded guilty to conspiracy. On Feb. 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 Feb. 25, 2010. On Jan.

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 Jan. 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 Sep. 26, 2013, of Conspiracy to violate the International Emergency 

Economic Powers Act. According to the charges and other information presented in court, 

between Oct. 2006 and Jun. 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 
48

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 Jul. 2007, after Alexander 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.

Satellite Hardware and Technology to Iran - On Dec. 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 

Jun. 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 Oct. 27, 2005. The launch was the first-ever Iranian satellite put into orbit. 

Previously, on Jun. 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 Jan. 2000 

through Nov. 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 Jun. 8, 2010 in 

Maryland. The indictment was dismissed against the remaining defendants on Dec. 30, 2013. 

The investigation was conducted by ICE and the IRS.

Radiation-Hardened Circuits to China - On Dec. 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 Sep. 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 radiation-hardened 

computer circuits concealed inside plastic infant formula containers. The circuits are used in 
49

satellite communications and had a total value of nearly $550,000. He did not have a State 

Department license. A Dec. 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 Jul. 2011 and later traveled from 

Mexico to Shanghai in Sep.. In Oct. 2011, he received a second shipment of 200 circuits from 

Aeroflex. He drove to the Port of Long Beach in Dec. 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 Dec.

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 Dec. 11, 2011 at the Port. 

This investigation was conducted by ICE and DCIS and Defense Security Service.

Industrial Parts to Iran - On Dec. 18, 2013, Mehdi Khorramshahgol was sentenced in the 

Eastern District of Virginia to 36 months in prison. Khorramshahgol was convicted on Aug. 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 Apr. 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 Dec. 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 Aug. 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 Mar. 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 Jan. 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.
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Aerospace-Grade Carbon Fiber to China - On Dec. 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 Aug. 19, 2013, Zhang pleaded guilty to violating the International 

Emergency Economic Powers Act by attempting to export massive quantities of aerospace-grade 

carbon fiber from the United States to China. On Sep. 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 Jul. 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 Nov. 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 Jul. 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 Sep. 2004 and Apr. 2006, Sriskandarajah and several co-conspirators 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 Dec. 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.
51

Carbon Fiber and Other Materials to Iran and China - On Nov. 26, 2013, Peter Gromacki, a 

U.S. citizen and resident of Orange County, NY, was sentenced in the Southern 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 Jul. 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 Jun. 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 Jul. 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 Jul. 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 Dec. 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.

Military Accelerometers to China – On Nov. 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 Jan. 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 Dec. 7, 2011 and later arrested on Jan. 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 Aug.

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 Aug. and Oct. 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 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 Jan. 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.

Firearms to China - On Nov. 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 Oct. 4, 2012, Lin, pleaded guilty to 
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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 Sep. 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 Lilan Li, were also arrested 

and charged in connection with the case in an Apr. 16, 2012 indictment in the Eastern District of 

New York. Debose was sentenced on Jul. 19, 2013 to 24 months imprisonment, 3 years 

supervised release, and $100 special assessment. Li pleaded guilty on Jun. 12, 2012 and is 

scheduled to be sentenced in Jun. 2016. This investigation was conducted by ICE, ATF, IRS,

BIS, and DOJ’s National Security Division (Recker).

Circuit Boards Supplied to the U.S. Navy by Taiwan Company - On Oct. 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 

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 Sep.

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.

Surface-to-Air Missiles to Iran - On Oct. 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 Oct. 10, 2012, pursuant to a 
53

U.S. request for his provisional arrest. He was extradited to the United States on Mar. 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 Oct. 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 Oct.

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 

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 Oct. 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 Jun. 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 Apr. 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. 

Manhattan Office Building Secretly Owned and Controlled by Government of Iran - On Sep.

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 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 
54

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 Dec. 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 Sep. 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 Jun. 25, 2013. Fratila was extradited to the United 

States on Feb. 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 Oct. 17, 2006, Fratila and codefendant 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 Nov. 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 Jul. 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 Jul. 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 Sep. 2008. Ghassemi remains a fugitive. The 

investigation was conducted by ICE and DCIS.

Acoustic Transducer and Other Technology Through U.A.E. to Iran – On Sep. 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 Feb. 2010 and Sep.

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 
55

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.

Computer Components to Iran - On Aug. 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 Mar. 7, 

2013, a superseding indictment filed in the Eastern District of Virginia against an 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 Dec. 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 Dubai; 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 Aug. 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.
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Thermal Imaging Scopes and Cameras to Belarus - Aug. 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 Aug. 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 Jan. 2008, to 

early Aug. 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 

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 Jul. 19, 2013 to 57 months in prison after pleading guilty on Dec. 6, 2012. 

Dubouskaya was sentenced to 6 months in prison on Feb. 6, 2013 after pleading guilty on Nov. 7, 

2012. Stashynski was sentenced to 6 months in prison on Nov. 28, 2012 after pleading guilty on 

Feb. 28, 2013. Tsishuk was sentenced to 24 months in prison on Feb. 14, 2013 after pleading 

guilty on Oct. 28, 2011. Osin pleaded guilty on Feb. 29, 2012.

Satellite Technology to Iran - On Aug. 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 Oct. 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 Aug. 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 Dec. 11, 2012 and pleaded guilty on 

Apr. 2, 2013 for violations of the International Emergency Economic Powers Act. According to 

the Indictment, in Mar. 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 Sep. 2012 without obtaining the requisite 

Commerce Department export license. This investigation was conducted by ICE.

Military Night Vision Equipment to New Zealand - On Jul. 11, 2013, in the District of 

Maryland, Anthony Torresi was sentenced to 18 months in prison followed by 3 years of 
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supervised release for unlawfully exporting military grade night vision equipment. According to 

his plea agreement on Feb. 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 Jan. 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 Feb. 11, 2011 from Miami, Florida to New Zealand. 

The shipping label signed by Torresi falsely showed the contents as a "gift" described as a 

"Rangefinder" valued at $70. Torresi never applied for a license to export these items. Similarly, 

on Mar. 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 Apr. 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 Jun. 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 Aug. 22, 2012, and convicted on Feb. 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 Nov. 2010 and Jul. 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 Jun. 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 Apr. 6, 2011, Regan and Alig 

both pleaded guilty on Jan. 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 Mar. 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 Dec. 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 Mar. 9, 2012, the indictment against Arias was dismissed. This investigation 

was conducted by ATF and ICE.
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Prohibited Exports to Iran - On Jun. 12, 2013, Markos Baghdasarian was sentenced in the 

District of South Carolina to 36 months in prison. Previously, on Dec. 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 required licenses and 

with making false statements. He was later indicted on Jun. 14, 2012. According to the charges, 

Baghdasarian served as the manager of Delfin Group USA, a Russian-owned producer of 

synthetic motor oils, located in North Charleston, South Carolina. From as early as Jun. 13, 2010, 

until Oct. 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.

Trade Secrets to India – On Jun. 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 Apr. 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 Nov. 14, 2011, 

Mohapatra was arrested on a criminal complaint in the District of Utah (filed on Nov. 10, 2011) 

charging him with stealing proprietary information from his employer, Frontier Scientific, 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.

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 Mar. 29, 2013, Ma reached out to 

undercover law enforcement officers in Feb. 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.
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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 Feb. 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 Mar. 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 Sep. 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 Jul. 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 

$250,000. Previously, on Oct. 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 

Oct. 28, 2010, for violating the Arms Export Control Act and conspiracy. The indictment alleged 

that beginning in Nov. 2005 through Feb. 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 T76 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 Feb. 4, 2013, Bishop was convicted in a bench trial in the Eastern 

District of Virginia of violating the Arms Export Control Act. In Aug. 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 
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the possession of firearms on Jordanian territory without a permit issued by the Public Security 

Directorate. 

Fighter Jet Components to Iran - On Apr. 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 Dec. 11, 2012. According to the 

indictment, Mohabat sent an email in Feb. 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 Oct. 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 Apr. 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 

Nov. 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 Nov. 2012. Qin was 

also convicted of wire fraud and obstruction of justice. The evidence at trial showed that from 

Dec. 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 

Jan. 2005, she copied more than 16,000 GM files, including trade secret documents, to 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 

information 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 Apr. 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 Feb. 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 Jul. 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 Jan. 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 
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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 Mar. 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 Apr. 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 Jul. 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 Sep. 4, 2012 and pleaded guilty on Dec. 11, 2012 to attempting to violate IEEPA. 

The investigation was conducted by ICE and BIS.

Military Technical Data and Trade Secrets to China - On Mar. 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 Sep. 26, 2012, Liu was convicted 

of nine of 11 counts of an Apr. 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 Nov. 12, 2010, Liu boarded a flight from Newark to China. 

Upon his return to the United States on Nov. 29, 2010, agents found Liu in possession of a nonwork-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 
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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 Mar. 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.

Aircraft and Aircraft Components to Iran - On Mar. 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 

U.S. to Iran. On Dec. 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 Aug. 2007 and continuing 

through Apr. 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 Sep. 2009 through Apr. 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 Jun. 1, 2012, while Karimian was arrested and made his initial 

appearance in federal court in Louisville on Jun. 6, 2012. This investigation was conducted by the 

FBI.

Ballistic Vests and Ammunition to Mexico - On Feb. 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 Dec. 2012, Ayala pleaded guilty to one count of facilitating the smuggling of 

goods from the United States. Ayala admitted that from Sep. 1, 2009, to Dec. 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 Jan. 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 
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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 

meetings in Kansas City were a sting operation that led to their arrests on Sep. 2, 2012. The case 

was investigated by the FBI. 

Military Lasers to Canada - On Jan. 23, 2013, Joel Stone was sentenced in the Western District 

of Texas to 24 months imprisonment. Stone previously pleaded guilty on Mar. 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 Feb. 2, 2012 

after being charged in a sealed criminal information on Jan. 12, 2012.

Sensitive Microwave Amplifiers to China and India - On Jan. 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 Oct. 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 Aug. 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.

Hawk Air Defense Missile Batteries to Iran - On Jan. 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 Nov. 1, 2012, admitting that from Dec. 2005 to Jan. 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 Oct. 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 specificallydesignated 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 Jan. 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 Feb. 7, 2007. He was extradited from the 
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United Kingdom to the United States for prosecution on Feb. 24, 2012. On Nov. 9, 2007, his codefendant 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 Aug. 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 Dec. 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 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 Dec. 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 Dec. 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 Dec. 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 Nov. 15, 2011, guilty plea by Xun Wang to conspiracy to violate IEEPA. Wang 

also reached a settlement with the Commerce Department on Nov. 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 Jun. 16, 2011, in Atlanta. On 

Jun. 7, 2011, a grand jury in the District of Columbia returned a sealed indictment against her. 

Wang was ultimately sentenced on Dec. 20, 2012, to one year and one day in prison in connection 
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with the scheme. According to Huaxing's plea documents, in Jan. 2006, PPG Industries sought an 

export license for the shipments of coatings to Chashma II. In Jun. 2006, the Department of 

Commerce denied that license application. Following that denial, Huaxing and its coconspirators agreed upon a scheme to export, re-export and transship the high-performance 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 Jun. 2006 through 

around Mar. 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 Dec. 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 Aug. 27, 2012, was arrested in Mar. 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 Dec. 2011, was charged in a Mar. 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 Dec. 2009 and Feb. 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 Nov. 30, 2012, Andro Telemi, a naturalized U.S. citizen 

from Iran who resided in California, was 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 Jul. 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 Dec. 2009, along with Davoud Baniameri, an Iranian citizen who 

lived in Woodland Hills, Calif. A superseding indictment returned in Jul. 2010 charged Telemi, 

Baniameri and Syed Majid Mousavi, an Iranian citizen living in Iran. According to court 

documents, sometime before Oct. 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 Aug. 12, 2011 to 51 

months in prison. Mousavi remains a fugitive. This investigation was conducted by ICE, DCIS, 

BIS, and IRS. 
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Military Antennas to Iran - On Nov. 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 Oct. 10, 2012 and the United States is seeking his 

extradition. According to the indictment, which was returned under seal on Nov. 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 Jul. and Sep. 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.

Military Aircraft Parts to Iran - On Nov. 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 Oct. 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 Oct. 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 Jul. 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 Mar. 2010, Cisneros also 
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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 Jan. 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 Oct. 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 Nov. 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 Mar. 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 Apr. 2, 2004, Fushine exported the 

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 Apr. 1, 2009. A 

superseding indictment was returned on Feb. 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 Mar. 24, 2010, but that were not included in 

the superseding indictment. On Oct. 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 Oct. 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 Jul. 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 Jul. 27, 2012, Freddy 

Arguelles, a former Venezuelan Air Force pilot living in the U.S., pleaded guilty to conspiracy to 

violate the AECA. On Jul. 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 

Jun. 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 Nov. 2008 through Aug.

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 
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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 Oct. 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 Jun. 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 Jul.

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 Foomanie using Ansari's company in Dubai. Foomanie and Ansari remain 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 Oct. 9, 

2007, to Jun. 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 Oct. 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 Jun. 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 Caulfield in connection with the investigation. 

This investigation was conducted by ICE.

Sensitive Military Encryption Technology to China – On Oct. 19, 2012, Chi Tong Kuok, a 

resident of Macau, China, was sentenced in the Southern District of California to time served. 

Previously, on Jul. 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, 
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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 Jun. 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 Jun. 23, 2009 

and an indictment returned on Jul. 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 Sep. 13, 2010, Kuok was sentenced to 96 months in prison. Kuok 

appealed and on Jul. 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 Oct. 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 Jul. 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 Oct. 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.

Theft of Trade Secrets for Potential Use in China - On Sep. 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 Jun. 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 

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 
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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 Sep. 28, 2011. This investigation was conducted by the FBI.

Motorola Trade Secrets to China - On Aug. 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 Feb. 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 Feb. 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 Feb. 2006. 

Between Jun. and Nov. 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 Nov. 2006 and Feb. 2007, Jin returned to China and did work for Sun Kaisens 

on projects for the Chinese military. On Feb. 15, 2007, Jin returned to the United States from 

China and reserved a flight to China scheduled to depart on Feb. 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 Feb. 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 Apr. 1, 2008 indictment. A superseding indictment returned on Dec. 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 Aug. 23, 2012, Jean Gordy Gedeon, a national of Haiti, was sentenced in 

the Middle District of Florida to 46 months imprisonment. Previously, on Jun. 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 

Aug. 22, 2012, Mexican national David Diaz-Sosa was sentenced in the District of Arizona to 25 

years in prison after pleading guilty on Apr. 19, 2011, to several violations related to his 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 Feb. 17, 2010, Diaz-Sosa and Jorge DeJesus-Casteneda were arrested as 
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they sought to finalize the weapons exchange with undercover agents. Diaz-Sosa, DeJesusCastaneda, and an additional defendant, Emilia Palomino-Robles, were charged in a sealed 

indictment on Mar. 16, 2010. Palomino-Robles pleaded guilty on Apr. 13, 2011 to one drug 

violation, stemming from her role as a money and drug courier in the weapons-for-drugs 

transaction. On Apr. 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 Aug. 3, 2011 to 146 months in prison and five years’

supervised release. Palomino-Robles was sentenced on Mar. 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 Aug. 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 Nov. 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 Jun. 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 

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 Sep. 29, 2010. The investigation was conducted by ICE.
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Military-Grade Riflescopes Overseas - On Jul. 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 

Dec. 6, 2011, indicted on Feb. 22, 2012 and pleaded guilty Mar. 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 Jul. 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 Mar. 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 Oct. 2008 through Jan. 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 export of two Twister Speed 

Lathes as well as nickel alloy 120 wire from the U.S. through China to Iran. On Oct. 1, 2014, a 

Suggestion of Death Order was signed by the Court regarding Khaki. Yi remains a fugitive. This 

investigation was conducted by ICE. 

Carbon Fiber Material to Iran - On Jun. 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 Jan. 18, 2012. According to court filings, in Oct. 
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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 Oct. 21, 2011. This investigation was 

conducted by ICE and the DCIS.

$619 Million Fine Against ING Bank for Transactions with Iran and Cuba - On Jun. 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 Jun. 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.

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 Feb. 6, 2012 to conspiracy to defraud 

the United States by facilitating the illegal export of goods to Iran. Davis was first arrested on 

Aug. 6, 2011. In Oct. 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 Nov. 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 
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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 Dec. 15, 2011, Majid Saboni pleaded guilty to a one-count 

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 Oct. 14, 2011 and was later 

arrested on Oct. 24, 2011. The information against him was filed on Nov. 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 Feb. 1, 2012 to a two count criminal information. The criminal information, 

dated Dec. 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 Jul. 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 

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 Jan. 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 Aug. 2006 through Jun.

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 

Oct. 2008 and Jun. 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 Jun. 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 Jun. 3, 

2009, at the Toronto International Airport pursuant to a provisional arrest warrant issued by U.S. 
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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 Dec. 1, 2012. According 

to court documents, in Apr. 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 Apr. 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 Jul. 18, 2011, in the 

Central District of California to violations stemming from his illegal exports of thermal imaging 

cameras to Hong Kong and China. Liang was first indicted on Jun. 2, 2010. An Aug. 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 Liang 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 Apr. 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 Sep. 8, 2010 to arms export violations. In Jun. 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 Apr. 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 Nov. 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 Mar. 5, 2008 by Thai authorities in Bangkok, Thailand. On Nov. 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 Nov. 2007 and Mar. 2008, Bout agreed to sell to the FARC millions 

of dollars' worth of weapons - including 700 - 800 surface-to-air 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 
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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 Mar. 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 Aug. 1, 2010 to one count of conspiracy to violate the Arms Export Control 

Act. In pleading guilty, Shor admitted that, beginning in Jul. 2009 until about Apr. 21, 2010, he 

conspired with others to illegally export 4,000 Gluck 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 Apr. 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 Aug. 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 Sep. 22, 2010, both Shor and Yao were charged in a 

superseding indictment in the Northern District of California with one count of conspiracy to 

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 Oct. 4, 2011 to conspiracy to violate the Arms Export Control Act and was sentenced on 

Nov. 22, 2011 to one year and one day in prison. The investigation was conducted by ICE.

Military Gyroscopes and Other Technology to Iran - On Feb. 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 
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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 Feb. 24, 2012, Andrew Silcox was sentenced to 

24 months in prison after pleading guilty on Dec. 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 Oct. 21, 2011. This 

investigation was conducted by ICE and DCIS.

Computer-Related Technology to Iran - On Feb. 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 Oct. 7, 2011. Three 

related defendants have also pleaded guilty in the case. On Feb. 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 

monetary penalty. On May 16, 2012, Habibion was sentenced to 13 months in prison, while 

Motamedian was sentenced to three years supervised release. On Apr. 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.

Military Antennae to Hong Kong & Singapore - On Jan. 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 Dec. 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 Jul. and Sep. 2007 of 55 military antennae 

from the United States to the Hong Kong and Singapore addresses of a 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 
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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 Jan. 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 Feb. 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 Jan. 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 Mar. 2, 2011. 

Greenoe was first charged by criminal complaint with Arms Export Control Act violations and 

other charges on Jul. 26, 2010. A 50-count superseding indictment returned on Feb. 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 Feb. 22, 

2010, to Jul. 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 Oct. 2010; as well as in the murder 

of Ian Langford, a father of four children, in Scotland on Apr. 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 Jan. 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 Sep. 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 

Mar. 11, 2010. According to his plea agreement, from Oct. 2005 through Mar. 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 
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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 Jan. 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 Apr. 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 Apr. 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 Jul. 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 Dec. 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 Oct. 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 Sep. 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 Jun. 16, 2010, Huang was 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 Oct. 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 Jan. 2003 until Feb. 2008, Huang was 
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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 Mar.

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 Jul. 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 Dec. 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 Dec. 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 Nov. 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 Jan. 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 Nov. 10, 2011 to 14 months in prison. Chun was 

charged in a criminal information on Jan. 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 Mar.

2000 and Nov. 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 email 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 Dec. 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 Aug. 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 on its behalf 

committed any offense under U.S. laws in this case. Doxer was a former employee of Akamai 

Technologies, Inc., who in Jun. 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 Sep. 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. 
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From Sep. 2007 through Mar. 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 Oct. 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 Dec. 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 Sep. 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 Aug. 3, 2011 and was later sentenced on Oct. 24, 

2011 to 24 months in prison and two years’ supervised release. On Mar. 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 Mar. 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 Mar. 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 Dec. 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 Aug. 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 Nov. 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 Apr. 28, 2011. On Sep. 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 Oct. 2008 and Sep. 2009 and then sold these items to 

customers via eBay, an Internet auction and shopping website. The indictment further 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.
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Radiation-Hardened Defense and Aerospace Technology to China - On Oct. 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 Mar. 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 Dec. 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 wiretransferred $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 Oct. 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 Jan. 14, 2011 to one count of violating the Arms 

Export Control Act. In Mar. 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 Jul. 15, 2010, Fermanova was arrested (pursuant to 

a Jul. 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 Sep. 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 Jun. 1, 2011. The defendants 

were arrested on Sep. 1, 2010 in Budapest by Hungarian authorities pursuant to a U.S. provisional 

arrest warrant. On Apr. 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 Apr. 2009 to Sep. 1, 2010, the defendants contacted a Virginia company 

seeking to purchase and export thousands of Programmable Read-Only Microchips (PROMs). 

The defendants ultimately attempted to purchase 40 PROMs from 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 Sep. 26, 2011, Chan Hok Shek was 

sentenced in the District of Massachusetts to 3 1⁄2 years in prison for conspiring to obtain 
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components for C-130 military flight simulators from the United States for delivery to Iran. On 

Mar. 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 Oct. 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 Sep. 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 Apr. 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 Aug. 2004 to Mar. 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 Sep. 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 

Jan. 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 Nov. 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 Aug. 24, 2011, in the District of Maryland, Connor Kraegel 

was sentenced to 8 months imprisonment and three years’ supervised release. On Jul. 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.

Fighter Jet Parts to Singapore - On Aug. 22, 2011, Russell Marshall was 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 Jun. 3, 2011. On Apr. 21, 2011, a criminal information was 
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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. On Apr. 24, 2015, Marshall’s probation was revoked. He was resentenced to six 

months imprisonment. This investigation was conducted by ICE. 

Automatic Rifles and Plastic Explosives to the FARC - On Aug. 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 Feb.

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 Aug. 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 role in 

a conspiracy to violate and violating the Arms Export Control Act and possessing short barrel 

rifles. ODonnell pleaded guilty on Feb. 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 exportcontrolled 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 Jul. 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 Nov. 8, 2011 to 

time served. Hua was first charged on Feb. 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 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 Feb. 10, 2011 after he arrived at the Los Angeles airport. He was later 

indicted on Mar. 10, 2011, on charges of smuggling and Arms Export Control Act violations. 

The investigation was conducted by ICE.
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Machine Gun Specifications and Components to China - On Jul. 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 Aug. 2004 to about Jul. 2009. On 

Nov. 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 Jul. 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 Sep. 22, 2010. The investigation was conducted by ICE, CBP, and ATF.

Vacuum Pumps With Potential Sensitive Applications to Iran - On Jul. 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 Dec. 30, 2009 and arrested in Jan. 2010. He pled 

guilty in Jul. 2010. Another individual involved in the conspiracy, Amirhossein Sairafi, of Iran, 

was arrested in Jan. 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 Sep. 2010, pled guilty on Nov. 30, 2010, and was sentenced to 41 months in Mar. of this 

year in connection with the scheme. Sairafi was first charged in a Jan. 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 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 Dec. 2007 and Nov.

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 
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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 Jun. 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 Jun. 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 Oct. 26, 2011 to 46 months in prison, a $10,000 fine and ordered to forfeit $160,362. He was 

resentenced on Oct. 24, 2012 decreasing his time in prison to 35 months. Seifi and his company 

pleaded guilty on Feb. 24, 2011, to conspiracy to violate the AECA and violating the IEEPA. On 

Jun. 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 Jun. 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 Jun. 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 Feb. 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 Nov. 30, 2010. Ghaemi was sentenced on Jun. 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 

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 
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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 Sep. 16, 2010, Hussein Ali Asfour also 

pleaded guilty. Previously, on Nov. 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-Jun. 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 Jul. 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 Nov. 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. De

Greef was arrested in the United Kingdom pursuant to a Mar. 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 Feb. 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 

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 
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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 Apr.

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 Aug. 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 Jun. 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 Apr. 13, 2011, Xiang Dong Yu, aka Mike 

Yu, was sentenced in the Eastern District of Michigan to 70 months in prison. Previously, on 

Nov. 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 Dec. 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 Dec. 20, 2006, 

Yu traveled to the location of his new employer in Shenzhen, China, taking the Ford trade secrets 

with him. On Jan. 2, 2007, Yu emailed his Ford supervisor from China and informed him that he 

was leaving Ford's employ. In Nov. 2008, Yu began working for Beijing Automotive Company, 

a direct competitor of Ford. On Oct. 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 Mar. 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 Apr. 12, 2011, the Justice Department announced that a government 

motion to dismiss the remaining deferred criminal charge against ITT Corporation, the leading 

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 
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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 Mar. 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 Feb. 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 Aug. 2016. The investigation was conducted by 

the ATF and ICE.

Assault Rifles and Explosives For Export - On Mar. 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 Jan. 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 Dec. 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 Aug. 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 Aug. 30, 2010. 

Urbay was arrested on Sep. 6, 2010 in Miami. The investigation was conducted by the FBI.

Fighter Jet Components to Iran - On Mar. 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 Jun. 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 Jan. 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 Mar. 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 Nov. 2009, Khalili 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 Feb. 1, 2011, an indictment returned on 

Jul. 21, 2010, was unsealed in the District of Columbia charging Milad Jafari, an Iranian citizen 
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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 Feb. 2004 through Aug. 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 Jul. 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. fiber-optic 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 Jan. 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 Aug. 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. 

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 Jul. 2003 to Jun. 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 
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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 Jan. 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 

Dec. 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 Feb. 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 Jan. 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 Dec. 14, 

2010 to 12 months and a day in prison followed by 24 months of supervised release. On Oct. 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 Apr. 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 Jun. 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 Jan. 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 

attempting to sell a bullet-proof vest on E-bay. In May and Jun. 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 Oct. 12, 2011. The investigation was conducted by ICE.

Iran Embargo Violations - On Jan. 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 
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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 Mar. 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 Jan. 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 

Oct. 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 Feb. 2, 2011, co-defendant 

Ibrahim A. Omer received a judgment of acquittal for his alleged role in the conspiracy. Codefendant 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 Jan. 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 Dec. 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 Jul. 21, 2011. On Jul. 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 

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.
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Valspar Trade Secrets to China - On Dec. 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 Sep. 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 Sep. 2008 and Feb. 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 Mar. 27, 2009. He did not inform Valspar that he had 

accepted a job at Nippon until he resigned on Mar. 16, 2009. Between Nov. 2008 and Mar. 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 Nov. 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 Sep. 2008 and May 2010. On Mar. 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 Nov. 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 Dec. 2010 

on charges that included violations of the Arms Export Control Act. Rama pleaded guilty on 

Mar. 9, 2011 to failure to notify a commercial carrier of a firearm and exporting defense articles 

without a license. He was sentenced on Jul. 21, 2011 to 18 months in prison. This investigation 

was conducted by ICE.

DuPont Trade Secrets to China - On Oct. 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 Jun. 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 

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 Jun. 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 Aug.

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 
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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 Oct. 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 Apr. 15, 2009, in Fort Lauderdale, Fla., 

and subsequently indicted on Apr. 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 

Mar. 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 Oct. 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 Dec. 16, 2010. Beginning in Feb.

2006, Naidu and his co-conspirators attempted to purchase state of the art weaponry from China, 

Thailand, North Korea, the Philippines 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 Apr. 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 Sep. 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 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, 
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pleaded guilty to export and money laundering violations in Jan. 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 Apr. 2007 to 12 months and 1 day in prison. Subandi was later 

sentenced in Dec. 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 Nov.

23, 2009, Monsieur pleaded guilty to conspiracy to illegally export F-5 fighter jet engines and 

parts from the United States to Iran. He and co-conspirator Dara Fatouhi were first charged by 

indictment on Aug. 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 Aug. 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 e-mails 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.

U.S. Missile Components to Iran - On Aug. 27, 2010, in the Southern District of Florida, Yi-Lan 

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 Sep. 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 Feb. 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.

Nuclear-Related Equipment to Iran - On Jul. 29, 2010, Mahmoud Yadegari was sentenced in a 

Canadian court in Toronto to four years and three months in prison for attempting to export 
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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 Mar. 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 Jul. 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 Jul. 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 Sep. 20, 2011 to five years supervised release and a $10,000 fine. Chou-Fu Ho was 

arrested on Jun. 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.

F-5 Fighter Jet Components to Iran - On Jul. 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 Jul. 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 Jun. 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 Jun. 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 Apr. 2005 and Oct. 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 
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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 

Mar. 17, 2010. The case was investigated by ICE and DCIS.

Illegal Oil Transaction with Iraq - On Jun. 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 Dec. 2002 without the required U.S. government license. AlHanooti was previously charged in a Feb. 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 Mar. 2011, AlHanooti 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 

for the same activity. Sam Lee was sentenced on Feb. 18, 2011 to 12 months in prison and a 

$10,000 fine, while Charles Lee was sentenced on Dec. 15, 2010 to 6 days in prison and a $3,000 

fine. The Lees were arrested on Dec. 30, 2008 in Hacienda Heights, Ca, pursuant to a Dec. 16, 

2008 indictment charging them with conspiracy to export and exporting national securitycontrolled 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 Apr. 2002 and Jul. 2007, defendants allegedly exported a total of ten thermalimaging 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. 

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 Feb. 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 

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 
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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 Dec. 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 Mar. 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 Apr. 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 Aug. 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 Sep. 12, 

2008. The investigation was conducted by ICE and DCIS.

U.S. - Origin Tools to Libya - On Mar. 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.

BAE Systems PLC Pleads Guilty and Ordered to Pay $400 Million - On Mar. 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 Mar. 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. 
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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 Feb. 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 Jun. 15, 2010, Estiven pled guilty to conspiracy to 

smuggle firearms and was sentenced on Aug. 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 Sep. 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 Feb. 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 Mar. 2007 through Jan. 2008, freight-forwarders Talavera, through Transamerica, and 

Gonzalez-Neira, through Jumbo, exported Sony brand electronics, including Play station 2 

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 Dec. 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 
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guilty on Sep. 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 Oct. 1, 2010 to conspiracy violations. Talavera and Transamerica Express of 

Miami pleaded guilty to conspiracy violations on Oct. 20, 2010. On Jan. 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 Aug. 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 Feb. 11, 2010 

former Rockwell and Boeing engineer Dongfan "Greg" Chung was sentenced to 188 months 

imprisonment and three years’ supervised release after his Jul. 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 Feb. 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 Jan. 11, 2010, Ali Amirnazmi, of Berwyn, PA, was 

sentenced in the Eastern District of Pennsylvania to 48 months in prison for his Feb. 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 Oct. 2008 with crimes relating to his participation from 

1996 to Jul. 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 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 Jul. 25, 

2008. The case was investigated by the FBI and IRS.

Military Equipment to Yemen, Libya & Other Locations - On Jan. 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 
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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.

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