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Prison Sentence, Substantial Fine Possible for Unlicensed Exports to Iran

Monday, October 31, 2016
Sandler, Travis & Rosenberg Trade Report

The Department of Justice announced Oct. 27 that an Iranian national has pleaded guilty to taking part in a conspiracy involving the purchase and shipment of various products, including aviation parts and supplies, from the U.S. to Iran without a license. Under federal sentencing guidelines the man faces a likely range of 46 to 57 months in prison and a potential fine of $20,000 to $200,000 when he is sentenced Dec. 14.

According to a DOJ press release, the man acknowledged that beginning in October 2005 Iranian companies requested that he (through his company) procure products for export to Iran. These products included a fiber optic video transmitter and receiver and aviation course indicators, which required a license from the Treasury Department’s Office of Foreign Assets Control. In October 2007 the Bureau of Industry and Security issued a temporary denial order prohibiting the man and his new company from participating, directly or indirectly, in any way in any transaction involving any commodity exported from the U.S. Nevertheless, the man and other conspirators exported and attempted to export numerous materials from the U.S., including resin, sealant, paint, pneumatic grease, film adhesive, and polyurethane coating and thinner, after the issuance of the TDO.

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