The U.S. Department of Justice reports that four Chinese nationals have been charged in an indictment in the District of Columbia with various federal crimes related to a years-long conspiracy to unlawfully export and smuggle U.S.-origin electronic components from the U.S. to Iran.

According to Justice, beginning as early as May 2007 and continuing until at least July 2020 the defendants used an array of front companies in China to funnel dual-use U.S.-origin items, including electronics and components that could be utilized in the production of unmanned aerial vehicles, ballistic missile systems, and other military end uses, to sanctioned Iranian entities with ties to the Islamic Revolutionary Guard Corps and the Ministry of Defense and Armed Forces Logistics.

Justice adds that throughout the course of the conspiracy the defendants concealed the fact that the goods were destined for Iran and Iranian entities and made material misrepresentations to U.S. companies regarding the end destination and end users. These deceptive practices ostensibly caused the U.S. companies to export goods to the defendants’ China-based front companies under false pretenses and under the guise that the ultimate destination of these products was China as opposed to Iran. As a result, a vast amount of dual-use U.S.-origin commodities with military capabilities were exported from the U.S. to Iran in violation of U.S. sanctions and export control laws and regulations.

The defendants have been charged with conspiring to violate the International Emergency Economic Powers Act, violating the IEEPA, and smuggling goods from the U.S., as well as one count of submitting false or misleading export information. If convicted, they face a maximum penalty of 20 years in prison for violating the IEEPA, up to 10 years in prison for smuggling goods from the U.S., and up to five years in prison for each count of conspiracy and submitting false or misleading export information.

For more information on export and sanctions penalties and how to avoid them, please contact attorney Kristine Pirnia via email.

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