Background

The Department of Justice reports that a former salesman of a multinational company with a U.S.-based subsidiary has been sentenced to 44 months in prison for conspiring to export millions of dollars of U.S.-made goods to Iran.

According to a DOJ press release, the man was convicted of conspiring with individuals affiliated with a company based in Iran to export heavy machinery indirectly to Iran without first obtaining the required licenses from the Office of Foreign Assets Control. The conspirators located an Iraq-based distributor to serve as the forward-facing purchaser from the U.S. subsidiary, which hired a U.S. freight forwarder to arrange the export to the purported ultimate destination of Iraq. The man thus caused the forwarder to enter false information about the shipment into the Automated Export System because the items were shipped to Turkey with the intent to transship or reexport them to Iran in circumvention of U.S. export control and sanction laws.

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