Background

The Department of Justice reports that an Australian man has been sentenced to 24 months in prison for exporting electronics to Iran. The man has also been ordered to pay a forfeiture amount of $199,227, which is the total value of the goods involved in the illegal transactions.

According to a DOJ press release, the man pleaded guilty to four counts of violating the International Emergency Economic Powers Act. Specifically, he solicited purchase orders and business from a representative of a trading company in Iran who also operated and controlled companies in Malaysia that acted as intermediaries for the Iranian company. The man then placed orders with U.S. companies for the goods, which were aircraft parts and other items that the Iranian representative could not have directly purchased from the U.S. without the permission of the U.S. government.

When necessary, DOJ states, the Australian man used a broker in the U.S. through whom orders for the parts could be placed to further conceal that they were intended for transshipment to Iran. The man intentionally concealed the ultimate end-use and end-users of the parts from manufacturers, distributors, shippers, and freight forwarders in the U.S. and elsewhere. In addition, he and others structured payments between each other to avoid trade restrictions imposed on Iranian financial institutions by other countries.

For more information on avoiding violations of U.S. sanctions laws and regulations, , please contact Kristine Pirnia at (202) 730-4964.

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