Iranian-U.S. Citizen Pleads Guilty to Evading Sanctions

On June 28, a dual Iranian-U.S. citizen pleaded guilty to conspiring to export goods and technology to the Central Bank of Iran (CBI). U.S. export laws prohibit procuring equipment for the CBI, which was sanctioned for providing support to terrorist organizations. Kambiz Attar Kashani, age 44, and his co-conspirators, used two front companies based in the United Arab Emirates to procure equipment and software between February 2019 and June 2021. Kashani lied to multiple companies based in the United States about the intended destination of the goods.

Kashani was arrested by the Federal Bureau of Investigation in Chicago on January 14, 2022. He later agreed to pay a $50,000 fine, in addition to any forfeiture owed. He faces a maximum penalty of 20 years in prison. The following are Department of Justice press releases on his plea and his arrest.

 

June 28, 2022

U.S. Citizen Pleads Guilty to Conspiring to Provide Electronic Equipment and Technology to the Government of Iran

Defendant Conspired to Illegally Export U.S. Goods and Technology Without Required Export Licenses

A dual citizen of the United States and Iran pleaded guilty today to conspiring to illegally export U.S. goods, technology and services to end users in Iran, including the Government of Iran, in violation of the International Emergency Economic Powers Act (IEEPA). 

DoJ sealAccording to court documents, Kambiz Attar Kashani, 44, and his co-conspirators, using two United Arab Emirates companies, evaded U.S. export laws between February 2019 and June 2021 by procuring electronic goods, technology and services from U.S. technology companies for end users in Iran without obtaining required licenses or other authorization from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Kashani acted at the direction of an arm of the Central Bank of Iran (CBI). CBI has been designated by OFAC for having materially assisted, sponsored or provided financial, material or technological support to known terrorist organizations.

Kashani faces a maximum penalty of 20 years in prison, and he has agreed to pay a $50,000 fine, in addition to any forfeiture owed. A federal district court judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.

U.S. Attorney Breon Peace for the Eastern District of New York, Assistant Attorney General Matthew G. Olsen for the Justice Department’s National Security Division and Special Agent in Charge Joseph R. Bonavolanta of the FBI’s Boston Field Office made the announcement.

Assistant U.S. Attorneys Alexander A. Solomon and Meredith A. Arfa of the Eastern District of New York are in charge of the prosecution, with assistance provided by Trial Attorney S. Derek Shugert of the National Security Division’s Counterintelligence and Export Control Section.

 

January 18, 2022

U.S. Citizen Charged with Conspiring to Provide Electronic Equipment and Technology to the Government of Iran

Defendant Allegedly Conspired to Illegally Export U.S. Goods and Technology without Required Licenses

A dual Iranian-U.S. citizen was arrested Friday in Chicago, on criminal charges related to his alleged conspiracy to illegally export U.S. goods, technology and services to end users in Iran, including the government of Iran, in violation of the International Emergency Economic Powers Act (IEEPA).

According to court documents, Kambiz Attar Kashani, 44, conspired to illegally export goods and technology to the Central Bank of Iran (CBI), which the U.S. government recognizes is an agency of the government of Iran.

“Kashani and his co-conspirators procured U.S.-origin goods and information technology for ultimate use in Iran, including for use by the Government of Iran,” said Assistant Attorney General Matthew G. Olsen of the Justice Department’s National Security Division. “Kashani repeatedly lied to numerous U.S. companies to conceal his intention to ship items to Iran, allowing him to illegally obtain information technology for use by the CBI and other Iranian entities. The Justice Department continues to do everything it can to end the illegal export of items that threaten our national security.”

“As alleged, Kashani orchestrated an elaborate scheme to evade U.S. export laws and use the U.S. financial system in procuring U.S. electronic equipment and technology for the CBI, which has been designated by the United States government as acting for or on behalf of terrorist organizations,” said U.S. Attorney Breon Peace for the Eastern District of New York. “The defendant allegedly used two United Arab Emirates companies as fronts to procure items from multiple U.S. technology companies, including a company in Brooklyn. Kashani’s arrest underscores the unrelenting resolve of this office and the Department of Justice to prosecute those who seek to profit by compromising our national security.”

“Technology illegally transferred to Iran from the United States could be used by terrorists, which is why the FBI and its partners devote significant resources to these investigations,” said Assistant Director Alan E. Kohler Jr. of the FBI's Counterintelligence Division. “Those doing the bidding for Iran in the United States should expect the full force of our law enforcement and Intelligence Community partners.”

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has classified CBI as a Specially Designated National (SDN) signifying that CBI is acting for or on behalf of a terrorist organization. According to the U.S. government, CBI has materially assisted, sponsored and provided financial, material or technological support, goods or services to Lebanese Hizballah, a terrorist organization, and to the Qods Force of Iran’s Islamic Revolutionary Guards Corps (IRGC). The IRGC is a branch of the Iranian armed forces and represents the primary means of the Government of Iran to direct and implement its global terrorism campaign.

Kashani allegedly perpetrated the illegal transshipping scheme through two separate United Arab Emirates (UAE) front companies for which he acts as principal. From around February 2019 through June 2021, Kashani and his co-conspirators used the two UAE companies to procure electronic goods and technology from multiple U.S. technology companies, including a company located in Brooklyn, New York, for end users in Iran, including CBI, without obtaining required OFAC export licenses. Kashani and his co-conspirators intentionally concealed from the U.S. companies that they intended to ship the items to Iran, falsely claiming that the UAE front companies would be the ultimate end users.

Kashani is charged with one count of conspiracy to unlawfully export goods to Iran, and will make his initial court appearance in the Northern District of Illinois this afternoon. If convicted, he faces a maximum penalty of 20 years’ imprisonment and a $1 million fine. A federal district court judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.

The FBI is investigating the case.

Assistant U.S. Attorneys Alexander A. Solomon and Meredith A. Arfa for the Eastern District of New York; Assistant U.S. Attorney Shawn McCarthy for the Northern District of Illinois; and Trial Attorney S. Derek Shugert of the National Security Division’s Counterintelligence and Export Control Section are prosecuting the case.

A complaint is merely an allegation, and all defendants are presumed innocent until proven guilty beyond a reasonable doubt in a court of law.