Iranian National Charged With Illegally Exporting Electrical Equipment to Iran

Sep 01, 2023

WASHINGTON – A federal grand jury in the District of Columbia returned an indictment today charging an Iranian national with the unlawful export of electrical cables and connectors from the United States to Iran, through Hong Kong. According to court documents, Mehdi Khoshghadam, a.k.a. "David Lei," and "Pouyan," an Iranian national residing in Tehran, Iran, was indicted by a grand jury in the U.S. District Court for the District of Columbia on one count of conspiracy, one count of violation of the International Emergency Economic Powers Act (IEEPA), and one count of conspiracy to commit money laundering. The indictment also includes a forfeiture allegation seeking all proceeds of the alleged crimes. A warrant has been issued for Khoshghadam's arrest and he remains a fugitive.

The charges were announced by United States Attorney Matthew M. Graves, Assistant Attorney General Matthew G. Olsen of the Justice Department's National Security Division, Special Agent in Charge Sean Fitzgerald of the Homeland Security Investigations Chicago Field Office, and Special Agent in Charge Aaron Tambrini of the Department of Commerce's Chicago Field Office, Office of Export Enforcement.

According to the indictment, Khoshghadam is the Managing Director of Pardazan Systems Namad Arman, an Iranian importer of electronics and other goods. In 2016, Khoshghadam began purchasing electrical connectors and cables from a U.S. Company, which were shipped to a freight forwarding company located in Hong Kong and then shipped to Iran. Khoshghadam used an alias of "David Lei" when communicating with the U.S. Company and a front company called Merlin International Trading Company, purported to be located in Singapore, to order the goods from the U.S. company. During one of the initial purchases of goods from the U.S. Company, Khoshghadam attempted to pay for the goods using a different name, but the U.S. Company informed him that its bank had rejected the payment because the payor name needed to be the same as the company submitting the order. Khoshghadam then contacted a co-conspirator located in China and had that person inform the U.S. Company that the co-conspirator was Khoshghadam's agent and would handle payment for the goods.

As alleged in the indictment, between January of 2016 and May of 2018, Khoshghadam, posed as a representative of the Singapore front company and submitted orders for the cables and connectors on at least three occasions to the U.S. Company. Khoshghadam and a co-conspirator used front companies located in China and Malaysia to make payments to the U.S. Company for the goods in order to conceal the true identity of the purchaser as Khoshghadam and that that the goods were destined for Iran. At the direction of Khoshghadam, the U.S. Company shipped the goods to a freight forwarding company located in Hong Kong, at which time the goods were repacked with falsified shipping records that listed a non-U.S. company as the shipper and the end destination as Iran. As further alleged in the indictment, on at least one occasion, Khoshghadam falsified a Department of Commerce, Bureau of Industry and Security form BIS-711, which requires the purchaser of U.S. goods to specify the identity and location of the true end user of the purchased goods. Khoshghadam falsely listed a China based company as the end user of the goods instead of listing that the true end user was located in Iran.

"Those who damage our national security by doing end-runs around sanctions and illegally exporting U.S. goods will find themselves facing serious charges," said U.S. Attorney Graves. "The U.S. Attorney's Office for the District of Columbia and our federal law enforcement partners will zealously pursue those who break these vital national security laws, regardless of where in the world they operate."

"It is important that the public understands the seriousness of these types of crimes," said Special Agent in Charge Fitzgerald. "This isn't a case of small illegal purchases of harmless products, but instead an attempt to conceal much larger criminal activities; activities that could funnel funds to other organized criminal networks."

"The diversion of U.S.-origin goods to Iran, including through front companies in third countries, and falsifying end-user information enabling shipments to prohibited end users, will be vigorously investigated," said Special Agent in Charge Tambrini. "The Office of Export Enforcement, working with our interagency law enforcement partners, is committed to investigating violations of BIS export control rules and prosecuting the individuals involved, as appropriate, whether in the U.S. or abroad."

The cables and connectors purchased by Khoshghadam required a license from the Department of the Treasury, Office of Foreign Assets Control ("OFAC") to be exported from the United States to Iran. No license authorizing the export of the cables and connectors was ever issued by OFAC to Khoshghadam or any other person or entity associated with these transactions. Khoshghadam also made, or caused to be made, three separate money transfers from bank accounts located in China, Malaysia, and elsewhere to bank accounts in the United States or by using U.S. correspondent banks with the intent to promote the unlawful exports to Iran described above.

Charges of conspiracy carry a statutory maximum of five years in prison. Violations of the IEEPA and the money laundering conspiracy charge carry a statutory maximum of 20 years in prison. The charges also carry potential financial penalties. A federal district court judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.

This case is being investigated by Homeland Security Investigations (HSI) Chicago Field Office and the Chicago Field Office of the Department of Commerce's Office of Export Enforcement. Assistant U.S. Attorney Steven B. Wasserman for the U.S. Attorney's Office in the District of Columbia and Trial Attorney Beau Barnes of the National Security Division's Counterintelligence and Export Control Section are prosecuting the case, with substantial assistance provided by Assistant U.S. Attorney Thomas Gillice.

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