Also Known As:
- United States
An Iranian government engineering company connected to Iran's Ministry of Defense. (This entity is distinct from KSP International located in Dubai, United Arab Emirates.)
Involved in a conspiracy to procure U.S.-origin goods, services, and technology with both military and non-military applications without the required licenses; also involved in the conspiracy were KSP employee Reza Rejali, Iranian-born Canadian Ghobad Ghasempour, Chinese businessman Yi Xiong, several Chinese front companies, including Modo International, Todi Enterprises, and IBC Trade Co., as well as Turkish businessman Gokdan Gokdat and his company, Gokdat Foreign Trade Consultancy, Portuguese national Paolo Vicente and his company, Firstfield Engineering, and Portuguese engineer Joao Manuel Pereira Da Fonseca.
Beginning in September 2013, conspired with Rejali, Ghasempour, and Xiong in an attempt to procure a $93,000 thin film measurement system (ECCN 3A999.f) from a U.S. company, using funds from Modo's bank account; in June 2014, the system was intercepted in the Netherlands; procured a less advanced thin film measurement system in April 2015 following a payment from Modo to Gokdat Foreign Trade.
In 2014, asked Firstfield to procure multiple high-end machines from the United States and Germany, including two German-origin Optotech machines, one German-origin Taylor Hobson Luphoscan machine, and one U.S.-origin Nanotech 250 UPL (ultra-precision lathe); rented a warehouse for Firstfield in Portugal in order to demonstrate a legitimate end-use location for the machines; received the two Optotech machines in the first half of 2014; did not receive the Nanotech 250 UPL, which was seized by the U.S. Department of Homeland Security's Homeland Security Investigations (HSI) in February 2016.
From June 2014 to July 2015, conspired with Rejali, Ghasempour, Xiong, Fonseca, and Vicente, using Firstfield Engineering, in an attempt to purchase a 2002PG-28-TL-SR120 two-axis positioning and rate table (ECCN 2B120) with missile applications from a U.S. company; the U.S. company was granted a license to export the machine through its Spanish distributor Alava Ingenieros to Firstfield Engineering in Portugal; in March 2016, Fonseca traveled to the United States for training on the table's operation and was detained by HSI when he attempted to return to Portugal; the table was not exported to KSP.
From January 2015 to March 2016, conspired with Rejali, Ghasempour, Xiong, and Vicente to procure TAU 2 640 9Hz (ECCN 6A993) and TAU 2 640 30Hz (6A003.b.4.b) thermal imaging cameras from a U.S. company; ten cameras were exported to KSP in early 2015 through Todi in China; 100 cameras were exported to KSP between August 2015 and March 2016, through Firstfield Engineering and several of the front companies in China.