From in or about November 2013 through in or about April 2018, in Morris County, in the District of New Jersey and elsewhere, the defendant, PEYMAN AMIRI LARIJANI, a/ k/ a "Paymen Larijani" did knowingly and intentionally conspire and agree with others known and unknown to export, re-export, sell and supply, and attempt to export, reexport, sell and supply, goods, to wit: aircraft components, directly or indirectly from the United States to Iran, without first obtaining the required export control licenses from the Office of Foreign Assets Control, in violation of Title 50, United States Code, Sections 1702 and 1 705; and Title 31, Code of Federal Regulations, Sections 560.203, 560.204, 560.205, and 560.208.

From in or about November 2013 through in or about April 2018, in Morris County, in the District of New Jersey and elsewhere, the defendant, PEYMAN AMIRI LARIJANI, a/k/ a "Paymen Larijani" did knowingly and intentionally conspire and agree with others known and unknown to transmit and transfer monetary instruments and funds from a place outside the United States, to wit, Turkey and Iran, to a place in the United States, to wit, New Jersey, with the intent to promote the carrying on of specified unlawful activity, namely the smuggling of aircraft components from the United States contrary to Title 18, United States Code, Section 554(a), and contrary to Title 18, United States Code, Section 1956(a)(2)(A), in violation of Title 18, United States Code, Section 1956(h).

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