On October 7, 2020, in the U.S. District Court for the District of New Jersey, Joyce Marie Eliabachus (‘‘Eliabachus’’) was convicted of violating 18 U.S.C. 371. Specifically, Eliabachus was convicted of knowingly and intentionally conspiring and agreeing with others known and unknown to export, re-export, sell and supply and attempting to, re-export, sell and supply aircraft components, directly or indirectly from the United States to Iran, including to Mahan Air, without first obtaining the authorization from the Office of Foreign Assets Control, in violation of 18 U.S.C. 371.

As a result of her conviction, the Court sentenced Eliabachus to 18 months in prison, one year of supervisor release, and a $100 court assessment.

Pursuant to Section 1760(e) of the Export Control Reform Act (‘‘ECRA’’), the export privileges of any person who has been convicted of certain offenses, including, but not limited to, 18 U.S.C. 371, may be denied for a period of up to ten (10) years from the date of his/her conviction. 50 U.S.C. 4819(e) (Prior Convictions). In addition, any Bureau of Industry and Security (BIS) licenses or other authorizations issued under ECRA, in which the person had an interest at the time of the conviction, may be revoked.

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