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I, Alexander A. Miris, being first duly sworn, hereby depose and state as follows:
INTRODUCTION AND AGENT BACKGROUND:
- I make this affidavit in support of an application for a criminal complaint and arrest warrant charging Aiden DAVIDSON (a/k/a Hamed ALIABADI), with the offense of Conspiracy to violate the International Emergency Economic Powers Act (“IEEPA”), 50 U.S.C. § 1705(a), (c), and the Iranian Transactions and Sanctions Regulations (“ITSR”), 31 C.F.R. Part 560.
- As shown herein, there is probable cause to conclude that DAVIDSON, between in or about March 2014 and until at least in or about February 2017, willfully conspired with others known and unknown to export and cause to be exported, directly or indirectly, from the United States to the Islamic Republic of Iran, heavy machinery equipment that included Department of Defense (DOD) surplus items, without prior authorization from the United States Department of Treasury, Office of Foreign Assets Control (OFAC), and to engage in transactions that evade or avoid, or have the purpose of evading or avoiding, any of the prohibitions contained in the ITSR, including prohibitions against the unauthorized exportation of goods from the United States to a third country if the goods are intended or destined for Iran.