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In or about and between February 2019 and June 2021, both dates being approximate and inclusive, within the Eastern District of New York and elsewhere, the defendant KAMBIZ ATTAR KASHANI, together with others, did knowingly and willfully conspire to cause the export, re-export, sale and supply, directly and indirectly, of goods, technology and services, to wit: two subscriptions to a proprietary computer software program; several fixed attenuators; two subscriptions to operating software; six power supplies; and several storage systems, from the United States to Iran and the Government of Iran, without having first obtained the required licenses or other authorization from the U.S. Department of the Treasury Office of Foreign Assets Control, contrary to Title 50, United States Code, Section 1705.

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