COMES NOW, Plaintiff the United States of America (the “United States”), by and through the United States Attorney for the District of Columbia, which brings this verified complaint for forfeiture in a civil action in rem against the defendant properties, namely all petroleum-product cargo aboard: the Bella with International Maritime Organization (“IMO”) number 9208124 (“Defendant Property 1”), the Bering with IMO number 9149225 (“Defendant Property 2”), the Pandi with IMO 9105073 (“Defendant Property 3”), and the Luna with IMO number 9208100 (“Defendant Property 4”) (collectively, the “Defendant Properties”), and alleges as follows.

NATURE OF ACTION AND THE DEFENDANT IN REM

1. This in rem forfeiture action arises out of an investigation by Homeland Security Investigations (“HSI”) and the Federal Bureau of Investigation (“FBI”). Specifically, the United States is investigating Iran’s transportation and sale of oil products to benefit sanctioned Iranian entities. This action seeks to forfeit petroleum that is aboard four ships en route from Iran and destined for Venezuela.
2. The Defendant Properties are subject to seizure and forfeiture pursuant to 18 U.S.C. § 981(a)(1)(G)(1), as foreign assets: (i) of the Islamic Revolutionary Guard Corps (“IRGC”), a designated foreign terrorist organization, which has engaged in planning and perpetrating federal crimes of terrorism as defined in 18 U.S.C. § 2332b(g)(5) against the United States, citizens or residents of the United States, or their property; or (ii) affording a person a source of influence over the IRGC.

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