Over a two-year period, Arash Jam, his brother Amin Jam, and Abdollah Momeni lied to American companies, purchased more than $100,000 in sophisticated American goods, and shipped those goods through the United Arab Emirates (UAE) to Iran in violation of U.S. sanctions. Arash and his team told the U.S. companies that they were working on behalf of the Iraqi Government or that the final destination of the goods was the UAE, even though Arash and his team knew all along that the goods were destined for Iran.

When companies confronted Arash and his team about the ultimate destination—stating that they believed that the goods were destined for Iran—the coconspirators created fake paper trails to “show” that the goods were destined for the UAE or simply found other sellers. In other instances, Arash and his team were more forthright about the goods’ ultimate destination. For example, when a U.S. shipping company made it clear that a license from the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) was required to ship the goods to Iran, as the coconspirators had requested, Amin Jam asked if there was a way around the requirement or if the U.S. shipping company could recommend another shipping company that would fulfill the order. When the U.S. company responded “no” to both questions, the conspirators found Iranian and global shipping companies willing to bypass U.S. sanctions—and then coordinated the shipping logistics in a manner to intentionally hide the ultimate destination from the American companies.

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