The Government respectfully submits this memorandum in advance of the sentencing of defendant Behzad Pourghannad, which the Court has set for Wednesday, November 13, 2019 at 9:30 a.m. The defendant pled guilty to one count of conspiracy to violate the International Emergency Economic Powers Act (“IEEPA”) for his central role in a five-year scheme to illegally export high-grade carbon fiber from the United States to Iran for use in Iran’s weapons of mass destruction (“WMD”) program. Pursuant to the plea agreement, the parties agree that the applicable United States Sentencing Guidelines range is 46 to 57 months’ imprisonment.

In his sentencing submission, the defendant offers a number of arguments for why the Court should impose a below-Guidelines sentence of time served (approximately 30 months’ imprisonment). Among other things, the defendant contends that there is “no evidence” that he endorsed the use of WMDs; that his arrest and incarceration have caused distress to his friends and family; and that a below-Guidelines sentence would not result in unwarranted sentencing disparities. (Def. Mem. 7-10).

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