The United States of America, by and through the undersigned counsel, submits this Sentencing Memorandum. Defendant Behrooz Behroozian (“Behroozian”) plead guilty to all counts as alleged in an Information filed on September 9, 2016 for violation of 50 U.S.C. § 1705 and 31 C.F.R. §§ 560.203 and 560.204, Violation of the Emergency Economic Powers Act (IEEPA).

For over a decade, Behroozian exported and caused the exportation of American-made Swagelok manifolds, valves, and connectors used for industrial pipelines in the gas and petrochemical (oil refinement) industry to the Islamic Republic of Iran (“Iran”) in deliberate violation of a U.S. embargo and trade sanctions. In so doing, Behroozian not only displayed a blatant disregard for the law on an international scale, but did so by making a calculated decision to sell-out the United States to its enemies abroad for $35,000 to $40,000 per-year. Behroozian also attempted to cover-up his crimes by using Sumar Industrial Equipment (the “Sumar” company) as a middle man company when illegally supplying industrial equipment to an Iranian company called Arman Pisaro Sanao (the “Arman” company). In other words, not only did  Behroozian use his considerable skills and expertise to do the bidding of one a state sponsor of terrorism, he also tried to conceal his criminal career with over a decade of deceit.

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