The Grand Jury charges that:
COUNT ONE- CONSPIRACY
At all times material to this Indictment:
1. Defendant ARASH SEPEHRI, also known as “William Anderson,” (hereinafter ASEPEHRI@), was an Iranian citizen residing in the Republic of Iran. Defendant SEPEHRI was the owner and managing director of defendant TAJHIZ SANAT SHAYAN, also known as Tajhiz Sanat Company, (hereinafter “TSS”), a company operating in Tehran, Iran. As part of his responsibilities, defendant SEPEHRI ordered U.S.-origin goods for Iranian customers.
2. Defendant TSS was a company which arranged for the transshipment of goods through third countries to Iran on behalf of Iranian customers. Defendant TSS has a listed address of No. 40, Yazdanpanah Street, Afriqa Blvd, Tehran, Iran. 3. Known members of the conspiracy include, but are not limited to, the following individuals: (1) OMIDEREZA KHADEMI (hereinafter KHADEMI), a citizen of Iran, living in the United Arab Emirates (U.A.E.), who is businessman, and owner of OMID GNERAL TRADING LLC (hereinafter “OMID LLC”), a company based in the United Arab Emirates (“U.A.E.”), and (2) an Iranian citizen who owns and operates Company B, another Iranian Supply Company (Conspirator B). DEFENDANT TSS and Company B were listed by the European Union on May 23, 2011, as entities who were being sanctioned for their involved in the procurement of components for the Iranian nuclear program. Defendant SEPEHRI was notified of these sanctions on or about May 25, 2011.
Read the full indictment below.