IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Holding a Criminal Term
Grand Jury Sworn in on January 8, 2016
The Grand Jury charges that:
At all times material to this Indictment:
1. Defendant GHOBAD GHASEMPOUR ("GHASEMPOUR") is an Iranian-bom Canadian national.
2. Defendant GHASEMPOUR worked with three front companies, identified herein as the "Company I," "Company M," and "Company T" (collectively, "the three fiont companies"). The three front companies are located in China, and were operated and managed by defendant GHASEMPOUR and two coconspirators, identified herein as "Coconspirator A" and "Coconspirator B."
3. ''Coconspirator A" is a Chinese national who lives in China.
4. "Coconspirator B" is an Iranian national who lives in Iran. "Coconspirator B" works lbr a company in lran, identified herein as the "lranian Company," which, among other things, procures goods, services and technology from companies in the United States, without first oblaining a license from the United States govemment, as required by laws of the United States.
Read the full indictment below.