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The Grand Jury charges that:
At all times material to this Indictment:
- Defendent MAHMOUD REZA ELYASSI ("ELYASSI") was an Iranian national who ordinarily resided in Iran. ELYASSI control Company C-1 and Company C-2, both of which conducted their business operations in Iran. Company C-1 was a customer of Standard Chartered Bank's ("SCB" or "the Bank") branch office in Dubai ("SCB Dubai") from around December 2006 through February 2011. Company C-2 was a customer of SCB Dubai from around February 2011 through September 2011. Both Company C-1 and Company C-2 conducted U.S. dollar financial transactions through the United States using their accounts at SCB Dubai.
- SCB was headquartered in London, United Kingdom, with branch offices around the world including in the United Arab Emirates ("UAE") and in New York, NY. The Bank's branch office in New York provided wholesale banking services, including U.S. dollar clearing services for international wire transactions.
- Person A worked at SCB's branch office in Dubai ("SCB Dubai") as a Relationship Manager from 2007 through 2014. As a relationship manager, Person A was the main point of contact between the bank and numerous small and medium enterprise ("SME") companies that were in his portfolio. Person A interacted with his customers frequently: answering questions, conducting research, and representing the customer's interests to other SCB components (e.g., the foreign exchange desk).