The Grand Jury charges that:

COUNT ONE-CONSPIRACY

At all times material to this Indictment:

Introduction

1. Sunarko Kuntjoro ("KUNTJORO") was an Indonesian citizen, who is the majority owner and President Director of PT MS Aero Support ("PTMS"), an Indonesian company based in Jakarta, Indonesia. Another shareholder and Director of PTMS is Person C, who is related to KUNTJORO.
2. PT Kandiyasa Energi Utama ("PTKEU") was an Indonesian company based in Jakarta, Indonesia. The Technical Director of PTKEU is Person D, who is related to KUNTJORO.
3. PT Antasena Kreasi ("PTAK"), was an Indonesian company based in Jakarta, Indonesia. PTAK is controlled by KUNTJORO and Person D.
4. Mustafa Oveici was an Iranian citizen, who is an executive for Mahan Air ("Mahan"), an Iranian airline company based in Tehran, Iran.
5. Conspirator A was a person living and working in the United States who was the owner of Conspirator B, a company incorporated and operating in the United States.

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