The defendant having waived in open court prosecution by indictment, the United States Attorney for the District of New Jersey charges:

• At all times relevant to this Information:
  • Defendant JOYCE MARIE ELIABACHUS, a/k/ a "Joyce Marie Gundran Manangan," ("ELIABACHUS") was a resident of New Jersey. ELIABACHUS was the principal officer and operator of Edsun Equipments LLC, a/k/a Edsun Equipment LTD ("Edsun Equipments"), a privately-held New Jersey business that purportedly traded in aviation equipment parts. Edsun Equipments was headquartered at ELIABACHUS' residence ("the New Jersey Address"), which residence had no commercial or manufacturing facilities or capabilities.
  • Peyman Amiri Larijani ("Larijani") was a citizen and resident of Iran. Larijani was the operations and sales manager for several purported foreign aviation supply and engineering companies including, among others: (i) Asa Ekvator Aviation, located in Tehran, Iran, and Istanbul, Turkey (formerly known as Kral Havacilik le Ve Dis Ticaret Sirketi, doing business as Kral Aviation Company); (ii) Blue Clouds Aviation, located in Tehran, Iran; (iii) Sun Bright Havacilik le Ve Dis Tic, also known as Sun Bright Aviation, located in Tehran, Iran; (iv) Pelikano Gida le Ve Dis Ticaret, located in Istanbul, Turkey; and (v) Tango le Ve Dis Tic LTD, located in Istanbul, Turkey (collectively, the "Iranian Network").

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