President of New York-Based Company Arrested for Conspiring to Violate U.S. Sanctions against Iran

Michael Rose Allegedly Sold More Than $350,000 in Goods to an Iranian Importer in Violation of U.S. Sanctions and Allegedly Committed Related Money Laundering and Bank Fraud Crimes
April 6, 2021

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Audrey Strauss, the United States Attorney for the Southern District of New York, William F. Sweeney Jr., Assistant Director-in-Charge of the New York Office of the Federal Bureau of Investigation (“FBI”), and Jonathan Carson, Special Agent in Charge of the New York Field Office of the U.S. Department of Commerce, Office of Export Enforcement (“DOC-OEE”), announced today the unsealing of charges against MICHAEL ROSE for conspiring to violate the International Emergency Economic Powers Act (“IEEPA”), and participating in bank fraud and money laundering conspiracies.  ROSE was arrested by the FBI and OEE today, and he will be presented later today in Manhattan federal court before United States Magistrate Judge Stewart D. Aaron.

Manhattan U.S. Attorney Audrey Strauss said:  “As alleged, Michael Rose participated in a years-long scheme to violate our sanctions by surreptitiously exporting cosmetics to Iran via front company intermediaries in the Middle East.  Today’s charges underscore that those who violate our sanctions on Iran will be investigated and prosecuted.” 

FBI Assistant Director William F. Sweeney Jr. said:  “Whatever his motivation – greed or something more sinister – we allege Mr. Rose intentionally disguised his products’ ultimate destination and lied about those products’ prices to limit his customs liability.  It’s a federal crime to violate sanctions the United States put in place to protect our national interests from Iran and other designated nation states.  Mr. Rose may have thought the rules didn’t apply to him, but, if he did, today’s action demonstrates otherwise.”

DOC-OEE Special Agent in Charge Jonathan Carson said:  “The Office of Export Enforcement will vigorously enforce sanctions violations involving Iran, including actions by exporters to undermine the integrity of our export control system through the submission of false or misleading information.  The Office of Export Enforcement will continue applying the investigative resources and authorities necessary to protect and promote U.S. national security, foreign policy, and economic interests.”

According to the Indictment unsealed today in Manhattan federal court:

MICHAEL ROSE is the president of a Long Island-based cosmetics manufacturer and supplier (“Company-1”).  In that role, ROSE manages, among other things, Company-1’s operations and its international sales business.  Between 2015 and 2018, ROSE participated in a conspiracy to evade U.S. sanctions on Iran by causing Company-1 to export from the United States more than $350,000 worth of cosmetics to an importer in Iran (“Importer-1”).  In or about June 2015, ROSE signed a contract with Importer-1 establishing that Importer-1’s Iran-based company would be the exclusive distributor for Company-1’s products in Iran.  Importer-1 then used front companies based outside Iran to make payments to Company-1 in New York and to arrange for the transshipment of Company-1’s goods to Iran via the United Arab Emirates.  In addition to shipping goods and accepting payments in violation of U.S. sanctions, ROSE also filed false and misleading information on United States Department of Commerce Shipper’s Export Declaration forms in connection with the illegal shipments.  The forms falsely represented that the “ultimate consignee” for the goods was in the United Arab Emirates, not Iran, and also falsely lowered the purchase price for the goods purchased by Importer-1 in order to evade customs payments.

ROSE, 50, of Ridgefield, Connecticut, is charged in the Indictment with (1) conspiring to violate IEEPA, in violation of 50 U.S.C. § 1705, which carries a maximum sentence of 20 years in prison; (2) conspiring to launder money, in violation of 18 U.S.C. § 1956(h), which carries a maximum sentence of 20 years in prison; and (3) conspiring to commit bank fraud, in violation of 18 U.S.C. § 1349, which carries a maximum sentence of 30 years in prison.  The statutory penalties are prescribed by Congress and are provided here for informational purposes only, as any sentencing of the defendant would be determined by the judge.

Ms. Strauss praised the outstanding efforts of the FBI and the Department of Commerce’s Bureau of Industry and Security (“BIS”) for their assistance.

This prosecution is being handled by the Office’s Terrorism and International Narcotics Unit.  Assistant U.S. Attorney Sam Adelsberg is in charge of the prosecution, with assistance from Trial Attorney Scott Claffee of the Counterintelligence and Export Control Section of the Department of Justice’s National Security Division.