The Government respectfully submits this Memorandum in advance of the sentencing of defendant Hamid Reza Hashemi, which the Court has set for Friday, November 15, 2013 at 3:00 p.m. The defendant pled guilty to one count of conspiracy to violate the International Emergency Economic Powers Act (“IEEPA”) and two counts of substantive violations of IEEPA for his critical role in a scheme to illegally export high-grade carbon fiber from the United States into Iran. Pursuant to the plea agreement, the parties agree that the applicable Sentencing Guidelines range is 46 to 57 months’ imprisonment.

In his sentencing submission, Hashemi offers a number of arguments for why he is seeking a below-Guidelines sentence of a year and a day. Among other things, Hashemi contends that he cannot stay in touch with his family as much as he would like, that he had “limited involvement” in the conspiracy and that “He only thought he was helping a friend,” that he supposedly abandoned one aspect of the conspiracy at the last minute, and that a sentence that is 75 percent below the bottom of the Guidelines range sentence would serve the objective of deterrence well.

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