The Government respectfully submits the following Statement of Facts in support of a plea of guilty by David Levick ("the defendant") to Counts Two through Five of the Indictment in the above-captioned matter.

I. Elements of the Offense

To sustain a conviction for a violation of the International Emergency Economic Powers Act ("IEEPA") at 50 U.S.C. 1701, et seq. and the Iranian Transaction Regulations ("ITR") at 31 C.F.R. Part 560, at trial, the government must prove the following elements:

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