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17. From approximately October 2000, and continuing to approximately March 2004, the defendants Cohen, Q.P.S., Wheels, P. AD., in the District of Connecticut and elsewhere, did knowingly, willfully and unlawfully combine, conspire, confederate and agree with others known and unknown to the Grand Jury, to cause the export from the United States of military defense articles listed on the United States Munitions List without a valid license or proper authorization from the United States Department of State, contrary to Title 22, United States Code, Section 2278.

Manner and Means of the Conspiracy

18. Among the means and methods employed by the defendants to carry out the conspiracy and effect its unlawful objects were those set forth below:

19. Cohen, who was living and doing business in Israel, used U.S.-based brokers to acquire and send United States Munition List items, which were manufactured in the United States and controlled for export by the Department of State, to Cohen and P. AD. in Israel.

20. Leib Kohn and "SW" served as U.S.-based brokers for Cohen.

21. Kohn and SW failed to obtain the necessary licenses and approvals for the exports to Cohen.

22. Kohn and SW made false and misleading statements to the parts suppliers and on the export documentation concerning the ultimate destination of the items, their value, and their true nature.

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Count Seven

On or about December 19, 2012, the defendant Eliyahu Cohen, a/k/a Eli Cohen, who was living in Israel and doing business as Q.P.S. Ltd., Wheels, Inc., P.AD. Ltd., and R.S.P. Spare Parts Ltd., within the District of Connecticut and elsewhere, did knowingly and willfully violate and cause to be violated the United States trade restrictions with Iran by exporting, reexporting, selling, and supplying, and attempting to export, reexport, sell, and supply a United States-origin defense article, that is, a Constant Speed Drive, P/N: 695145G, for the F-4C aircraft fighter jet, an item designated as a defense article on the United States Munitions List, to Iran, via Athens, Greece without having first obtained the required authorization from the Department of Treasury.

In violation of Title 50, United States Code, Sections 1701-1707; 31 Code of Federal Regulations, Sections 560.204, 560.205, and 560.701; and Title 18, United States Code, Section 2.

Count Eight

On or about March 3, 2013, the defendant Eliyahu Cohen, a/k/a Eli Cohen, who was living in Israel and doing business as Q.P.S. Ltd., Wheels, Inc., P. AD. Ltd., and R.S.P. Spare Parts Ltd., within the District of Connecticut and elsewhere, did knowingly and willfully export, reexport, and retransfer, or attempt to reexport, and retransfer, or cause to be reexported, and retransferred, from Israel to Iran, via Athens, Greece, a United States-origin defense article, that is, a Sensor Outline, Absolute Pressure, P/N: 949470-6-1, for the F-14 aircraft fighter jet, which item is designated as a defense article on the United States Munitions List, without having first obtained from the Department of State a valid license or written authorization for such reexport or retransfer.

In violation of Title 22, United States Code, Sections 2278(b) (2) and 2278(c); 22 Code of Federal Regulations, Sections 121.1, 123.1, 123.9, and 127.1; and Title 18, United States Code, Section 2.

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