INDICTMENT

The Grand Jury charges that:

COUNT ONE

At all times material to this Indictment:

INTRODUCTION

1. Defendant BAHRAM MAHMOUDI MAHMOUD ALILOU, also known as BAHRAM ARAN (hereinafter “ARAN”), was a citizen of Iran and resident of Azerbaijan. Defendant ARAN was an owner and managing director of ARAN MODERN DEVISES KISH COMPANY (hereinafter “AMD”), a company located in Iran, which procured goods on behalf of Iranian customers. Defendant ARAN also conducted business as an employee of defendant MODERN TECHNOLOGIES (FZC). As part of his responsibilities, Defendant ARAN procured U.S.-origin goods for Iranian customers.

2. Defendant ASGHAR MAHMOUDI (hereinafter “MAHMOUDI”), was a citizen and resident of Iran. Defendant MAHMOUDI was an owner and managing director of AMD, a company located in Iran, which procured goods on behalf of Iranian customers. As part of his responsibilities, Defendant MAHMOUDI procured U.S.-origin goods for Iranian customers.

3. Defendant SHAHIN GOLSHANI (hereinafter “GOLSHANI”) was a resident of the United Arab Emirates (“U.A.E.”). Defendant GOLSHANI was the General Manager of defendant MODERN TECHNOLOGIES (FZC). As part of his responsibilities, defendant GOLSHANI received U.S.-origin goods from the United States and elsewhere, and then shipped those goods to customers located in Iran.

4. Defendant MODERN TECHNOLOGIES (FZC), also known as MODERN TECHNOLOGIES, (hereinafter “MODERN TECHNOLOGIES”) was a company that procures U.S.-origin goods on behalf of foreign customers. Defendant MODERN TECHNOLOGIES was located in the U.A.E., with a mailing address of No. 29, Building Y, SAIF-Zone, Shaxjah, U.A.E., P.O. Box 8032.

[...]