United States of America v. Baoxia Liu, Yiu Wa Yung, Yongxin Li, and Yanlai Zhong

January 30, 2024

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The Grand Jury charges that:
At times material to this indictment:
1. These charges arise from an illicit scheme by Defendants BAOXIA LIU ("LIU"), YIU WA YUNG ("YUNG"), YONGXIN LI ("LI"), and YANLAI ZHONG ("ZHONG"), acting through companies based in the People's Republic of China ("PRC" or "China"), to procure U.S.origin
dual-use goods for end users in Iran, in violation of U.S. export control and sanctions laws. The ultimate end users in Iran were entities connected to Iran's Islamic Revolutionary Guard Corps ("IRGC") that manufactured and produced products for Iran's military programs.
2. Since at least 2007, LIU, YUNG, LI, and ZHONG have conspired together and with others to use PRC-based companies to procure dual-use commodities directly from U.S.based companies for the ultimate benefit of end users in Iran. LIU, YUNG, LI, and ZHONG routinely misrepresented the ultimate end users of these U.S.-origin commodities and caused the reexport of these commodities from China to Iran. The procured dual-use commodities included products that could be utilized in the production of unmanned aerial vehicles ("UAVs"), ballistic
missile systems, aerospace products, and other military systems.