UNITED STATES OF AMERICA

v.

SAEID HAJI AGHA MOUSAEI,

FARAMARZ PAIEZI, also known as "Albert Smit,"

JULIE IMELDA LACAR PASION, and

MILLENNIUM PRODUCT COMPANY, LLC, also known as "MPC"

COUNT ONE

The SPECIAL AUGUST 2017 GRAND JURY charges:

1. At times material to this indictment:

a. Defendant MILLENNIUM PRODUCT COMPANY, LLC, also known as "MPC," was a registered company in the United Arab Emirates with an office located in Dubai.

b. Defendant SAEID HAJI AGHA MOUSAEI was a resident of Iran and held an Iranian passport. Defendant MOUSAEI was a manager of defendant MILLENNIUM PRODUCT COMPANY, LLC.

c. Defendant JULIE IMELDA LACAR PASION was a resident of the United Arab Emirates and held a Filipino passport. Defendant PASION assisted in operating defendant MILLENNIUM PRODUCT COMPANY, LLC.

d. Defendant FARAMARZ PAIEZI, also known as "Albert Smit," operated as an agent of defendant MILLENNIUM PRODUCT COMPANY, LLC. 

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