United States of America v. Shaoyun Wang, Mahmood Rashid Amur Al Habsi

January 25, 2024

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The Grand Jury charges that, at times material to this Indictment:


(Conspiracy to Violate IEEP A)


1. Between December 2019 and July 2021, the Islamic Republic of Iran ("Iran") and Chinese government-owned entities engaged in an illicit scheme to facilitate the sale oflranian oil to the People's Republic of China ("China"), ultimately for the benefit of the Islamic Revolutionary Guard Corps ("IRGC") Qods Force ("QF"), a designated Foreign Terrorist Organization. The scheme relied on the use of the U.S. financial system and was facilitated by U.S. persons and entities, which processed payments of Iranian oil, all in violation of U.S. sanctions against Iran. As a result of this scheme, Iranian government actors and their coconspirators caused over a hundred million dollars' worth of Iranian oil to be transported to China for the benefit of the IRGC-QF.