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A. The Conspiracy
14. Beginning in or around May 2017 through in or about April 2018, within the District of Columbia and elsewhere, defendant ROHOLLAHNEJAD and his co-conspirators,
named and unnamed, most notably IPAXIOM, CO-CONSPIRATOR A, CO-CONSPIRATOR B, CO-CONSPIRATOR C, and CO-CONSPIRATOR D, did knowingly combine, conspire, confederate and agree with others known and unknown to the Grand Jury, to commit offenses against the United States, and to defraud the United States, more particularly:
A. to fraudulently or knowingly export, attempt to export, and cause the export of an Industrial Microwave System and a Counter-Drone System contrary to law, that is, to export the items from the United States to Iran by providing false and fraudulent export information and concealing the true ultimate destination of the goods in order to avoid obtaining the required licenses or authorizations, in violation of Title 18, United States Code, Section 554; and
B. to defraud the United States by interfering with and obstructing a lawful government function, that is, the enforcement of laws and regulations prohibiting the export or supply of goods from the United States to Iran without the required licenses or authorizations, in violation of Title 18, United States Code, Section 371.
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Read the full indictment below.