The defendant admits that if this case were to proceed to trial, the government could prove the following facts. The criminal information is fully incorporated herein as true and accurate:

On or about July 28, 2018, an outbound shipment of a Solar brand gas turbine assembly ("turbine") with a declared value of approximately $200,000.00 was detained by the U.S. Department of Commerce/Bureau of Industry and Security ("BIS") in Mobile, Alabama. The exporter of the turbine was Turbine Resources International, LLC (TRI), located in Pensacola, Florida. The turbine was consigned to Company A in Sharjah, United Arab Emirates (UAE). The turbine was detained because Company A, to which the turbine was going, is involved in the diversion of turbines to Iran.

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