1. The charges in this Indictment arise out of a multi-year scheme to violate and evade U.S. sanctions and national security controls against Iran. MICHAEL ROSE, the defendant, and others known and unknown, used front companies located in the United Arab Emirates ("UAE") and elsewhere to evade prohibitions against Iran's access to the U. S. financial system and against exporting goods from the United States to Iran.
2. At all times relevant to this Indictment, MICHAEL ROSE, the defendant, served as the President of Forsythe Cosmetic Group, Ltd ("Forsythe"), a Long Island-based cosmetics manufacturer and supplier. In that role, ROSE managed, among other  things, Forsythe's operations and its international sales business, and caused Forsythe to export from the United States more than $350,000 worth of cosmetics to a co-conspirator not named
   as a defendant herein ("CC-1") and CC-1's company in Iran ("Company-1") via the UAE. CC-1 used front companies to make payments to Forsythe in New York on behalf of Company-1 in Iran and to arrange for the transshipment of the U.S. goods to Iran via the UAE.

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