The Grand Jury charges that:

COUNT ONE

(Conspiracy)

At all times material to this Indictment:

A. Introduction

The Defendants

1. Defendant KRAL HAVACILIK IC VE DIS TICARET SIRKETI, doing business as KRAL AVIATION, was a company which brokered aircraft parts and related goods on behalf of foreign customers. Defendant KRAL AVIATION was registered in the Republic of Turkey with a mailing address of Florya Senlikkoy Mh. Gumus Sk. Slrln Vlia No: 3/1, 1 Bakukoy-Istanbul, Turkey.
2. Defendant PEYMAN AMIRI LARIJANI, also known as PAYMEN LARIJANI, is a citizen of Iran and resident of Turkey. Defendant PEYMAN AMIRI LARIJANI was the operations manager of Defendant KRAL AVIATION. As part of his responsibilities, Defendant PEYMAN AMIRI LARIJANI procured aircraft parts and related goods for foreign customers.

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