THE UNITED STATES GRAND JURY CHARGES THAT:

At times relevant to this Indictment:

INTRODUCTORY ALLEGATIONS

A. Defendants

Defendant SEYED SAJJAD SHAHIDIAN is an Iranian national residing in Iran who is the founder of PAYMENT24 and is PAYMENT24's Chief Executive Officer. Defendant VAHID VALI is PAYMENT24's Chief Operating Officer and is also an Iranian national residing in Iran. Defendant PAYMENT24 is an internet-based financial services company located in Iran. The primary business of PAYMENT24 is assisting Iranian citizens residing in Iran with conducting financial transactions with businesses based in the United States that are prohibited by international sanctions. These transactions include the unlawful purchase and importation into Iran of computer servers 
and software from United States-based businesses, among others. In order to facilitate these transactions, PAYMENT24 obtains payment processing accounts from United States-based businesses using fraudulent passports and other false residency documentation. PAYMENT24 charges a fee for its services, which, according to PAYMENT24's website, are used to circumvent "American sanctions." PAYMENT24 has more than 40 employees and has offices in Tehran, Shiraz, and Isfahan, Iran. PAYMENT24 claims on its website that it has brought millions of dollars of foreign currency into Iran.

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