THE GRAND JURY CHARGES THAT

INTRODUCTORY ALLEGATIONS

At all times material to this. indictinent:

The International Emergency Economic Powers Act and the Iranian Transactions and Sanctions Regulations

1. The International Emergency Economic Power Act ("IEEPA") authorizes the President of the.United States to deal with ''unusual and extraordinary threat[s] ... to the national security, foreign policy, or economy of the United States," by declaring national emergencies with respect to such threats. 50 U.S.C. § 1701(a). Since 1979, and through the present day, U.S. presidents have repeatedly·declared that the actions and polides of the Government of Iran ("GOI'') pose a thteat to the United States' national security inclucling, among other actions, the GOI's pursuit of nuclear weapons and its sponsorship of terrorism.

[...]