THE GRAND JURY CHARGES THAT:

COUNT 1

[50 U.S.C. § 1705 – Conspiracy to Violate International Emergency Economic Powers Act]

Introduction

At all times relevant to this Indictment:

1. Through the International Emergency Economic Powers Act (“IEEPA”), 50U.S.C. §§ 1701-1707, the President of the United States was granted authority to deal with unusual and extraordinary threats to the national security, foreign policy, or economy of the United States. 50 U.S.C. § 1701(a). Pursuant to that authority, the President and the executive branch have issued orders and regulations governing and prohibiting certain activities and transactions with Iran by U.S. persons or involving items of U.S. origin or exported from the United States.
2. Pursuant to IEEPA, Title 50, United States Code, Section 1705(a), “[i]t shall be unlawful for a person to violate, attempt to violate, conspire to violate, or cause a violation of any license, order, regulation, or prohibition issued under this chapter,” and pursuant to Section 1705(c), “[a] person who willfully commits, willfully attempts to commit, or willfully conspires to commit, or aids or abets in the commission of, an unlawful act described in subsection (a) of this section shall” be guilty of a crime.

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