On January 31, 2020, the US Attorney for the Southern District of New York announced that Iranian national Bahram Karimi had been charged with conspiracy to commit bank fraud, bank fraud and making false statements. These charges were brought after an FBI investigation uncovered a scheme in which Karimi initiated the transfer of $115 million to Iranian persons and entities through US banks in an effort of evade US sanctions against Iran.
According to the indictment, in 2007 an Iranian company known as the Iranian International Housing Corporation (IIHC) entered into a $475 million contract with VE Company, a Venezuelan state-owned energy company, to build approximately 7000 housing units in Venezuela. The Department of Justice alleges that Karimi was part of an executive committee formed by IIHC’s founding company to oversee the Venezuela contract, and that Karimi and his associates formed two entities, Clarity Trade and Finance in Switzerland and Stratus International Contracting in Turkey, for the sole purpose of receiving payments related to the construction project on behalf of IIHC. The indictment further alleges that from April 2011 to November 2013, Karimi and his associates instructed VE Company to make approximately fifteen payments to Clarity and Stratus’s Swiss bank accounts, using correspondent banks in New York. According to the DOJ, the deceptive banking scheme was used to transfer funds to the government of Iran as well as Iranian persons and entities, in violation of Title 18, US Code, Section 1344 and Section 1349.
Additionally, the indictment alleges that, when interviewed by FBI agents about these bank transactions in January 2020, Karimi falsely stated that throughout the Venezuela project, he believed that international sanctions against Iran did not apply to Iranian companies. If proved, these false statements could constitute violations of Title 18, US Code, Section 1001. If found guilty of all offenses, Karimi faces over 30 years in prison as well as the forfeiture of all proceeds derived directly or indirectly from his misconduct.