On February 11, 2020, the US Department of Justice announced the arrest of five men on charges of conspiracy to violate, and violation of, the International Emergency Economic Powers Act (IEEPA), and the Iran Transactions and Sanctions Regulations (ITSR), 31 CFR Part 560, promulgated thereunder.
As alleged in the complaint, the five conspired between July 2019 and February 2020 to arrange for the purchase of oil from Iran and resale to China. The conspirators allegedly sought to obtain six million barrels of Iranian oil per month, to be sold to a Chinese refinery through a Polish shell company, with the knowledge that the source of the oil would have to be concealed. The complaint details the measures taken by the alleged conspirators to evade US sanctions, such as fake letters between the Polish shell company and the refinery, suggestions to turn off the satellite tracking equipment on the tanker ship so that its movements would remain undetected, use of a company owned by one of the co-conspirators to launder the funds obtained from the oil transaction, and the acquisition of Antigua passports for the purpose of opening Swiss bank accounts that would not be reported to US authorities.
The five defendants are each charged with one count of conspiracy and one count of violating IEEPA.