OFAC designations and DOJ charges for an Iranian businessman and two Dubai-based businesses for attempting to evade sanctions

On August 19, 2020, the US Department of Justice announced that charges were filed in the US District Court for the District of Columbia against Iranian national Amin Mahdavi, and Dubai-based Parthia Cargo LLC, for criminal conspiracy to violate US export laws and sanctions against Iran.  More specifically, Mahdavi and Parthia Cargo were charged with conspiracy to defraud the US and violating the International Emergency Economic Powers Act (IEEPA) and the Iranian Transactions and Sanctions Regulations (ITSRs), for illegally shipping US commercial aircraft parts to an Iranian air transport company without first obtaining a license from the US government, despite acknowledgements by Mahdavi that a US license was required in order to ship the goods to Iran.

According to an affidavit filed in support of the criminal complaint, Mahdavi, the managing director of Parthia Cargo, conspired with individuals and businesses outside of the US to ship an aircraft part manufactured in the US to an Iranian airline, after falsely indicating to the US parts supplier that the goods would not be shipped to Iran without obtaining proper US authorization.  According to the DOJ, Mahdavi faces up to five years in prison and a fine of $250,000, and Parthia Cargo faces a fine of up to $500,000, if convicted.

In a concurrent action, the US Department of the Treasury’s Office of Foreign Assets Control designated Parthia Cargo and Dubai-based Delta Parts Supply FZC, pursuant to Executive Order 13224, as amended, for providing material support or goods or services to Mahan Air.  Mahan Air was designated by the US Department of State in 2019 pursuant to E.O. 13882, for transporting weapons of mass destruction for terrorist groups such as Hizballah, Iran’s Islamic Revolutionary Guard Corps – Qods Force (IRGC-QF) and has routinely flown fighters and materials to Syria in support of the Assad regime.  OFAC also designated Mahdavi, pursuant to E.O. 13224, as amended, for owning or controlling Parthia Cargo.

As a result of these designations, all US property belonging to this individual and entities is blocked, and all transactions in the US are generally prohibited.  Furthermore, any person who transacts with any designated person or entity may themselves be exposed to sanctions, and any foreign financial institution that knowingly conducts transactions on behalf of a designated person or entity, could be subject to US correspondent account or payable-through account sanctions.

DOJ Press Release | DOJ Affidavit in Support of Complaint | OFAC Press Release

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