On November 10, 2020, the US Department of Justice announced that it brought charges against Chin Hua Huang, a resident of Taiwan, and two businesses, DES International Co., Ltd. and Soltech Industry Col, Ltd., headquartered in Taiwan and Brunei, respectively.
According to the criminal complaint, between October 2011 and May 2018, Huang operated as a sales agent for DES and Soltech, communicating with suppliers -- including suppliers in the US -- and customers -- including an Iranian electronics testing and research organization. The complaint further alleges that Huang facilitated the unlicensed acquisition of a power amplifier and cybersecurity software by DES and Soltech on behalf of the Iranian organization, and helped conceal the origin of the equipment by changing the packaging and removing the serial number and “Made in USA” sticker, in violation of the Iranian Transaction and Sanctions Regulations (ITSRs), 31 CFR Part 560, which implements the sanctions imposed by Executive Orders 12957 and 12959. According to the complaint, Huang’s conduct, together with DES and Soltech, constituted a conspiracy to defraud the United States and to violate the International Emergency Economic Powers Act by causing US-origin goods to be exported to Iran without a license.
In a parallel action, the Office of Foreign Assets Control of the US Department of the Treasury designated Huang, DES, Soltech, three individuals, and two other companies pursuant to Executive Order 13382, for acting on behalf of Iran Communications Industries, the Iranian electronics testing and research organization described in the criminal complaint and designated by the US in 2008 and the EU in 2010, and for furnishing goods and support or acting on behalf of designated entities.
Pursuant to the sanctions, US property of the designated individuals and entities is blocked, and US persons are generally prohibited from dealing with such property. Furthermore, persons who transact with designated individuals and entities may be exposed to sanctions or enforcement, and foreign financial institutions that knowingly facilitate a significant transaction on behalf of a designated person may be subject to sanctions.