US-Iranian citizen pleads guilty to IEEPA and ITSR violations

A naturalized US citizen originally from Iran has pleaded guilty to one count of conspiracy to evade US sanctions against Iran.  The defendant, Behrouz Mokhtari, is a resident of Virginia and Tehran; he entered a plea in US District Court for Maryland, admitting to participating in two conspiracies to violate the International Emergency Economic Powers Act (IEEPA) and Iranian Transactions and Sanctions Regulations (ITSR), which are designed to restrict exportation, sale or supply of goods, technology or services to Iran.

According to the stipulation of facts attached to the guilty plea, between February 2013 and June 2017, Mokhtari and several Iranian citizens conspired to conduct illegal shipments of petrochemical products into and out of Iran; to do this, Mokhtari purchased two liquid petroleum gas tanker vessels through a Panamanian front company for the transport of petrochemical products on behalf of entities associated with the government of Iran.  He then transferred ownership of the vessels in order to conceal the true owners, and to control the vessels’ operations – which involved the use of the US financial system -- through other entities.  In 2017, one of the tankers was sold for scrap for over $3 million, and the proceeds of the sale were transferred to bank accounts held by Mori Construction and Development, LLC, an entity owned solely by Mokhtari.  In 2018, Mokhtari used over $1.5 million of those proceeds to purchase a residence in California.

The second conspiracy described in the plea agreement documents took place between March 2018 and September 2020, when Mokhtari and co-conspirators used a network of at least five businesses in Iran and the United Arab Emirates to provide services to Iranian entities and to transact business involving Iranian petrochemical products.  Specifically, Mokhtari used one of those businesses, Bitubiz FZE, located in the UAE and partially or wholly controlled by him, as a conduit for processing US dollar transactions involving Iranian petrochemicals.  Large portions of wire transfers received by Bitubiz were credited to Ayegh Isfahan Manufacturing Company, a firm located in Iran and involved in the petrochemical industry there.

As noted in the plea agreement, Mokhtari knew that, as a US citizen, he was prohibited from engaging in business with Iranian entities or providing services to them without obtaining a license from the Office of Foreign Assets Control of the US Department of the Treasury; he was also aware that it is illegal to evade US sanctions against Iran or engage in transactions related to Iranian-origin goods.

Mokhtari is scheduled to be sentenced on April 3, 2023.  Amirreza Rahvarian, the Iranian-born naturalized US citizen indicted with Mokhtari, resides in Iran.

DOJ press release | Plea Ageement | Stipulation of Facts

 
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