On July 25, 2023, the US Department of Justice announced that Behrouz Mokhtari was sentenced to 41 months in prison for conspiring to engage in business activities in violation of US sanctions. The DOJ reports that Mokhtari, a resident of Virginia and Tehran, also received 3 years of supervised release and was ordered to forfeit $2.8 million in proceeds obtained from his criminal activity, including a California residence he purchased with the proceeds for more than $1.5 million.
In January 2023, Mokhtari pleaded guilty in the US District Court for the District of Maryland and admitted to participating in two schemes that violated the International Emergency Economic Powers Act (“IEEPA”) and the Iranian Transactions and Sanctions Regulation (“ITSR”). According to OFAC, the first scheme occurred between February 2013 and June 2017 during which time he conspired with several Iranian citizens to illegally ship petrochemical products into and out of Iran on behalf of Iranian entities associated with the government of Iran. To facilitate the shipments, Mokhtari reportedly purchased two liquid petroleum gas tanker vessels. When the tankers were eventually sold for scrap in 2017, Mokhtari received approximately $2.8 million and used $1.5 million to purchase the California residence in 2018. The second conspiracy, which occurred between March 2018 and September 2020, involved a network of at least five businesses in Iran and the United Arab Emirates, collectively referred to as “the FSR Network,” that was used by the conspirators, including Mokhtari, to conduct business and provide services to Iranian entities involving Iranian petrochemicals.
According to the DOJ, Mokhtari and his co-conspirators never applied for a license from the US Office of Foreign Assets Control or sought OFAC’s permission to engage in the transactions. Mokhtari also admitted that he knew that US sanctions evasion was illegal and that engaging in these transactions without permission from OFAC was prohibited.
The case against Amirreza Rahvarian, a naturalized US citizen from Iran who was indicted with Mokhtari, continues. According to the criminal information, Rahvarian left the US in 2016 and has not returned.