Major Export Enforcement Cases - Directorate of Defense Trade ...

of goods. The charges in the indictment stem from MEDCHEM, located in South San Francisco,
exporting chemicals (including hazardous materials), medical equipment, and diagnostics to
Constant Trading Activity (“CTA”), a business in Saudi Arabia. Ibrahim was the owner and
president of MEDCHEM, until one of his sons became involved in MEDCHEM prior to June
2010. Ibrahim was MEDCHEM’s sole employee. Ibrahim was also a founder of CTA and
served as CTA’s vice president. According to the indictment, Ibrahim caused a shipment
consisting of five pallets containing sixty-four boxes to be delivered to a freight forwarder for
export to Saudi Arabia. None of the boxes were labeled as containing hazardous material. The
shipment contained over 25 separate chemicals designated as hazardous materials under the
Hazardous Materials Regulations. Two of the hazardous materials – Sulfuryl Chloride (classified
as a corrosive) and Chloroacetonitrile (classified as poisonous material, with a subsidiary hazard
that it is a flammable and combustible liquid) – were poisonous by inhalation and prohibited
under federal law from transportation on any aircraft. The investigation was conducted by the
FBI, Department of Commerce, IRS and Federal Aviation Administration.
Radiation-Hardened Defense and Aerospace Technology to China –On Oct. 27, 2011, Lian
Yang, a resident of Woodinville, Washington, was sentenced in the Western District of
Washington to 18 months in prison and a $10,000 fine. On March 24, 2011, Yang pleaded guilty
to conspiring to violate the Arms Export Control Act by trying to sell radiation hardened military
and aerospace technology to China. Yang was arrested on Dec. 3, 2010, pursuant to a criminal
complaint filed charging him with conspiracy to violate the Arms Export Control Act. According
to the complaint, Yang attempted to purchase and export from the United States to China 300
radiation-hardened, programmable semiconductor devices that are used in satellites and are also
classified as defense articles under the U.S. Munitions List. The complaint alleges that Yang
contemplated creating a shell company in the United States that would appear to be purchasing
the parts, concealing the fact that the parts were to be shipped to China. Yang allegedly planned
that false purchasing orders would be created indicating that parts that could be legally exported
were being purchased, not restricted parts. Yang and his co-conspirators allegedly wiretransferred
$60,000 to undercover agents as partial payment for a sample of five devices. As part
of the conspiracy, Yang allegedly negotiated a payment schedule with the undercover agents for
the purchase and delivery of the remaining 300 devices in exchange for a total of $620,000. This
investigation was conducted by the FBI, ICE and CBP.
Components for IEDs to Iran and Iraq –On Oct. 25, 2011, prosecutors in the District of
Columbia unsealed a Sept. 15, 2010 indictment which charged four individuals in Singapore,
another individual in Iran, and four companies with various violations, including conspiracy to
defraud the United States, smuggling, illegal export of goods to Iran, illegal export of defense
articles, false statements and obstruction of justice. Among other things, the indictment alleged
that the defendants participated in conspiracies to defraud the United States, including a
conspiracy that allegedly caused 6,000 radio frequency modules to be illegally exported from the
United States to Iran via Singapore, at least 16 of which were later found in Improvised Explosive
Devices (IEDs) in Iraq. The defendants were Iranian national Hossein Larijani, and his companies
Paya Electronics Complex, based in Iran, and Opto Electronics Pte, Ltd., based in Singapore.
Also charged was Wong Yuh Lan, an agent of Opto Electronics who was allegedly supervised by
Larijani from Iran. The indictment also charges NEL Electronics Pte. Ltd., a company in
Singapore, along with NEL’s owner and director, Lim Yong Nam. Finally, the indictment charges
Corezing International Pte. Ltd., a company in Singapore that maintained offices in China, as well
as Lim Kow Seng, an agent of Corezing, and Hia Soo Gan Benson, a manager, director and agent
of Corezing. On Oct. 24, 2011, authorities in Singapore arrested Wong, Nam, Seng and Hia
pursuant to a U.S. extradition request. Larijani remains a fugitive in Iran. The indictment alleges
that, between June 2007 and February 2008, the defendants fraudulently purchased and caused
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