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

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contracts. Swiss Tech was under contract with the Department <strong>of</strong> <strong>Defense</strong> to manufacture<br />

components for the M249 machine gun. In order to lower its manufacturing costs, Swiss Tech<br />

sent defense articles, including specification drawings and parts samples, to a company in the<br />

People’s Republic <strong>of</strong> China so that the Chinese company could make these machine gun<br />

components for Swiss Tech. Swiss Tech did not have the required State Department license for<br />

exports <strong>of</strong> these munitions to China. After receiving the components from the Chinese company,<br />

Swiss Tech then shipped the defense articles and other parts to the Department <strong>of</strong> <strong>Defense</strong>,<br />

purporting that the defense articles were made by Swiss Tech in conformance with its contract.<br />

Among other things, Swiss Tech illegally exported to China specifications for the production <strong>of</strong><br />

M249 machine gun parts, as well as components for the M249 machine gun, and M16 or M4<br />

rifle. This investigation was conducted by DCIS and ICE.<br />

Firearms to Nigeria – On July 11, 2011, Boniface Ibe was sentenced in the District <strong>of</strong> Maryland<br />

to five months in prison followed by 10 months <strong>of</strong> supervised release for illegally exporting<br />

shotguns, a handgun and ammunition to Nigeria without a license, and for delivering a firearm to<br />

a common carrier without notice. Ibe attempted to export these items to Nigeria concealed in a<br />

vehicle that was in a shipping container. The container and weapons were intercepted at the Port<br />

<strong>of</strong> Baltimore on Sept. 22, 2010. The investigation was conducted by ICE, CBP, and ATF.<br />

Vacuum Pumps With Potential Sensitive Applications to Iran -- On July 6, 2011, in the Central<br />

District <strong>of</strong> California, Jirair Avanessian, <strong>of</strong> Glendale, California, was sentenced to serve 18<br />

months in prison in connection with his role in a conspiracy to violate International Emergency<br />

Economic Powers Act and the Iranian trade embargo, including smuggling, money laundering<br />

and other crimes. Avanessian also must pay a $10,000 fine and forfeit the proceeds <strong>of</strong> his<br />

criminal activity. Avanessian was indicted on Dec. 30, 2009 and arrested in January 2010. He<br />

pled guilty in July 2010. Another individual involved in the conspiracy, Amirhossein Sairafi, <strong>of</strong><br />

Iran, was arrested in January 2010 in Frankfurt, Germany by German law enforcement authorities<br />

based on a provisional arrest warrant from the United States. Sairafi was later extradited to the<br />

United States in September 2010, pled guilty on Nov. 30, 2010, and was sentenced to 41 months<br />

in March <strong>of</strong> this year in connection with the scheme. Sairafi was first charged in a Jan. 4, 2010<br />

criminal complaint. Avanessian, who was born in Iran, is the owner and operator <strong>of</strong> XVAC, a<br />

company located in California. Avanessian corresponded with Sairafi and another individual in<br />

Iran, Farhad Masoumian, via e-mail over several years to arrange the export <strong>of</strong> high-dollar<br />

vacuum pumps and pump-related equipment to Iran through a free trade zone located in the<br />

United Arab Emirates. The vacuum pumps and related equipment at issue have a number <strong>of</strong><br />

applications, including in the enrichment <strong>of</strong> uranium. Avanessian purchased and arranged to ship<br />

the goods ordered by Masoumian to the United Arab Emirates, making it appear that the U.A.E.<br />

was the ultimate destination. Sairafi would then send the same goods from the location in the<br />

U.A.E. to Iran. As part <strong>of</strong> the conspiracy, Masoumian, Avanessian and Sairafi re-labeled and<br />

undervalued the contents <strong>of</strong> the shipments in order to mask the true contents and to avoid<br />

interception by U.S. <strong>of</strong>ficials. In most cases, Avanessian prepared air waybills indicating his<br />

shipments contained "spare parts" and that no shipper's export declaration was needed. Between<br />

December 2007 and November 2008, there were at least seven shipments containing vacuum<br />

pump equipment purchased and exported by Avanessian at Masoumian’s request. The<br />

investigation continues as Masoumian remains at large and is believed to be in Iran. This case<br />

was the product <strong>of</strong> an investigation by the <strong>Export</strong> and Anti-proliferation Global Law <strong>Enforcement</strong><br />

(EAGLE) Task Force in the Central District <strong>of</strong> California, which includes the FBI, ICE, BIS,<br />

CBP, Diplomatic Security Service and the Transportation Security Administration.<br />

Firearms to Mexico – On July 1, 2011, Avaro Hernan Ramirez was sentenced to 41 months in<br />

prison, followed by three years supervised release, for conspiracy to possess a machine gun and<br />

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