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

allegedly concealed that Iranian customers were the true recipients of the shipment by falsely
asserting that a business entity in the UAE was the ultimate consignee for the goods. The
investigation was conducted by ICE and Department of Commerce.
Aircraft and Aircraft Components to Iran – On Dec. 3, 2012, Hamid Asefi and Behzad
Karimian pleaded guilty in U.S. District Court for the Western District of Kentucky to charges
related to the unlawful export of aircraft and aircraft parts from the United States to Iran. Asefi,
68, is a citizen and resident of the Republic of Iran, and is the principal officer of Aster Corp Ltd.,
an Iranian company with offices in both Iran and the United Kingdom. Karimian, also known as
“Tony” Karimian, 53, is a U.S. citizen living in Louisville, who holds a valid Iranian passport and
is employed as a Mesaba Airlines pilot. Asefi and Karimian were both charged with conspiracy
to violate and violating the International Emergency Economic Powers Act for exporting, selling
or causing the export or sale of aircraft and aircraft parts without first having obtained the
required license from the U.S. Department of Treasury. Asefi made his initial appearance in U.S.
District Court in Louisville on June 1, 2012. Karimian was arrested and made his initial
appearance in U.S. District Court in Louisville on June 6, 2012. According to documents filed in
the case, Asefi and Karimian conspired to export and/or sell a General Electric CF6-50 aircraft
engine and Bell helicopters to entities in Iran. This investigation was conducted by the FBI.
Specialty Coatings to Pakistani Nuclear Facility – On Dec. 3, 2012, in the District of Columbia,
the China Nuclear Industry Huaxing Construction Co., Ltd. (Huaxing), a corporate entity owned,
by the People’s Republic of China (PRC), pleaded guilty to conspiracy to violate the International
Emergency Economic Powers Act (IEEPA), and three unlawful exports of high performance
coatings to a nuclear reactor in Pakistan. The plea marked the first time that a PRC corporate
entity has entered a plea of guilty in a U.S. criminal export matter. Huaxing was also sentenced
to the maximum criminal fine of $2 million, $1 million of which was stayed pending its
successful completion of five years of corporate probation. The terms of Huaxing’s probation
require it to implement an export compliance and training program that recognizes Huaxing’s
obligation to comply with U.S. export laws. In both the criminal and administrative case,
Huaxing was accused of conspiring to export, re-export, and transship high-performance epoxy
coatings to the Chashma II Nuclear Power Plant in Pakistan, a nuclear reactor owned by the
Pakistan Atomic Energy Commission (PAEC), an entity on the Department of Commerce’s
Entity List. The Huaxing guilty plea was related to the Dec. 21, 2010, guilty plea of PPG Paints
Trading Co., Ltd. to a four-count information in the District of Columbia. Together, PPG Paints
Trading and its parent company, PPG Industries, Inc., paid $3,750,000 in criminal and
administrative fines and over $32,000 in restitution. The Huaxing guilty plea was also related to
the Nov. 15, 2011, guilty plea by Xun Wang to conspiracy to violate IEEPA. Wang also reached
a settlement with the Commerce Department on Nov. 15, 2011, in which she agreed to pay a civil
penalty of $200,000, with another $50,000 payment suspended, and to be placed on the
Commerce Department’s Denied Persons List for five years, with an additional five years
suspended. Wang, a former Managing Director of PPG Paints Trading, was the senior most PPG
Paints Trading employee responsible for the unlawful export scheme. Wang, a Chinese national
and lawful permanent resident of the United States, was arrested on June 16, 2011, in Atlanta.
On June 7, 2011, a grand jury in the District of Columbia returned a sealed indictment against
her. Wang was ultimately sentenced on Dec. 20, 2012, to one year and one day in prison in
connection with the scheme. According to Huaxing’s plea documents, in January 2006, PPG
Industries sought an export license for the shipments of coatings to Chashma II. In June 2006,
the Department of Commerce denied that license application. Following that denial, Huaxing and
its co-conspirators agreed upon a scheme to export, re-export and transship the high-performance
epoxy coatings from the U.S. to Chashma II, via a third-party distributor in China, without first
having obtained the required export license from the Department of Commerce. From June 2006
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