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

manager at Ariana and current lead manager for Servex allegedly responsible for coordinating
transshipment of U.S.-origin goods from Dubai to Iran; Michelle Liboon Diaz, the former frontline
manager at Ariana and current front-line manager at Servex allegedly responsible for
coordinating transshipment of U.S.-origin goods from Dubai to Iran; Esmaeil Ghahremani, an
Iranian citizen with ties to the United States who allegedly relies on BMWW to unlawfully export
U.S.-origin goods to Iran through Dubai; Ehsan Mahmoud Ghorbanali Barati, an Iranian citizen
who allegedly relies on BMWW to unlawfully export U.S.-origin goods to Iran through Dubai;
Amir Mazlomian, a naturalized U.S. citizen of Iranian descent living in Newport Coast, Calif.,
and an officer with D&A Trading Corp., which has allegedly shipped nearly $300,000 in
computer-related goods to Iran through BMWW and Ariana; Alirez Beshcari, a citizen of the
Netherlands and a legal permanent resident in the U.S. living in Laguna Niguel, Calif., who owns
ATA Trade Co., which has allegedly shipped nearly $800,000 in electronic goods to Iran through
BMWW and Ariana; and Mikaeil Ghahramani, of Santa Ana, Calif., who owns Notebook
Spectrum, which has allegedly shipped nearly $2 million in electronic equipment to Iran through
BMWW and Ariana. This investigation was conducted by ICE and Commerce’s BIS.
Dual-Use Programmable Logic Devices to China – On Dec. 18, 2012, federal prosecutors in the
District of Oregon unsealed a 12-count indictment charging Wan Li Yuan, aka “Nicholas Bush,”
a resident of China, and another Chinese resident known as “Jason Jiang,” with export and money
laundering violations in connection with their alleged efforts to obtain dual-use programmable
logic devices (PLDs) from the United States for export to China. According to the indictment,
while operating from China, Yuan and Jiang created a sophisticated scheme to conceal their true
identity and location in order to mislead U.S. companies into believing they were dealing with
American customers so they could procure and send sensitive technologies to China without the
required export licenses. Yuan and Jiang allegedly sought to procure PLDs made by Lattice
Semiconductor Corporation in Oregon, which are designed to operate at extreme temperature
ranges and which can have military applications such as in missiles and radar systems. To further
his efforts, the indictment alleges that Yuan created a fake website and email addresses using the
name of a legitimate New York-based company. Yuan requested U.S. companies to ship the
desired parts to the address of a freight forwarder in New York, which he also falsely represented
as being associated with the New York company whose business name Yuan had stolen.
Through the investigation and use of an undercover operation, the FBI and Department of
Commerce were able to seize approximately $414,000 in funds sent by Yuan as down payments
for the Lattice PLDs. Lattice Semiconductor cooperated with the government in the
investigation, which was conducted by the FBI and Department of Commerce’s BIS.
Information Technology Services and Support to Iran – On Dec. 17, 2012, John Alexander
Talley of Seattle was arrested pursuant to a Dec. 15, 2012, criminal complaint in the Middle
District of Florida charging him with providing remote Information Technology (IT) services and
support for U.S.-origin computer systems located in Iran in violation of the International
Emergency Economic Powers Act. According to the complaint, Talley was hired by Tampa
resident Mohammed Reza Hajian to provide technical computer support for high-end Americanmade
computers and storage equipment that Hajian had previously illegally exported from the
United States to Iran. Talley never went to Iran to provide the support, but allegedly provided the
technical support requested, remotely, from the United States and during a visit to the United
Arab Emirates. He also provided an engineer in Iran with his user name and password so the
Iran-based customer could access the networks of the U.S. computer manufacturer where Talley
worked. Talley was interviewed by federal agents in 2011 and warned his actions were illegal.
Hajian was arrested and ultimately pleaded guilty on July 11, 2012, in the Middle District of
Florida to conspiracy to export roughly $10 million worth of computers from the U.S. to Iran via
the UAE. On Oct. 18, 2012, Hajian was sentenced to four years in prison and ordered to forfeit
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