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indictment with violating IEEPA by working to export helicopter component parts from the U.S.
to Iran, via South Korea. The components were for a particular type of helicopter that can be
used for military purposes. Tamimi was arrested upon arrival in New York City on Oct. 5, 2012.
None of the defendants obtained the requisite approval from the Department of Treasury for such
exports. This investigation was conducted by the FBI, ICE, and Department of Commerce.
• Prohibited Exports to Iran – On Dec. 4, 2012, Markos Baghdasarian pleaded guilty in the
District of South Carolina to conspiracy to violate the International Emergency Economic Powers
Act and to defraud the United States, violating the Iranian embargo and making false statements.
On May 19, 2012, Baghdasarian was arrested in Atlanta prior to boarding a flight to the United
Arab Emirates (UAE). Baghdasarian was charged by criminal complaint in the District of South
Carolina with exporting goods from the United States to Iran without the required licenses and
with making false statements. He was later indicted on June 14, 2012. According to the charges,
Baghdasarian served as the manager of Delfin Group USA, a Russian-owned producer of
synthetic motor oils, located in North Charleston, South Carolina. From as early as June 13,
2010, until October 12, 2011, Baghdasarian is alleged to have engaged in prohibited transactions
with customers in Iran, including Pars Oil, which is an oil company owned by the Government of
Iran. He alleged exported to Iran aviation engine oils and polymers valued at $850,000 and
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. It is believed that the plea marks 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 is 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 is related to the Dec. 21, 2010, guilty plea of PPG Paints
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