JUL 2 2 2008

Census to collect trade statistics and by the Bureau of Industry and Security, Department ofCommerce, which is located in the District of Columbia, for export control purposes. Other UnitedStates government agencies located in the District of Columbia also rely upon the informationprovided by SED and AES records.COUNT ONE(Conspiracy to Export to Embargoed Country and Defraud the United States)15. The allegations in Paragraphs 1 through 14 are incorporated and re-alleged byreference in this Count.16. Beginning as early as in or about August 10,2005, the exact date being unknown tothe Grand July, and continuing through in or about July 2008, in the District of Columbia andelsewhere, the defendants,MAC AVIATION,TOM McGUINN,SEAN BYRNE,andSEAN McGUINN,did knowingly and willfully combine, conspire, confederate, and agree with each other, and withothers known and unknown to the Grand Jury, to commit offenses against the United States, that is,(a) to export and cause the exportation of aircraft engines and parts, and to attempt to export andcause the exportation of aircraft engines and parts, from the United States to Iran in violation of theembargo imposed upon that country by the United States, without having first obtained the requiredlicenses or authorizations from the Office of Foreign Assets Control, United States Department ofthe Treasury, located in the District of Columbia, in violation of Title 50, United States Code,Sections 1702. and 1705; and Title 3 1, Code of Federal Regulations, Parts 560.203 and 560.204; and