Iran sanctions: Feds charge two, move to seize $12.3 million of funds

Iranian nationals Amir Dianat, 55, and Kamran Lajmiri, 42, were on May 1 charged with violating U.S. export laws and sanctions against Iran. In a two-count criminal complaint filed in the U.S. District Court for the District of Columbia, the pair were charged with conspiracy to provide U.S. financial services to Iranian entities and their front companies attempting to purchase a petroleum tanker, the Nautic, in September 2019. [According to the Equasis data base, the Nautic, renamed as Gulf Sky in October 2019, is a 1998-built, 150,812 dwt crude oil tanker].

The complaint alleges that the defendants concealed from the seller, financial institutions that clear U.S. dollar transactions, and the U.S. government that the sale of this vessel was destined for Iran, all as part of a scheme to enrich the defendants and other conspirators, and to evade the regulations, prohibitions, and licensing requirements of the International Emergency Economic Powers Act (IEEPA) and the Iranian Transactions and Sanctions Regulations (ITSR).

CIVIL FORFEITURE

A related verified civil forfeiture complaint was filed against $12,338,941.91 of funds that were allegedly involved in this scheme to launder funds into the United States to illicitly procure the Nautic. The civil forfeiture was filed against an entity identified as “Liberian company 1” ($2,340,000) and “U.S. Bank 1” ($9,998,941.91).

The forfeiture complaint alleges that the scheme involved the National Iranian Oil Company, the National Iranian Tanker Company (NITC), and the IRGC-Qods Force (IRGC-QF), all specially designated nationals. The IRGC has also been designated a Foreign Terrorist Organization. This forfeiture action represents the largest ever seizure of IRGC-QF related funds. All funds of terrorist organizations are subject to forfeiture.

SANCTIONS VIOLATIONS

“ These defendants purchased a crude oil tanker valued at over $10 million by illegally using the U.S. financial system, defiantly violating U.S. sanctions,” said Assistant Attorney General for National Security John C. Demers. “This is yet another example of Iran brazenly using front companies and false documentation in an attempt to hide the illegal transactions that the Iranian regime desperately needs to fund its malign activities. The enforcement of U.S. sanctions and related financial criminal laws is a major component of the National Security Division’s commitment to protecting the national security of the United States. I commend the efforts of the prosecutors, agents, and analysts who uncovered this illegal scheme and whose work resulted in the largest ever forfeiture action involving IRGC-QF.”

“Employing civil forfeiture authorities specifically available to the U.S. Attorney’s Office in the District of Columbia, we will continue to aggressively prosecute those who abuse our financial system to support sanctioned entities,” said U.S. Attorney Timothy J. Shea for the District of Columbia.”

TREASURY ACTION

A concurrent action was filed by the Department of the Treasury, sanctioning Dianat and his related front company, Taif Mining.

According to the pleadings, beginning around May 2019 through December 2019, Dianat and Lajmiri conspired to purchase the Nautic via a complex web of front companies, including Taif Mining. After sending the final wire payment to the seller, Taif Mining took possession of the Nautic. It quickly changed its name and began making trips to Iran to load Iranian petroleum. Because a U.S. bank froze the funds related to the sale of the vessel, the seller never received payment. As a result, the seller instituted a civil action in the U.A.E. to recover the vessel.

If convicted, Dianat and Lajmiri would face a maximum of 20 years imprisonment.