Indictment Returned Charging Two Foreign Nationals With Violating U.S. Money Laundering and Sanctions Laws Against Iran

           WASHINGTON - Issam Shammout of Jordan, 48, and Ali Abdullah Alhay of Saudi Arabia, 61, were charged with violating U.S. export laws and sanctions against Iran in the United States District Court for the District of Columbia.  The announcement was made by U.S. Attorney Jessie K. Liu for the District of Columbia, Special Agent in Charge Jill Sanborn of FBI Minneapolis, and Acting Director of the Office of Export Enforcement John Sonderman of the U.S. Department of Commerce.

           A 17-count indictment returned on Tuesday December 16, 2019 charges Shammout and Alhay with conspiracy to acquire U.S. origin aircrafts and parts to supply to end-users in Iran, specifically Mahan Air, a specially designated national.  The indictment alleges that the defendants concealed from companies, financial institutions that clear U.S. dollar transactions, and the U.S. government that the U.S.-origin goods were destined for Mahan Air, 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), the Iranian Transactions and Sanctions Regulations (ITSR), and the Export Administration Regulations (EAR).

           A related verified civil complaint in rem filed in July 2017 in the District of Columbia against $17,035,935 in funds for benefit of Al Naser airlines has also been unsealed. These funds were allegedly involved in this scheme to launder funds in to the United States to illicitly procure airplanes destined for Mahan Air. A criminal forfeiture allegation against the funds and nine airplanes was also included in the indictment against Shammout and Alhay.

            “We will continue to aggressively prosecute those who violate our export control laws and use every measure available under the law, to include civil forfeiture, to recover funds for the victims of terrorism,” said Jessie K. Liu, U.S. Attorney for the District of Columbia. “These laws serve to prevent hostile countries from obtaining and proliferating goods that could be used to harm our nation.”

           "Today's indictment underscores an important fact that those who support this type of procurement effort by Mahan Air will be thoroughly investigated by the FBI and prosecuted to the fullest extent of the law," said FBI Minneapolis Special Agent in Charge Jill Sanborn. "We applaud the efforts of our agents and other partners for their outstanding work on this significant case," Sanborn added.

           “The Department of Commerce and our interagency partners will relentlessly pursue any commercial entity which flagrantly disregards American laws to support the spread of terrorism," said Acting Director of the Office of Export Enforcement John Sonderman. “This is just the latest in a string of actions dating back to 2008 to end Mahan Air's systematic violation of U.S. export controls.”

           According to the indictment, beginning around August 2012 through May 2015, Shammout and Alhay conspired to purchase and deliver U.S.-made engine parts valued at over ten percent of the value of the aircraft, subjecting them to the strictures of IEEPA and the Iran Sanction Regulations. The conspiracy utilized the U.S. correspondent banking system to process the illicit transactions as they were in U.S. Dollars, and at no time were U.S. financial institutions alerted that they were financing Mahan Air’s aircraft supply.

           Mahan Air has been designated by the U.S. Department of the Treasury since October  12, 2011 as a Specially Designated National for providing financial, material and technological support to Iran’s Islamic Revolutionary Guard Corps-Qods Force.  The Department of Commerce has placed Mahan on its Denied Parties List.

           On March 15, 1995, the President, pursuant to IEEPA, issued Executive Order No. 12957, finding that “the actions and policies of the Government of Iran constitute an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States” and declaring “a national emergency to deal with the threat.”  In subsequent Executive Orders, the President imposed economic sanctions, including a trade embargo, on Iran.  The Executive Orders and the ITSR prohibit the exportation, re-exportation, sale, or supply, directly or indirectly, to Iran of any goods, technology, or services from the United States or by a United States person without prior authorization or license from the United States Department of the Treasury, the Office of Foreign Assets Control, located in Washington, D.C.

           If convicted, Shammout and Alhway would face a maximum of 20 years imprisonment.

           The investigation was conducted by special agents from the FBI Minneapolis Field Office and U.S. Department of Commerce, Bureau of Industry and Security Office of Export Enforcement Washington D.C. Field Office. 

           The details contained in an indictment are mere allegations.  All defendants are presumed innocent unless and until proven guilty in a court of law.

           Assistant U.S. Attorneys Zia M. Faruqui, Chris Brown, and Arvind Lal, Special Assistant U.S. Attorney Chris Kaltsas, National Security Division Trial Attorney Dave Recker, and Paralegal Specialist Rosalind Pressley, all from the U.S. Attorney’s Office for the District of Columbia, are representing the government.  Former Intelligence Analyst Lia Anter also provided support of this investigation.