Iranian National Charged In Scheme To Evade U.S. Sanctions

A Morris County, NJ woman today admitted her role in a scheme to illegally smuggle millions of dollars’ worth of aircraft parts from the United States to Iran, U.S. Attorney Craig Carpenito announced.

Joyce Eliabachus, a/k/a “Joyce Marie Gundran Manangan,” 52, of Morristown, NJ pleaded guilty before U.S. District Judge Madeline Cox Arleo to an information charging her with one count of conspiracy to violate the International Emergency Economic Powers Act (IEEPA) in connection with her role in an international procurement network that smuggled over $2 million worth of aircraft components to Iran.

In addition to the guilty plea, a complaint was unsealed today in New Jersey against Peyman Amiri Larijani, 33, a citizen and resident of Iran charging him with one count each of conspiracy to violate Iranian Transactions and Sanctions Regulations (ITSR), conspiracy to commit money laundering, and conspiracy to smuggle goods from the United States. Larijani was also charged in U.S. District Court for the District of Columbia in two separate indictments unsealed June 4, 2019.

The guilty plea by Eliabachus and the charges unsealed against Larijani follow a joint investigation by the U.S. Department of Homeland Security, Homeland Security Investigations, and the U.S. Department of Commerce, Office of Export Enforcement.

“Eliabachus and others allegedly ran an international smuggling ring that shipped $2 million in aircraft parts to multiple Iranian airlines, including a company that has provided financial, material, and technological support to the Islamic Revolutionary Guard Corps,” U.S. Attorney Carpenito said. “This arrest, which was made possible by a close collaboration between our office and our partners at Homeland Security Investigations and the Office of Export Enforcement, has snuffed out another source of funds and goods to overseas entities that may endanger our national and economic security.”

“Today’s action is the result of outstanding collaborative efforts by the Office of Export Enforcement, the Justice Department, and Homeland Security Investigations,” Special Agent in Charge Jonathan Carson of the Office of Export Enforcement said. “This arrest will cut-off a key supplier to a proliferation network which illegally sold U.S. origin items to Iran. Violations such as these jeopardize national security and undermine U.S. foreign policy. We will continue to vigorously pursue violators wherever they may be.”

“For over two years, Eliabachus illegally engaged in aircraft component sales to Iran, a nation listed by the United States as a state sponsor of terrorism,” Brian Michael, HSI Newark Special Agent in Charge, said. “This potentially endangered U.S. security, particularly as one of the Iranian companies sold to does business with the Iranian Revolutionary Guard, a military unit tied to terrorist acts around the world. As protectors of the homeland, HSI is proud to have worked with other government agencies to have exposed this dangerous network.”

According to documents filed in this case and statements made in court:

Eliabachus, Larijani and others were part of an international procurement network that surreptitiously acquired large quantities of aircraft components from United States-based manufacturers and vendors and unlawfully exported them to entities in Iran using freight-forwarding companies in the United Arab Emirates (UAE) and Turkey.

Eliabachus was the principal officer and operator of Edsun Equipments LLC, a purported New Jersey-based aviation parts trading company run out of her Morristown residence. Larijani was the owner of an Iran-based procurement firm and served as operations and sales manager of a network of supply and engineering companies in Tehran, Iran, and Istanbul, Turkey.

From May 2015 through October 2017, Eliabachus, Larijani, and their conspirators facilitated at least 49 shipments containing 23,554 license-controlled aircraft parts from the United States to Iran, all of which were exported without the required licenses.

Eliabachus conspired with Larijani, whose international network helped initiate the purchase of United States-origin aircraft components on behalf of Larijani’s clients in Iran. The network’s client list included Iranian airline companies, several of which have been officially designated by the United States as a threat to national security, foreign policy, or economic interests. One company, Mahan Air Co., has been subject to sanctions by the United States for providing financial, material and technological support to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), and allegedly ferrying arms and reinforcements to designated terrorist groups such as Hezbollah and Hamas.

Eliabachus used her company to finalize the purchase and acquisition of the requested components from the various United States-based distributors. She repackaged and shipped the components to shipping companies in the UAE and Turkey, where Larijani and other Iranian conspirators directed the components to locations in Iran.

In order to obscure the extent of the network’s procurement activities, Eliabachus routinely falsified the true destination and end-user of the aircraft components she acquired. She also falsified the true value of the components being exported in order to avoid filing export control forms, which further obscured the network’s illegal activities from law enforcement.

The funds for the illicit transactions were obtained from the Iranian purchasers, funneled through Turkish bank accounts held in the names of shell companies controlled by the Iranian conspirators. The money was ultimately transferred into one of Edsun Equipments’ accounts in the United States. The network’s creation and use of multiple bank accounts and shell companies abroad was intended to conceal the true sources of funds in Iran, as well as the identities of the Iranian entities who were receiving U.S. aircraft components.

The count of conspiracy to violate IEEPA, to which Eliabachus pleaded guilty, carries a maximum potential of five years in prison and a $250,000 fine. Sentencing is scheduled for Sept. 24, 2019.

The counts against Larijani are punishable as follows: conspiracy to violate the ITSR carries a maximum penalty of 20 years in prison and a $1 million fine; conspiracy to commit money laundering carries a maximum penalty of 20 years in prison and a $500,000 fine; conspiracy to smuggle goods carries a maximum penalty of five years in prison and a $250,000 fine. The charges against Larijani are only allegations, and he is presumed innocent unless and until proven guilty.

U.S. Attorney Carpenito credited special agents of the Department of Homeland Security, Homeland Security Investigations, under the direction of Special Agent in Charge Brian Michael in Newark, and the U.S. Department of Commerce, Bureau of Industry and Security, Office of Export Enforcement, under the direction of Special Agent in Charge Jonathan Carson in New York, with the investigation.

(Source: U.S. Department of Justice news release)

FMI: www.justice.gov