Iranian Entities’ Illicit Military Procurement Networks

On September 17, 2008, the United States District Court of the Southern District of Florida unsealed a federal grand jury indictment against sixteen foreign individuals and companies involved in procuring items with military applications for Iranian entities through Dubai and Malaysia-based trade networks.>> Those under indictment allegedly violated U.S. law under the International Emergency Economic Powers Act, Iran Trade Embargo, Iranian Transactions Regulations, and relevant executive orders by filing inaccurate export and end user declarations. The Iranian Transactions Regulations in particular prohibit unauthorized exportation of goods from the United States to a third country if the goods are intended or destined for Iran.>> The indicted individuals and entities allegedly circumvented U.S. export controls by utilizing a transnational network of firms located throughout the world to successfully purchase and channel goods to Iran. In each instance of alleged illegal procurement, the shipment of goods was complicated and did not include direct shipment from an American company to Iran.>> The dual-use items targeted by the network included electronic components capable of being used to construct Improvised Explosive Devices, or IEDs, according to U.S. allegations. The items, as described in the U.S. indictment, included: field-programmable gate arrays, integrated circuits, Global Positioning Systems (GPS), Field Communicators, and microcontrollers. The same types of items have been found in IEDs in Iraq and Afghanistan.>> One hundred and eight individuals in total were placed on the Bureau of Industry and Securitys Entity List on September 22, 2008. The U.S. Department of Commerce imposed export license and transaction requirements on exports by U.S. companies to any of the 108 individuals associated with the alleged Dubai and Malaysia networks also as of September 2008. It had earlier placed sanctions on the core 16 entities and individuals mentioned in the indictment in 2006.