By Tom Reynolds, Export Solutions

Earlier this month, a 72-year-old Virginia man pleaded guilty to conspiring to violate Iranian sanctions.  Behrouz Mokhtari of McLean, VA, is a naturalized U.S. citizen and a native of Tehran, Iran.

According to the Justice Department, from March 2018 until approximately September 2020, Mokhtari conspired to evade Iranian sanctions administered by the Treasury Department’s Office of Foreign Assets Control (OFAC).  The charges allege that Mokhtari managed or operated several businesses in Iran and the UAE, referred to as the “FSR Network.”  Through this network, Mokhtari and his co-conspirators engaged in business with Iranian entities and transactions involving Iranian petrochemical products.  They used bank accounts located in the UAE – including at least one account controlled by Mokhtari – to process the transactions in U.S. dollars.

To help further this scheme, Mokhtari established a Panamanian front company – East & West Shipping, Inc. – to purchase two tanker vessels worth approximately $38 million.  These vessels were used to transport Iranian petrochemical products on behalf of the Government of Iran. According to the press release:

Mokhtari and his co-conspirators frequently communicated by email about the nature and source of the products that the vessels were transporting, as well as the use of false shipping documents and other measures taken to conceal the fact that the vessels were transporting products to and from Iran, in order to evade the Iranian sanctions.

Later, Mokhtari sold one of the vessels for scrap – netting almost $3 million from the sale. He then used part of these proceeds to purchase a $1.5 million home in California.

In his guilty plea, Mokhtari admitted to knowing that, as a U.S. citizen, his activities were illegal.  He faces a maximum sentence of five years in prison for each of the two conspiracy counts.  Further, he is required to forfeit all money, property and assets derived from these illegal activities, in addition to a $2.8 million judgement.

You can read the full details of the Justice Department press release here.


Tom Reynolds is the President of Export Solutions, a consultancy firm which specializes in helping companies with import/export compliance.