An investigation conducted by Homeland Security Investigations (HSI) Washington, D.C. and FBI Minneapolis led to two foreign nationals being charged for engaging in a plot to export Iranian petroleum to China and use the proceeds to benefit Iran’s Islamic Revolutionary Guard Corps-Qods Force, a designated terrorist organization. Shaoyun Wang, 54, of China, and Mahmood Rashid Amur Al Habsi, 39, of Oman, were charged in a 12-count indictment unsealed Feb. 2 at the U.S. District Court for the District of Columbia.

According to the indictment, between December 2019 and July 2021, Wang, Al Habsi and unnamed co-conspirators negotiated and completed sales of sanctioned oil from the Islamic Republic of Iran to the People’s Republic of China using the services and funds of U.S. persons and financial institutions, without prior authorization or a license from the U.S. Department of the Treasury. They allegedly obtained the oil from Iran using surreptitious means, which included AIS spoofing and engaging in multiple transfers between oil tankers. The alleged scheme also relied on the use of the U.S. financial system and was facilitated by Turkish, Omani and U.S. persons and entities, all in violation of U.S. sanctions against Iran.

“Those who choose to conspire with terrorist organizations will face the full force of justice,” said FBI Minneapolis Special Agent in Charge Alvin M. Winston Sr.. “The FBI remains committed to disrupting financial networks that fund and support terrorism. We will continue to collaborate with our partners to prevent the exploitation of legitimate industries for unlawful purposes, protecting global security and stability.”

“The only way that Iran can illegally sell oil is if people and business organizations outside Iran help it to do so,” said U.S. Attorney Matthew M. Graves. “The indictment unsealed today demonstrates that the U.S. government will seek to hold accountable those who knowingly help Iran sell oil illegally — wherever in the world they are located.”

The investigation further alleges that Wang and Al Habsi used fraudulent documents to mask that the oil originated from Iran, used electronic communications to arrange the sales, used shell corporations to launder the proceeds through the U.S. financial system, and misled U.S. financial institutions about the source of the money generated by the transactions. In addition, the scheme allegedly used U.S. companies as a “trust” to hold the profits for the Islamic Revolutionary Guard Corps.

The investigation also alleges that Al Habsi, acting through one of his companies, procured a $16.5 million loan in June 2020 from U.S. financial companies to purchase an oil tanker, later named M/T Oman Pride. Beginning in July 2020, M/T Oman Pride transferred Iranian oil to third-party vessels for sale to Chinese government-owned refineries and companies in China.

Wang allegedly used a U.S. front company, a U.S. facilitator and U.S. financial institutions to facilitate the sale of Iranian oil to China. Wang, who served as a director of a Chinese oil refinery, was also the chair of a U.S. company in Las Vegas, Nevada, and general manager of the U.S. company’s Hong Kong-based parent company, which allegedly acted as a front for oil transactions. Wang allegedly engaged with senior IRGC officials to affect the purchases. The alleged scheme resulted in millions of dollars’ worth of transactions that were processed by U.S. banks and facilitated by U.S. persons.

This case is being investigated by the HSI Washington, D.C. and FBI Minneapolis field offices. It is being prosecuted by the U.S. Attorney’s Office for the District of Columbia, with valuable assistance from the Counterintelligence and Export Control Section of the United States Department of Justice.

HSI is the principal investigative arm of the U.S. Department of Homeland Security (DHS), responsible for investigating transnational crime and threats, specifically those criminal organizations that exploit the global infrastructure through which international trade, travel and finance move. HSI’s workforce of more than 8,700 employees consists of more than 6,000 special agents assigned to 237 cities throughout the United States, and 93 overseas locations in 56 countries. HSI’s international presence represents DHS’ largest investigative law enforcement presence abroad and one of the largest international footprints in U.S. law enforcement.

Jeffrey Newman is a whistleblower lawyer and his firm represents whistleblowers in healthcare fraud under the False Claims Act (FCA) also whistleblowers under the SEC whistleblower program and CFTC whistleblower program. He can be reached at Jeff@JeffNewmanLaw.com or at 617-823-3217