Jalal Hajavi, a Virginia man was sentenced yesterday to 24 months in prison followed by three years of supervised release for criminal conduct in connection with a scheme to unlawfully export heavy equipment from the United States to Iran by routing the shipments though the United Arab Emirates (UAE). Hajavi, was convicted by a jury in September 2023, of conspiring to violate the International Emergency Economic Powers Act (IEEPA) and the Iranian Transactions and Sanctions Regulations (ITSR), smuggling, and unlawfully exporting and reexporting goods from the United States to Iran without a license. According to court documents, Jalal Hajavi and a co-conspirator located in Iran conspired to evade U.S. sanctions by exporting U.S. heavy machinery through the UAE to Iran without first obtaining the required licenses from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Hajavi, through his company JSH Heavy Equipment LLC, located heavy equipment for sale in the United States, such as bobcats and wheel loaders, and sent information about his findings to the co-conspirator in Iran. Hajavi purchased the items from U.S. sellers and used freight forwarding companies to ship the heavy equipment from the United States to the UAE, where his Iranian co-conspirator diverted the machinery to Iran in circumvention of the U.S. export license requirement.
In addition to evading OFAC licensing requirements, Hajavi concealed his activities with the co-conspirator by causing false information to be entered into the Automated Export System (AES), a U.S. government database containing information about exports from the United States. Hajavi falsely claimed that the items were destined for his supposed UAE customers, which typically were general trading companies located in free trade zones in the UAE, but in reality, the items were destined for Iran.
At one point, Hajavi met with a Special Agent from the Bureau of Industry and Security who informed Hajavi about the U.S. sanctions against Iran, including the prohibition to transship U.S. goods through third countries to Iran. Undeterred, Hajavi continued his unlawful conduct.
One of the items that Hajavi purchased and unlawfully caused to be shipped was an Ingersoll Rand Blasthole Drill, which is a type of heavy machinery used in construction to drill holes in the ground usually filled with controlled charges. Hajavi purchased the drill from a U.S. company and, as part of a sham transaction, purportedly sold the drill to a UAE company. Hajavi hired a U.S. freight forwarder to arrange the drill’s export from the United States to the UAE. During the shipping process, the freight forwarder submitted information provided by Hajavi to AES about the shipment. Hajavi falsely told the freight forwarder that the UAE company was the ultimate consignee and provided the false ultimate destination of the UAE, when Hajavi knew that the Iranian co-conspirator was the true buyer and that Iran was the ultimate delivery destination. The Iranian co-conspirator subsequently shipped the drill from the UAE to Iran.
“Mr. Hajavi illegally shipped industrial equipment to the Iranian regime, smuggled restricted goods through the UAE to Iran, and caused a shipping company to submit false information to the U.S. government. He has been held to account for his crimes,” said Assistant Attorney General Matthew G. Olsen of the Justice Department’s National Security Division. “As this case shows, the Justice Department remains committed to enforcing U.S. sanctions and export control laws to deny Iran the commodities that fuel its malign activities abroad and threaten our nation’s security.”
“Shipping items to Iran is against the law, regardless of whether done directly or by way of a third country,” said Assistant Secretary for Export Enforcement Matthew S. Axelrod. “As demonstrated by this sentencing, when proliferators falsify export records to support illicit Iranian procurement schemes, they get caught and they do prison time.”
“Hajavi’s conduct was particularly egregious because he was previously informed on at least two occasions that his conduct was prohibited,” said U.S. Attorney Ryan K. Buchanan for the Northern District of Georgia. “Instead of heeding the warnings, he continued to divert U.S. goods to Iran. Trade sanctions against Iran comprise a critical component of U.S. foreign policy designed to keep our country and citizens safe. Criminal actors like Hajavi, who seek to profit by evading these prohibitions and jeopardize our national security, will be prosecuted.”
The Department of Commerce Bureau of Industry and Security’s Office of Export Enforcement conducted the investigation, with valuable assistance provided by the FBI.
Jeffrey Newman Esq. and members of his firm represent whistleblowers under the SEC, CFTC and FINCEN whistleblower programs. Persons providing original information to these agencies through counsel may receive rewards totaling up to 30 percent of a successful recovery made by the SEC, CFTC OR FINCEN and the names and identification of the whistleblowers are kept confidential. His firm also represents whistleblowers in healthcare fraud cases relating to Medicare of Medicaid. Attorney Newman can be reached at Jeff@Jeffnewmanlaw.com or at 617-823-3217
