Justice Department Announces First Criminal Resolution Involving the Illicit Sale and Transport of Iranian Oil in Violation of U.S. Sanctions
The Government Also Seized Almost One Million Barrels of Iranian Crude Oil
WASHINGTON – The Justice Department announced today the successful disruption of a multimillion-dollar shipment of crude oil by the Islamic Revolutionary Guard Corps (IRGC), a designated foreign terrorist organization, that was bound for another country. This is the first-ever criminal resolution involving a company that violated sanctions by facilitating the illicit sale and transport of Iranian oil and comes in concert with a successful seizure of over 980,000 barrels of contraband crude oil.
According to court documents, on April 19, 2023, Suez Rajan Limited pleaded guilty to conspiring to violate the International Emergency Economic Powers Act (IEEPA). On that same date, the company was sentenced by U.S. District Court Judge Carl J. Nichols for the District of Columbia to three years of corporate probation and a fine of almost $2.5 million. In addition, pursuant to a deferred prosecution agreement (DPA) and a seizure warrant issued by the U.S. District Court for the District of Columbia, Empire Navigation, the operating company of the vessel carrying the contraband cargo, agreed to cooperate and transport the Iranian oil to the United States – an operation which has now concluded. Empire Navigation incurred the significant expenses associated with the vessel’s voyage to the United States.
The contraband cargo is now the subject of a civil forfeiture action in the U.S. District Court for the District of Columbia. The United States’ forfeiture complaint alleges that the oil aboard the vessel is subject to forfeiture based on U.S. terrorism and money laundering statutes. The complaint alleges a scheme involving multiple entities affiliated with Iran’s IRGC and the IRGC-Qods Force (IRGC-QF) to covertly sell and transport Iranian oil to a customer abroad. Participants in the scheme attempted to disguise the origin of the oil using ship-to-ship transfers, false automatic identification system reporting, falsified documents, and other means. The complaint further alleges that the charterer of the vessel used the U.S. financial system to facilitate the transportation of Iranian oil.
The complaint further alleges that the oil constitutes the property of, or provided a “source of influence” over, the IRGC and the IRGC-QF, both of which have been designated by the United States as foreign terrorist organizations, and that the oil facilitated money laundering. The documents allege that profits from oil sales support the IRGC’s full range of malign activities, including the proliferation of weapons of mass destruction and their means of delivery, support for terrorism, and both domestic and international human rights abuses.
Funds successfully forfeited with a connection to a state sponsor of terrorism may in whole or in part be directed to the U.S. Victims of State Sponsored Terrorism Fund.
HSI Washington D.C. and FBI’s Minneapolis Field Office are investigating the cases. Assistant U.S Attorneys Stuart D. Allen and Rajbir S. Datta for the District of Columbia prosecuted the criminal case and they, along with Assistant U.S. Attorney Brian Hudak, are litigating the civil forfeiture case. On both actions, they received assistance from Paralegal Specialists Brian Rickers and Legal Assistant Jessica McCormick. Former Assistant U.S. Attorney Michael Grady participated in prior phases of the investigation. The Counterintelligence and Export Control Section of the National Security Division is also prosecuting and litigating these matters. The Money Laundering and Asset Recovery Section of the Criminal Division provided significant assistance in this matter. The Department thanks United Against Nuclear Iran for its valuable assistance.
A civil forfeiture complaint is merely an allegation. The burden to prove forfeitability in a civil forfeiture proceeding is upon the government.