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Justice News

Department of Justice
U.S. Attorney’s Office
Southern District of New York

Thursday, November 10, 2016

Manhattan United States Attorney Announces Charges Against Turkish And Iranian Nationals For Conspiring To Evade U.S. Sanctions Against Iran And Other Offenses

Charges Unsealed Today Against Four Defendants Who Allegedly Used the U.S. Banking System to Conduct International Financial Transactions for Iranian Entities

Preet Bharara, the United States Attorney for the Southern District of New York, and William F. Sweeney Jr., Assistant Director-in-Charge of the New York Division of the Federal Bureau of Investigation (“FBI”), announced today the unsealing of an Indictment charging HABIBOLLAH ZAREI, a/k/a “Adasi Habik,” a/k/a “Emre Polatkan,” BORA DENIZ, NESTEREN ZAREI DENIZ, and ABDULLAH EVREN ERDEM with using the U.S. financial system to conduct hundreds of millions of dollars’ worth of transactions on behalf of the Government of Iran and other Iranian entities, which were barred by United States sanctions; laundering funds in connection with those illegal transactions; and defrauding several financial institutions by concealing the true nature of these transactions.  The four defendants are alleged to have orchestrated fraudulent transactions that were intended to hide the fact that the transactions were for the benefit of Iranian entities and to have laundered funds in connection with that illegal activity.  The case is assigned to United States District Judge Crotty.

All four defendants currently remain at large.

Manhattan U.S. Attorney Preet Bharara stated:  “As alleged, these defendants conspired and schemed to hide millions of dollars’ of financial transactions specifically to evade U.S. sanctions laws.  These alleged transactions were criminal violations of long-standing economic sanctions against the government of Iran, and warrant strong legal action.  This Office and its law enforcement partners are committed to policing sanctions laws designed to protect the security of the United States.”

Assistant Director-in-Charge William F. Sweeney Jr. stated: “The United States has stringent laws against dealings with Iran because of the threat posed to our national security.  The subjects named in this case allegedly concealed how they were aiding entities in Iran, and knowingly evaded sanctions.  Our job in the FBI is to make sure entities with ties to the Iranian government can’t use our banking and businesses communities to unwittingly harm our country by hiding their origin and intent.”

According to the allegations contained in the Indictment,[1] unsealed today in Manhattan federal court:

Beginning in 1979, the President has repeatedly found that the situation in Iran constitutes an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States and declared a national emergency to deal with the threat.  Pursuant to these Presidential declarations, the United States has instituted a host of economic sanctions against Iran and Iranian entities pursuant to the International Emergency Economic Powers Act (the “IEEPA”).  This sanctions regime prohibits, among other things, financial transactions involving the United States or United States persons that were intended for the Government or Iran or Iranian entities. 


Between at 2014 and 2016, HABIBOLLAH ZAREI, BORA DENIZ, NESTEREN ZAREI DENIZ, and ERDEM conspired to conduct international financial transactions on behalf of and for the benefit of Iranian businesses.  As part of the scheme, the defendants caused U.S. banks to conduct at least $100,000,000 in international financial transfers in furtherance of Iranian steel and copper transactions.  Specifically, the defendants facilitated the export of thousands of tons of copper and steel from Iran, routing the financial transactions linked to these exports through U.S. financial institutions.  Using shell companies, the defendants concealed from the U.S. banks, however, the fact that these transactions were related to metal exports from Iran.   

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HABIBOLLAH ZAREI, 67, is a resident of Turkey and dual citizen of Turkey and Iran.  BORA DENIZ, 44, is a resident and citizen of Turkey.  NESTEREN ZAREI DENIZ, 39, is HABIBOLLAH ZAREI’s daughter and BORA DENIZ’s wife, and is a resident of Turkey and dual citizen of Turkey and Iran.  ERDEM, 32, is HABIBOLLAH ZAREI’s son-in-law and a resident and citizen of Turkey.  Each defendant is charged with conspiracy to defraud the United States, which carries a maximum sentence of five years in prison; conspiracy to violate the IEEPA, which carries a maximum sentence of 20 years in prison; conspiracy to commit bank fraud, which carries a maximum sentence of 30 years in prison; and conspiracy to commit money laundering, which carries a maximum sentence of 20 years in prison.  The maximum potential sentences are prescribed by Congress and are provided here for informational purposes only, as any sentencing of the defendant will be determined by the judge.

Mr. Bharara praised the outstanding investigative work of the FBI and its New York Field Office, Counterintelligence Division, and the Department of Justice, National Security Division, Counterintelligence and Export Control Section.

The prosecution of this case is being handled by the Office’s Terrorism and International Narcotics Unit.  Assistant United States Attorneys Michael D. Lockard and Sidhardha Kamaraju are in charge of the prosecution, with assistance from Elizabeth Cannon of the Counterintelligence and Export Control Section.  Assistant United States Attorney Jaimie Nawaday is principally responsible for the forfeiture aspects of the case.

The charges contained in the Indictment are merely accusations, and the defendants are presumed innocent unless and until proven guilty.


[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein, constitute only allegations, and every fact described should be treated as an allegation.

Financial Fraud
Press Release Number: 
Updated November 10, 2016