ADMINISTRATIVE SUBPOENA
ENF 37795

DEC 14 2011

Christopher Von Holt
FIU Investigations Unit Manager
Union Bank NA
400 California Street
San Francisco, CA 94194

Dear Mr. Von Holt

It has come to the attention of the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") that between September 3. 2010, and October 18, 2011, accounts associated with Epsilon Electronics Inc., d/b/a Power Acoustik, received five funds transfers totaling $1,190,717.21 from the Commercial Bank of Dubai P.S.C. which appear to be on behalf of Asra International Corporation, LLC. it appears that these payments may have been for products destined for Iran.

Pursuant to Iranian Transactions Regulations (the “Regulations"), 31 C.F.R. part 560, and section 602 of the Reporting, Procedures and Penalties Regulations ("RPPR''), 31 C.F.R. § 501.602, you are directed to provide OFAC with the following information:

1. The addresses of record and signature cards for any account owned by Epsilon Electronics Inc., Power Acoustik Electronics, Sound Stream, Precision Power, Kole Audio, Jack Rochel, or Sohail Rochel.
2. Account statements for any accounts owned by Epsilon Electronics Inc., Power Acoustik Electronics, Sound Stream, Precision Power, Kole Audio, SPL, Jack Rochel, or Sohail Rochel covering the five (5) years preceding the date of this Administrative Subpoena or since the date of account opening, if less than five years ago.
3. Any letters of credit, documentary credits, or related documents between Asra International Corporation LLC and Epsilon Electronics Inc., Power Acoustik Elecronics, Sound Stream, Precision Power, Kole Audio, Jack Rochel, or Sohail Rochel.
4. Payment instructions and any other available documents related to the following transactions:
a. Wire transfer for $11,143.01 from Asra International Corporation LLC to Epsilon Electronics Inc., d/b/a Power Acoustik Electronics, on or about September 24 2010. '
b. Wire transfer for $82,294.20 from Asra International Corporation LLC to Epsilon Electronics Inc., d/b/a Power Acoustik Electronics, on or about November 4, 2010. .
c. Wire transfer for $702 from Asra International Corporation LLC to Epsilon Electronics Inc. d/b/a Power Acoustik Electronics, on or about March 11, 2011.
d. Letter of credit deposited for $221,429 from Asra International Corporation LLC to Epsilon Electronics Inc. d/b/a Power Acoustik Electronics, on or about July 9, 2011.
e. Wire transfer for $875,149 from the Commercial Bank of Dubai P.S.C. that appears to be on behalf of Asra International Corporation LLC to Epsilon Electronics Inc., d/b/a Power Acoustik Electronics, on or about August 30, 2011.

You should be aware that failure to respond to this Administrative Subpoena may result in the imposition of civil penalties by OFAC. further, under 18 U.S.C. § 1001 knowingly and willfully falsifying or concealing a material fact. In your response to this Administrative Subpoena may result in criminal fines, imprisonment, or both.

OFAC's request for the information sought above is made pursuant to § 203(a)(2) of the International Emergency Economic Powers Act (“IEEPA”), 50 U.S.C. § 1702(a)(2). Broadly stated, this section authorizes the President (whose authority has been delegated to the Secretary of the Treasury) to require that complete information on transactions or acts subject to regulation pursuant to the President's exercise of emergency powers under IEEPA be maintained and provided under oath. OFAC has been delegated authority to request information with respect to any transaction subject to regulation pursuant to section 203(a)(2) of IEEPA and the Regulations. This Administrative Subpoena, therefore, is covered by Section 1113(d) of the Right to Financial Privacy Act (“FRPA”), 12 U.S.C. §§ 3401-22, which provides that nothing ln that Act authorizes the withholding of Financial records or information required to be reported in accordance with any Federal statute or role promulgated thereunder," RFPA, § 1113(d), 12 U.S.C. § 3413(d).

Please provide this information in writing, either in hardcopy or electronic format, and mail it no later than 30 calendar days from the date of this Administrative Subpoena. Address your response as follows:

U.S. Department of the Treasury
Office of Foreign Assets Control
Attn: John Hinton
Office of Enforcement
1500 Pennsylvania. Ave. NW
Washington, DC 20220

The enclosed yellow half-sheet must be stapled to the front of your response and your response must reference the "ENF" number printed above.

All aspects of this investigation are being handled by Enforcement Officer John Hinton. If you have any questions, please contact Mr. Hinton at (202) 622-1664 or [email protected] .

Issued on behalf of the Director of OFAC:

Amber Stokes
Enforcement Section Chief
Office of Foreign Assets Control

Enclosures: Yellow half-sheet

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MAY 23 2012

ENF 37795

Charles Rettig
Hochman, Salkin, Rettig, Toscher & Perez, P.C.
9150 Wilshire Boulevard
Suite 300
Beverly Hills, CA 90212

Re: Administrative Subpoena

Dear Mr. Rettig:

Thank you for your correspondence dated January 12, 2012. The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") has reason to believe that Epsilon Electronics Inc. ("Epsilon"), d/b/a Power Acoustik Electronics, may have sold products to Asra International Corporation, LLC which were destined for Iran. OFAC is conducting a civil investigation of this matter.

OFAC administers and enforces a comprehensive trade embargo against Iran as set forth in the Iranian Transactions Regulations (the "Regulations"), 31 C.F.R. part 560; issued under the authority of the International Emergency Economic Powers Act, 50 U.S.C. §§ 1701-06, and other statutes. The Regulations generally prohibit virtually all direct or indirect commercial, financial or trade transactions with Iran by U.S. persons or within the United States, unless authorized by OFAC or exempted by statute. For more information, please see the Regulations, as well as other information specific to each sanctions program on our Web site at www.treasury.gov/ofac.

Enclosed, please find an Administrative Subpoena directed to Epsilon seeking further information about sold products to Asra International Corporation, LLC which may have been destined for Iran. You have previously informed us that you are authorized to accept service of this Subpoena on behalf of Epsilon. If this is not the case, please inform us immediately. The Subpoena requires a response within 30 days of the date of the Subpoena. A response to this Subpoena is required by law.

The enclosed yellow half-sheet must be stapled to the front of your response and your response must reference the "ENF" number printed above.

Your attention is also directed to OFAC's Economic Sanctions Enforcement Guidelines, 74 Fed. Reg.57,593 (Nov. 9, 2009), available at www.treasury.gov/ofac, which set forth the General Factor that OFAC will consider in determining the appropriate administrative action in response to an apparent violation of U.S. sanctions. In addition to the required information set forth on the attached Administrative Subpoena, you are also invited to submit such additional information or evidence that you deem relevant to OFAC's consideration of this matter.

All aspects of this investigation are being handled by the undersigned. If you have any questions, please contact me at (202) 622-1664 or [email protected].

Your prompt attention to this matter is appreciated.


Sincerely,

John Hinton
Enforcement Officer
Office of Foreign Assets Control



Enclosures: Administrative Subpoena
Yellow half-sheet
Certificate of Compliance



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MAY 23 2012

ADMINISTRATIVE SUBPOENA

ENF 37795

Jack Rochel President
Epsilon Electronics Inc. d/b/a Power Acoustik Electronics
1550 S. Maple Ave.
Montebello, California 90640

Dear Mr. Rochel:

Pursuant to Iranian Transactions Regulations (the "Regulations"), 31 C.F.R. part 560, and section 602 of the Reporting, Procedures and Penalties Regulations, 31 C.F.R. § 501.602, Epsilon Electronics Inc. ("Epsilon"), d/b/a Power Acoustik Electronics, is directed to provide the Office of Foreign Assets Control ("OFAC") at the U.S. Department of the Treasury with the following detailed information:

1) A detailed description of all transactions with Asra International Corporation LLC and Asra Electronics Co., including the names, titles, and business units of all individuals who performed any work for Epsilon relating to these transactions. This includes, but is not limited to, any sales person or other employee who communicated with Asra International Corporation LLC or Asra Electronics Co. If any such individual was located outside of the United States while performing any work for Epsilon relating to these transactions, state whether that individual is a United States citizen or permanent resident alien.

2) A copy of all documents related to the above-referenced transactions, including but not limited to distribution agreements, contracts, invoices, air waybills, shipping documents, financing and payment documents, and correspondence (including but not limited to electronic mail and facsimile transmissions).

3) A detailed description identifying all other instances, during the five (5) years preceding the date of this Administrative Subpoena, in which (a) Epsilon, (b) its U.S. affiliates ("Affiliated Entities"), or (c) branches, offices, agents, representatives, or distributors of Epsilon or any of its Affiliated Entities directly or indirectly exported goods, services, or technology to Iran. Provide the names, titles, and business units of all individuals who performed any work for Epsilon relating to these transactions. If any such individual was located outside of the United States while performing any work for Epsilon relating to these transactions, state whether that individual is a United States citizen or permanent resident alien. If there are no such exports, state so.

4) A detailed description identifying all instances, during the five (5) years preceding the date of this Administrative Subpoena, in which Epsilon directly or indirectly facilitated transactions engaged in by any other individual or entity involving Iran. Provide the names, titles, and business units of all individuals who performed any work for Epsilon relating to these transactions. If any such individual was located outside of the United States while performing any work for Epsilon relating to these transactions, state whether that individual is a United States citizen or permanent resident alien. If there are no such instances of facilitation, state so.

5) A copy of all sales, service, distribution, marketing, partnership, delivery or supply contracts or agreements, requests for proposal, and bid information or correspondence between (a) Epsilon, (b) its U.S. affiliates ("Affiliated Entities"), or (c) branches, offices, agents, representatives, or distributors of Epsilon or any of its Affiliated Entities and any individual or entity located in Iran. If none, state so.

6) A detailed description identifying any funds transfers, letters of credit, loan agreements, or any other means of financing, directly or indirectly, involving (a) Epsilon, (b) its U.S. affiliates ("Affiliated Entities"), or (c) branches, offices, agents, representatives, or distributors of Epsilon of any of its Affiliated Entities and any individual or entity located in Iran during the five (5) years preceding the date of this Administrative Subpoena, as well as a copy of all documents relating to such financing. If none, state so.

7) The names and addresses of any third parties who may have acted as an intermediary between Epsilon and any individual or entity located in Iran for any transactions during the five (5) years preceding the date of this Administrative Subpoena. If none, state so.

8) For all transactions identified in response to the questions above, the names and addresses of all parties involved in the transactions and a description of the relationships between or among those parties. Describe how the transactions were authorized within Epsilon, and provide the names, titles, and business units of all individuals who authorized them. If the transactions were not authorized, please explain.

9) For all transactions identified in response to the questions above, a copy of all documents related to the transactions, including but not limited to invoices, air waybills, shipping documents, financing and payment information, and correspondence (including but not limited to electronic mail and facsimile transmissions). If none, state so.

10) A statement as to whether Epsilon is currently engaging, or likely to engage, in any conduct or transactions directly or indirectly involving Iran, including but not limited to the types of transactions referred to in the questions set forth above. If Epsilon engaged in such conduct or transactions in the past but has ceased, explain when and why such conduct or transactions ceased.

11) A copy of Epsilon's internal procedures, if any, on compliance with the regulations administered by OFAC, or a description of the same, as well as the names, titles, and business units of the persons responsible for implementation of any compliance programs. Provide a copy of all compliance manuals and training materials. If Epsilon has no OFAC compliance program, state so.

Failure to respond to this Administrative Subpoena may result in the imposition of civil penalties by OFAC. Further, under 18 U.S.C. § 1001, knowingly and willfully falsifying or concealing a material fact in your response to this Administrative Subpoena may result in criminal fines, imprisonment, or both.

Please provide the information set forth above in writing, either in hardcopy or electronic format, and mail it, along with a completed Certificate of Compliance (enclosed), no later than 30 calendar days from the date of this Administrative Subpoena. Address your response as follows:

U.S. Department of the Treasury
Office of Foreign Assets Control
Attn: John Hinton
Office of Enforcement
1500 Pennsylvania Avenue,
NW Washington, DC 20220

The enclosed yellow half-sheet must be stapled to the front of your response and your response must reference the "ENF" number printed above.

All aspects of this investigation are being handled by Enforcement Officer John Hinton. If you have any questions, please contact Mr. Hinton at (202) 622-1664 or [email protected].

Issued on behalf of the Director of OFAC:

Amber Stokes
Enforcement Section Chief
Office of Foreign Assets Control


Enclosures: Yellow half-sheet
Certificate of Compliance