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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
- v. -
ALIREZA SHAHVAROGHI FARAHANI,
a/k/a "Vezarat Salimi," a/k/a "Haj Ali,"
MAHMOUD KHAZEIN, KIYA SADEGHI, OMID NOORI, and
NILOUFAR BAHADORIFAR,
a/k/a "Nellie,"
Defendants.
SEALED
SUPERSEDING INDICTMENT
S1 21 Cr. 430 (RA)
- X
BACKGROUND
1. The charges in this Indictment arise out of a scheme by the Government of the Islamic Republic of Iran to target dissidents who oppose the regime's violations of human rights, suppression of democratic participation and freedom of expression, and corruption. The regime has targeted such individuals for harassment, intimidation, and incarceration, among other tactics. In recent years, the regime has also targeted its...
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1) LEGAL BASIS FOR LIABILITY
This indictment appears to be, at least partially, based on theories of liability that are unlike anything that OFAC has ever charged in the civil enforcement context. These comments are limited only strictly to “Count Two” and the facts that appear to be related thereto. The other charges related to criminal laws that are not administered by OFAC.
The government alleges violations of the ITSR and GTSR. As is not uncommon of these indictments, there is a fairly weak connection of the dots between the facts alleged and the specific violations charged. The violations of the IEEPA-based sanctions regulations (i.e. the ITSR and GTSR) appear to stem from activities in furtherance of the plot to...