On January 28, 2021, in the U.S. District Court for the Northern District of California, Hassan Ali Moshir-Fatemi (“Moshir-Fatemi”), was convicted of violating the International Emergency Economic Powers Act (50 U.S.C § 1701, et seq.) (“IEEPA”).

According to court documents, between May and October 2015, Niknia, Lant and others conspired to unlawfully sell and supply 500 Russian-made tank helmets to Niknia’s contact in Tehran, Iran. The helmets were to be configured for a Russian-produced T-72S battle tank and were required to have a five-pin plug, a feature that is necessary to enable a tank communication device. In May 2015, Niknia contacted Lant, who operated R&L Ltd., a company that sold Russian items, and requested to purchase 500 T-72S tank helmets and to have the helmets shipped to Tehran.

CAIS is a financial institution based in Switzerland that specializes in wealth management and corporate and investment banking. CAIS serves clients worldwide, including during the relevant time period 17 individual clients located in Iran, Syria, Sudan, the Crimea region of Ukraine, and Cuba. Following a periodic oversight review conducted by Compliance, CAIS identified the USD denominated accounts belonging to 17 individual clients ordinarily resident in Iran, Syria, Sudan, Crimea, and Cuba.

In total, between September 2016 and September 2021, Tango Card transmitted 27,720 merchant gift cards and promotional debit cards, totaling $386,828.65, to individuals with email or IP addresses associated with Cuba, Iran, Syria, North Korea, or the Crimea region of Ukraine. As a result of the foregoing, Tango Card engaged in apparent violations of part 515; § 560.204 of the Iranian Transactions and Sanctions Regulations (ITSR).

Bittrex’s compliance deficiencies resulted in 94,634 apparent violations of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. §560.204. Bittrex did not, for example, screen IP address information that indicated the customer was in a sanctioned location or physical address information provided by the customer, such as an Iranian passport or a customer who self-identified at account opening as being in Iran.