Liu "Willow" Yang

Liu “Willow” Yang, a Chinese national located in China, began procuring electronic components for an Iranian she met while she was employed as a sales representative of a Chinese digital audio player company. The Iranian approached Yang while at a meeting in China, and requested if she could obtain electronic components for him from the U.S. as a side business. Yang agreed to obtain the products for a small commission. Yang registered her business in Hong Kong in 2009 to avoid scrutiny from U.S. suppliers, and began
purchasing products from the U.S. for her Iranian customer as a side business that she ran in the evening from her home in China. The Iranian customer would provide Yang with a list of products being sought and instructions on which U.S. supplier she should contact for the items. Yang would negotiate with the U.S. supplier for the best price and would purchase the items when her customer approved the purchase price. From 2011 to 2018, Yang procured over 300 exports of U.S.-origin electronic components and sensors from a single U.S. supplier, designated ECCN 3A991 and EAR99, for her Iranian customer while concealing the ultimate end-user in Iran from U.S. companies, shippers, and freight forwarders. When asked about the end-use or end-user for a purchase by a U.S. supplier, Yang would provide false information to the U.S. supplier that was furnished to her from her Iranian customer. Yang was also instructed to route the shipments through logistics companies/freight forwarders in Hong Kong where the 20 shipments would be de-valued and rerouted to Iran. Upon receipt in Hong Kong, Yang was further instructed by her Iranian customer to remove the shipping invoices that showed U.S.-origin references and replace them with false invoices that indicated the products originated in Hong Kong or China. Yang was also instructed to devalue the items and alter their descriptions to avoid scrutiny. When U.S. suppliers began to ask more frequently for end-use and end-user information, Yang was instructed by the Iranian customer to change the name of her business, which she did several times. Yang was arrested in California, while on vacation, in October 2018.