UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

-x
UNITED STATES OF AMERICA

SUPERSEDING INDICTMENT

- v. -

S 2 15 Cr . 8 6 7 (RMB)

REZA ZARRAB,
a/k/a
"Riza Sarraf,"
MOHAMMAD
ZARRAB,
a/k/a
"Can Sarraf,"
a/k/a
"Kartalmsd,"
CAMELIA JAMSHIDY,
a/k/a
"Kamelia
Jamshidy,"
HOSSEIN NAJAFZADEH,

and

Defendants.

- - - - - - - - - - - - - - - - - -x
COUNT ONE
(Conspiracy
The Grand

to

Jury

Defraud

the

United

States

Economic

Powers

charges:
BACKGROUND

The International
1.

The International

("IEEPA"),

codified

at

1701-1706,

confers

upon

unusual

and

foreign

policy

part,

that

attempt
any

to

license,

Emergency

Title

of

"[i]t
violate,
order,

the

50,

the

extraordinary

United

President
threats

United

shall

Emergency

States.

be unlawful

conspire
regulation,

to

States

the

violate,

to

national
1705

prohibition

to

cause

Act

Sections
deal

with

security

a person
or

Powers

Code,

Section
for

or

Economic

authority
to

Act

provides,

and
in

violate,
a violation

issued

under

of
this

 title."

2.
on November
Iran

§ 1705(a).

50 U.S.C.

Beginning
14,

1979,

constitutes

national
States

the

Executive

President

an unusual

and

foreign

policy

security,
and

with

declare[d]

Order

found

No.

that

"the

extraordinary
and

a national

economy

emergency

12170,

to

issued

situation

threat

to

of

United

the

deal

with

in

the

that

threat."
3.

On May 6,

Order

No.

12959,

adopting

12170

(collectively,

the

among

other

supply,

things,

directly

technology,

or

States

person.

States

Secretary

regulations
Pursuant

to

"ITSR")

the

or

the

and

"Executive

the

the

Orders

carry

authority,
Iranian

to
out

the

Transactions

implementing

the

of

Order

and

and

any

States

the

by a United

the

United

rules

and

Executive

Orders.

of

Treasury

the

Regulations
Sanctions

or

goods,
or

promulgate

No.

prohibiting,
sale,

authorized

Secretary

Transactions

Iranian

Iran

United

Treasury
to

Executive

reexportation,

the

The Executive

this

Orders"),

to

from

issued
Executive

exportation,

services

of

President

continuing

indirectly,

necessary

promulgated
2013,

the

1995,

(renamed
Regulations,

sanctions

imposed

by the

Title

Code of

Federal

in
the

Executive

Orders.
4.
Section

560.204,

The ITSR,
prohibits,

31,

among other
2

things,

Regulations,
the

exportation,

 reexportation,

sale,

United

or

States,

technology,

or

certain

limited

services
without

or

or

intended

violation

of

supply
that

the

Foreign

have

the

purpose

of

the

violate

A to

the

Iran

or

(with

Control

services

technology

or

of

Department

Iran,
of

the

("OFAC").

prohibit

to

of

Government

evading

the

goods,

technology

States

from

exportation,

goods,

the

Assets

ITSR further

attempt

or

of

Government

goods,

United

The

or

the

such

Iran

indirectly,

Person,

or

of

5.

of,

or

including

for

from

Office

avoid,

Iran

knowing

a license

Treasury,

to

States

exceptions),

country
are

directly

by a United

sale

a third

supply,

services

reexportation,
to

or

transactions
or

that

avoiding,

the

ITSR.

cause

evade
a

31 C.F.R.

§ 560.203.
Appendix

6.

persons

determined

relevant
owned
this

to
bank

this
on the

an Iranian

("NICO"),
Naftiran
company

Oil
to

list
the

National
on the

Indictment,

an Iranian
Intertrade

company
Company

in

Government

Switzerland,

of

Bank Mellat

in Appendix

Company

this

located

be the

Indictment,

Indictment,

relevant

to

ITSR contained

A.

Iranian
list

At all

Company

3

A.

Intertrade
in

the

on the

list

times
state-

relevant

to

("NIOC")

was

At all

times

Company

United

("NICO Sarl"),
were

At all

times

in Appendix

located
Sarl

Iran.

of

was an Iranian

Oil

Naftiran

a list

Ltd.

Kingdom

and

an Iranian
in Appendix

A.

 7.

Bank Mellat

subsidiaries
2007,

as

the

Iranian

Part

561,

Sanctions
Mellat

were

the

Weapons

owned

relevant

to
8.

and

Iran's

Islamic

this
times
was

13599

July

relevant
identified
9.

Mahan Air

times

12,

Indictment

as

("HKICO")

Guard

on or

about

the

2012,
after

this

May 23,

this

as

an agent

2012,

Indictment

an agent

about

an SDN pursuant

or

on or

October
to

Executive
4

the

affiliate

2012,

September
the

2011,

to

NICO Sarl,

about

and

May 23,

after

on or

times

relevant

24,

2012,

IRGC.

OFAC designated

Order

of

and

was an SDN.

of
12,

Hong

pursuant

24,

Jashnsaz

affiliate

times

to

or

("IRGC")

Indictment

after

services

OFAC designated

HKICKO was an SDN. At all

to

On or

to

544.

was an SDN.

of NICO,

WMDSanctions

relevant

Part

At all

September

chairman

ITSR,

31 C.F.R.

an SDN pursuant

Corp

the

was a money

2012,

as

25,

Proliferators

31 C.F.R.

NIOC as

Jashnsaz,

an SDN under

At all

Destruction

12,

under

("IFSR"),

Bank Mellat
July

October

("SDNs")

Exchange")

identified

Seifollah

HKICO, as

about

about

and

about

by Bank Mellat.

Revolutionary

Order

designated

Mass

("Mellat

Company

OFAC further

Executive

of

Indictment,

ITSR.

branches

Regulations

controlled

On or

Kong Intertrade

its

("WMD Sanctions"),

Company

this

of

Nationals

Sanctions

Regulations
Exchange

all

by OFAC on or

Designated

Financial

business

2012.

designated

Specially

and

and

13224

for

to

At all
NIOC

 providing
Islamic

financial,
Revolutionary

According

to

.flown

training,

facilitating
into

to

and

procedures

and

eliminate

records

controlled
Mahan Air

out

also

by the

personnel,

and

from

omitted

shipments

bound

Tehran,

travel

for

travel

of

normal

facilitated
the

Foreign
weapons

and

cargo

IRGC-QF

security
manifests

services

of
to

to

OFAC,

Hizballah,

Organization,

goods

on behalf

manifests

to

IRGC-QF

according

Terrorist

to

IRGC-QF

procurement

Further

transportation

to

suspected

IRGC-QF travel,
for

services

military

on flight

funds

the

provided

services

Syria

to

("IRGC-QF").

information

Mahan Air
for

and

IRGC-QF.

designated

transported

in

by bypassing

received

provided

Lebanon-based

Iran

Iraq

the

Force

travel

covert

of

support

and personnel

including

and

goods

from
the

of

shipments,

based

by providing

and

not

technological

Corps-Qods

transfers

including

personnel

arms

Guard

funds

IRGC-QF,

officers

and

OFAC, Mahan Air,

transportation,
the

material

secret

of

a

and

has

Hizballah

weapons

Hizballah.
The Defendants

10.
ZARRAB, a/k/a
network

of

Emirates,
A.S.

At all
"Riza

companies
including

("Royal

Holding"),

times
Sarraf,"
located
a group

relevant
the
in
of

to

this

Indictment,

defendant,
Turkey

and

companies

a holding

company

5

owned
in

under
in

the

and

REZA
operated

United

Royal
Turkey,

Arab

Holding
Durak

Doviz

a

 Exchange,

a money

Exchange

LLC ("Al

in

the

United

entities

services
Nafees

Arab

includes
11.

Royal
At all

Turkey

owned
and

Exchange

in

General

company

in

the
12.

JAMSHIDY, a/k/a

Royal

the

times
"Can

Trading

Sarraf,"

a/k/a

13.
NAJAFZADEH, the

others.

"Kartalmsd,"

Emirates,

including

services

of

Indictment,

of

LLC ("Hanedan

the

companies

located
Flash

Doviz

in

Turkey;

business

General

in

Trading"),

a

others.

times

relevant

Jamshidy,"

related

At all

among

this

business

group

a network

a money

"Kamelia

and

services

Investments,

of REZA ZARRAB, a/k/a

Holding

and Al Nafees

Holding

to

Arab

UAE, among
At all

a money

relevant

operated

Doviz"),

Turkey,

The Royal

Emerald

United

("Flash

Hanedan

employee

and

in

Exchange"),

Emirates.

MOHAMMAD
ZARRAB, a/k/a
defendant,

business

to
the

"Riza

this

Indictment,

defendant,

Sarraf,"

CAMELIA

was an

the

defendant,

at

entities.

times

defendant,

relevant

to

was a senior

this

Indictment,

officer

at

HOSSEIN

Mellat

Exchange.
14.
ZARRAB, a/k/a
Jamshidy,"
assisted
Mellat,

and
Iranian
Mellat

At all
"Riza

times
Sarraf,"

relevant

to

Exchange,

Indictment,

CAMELIA JAMSHIDY, a/k/a

HOSSEIN NAJAFZADHEH, the
individuals

this

and
NIOC,

defendants,

companies,

HKNICO, and

6

"Kamelia
and

including
others,

REZA

others

Bank
to

evade

U.S.

 sanctions
using

by conducting

Turkish

and

benefit

of

these

conceal

from

provided

to

affiliates
the

Emirati

to

the

and

the

and

others

that

Government

IRGC in violation

of

and

entities

in

services

of

Iran,

of

the

for
order

were

and

to

IEEPA,

the
to

being

agents

the

or

ITSR,

and

IFSR.
Statutory
15.

including
York,

.in

From at
or

Turkey,

Sarraf,"

known

the

impair,

impede,

governmental

United

enforcement
administered

Arab

or
the

about

States

Southern

Emirates,

and

economic

by that

up to

and

and

of New

elsewhere,

did

together

and

an agency
the

operations

Foreign
sanctions

laws

agency.

7

and
of

Assets

"Kamelia
and

with

each
to

wit,

other

to

to

legitimate

the

U.S.

Control
and

others

combine,

thereof,

lawful

REZA
"Can

defendants,

willfully

agree

and

District

MOHAMMAD
ZARRAB, a/k/a

and

obstruct

of

2010,

CAMELIA JAMSHIDY, a/k/a

and

and

Office
of

in

knowingly

functions

Treasury,

in

Sarraf,"

confederate,

defraud

Allegations

HOSSEIN NAJAFZADEH, the

unknown,

conspire,

2015,

"Kartalmsd,"

and

and

least

United

"Riza

a/k/a

Jamshidy,"

about

the

ZARRAB, a/k/a

the

transactions

on behalf

individuals

banks

Iran,

financial

companies

Iranian

U.S.

of

international

Department

("OFAC")

regulations

in

of
the

 Overt

16.
the

illegal

In

furtherance

object

Acts

of

thereof,

the

conspiracy

and

REZA ZARRAB, a/k/a

"Riza

("ZARRAB"),

MOHAMMAD
ZARRAB, a/k/a

"Kartalmsd"

("MOHAMMADZARRAB"),

"Kamelia
others

Jamshidy,"
committed

and
the

a.

addressed
prepared

to
for

the

following

an email
General

ZARRAB's

Sarraf"

CAMELIA JAMSHIDY, a/k/a

overt

about

acts,

December

attaching

Manager

of

signature,

among
3,

2011,

a draft
the

stating

defendants,

Central
in

the efforts
children
of
8

and

others:
ZARRAB and

letter
Bank

in
of

part:

The role
that
the Supreme Leader
[the
Ayatollah
Khamenei]
and the esteemed
officials
and employees
of Markazi
Bank [the
Central
Bank of Iran]
play against
the
sanctions,
wisely
neutralizes
the sanctions
and even turns
them into opportunities
by
using
specialized
methods.
It is no secret
that
the trend
is moving towards
intensifying
and increasing
the sanctions,
and since
the wise leader
of the Islamic
Revolution
of Iran has announced
this
to be
the year of the Economic
Jihad,
the Zarrab
family,
which has had half
a century
of
experience
in foreign
exchange,
while
establishing
branches
in Turkey,
United
Arab
Emirates,
Russia,
and Azerbaijan,
considers
it to be our national
and moral duty to
declare
our willingness
to participate
in
any kind of cooperation
in order
to
implement
monetary
and foreign
exchange
anti-sanction
policies
....
Hoping that
the zealous

effect

a/k/a

HOSSEIN NAJAFZADEH, the

On or

NAJAFZADEH received

"Can Sarraf,"

to

and cooperation
of
Islamic
Iran will

Farsi
Iran

and

 · result
in an upward increase
in the
of our dear nation
in all
international
financial
arenas.
Transactions
b.
conspirator

not

employee
sent

On or

named

of Mellat

an email

to

described

in paragraph

the

amount

Canada

plant

the

("CC-1"),

in

an

paragraph
not

7 above,

named

as

of Al Nafees
instructions

a

Exchange,
for

transfers

instructions

Al Nafees

on behalf

of

was a payment

in

$953,288.85

to

a company

located

described

as

"transfer

by MAPNA."

MAPNA Group,

On or

about

a co-conspirator

an international

Company-1

in

processed

by a United

payment

to

with

a co-

an Iranian

construction

27,

Royal

in

and

company.

Investments,

transfer

in

2011,

herein

financial

Company-1")

c.

caused

9 above,

approximately

a reference

26,

an employee

Included

("Canadian

MAPNA is
power

of

January

co-conspirator

international

Exchange.

Exchange

described

("CC-2"),

to make

Mellat

a defendant

a second

herein

Mellat

about

Exchange,

defendant

Exchange

as

for

progress
and

the

information
was related

wire

amount

of

January
not

named

transfer

bank

provided

to

fire

from

approximately

States

to

as

equipment,

MAPNA Group.

9

the

but

herein,

UAE to

Canadian

which

Bank-1").

Bank-1

Emerald

a defendant

$953,289,

("U.S.
U.S.

2011,

purported

was

The wire
that

made no mention

the
of

 d.
Mellat

Exchange

instructions

sent

for

transfers,

On or

an email

making

including

on behalf

of Mellat

a payment

in

located

in

the

four

United

("U.S.

("CC-3"),

of

four

the

Exchange

to

sent

instructions
transfers

Included

in

States

the

identifying
as

currency,

instructions

Company-1"),

about

March

of

to

was

a company
the

a bank

about

located

in

16(c)

above.

March

9,

("Hong

Kong Company-1").
On or

an email

to

about

named

the

to

on behalf

for

a list

Mellat

CC-1 of Mellat

Exchange

with

financial
of

Mellat

2011,

located

in
in

CC-1 of

ZARRAB, JAMSHIDY, and
10

a defendant

was a payment

a company

May 24,

as

an

attaching

2011,

international

instructions

$9,225

CC-1 sent

Holding,

CC-2 of Al Nafees

several

the

2011,

instructions

in

approximately

1,

not

Royal

currency

of

sent

United

transaction

with

financial

$76,950

States

amount

Exchange

to

making

g.

in

payment

On or

in United

Exchange.

international

in paragraph

an email
for

Exchange

a co-conspirator

U.S.-currency

f.
Exchange

CC-2 of Al Nafees

approximately

an employee

described

CC-1 of

Included

the

On or

ZARRAB and

herein

28,

Bank-2").

e.
to

of

for

2011,

transfers

("Chinese

Bank"

email

to

Exchange.

"Intermediary
States

February

several

amount

China

about

the

Hong Kong

Mellat

CC-3 of Royal

 Holdings

with

the

subject

urgent!!!!!!!!!!"

addressed

indicating

amount

of

Bank-1

because

payment

Farsi,

to

the

email

to

that

an

approximately
of

related

development
Exchange

in

Attached

SWIFT message
Unit"

line,

of
to

€3,711,365
sanctions;

services

a gas

of

had

field

ZARRAB stating

(1)

a portion

transfer

been

stopped

in

that

connection

in

Iran;

and

(3)

in

part,

in

Farsi:

the

by U.S.

a statement

in

of

"OFAC/Compliance

wire

(2)

provided

very

were

attention

international

global

to

the

"very

the

with

a letter

from

Mellat

Based on the results
of the continuous
follow-ups
regarding
the above transfer,
and
your suggestion
regarding
communication
with
the OFAC agency
in Turkey
regarding
facilitating
transfers
or returns
thereof,
the information
received
from the credit
applicant
is reflected
exactly
for follow
up
and appropriate
action.
h.
email

to

Mellat

Exchange,
the
to

signed

Mellat

sent

Farsi,

"very

portion

of

of

Exchange

of

On or

urgent"

to
and

in

$9,225

attaching

1,

ZARRAB with

had

Al Nafees

2011,

the
among

noting

that

been

blocked
11

a letter

an

from
Exchange
in

U.S.

Iran.

June

attaching,

JAMSHIDY sent

$30 million

Tehran,

about

a SWIFT message

approximately

2011,

approximately

Exchange

an email

May 31,

by NAJAFZADEH, to

delivery

i.
Exchange

about

CC-2 of Al Nafees

requesting
currency

On or

CC-1 of

subject
other

a payment

Mellat

line,

in

things,
in

by a United

(1)

the

a

amount

States

bank

a

 ("U.S.

Bank-3")

"pursuant

Gov Dept.

of

Company-1'

.s bank

from

Asi

Treasury

OFAC;

(3)

payment
1 in

the

United

to

of

a second

amount

sanctions;

of

a relative

Exchange,
"through

the

been

to

of

by U.S.

Bank-3

because

noting

that

to
had

been

a result

of

Exchange

blocked

dated

May 15,
signed

two blocked

payments;

and

June

1,

by NAJAFZADEH, concerning
Exchange,"

which

stated

2011,
the
in

to

2011,

by
(5)

Durak

a
Doviz

two payments
part,

[T]he above amounts
were blocked
by OFAC,
and despite
repeated
follow-ups
to execute
these
transfers
by providing
all
necessary
documents,
unfortunately,
the transfers
have
not been executed
and deposited
in the
beneficiary's
account.
Therefore,
despite
the lack of communication
with you regarding
the covered
topic,
and only with regard
to
your excellent
achievements
regarding
similar
prior
cases,
it is requested:
Regarding
the passage
of more than 2 months,
and the lack of any results
from the followups of Nafiss
Exchange,
please
arrange
that
with your guidance
this
case can be closed.

12

by a

OFAC

Exchange,

dated

of

Hong Kong Company-

Al Nafees

Exchange

Nafees

Hong Kong

amount

$35,000

Mellat

U.S.

the

transfer

as

by the

Hong Kong Company-1

SWIFT message

Bank-4")

the

from

Otom in

blocked

a second

from

imposed

a payment

Turizm

ZARRAB's at

Mellat

signed

that

("U.S.

a letter
of

from

a letter

approximately

NAJAFZADEH, concerning
letter

(2)

international

bank
(4)

OFAC";

had

a portion

States

sanctions

Madenler

$9,200

of

the

advising

Kiymetli

approximately

to

in

Farsi:

 Transactions

for the Iranian
Ministry
NIOC, NICO, and HKNICO

j.
email

to

a co-conspirator

Kuyumculuk
of

approximately

to

("CC-5")

1.

which

Company-1

was processed
m.

conspirator
email
Seifollah
HKICO's

not

to

not

On or

named

from

in

Jashnsaz

in

the

located

the

16,

as

ECB

amount

in

a payment

Gunes

General

Turkmeni

not

as

the

November

stamped

a letter

11,

13

a

("CC-6")
HKICO,

€100

General
herein,
to

$999,907,

2013,

herein
from

Gunes

("U.S.

"CONFIDENTIAL,"

an approximately

amount
LLC,

U.A.E.

On or

(1)

the

a defendant

from

a defendant

in

2013,

bank

as

herein

Trading

States

about

an

Company-1.

16,

named

transfer

ZARRAB sent

a defendant

January

amount

2013,

by a United

concerning

company

Sirketi

approximately

and

herein

Turkish

of

named

an

instructions

company

for

to

about

wire

ZARRAB attaching

bank

Limited

January

U.A.E.,

an international

Turkmeni

from

an energy

LLC, a co-conspirator

caused

ZARRAB sent

a defendant

transfer

about

$1,000,000
the

Oil,

Company-1").

On or

in

as

2013,

attaching

a SWIFT message

located

7,

Holding,

Ticaret
to

a co-conspirator

approximately

Trading

Sanayi

("Turkmeni

attaching

company

named

Royal

$600,000

k.
email

January

financial

Ic Vedis

Turkmenistan

of

of

an international

about
not

, an employee,

( "CC-4")
for

On or

of

Bank-5").
a cosent

an

signed

by

addressed
million

to
transfer

 to

HKICO's

account;

international

(2)

financial

Company-1

dated

of

Oil

Iran's

Company-1

May 30,
Ministry,

be made

a letter

from

transfer;

and

2013,

U.S.

conspirator

not

individual
an email

from

"IMPORTANT!!
Department"
a bank

had

from

including,

CC-7 as

the

note

Farsi

in

Mahan Air's

sanctions

defendant

On or

licensee

2011,

Minister
Turkmeni

in

an

Dubai,

with

the

OFAC listed

other

a co-

("CC-7"),

Mahan Air

received

subject

from

things,

transactions

about

US Treasury

a statement

to/from
following

December

of Al Nafees

that

Mahan Air
the

office,
("CC-8");

copies

Trading,

and manager,

18,

addition

a Dubai

on which

"Mahan"

and

the

a co-conspirator
(2)

pages

14

2013,

Exchange

electronic

General

referencing

herein

to

office

policy,

attaching

Ascot

Dubai

among
"all

an employee

for

payment

Turkmeni

will
of

OFAC list[.]"

"ASCOT" and

information

Deputy

herein

been

the

the

13,

Mahan Air's

MAHANAIR has

o.
an email

a defendant

--

that

from

Mahan Air

October

of

as per
to

about

with

advised

Mahan Air

for

a representative

and

be rejected

line:

as

affiliated

an

currency.

On or

named

a letter

to

that

Transactions
n.

(3)

addressed

instructing

in

NIOC concerning

from

CC-2 received

with
of

(1)

the

subject

license

company,

showing

was a handwritten
name of
not
the

an officer

named
passport

as

in

a
of

CC-7;

 (3)

an Al Nafees

General

Exchange

Trading

letter

dated

letterhead,

showing

December
signed

directing

with

from

an email
wire

from

transfer

stating,

On or

and

among

other

received

an email

attaching

a copy

Flash

Doviz,

Ascot

and

naming

General
CC-8.

read

Mahan

account

about

19,

in

dollars)

part:

show us

r.

On or
from

Flash

Doviz

2015,

25,

2015,

a

CC-7 received
a returned

to

about

transfer

of

concerning

6,

of

2015,

order,

amounts

in

in
the

MOHAMMAD
ZARRAB

Al Nafees

Exchange

an Al Nafees

Exchange

a payment
15

"FOR MAHAN"

slips."

July

(1)

payment

above

of

of €129,901.00

Exchange

the

for

a payment

payment

on the

deposit

Order

concerning

Doviz

note

Exchange

Payment

a second

Flash

the

MOHAMMAD
ZARRAB

of Al Nafees

an employee

copies

to

a SWIFT message

Exchange

and

"Please

and

Exchange,

account

concerning
of

June

an employee

Trading

Al Nafees

"ORIGINATOR IN OFAC SANCTIONLIST."

an Al Nafees

electronic
for

January
business

A handwritten

an email

attaching
Order

of

(U.S.

Farsi,

received

from

(4)

bank.

MOHAMMAD
ZARRAB's company,

$1,180,238.00
from

On or

and

Trading

Trading's

a portion

Ascot

signatory;

to

an Iranian

services

for

General

General

about

things,

q.

account

addressed

at

including

card

on Ascot

Ascot

an account

a money

the

2013,

by CC-7 and

p.

signature

CC-7 as
17,

a transfer

beneficiary

account

of

approximately

Payment

a

 €570,613.00

from

"FOR MAHAN" and
that
and

read,
(2)

four

Fund

totaling

Austria,

Greece,

General

naming

in part:

payments

General

Ascot

CC-8,

Trading
with

Request

approximately
Singapore,

Trading

into
Forms

Germany,

each

On or

about

July

7 and

CC-2 approximately

electronic

July

four

in
an Ascot

records

to

the

July

6,

Fund Transfer

were

2015,

16(r)

two Turkish

above.

8,

2015,

emails

transfer

transfers

attaching

concerning

payments

Requests

The originators

companies

("Turkish

on the

Company-1"

wire

and

Company-2").
t.

On or

about

a co-conspirator
received

Exchange

attaching

paragraph

16(s)

two

an email

SWIFT message
to

July

not
emails

two of

the

2015,

9,

named

as

an officer

a defendant

from

an employee

wire

transfer

of

with

herein
Al Nafees

records

described

in

above.
u.

Company-1

requested

bearing

wire

in paragraph

sent

Farsi

account;"

recipients

of

described

("CC-9"),

Mahan

copies

corresponding

Exchange
in

concerning
to

MOHAMMAD
ZARRAB sent

Mahan Air,

note

your

€560,613
and

Doviz

stamp.
s.

"Turkish

Flash

a handwritten

"To be deposited
Transfer

to

to

On or

about

an employee

concerning
a company

July

of Al Nafees

a transfer
in

13,

Malaysia
16

of

2015,

MOHAMMAD
ZARRAB

Exchange

$324,690

("Malaysian

attaching

from

a

Turkish

Company-1").

The

 SWIFT message
from

record

a bank

in

"New York,

Turkey

would

held

Bank-6.

the

"tt's"

transfers.

Flash

Doviz

Exchange

order

attached

were

General

Trading

Hong Kong
entity
and

four

in

w.

On or

a defendant
Exchange

of

herein
attaching

"Put

Request

Belize

Greece,

July

a copy

of

to

17

transfer
on the

account."

Also

Forms,

bearing

an Ascot

(1)

and

to

Transfer

a company

and

(2)

an account

in

an
in

Latvia

Belgium.

2015,

an employee

a Wire

to

of €363,971,

an email

MOHAMMAD
ZARRAB, a co-conspirator
("CC-10"),

Exchange

Mahan

having

22,

or

Trading

Farsi

$100,000,

France,

about

General

in

payments

but

with

transfers,

$116,385.00

the

for

Exchange

amounts

note
in

Kong Company-2")
in

the

an additional

Transfer

located

by an employee

in

Ascot

the

account

was an Al Nafees

from

concerning

an address

entities

email

Mahan Air

in part,

stamp,

("Hong

with

telegraphic

payments

that

in

MOHAMMAD
ZARRAB

to

and

Fund

2015,

a reference

A handwritten

read,

indicating

21,

sent

Bank-6")

a correspondent

July

the

been

("U.S.

Al Nafees

to

had

bank

of

for

individual.

States

an employee

concerning

and €298,984,

a named

payment

--

message

of America,"

about

Attached

Order

$100,000,
to

from

the

through

On or

an email

Payment

a United

be transferred

subject:

wire

that

States

v.
received

to

NY, United

payment
at

reflected

of

not

was sent
named

Al Nafees

Send

Money Receipt

as

 from

a money

transfer

of

services

business

$100,000

from

x.

On or

in Dubai

Hanedan

reflecting

General

a wire

Trading

to

Hong Kong

Company-2.

received

an email

attaching

from

electronic

Order,

with

account,"

Trading

to

copies

of

(1)

note

concerning

a named

July

an employee

a handwritten

Mahan

about

in

23,

Exchange

an Al Nafees

Exchange

Farsi

stating
(a)

in

MOHAMMAD
ZARRAB

of Al Nafees

transfers

individual

2015,

the

"Pay

from

amount

Ascot

of

Payment

into

the

General

€200,000,

(b)

Flash

Doviz

for

Mahan Air

in

the

amount

of €87,520,

and

(c)

Flash

Doviz

for

Mahan Air

in

the

amount

of

$50,000;

and

(2)

Ascot

General

Forms

concerning

Trading

payments

to

entities

located

to

"Re:

in

from

identifying

Bank-4

On or

about

in

from

of

Hanedan
the

in

the

amount

Germany
July

for
23,

and

in

2015,

amount

Trading
bank

$50,000

of

to
for

and €60,000.
sent

the

subject:

a wire

transfer

an

approximately

Hong Kong Company-2
the

transfer

as

U.S.

NY USA."
Later

an employee

on July

of Al Nafees
18

23,

to

and

CC-10

with

attaching

the

General

of

€27,520

Exchange

intermediary

"New York,

Request

Al Nafees

a transfer

z.
email

and

USD MAHANAIR"

reflecting

$99,940.00
and

France

an employee

100.000,00

record

Transfer

Hong Kong Company-2

y.
email

Fund

to

2015,

Exchange

CC-9 received
attaching

an
an

to

 electronic

copy

paragraph
among

16(y)

other

of

the

above,

things,

the

bank

(U.S.

intermediary

aa.
email

to

money

copy

services

$50,000

from

to

"Re:
record

of

and

Hanedan

July

the

about

and

(Title

United

2015,
with

States

from

a

transfer

CC-10

sent

the

subject:

a wire

amount

bank

an

of

Hong Kong Company-2.

29,

Trading

intermediary

sent
an

a wire

attaching

the

CC-10

attaching

Exchange

General

reflecting,

Money Receipt

to

July

in

NY USA."

but
and

2015,

reflecting

Trading

"New York,
18,

Send

of Al Nafees

Hanedan

27,

Exchange

Dubai

General

out

in

"NEW YORK, NY USA."

Transfer

a transfer

from

in

about

in

described

beneficiary,

Bank-4)

USD MAHANAIR"

identifying
in

blacked

On or

reflecting

Bank-4

portions

a Wire

an employee

$49,950.00

with

originator,

business

50.000,00

record

of Al Nafees

bb.
email

transfer

On or

an employee

electronic

wire

of

to
for

transfer

approximately

Hong Kong Company-2,
the

Code,

an

transfer

Section

as

U.S.

371).

COUNT TWO
International

The Grand
17.
including
York,

in

Turkey,

(Conspiracy
to Violate
the
Emergency Economic Powers

Jury

From at
or

about

the

further
least

2015,

United

Arab

charges:

in
in

Act)

or
the

about
Southern

Emirates,
19

2010,

and

up to

District
elsewhere,

and
of New
REZA

 ZARRAB, a/k/a
a/k/a
and

"Riza

Sarraf,"

"Kartalmsd,"

CAMELIA JAMSHIDY, a/k/a

HOSSEIN NAJAFZADEH, the

unknown,

knowingly

and

confederate,

and

and

a violation

to

cause

prohibitions
Powers
Part
of

MOHAMMAD
ZARRAB, /k/a

Act,
560 of

Title

of,

under

United

Title

31,

Code of

18.

of

It

Federal

REZA ZARRAB, a/k/a

"Can

Sarraf,"

others

a/k/a

known

and

supply,

and
and

supplied,

directly

services,

to

and

to

the

required
within

wit,

to

and

approval
the

United

Title

50,

United

31,

Code of

Federal

the

States
States

each

other

Federal

to violate,

regulations,
Emergency

Code,

and

Sections

and

Economic

1701

Regulations,

an object

Sarraf,"

and

to

1707,

Part

561

of

the

would

MOHAMMAD
ZARRAB, a/k/a

and

did

be exported,

Iran,
Office

export,

from

the

financial
without
of

of

Section
20

sell,

sold,

and

States,

transactions,

Foreign

obtaining
Assets

Treasury,
1701

and

reexport,

United

first

Sections

Regulations,

defendants,

reexported,

Department
Code,

conspiracy

CAMELIA JAMSHIDY, a/k/a

indirectly,

of

of

conspire,

orders,

States

international

Government

known and

HOSSEIN NAJAFZADEH, the

unknown,
cause

with

International

"Riza

and

others

and

licenses,

"Kartalmsd,"

Jamshidy,"

Jamshidy,"

Regulations.

was a part

that

"Kamelia

combine,

and

the

50,

Code

did

together

Title

31,

"Kamelia

willfully

agree

issued

defendants,

"Can Sarraf,"

to

560.204.

to

Iran

the

Control,
in

1707,

violation
and

Title

of

 19.
conspiracy

that

ZARRAB, a/k/a
a/k/a

was

"Can

and

others

and

avoiding,

violate

one

or more

Code of

Federal

Federal

and

"Kartalmsd,"

and

avoided,

had

caused

a violation

560,

1701

to

the

illegal

In

furtherance

objects

thereof,

MOHAMMAD
ZARRAB, a/k/a
JAMSHIDY, a/k/a

"Kamelia

defendants,

others

acts
which

set
are

Title

and
forth
fully

known

did

purpose

forth

and

of

attempted
in

in violation
1707,

engage

Title
of

Title

to
31,

Title

31,

50,

Code of

560.203.
Acts

of

the

conspiracy

Sarraf,"

Jamshidy,"

incorporated

the

REZA ZARRAB, a/k/a

"Can

in paragraph

and

and

set

Part

Overt

20.

of,

prohibitions

Section

MOHAMMAD

HOSSEIN NAJAFZADEH, the

evaded

Sections

the

CAMELIA JAMSHIDY,

would

the

of

Sarraf,"

unknown,

of

Regulations,

an object

and

Regulations,
Code,

and
"Riza

a/k/a

known

that

evading

States

a part

Sarraf,"

Jamshidy,"

a transaction

United

further

REZA ZARRAB, a/k/a

"Kamelia

defendants,
in

It

and

a/k/a
and

this

by reference

to

"Riza

effect
Sarraf,"

"Kartalmsd,"

CAMELIA

HOSSEIN NAJAFZADEH, the

unknown,

16 of

and

committed

Indictment,

the
among

overt
others,

herein.

(Title
50, United
States
Code, Section
1705;
31, Code of Federal
Regulations,
Sections
560.203,
560.204,
560.205,
561.202,
& 561.205.)

21

 COUNT THREE
(Conspiracy

The Grand
21.
including
York,

in

Turkey,

known

did

and

with

18,

United

United

and

other

States
22.

It

a/k/a

institution,

and

and
and

and

of

fraudulent

known

and

"Riza

other

REZA
"Can
"Kamelia

defendants,

and

unknown,

knowingly

and

fraud,

and
in

an object

Sarraf,"

would
or

others

agree

and
together

violation

of

Title

of

the

conspiracy

MOHAMMAD
ZARRAB, a/k/a

CAMELIA JAMSHIDY, a/k/a

and

did

institution,

representations,

22

to

funds,

owned

defendants,

knowingly

artifice

moneys,

property

a financial

of New

elsewhere,

HOSSEIN NAJAFZADEH, the

obtain

and

1344.
and

a scheme

pretenses,

bank

Section

unknown,

to

District

confederate,

commit

and

execute

securities,
control

Emirates,

"Kartalmsd,"

Jamshidy,"

to

Southern

up to

MOHAMMAD
ZARRAB, a/k/a

was a part

Sarraf,"

attempt

2010,

CAMELIA JAMSHIDY, a/k/a

Code,

"Can

known

Arab

others

to

REZA ZARRAB, a/k/a

others

about

the

conspire,

that

"Kamelia

in

or

HOSSEIN NAJAFZADEH, the

combine,

each

charges:

in

Sarraf,"

unknown,

willfully

least

"Kartalmsd,"

and

and

further

2015,

"Riza

a/k/a

Jamshidy,"

about

the

ZARRAB, a/k/a
Sarraf,"

Jury

From at
or

to Commit Bank Fraud)

execute

defraud

and

assets,

under

by means

and

a financial

credits,

by and

and

the
of

promises,

custody
false
in

and

 violation

of

Title

18,

United

States
Overt

23.
the

illegal

In

furtherance

object

thereof,

MOHAMMAD
ZARRAB, a/k/a

"Can

JAMSHIDY, a/k/a

"Kamelia

defendants,

others

acts

set

which

and
forth

are

in

fully

of

and

REZA ZARRAB, a/k/a

"Riza

the

Sarraf,"

known

18,

a/k/a
and

this

effect

Sarraf,"

"Kartalmsd,"

committed

CAMELIA

the

Indictment,

by reference
States

to

HOSSEIN NAJAFZADEH, the

and unknown,
16 of

United

1344.

conspiracy

incorporated

(Title

Section

Acts

Jamshidy,"

paragraph

Code,

overt

among

others,

herein.

Code,

Section

1349.)

COUNT FOUR
(Conspiracy

The Grand
24.
including
York,

in

Turkey,

ZARRAB, a/k/a
Sarraf,"

a/k/a

Jamshidy,"
known
willfully

and

to

Jury

From at
or

about

the
"Riza

Commit Money Laundering}

further
least

2015,

United

in
in

Arab

Sarraf,"

"Kartalmsd,"

charges:
or
the

about
Southern

Emirates,

and

agree

together

States

Code,

and
Section

with

District

with

others

did

combine,

each

other

1956(a)

(2) (A).

23

defendants,
known
conspire,

to

violate

and
of

elsewhere,

CAMELIA JAMSHIDY, a/k/a

together

knowingly

and

up to

MOHAMMAD
ZARRAB, a/k/a

and HOSSEIN NAJAFZADEH, the
unknown,

2010,

REZA
"Can
"Kamelia
and

and

others

unknown,

confederate,
Title

New

18,

and
United

 25.

It

was a part

that

REZA .ZARRAB, a/k/a

"Can

Sarraf,"

"Kamelia
others

a/k/a

interstate

and

transfer,

monetary
from

amounts

exceeding

carrying

on of

export

of

Indictment

and

Indictment,

in

United

States

in

and

through

attempt

specified
to

bank

and

the

unlawful
Iran

as

fraud

violation

as
of

In

object

furtherance
thereof,

MOHAMMAD
ZARRAB, a/k/a
JAMSHIDY,
defendants,
acts

set

funds

to
the

charged

in

transmit,
in

United

1956(a)

the

promote

Count

and
United

States,

.to wit,

Count

affecting

transport,

places

to

in

charged

and

and

in

the
the

Two of
Three

this

of

(2) (A) of

illegal

this

Title

18,

Code.

26.
illegal

transport,

intent

Section

did

to

activity,

Overt

the

and

outside

with

defendants,

involving

would

places

$10,000,

conspiracy

MOHAMMAD
ZARRAB, a/k/a

an offense

instruments

services

the

CAMELIA JAMSHIDY, a/k/a

commerce,

transfer,

and

Sarraf,"

of

HOSSEIN NAJAFZADEH, the

unknown,

foreign

transmit,

States

and

and

and

"Riza

an object

"Kartalmsd,"

Jamshidy,"
known

and

a/k/a
and
forth

"Can

"Kamelia
others
in

Acts

of

the

conspiracy

and

REZA ZARRAB, a/k/a

"Riza

Sarraf,"

a/k/a

Jamshidy,"
known

paragraph

and

and

24

this

effect

Sarraf,"

"Kartalmsd,"

CAMELIA

HOSSEIN NAJAFZADEH, the

unknown,

16 of

to

committed

Indictment,

the
among

overt
others,

 which

are

fully

incorporated

(Title

18,

by reference

United

States

herein.

Code,

Section

1956(h)

.)

FORFEITURE ALLEGATION
(Counts

27.
Counts
"Riza

As a result

Two and

Three

Sarraf,"

of

of

this

States,

pursuant

981(a)

(1) (C) and

property,

limited
obtained

property,

to

real

Title

and

traceable
Two and
to

defendants,

Title

18,

"Can

States

Code,

of

offenses

this

the

Indictment,

representing

the

offenses.

Substitute

Assets

any

Code,

is

but

amount

of

forfeitable

of

any

act

of

b)

has been
deposited

c)

has
the

omission
upon

transferred
or
with,
a third

been placed
court;
25

all
from
in

not

proceeds

Provision

above-described

cannot
be located
diligence;

2461,

alleged

the

a)

United

derived

of

or

the

Section

including
the

and

Section

commission

of

States

to

or

of

a result

forfeit

constitutes

a result

as

shall

Jamshidy,"

that

the

in

a/k/a

personal,

Three

If

Sarraf,"

"Kamelia

United

alleged

REZA ZARRAB, a/k/a

United

to

28.

offenses

28,

a sum of money

as

the

Indictment,

CAMELIA JAMSHIDY, a/k/a

HOSSEIN NAJAFZADEH, the

Counts

committing

MOHAMMAD
ZARRAB, a/k/a

"Kartalmsd,"

proceeds

Two and Three)

beyond

the

the

exercise

sold to,
person;
the

defendants:
of

due

or

jurisdiction

of

 it

is

the

United
other

d)

has
or

e)

has been commingled
with
which cannot
be subdivided
difficulty;

intent

of

States

Code,

property

of

forfeitable

been

the

substantially

United

Section
said

diminished

States,

853(p),

defendants

other
property
without

pursuant
to

seek

up to

in value;

to

Title

forfeiture

the

value

21,
of

of

the

any
above

property.
FORFEITURE ALLEGATION
(Count

29.
offense
a/k/a

As a result

alleged
"Riza

in

Count

Sarraf,"

"Kartalmsd,"

all

property,

amount
offense

to
real

offense

including

but

not

of property
or

Four

of

this

CAMELIA JAMSHIDY, a/k/a

pursuant

laundering

committing

is

the

defendants,

Title

18,

and

personal,

and

all

limited
that

traceable

property
to,

was
to

involved

Code,
in

traceable

a sum of money
involved

such

in

property.

26

the

Sarraf,"

Jamshidy,"

forfeit

States

laundering
REZA ZARRAB,

"Can

"Kamelia
shall

United

money

Indictment,

MOHAMMAD
ZARRAB, a/k/a

HOSSEIN NAJAFZADEH, the
States,

of

Four)

the
to

to

and

the

United

Section

982,

money
such

property,

representing
money

a/k/a

laundering

the

 Substitute

30.
property,

it

is

United
other

If

any of the

as a result

the

intent

States

forfeitable

Provision

above-described

of any act

forfeitable

or omission

of the

a)

cannot be located
diligence;

b)

has been transferred
or sold to,
deposited
wi th, a th i rd person;

c)

has

be e n placed

the

cour t ;

upon the

beyond

the

defendants:

exercise

of due
or

jurisdiction

has been substantial
or

e)

has been commingled with other property
which cannot be subdivided
without
difficulty;
of the

United

Section

of said

States,

853(p),

defendants

l y diminished

of

d)

Code,

property

Assets

pursuant
to seek

up to the

to Title

forfeiture
value

in value;

21,
of any

of the

above

property.
(Title

18, United

States
Code, Sec ti ons 981, 982;
States
Code, Section
853;
tates

Code,

Section

2461.)

PREET BHARARA
United States Attorney

Foreperson

27

 Form No.

USA- 33s - 27 4 (Ed.

9 - 25-58)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

v.
REZA_ ZARRAB, a/k / a "Riza Sarraf,"
MOHAMMAD
ZARRAB, a / k / a "Can Sarraf,"
a / k/a "Kartalmsd,"
CAMELIA JAMSHIDY, a / k / a "Kamelia
Jamshidy,"
and
HOSSEIN NAJAFZADEH,
Defendants.

SUPERSEDING INDICTMENT
S2 15 Cr.

867

(RMB)

(18 u.s .c. § 371; 50 u.s.c.
C . F.R. §§ 560.203,
560.205;
§§ 1349 , & 1956.)

1705; 31
18 U.S.C.

§

PREET BHARARA

A TR