Print Article

Dual U.S.-Iran citizen charged for procuring and supplying goods in violation of U.S. sanctions

  1. A dual U.S.-Iran citizen was charged with using companies he controls in the United Arab Emirates to procure and supply goods to the Central Bank of Iran (CBI) in violation of U.S. sanctions.
  2. Kambiz Attar Kashani was arrested in Chicago and was remanded into custody after an initial court appearance before a magistrate judge there, prosecutors in Brooklyn, New York, said Friday.
  3. Breon Peace, U.S. Attorney for the Eastern District of New York, said in a statement.
  • “Kashani orchestrated an elaborate scheme to evade U.S. export laws and use the U.S. financial system in procuring U.S. electronic equipment and technology for the [CBI],”
  1. The CBI was
    1. Sanctioned and delisted as part of a nuclear deal with Iran, was added back onto the sanctions list in November 2018 after the U.S. had exited the agreement.
    2. Sanctioned again in September 2019 under
  • U.S. counterterrorism authorities due to its support to Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Hizballah, the U.S. Treasury Department said at the time. The U.S. issued a license in February 2020 allowing particular humanitarian trade with the CBI following concerns that the counterterrorism designation had complicated pathways for such transactions.
  1. Kashani, who resides in the UAE,
    1. Worked for companies that distributed technology in the Middle East and
    2. That worked in cooperation with the Iranian government, according to the complaint, which cited an online business profile.
  2. The complaint said that an Iranian company, sometimes acting on behalf of the CBI, tasked Kashani and others to buy the items and arrange trans-shipment to Iran.
  3. To fulfil the requests, Kashani and his co-conspirators used two UAE firms, both at least part-owned by Kashani, to conceal the purchases, according to the complaint.
  • At no time did Kashani or any co-conspirator apply for, receive or possess a license to export items from the U.S. to Iran, the complaint said.

9.The Iranian company isn’t named, nor are the two UAE firms associated with Kashani. But they are both described in the complaint:

  1. The Iranian firm was founded in 1993 as the executive and technological arm of CBI, and the central bank is its largest client.
  2. The UAE firms “function as alter-ego companies,” operating from the same office space, sharing employees and are “licensed to conduct substantially the same activities,” according to the complaint.

10. Kashani is a partial owner and a board member of one of the UAE companies, serving as its technical manager, business development manager and contact for                 outbound shipments, the complaint said.

  • He is the founder, sole owner and chief executive officer of the second UAE firm.

11. Each of the UAE firms appear to only have one direct customer: the Iranian company, the complaint said.

12. Kashani bought items from several U.S.-based companies, including

  • A program from one that allows large organizations to deploy internal-use applications with their employees, along with a renewable subscription, according to the complaint.
  1. Renewals in 2020 and 2021 caused nettlesome problems due to U.S. sanctions, but the complaint said they were resolved.

13. In June 2021, the U.S. producer of the program updated its licensing agreement, requiring a user to attest that they aren’t deploying the software in a sanctioned             jurisdiction; Kashani was doing business in Iran at the time and continued to do so after making the representation, according to the complaint.

14. That month, Kashani bought a digital content platform from the program’s producer. The same day, the U.S. company sent an email to Kashani saying someone                 had logged into his account from Iran; Kashani didn’t respond.

15. Three days later, an employee at the Iranian company requested non-Iran SIM cards so that they can use the U.S. firm’s software, the complaint said.

16. Kashani didn’t use his email or phone number at the Iranian company for the purchases, one of a multitude of steps he took to conceal dealings with Iranians,                   according to the complaint.

17. Among other things, Kashani signed a questionnaire for a UAE bank saying that, to the best of his knowledge, the second UAE-based company, which he fully                   owned, didn’t have a presence in Iran, and that its related parties were not under U.S. sanctions, the complaint said.



The Team

Meet the team of industry experts behind Comsure

Find out more

Latest News

Keep up to date with the very latest news from Comsure

Find out more


View our latest imagery from our news and work

Find out more


Think we can help you and your business? Chat to us today

Get In Touch

News Disclaimer

As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email