January 19, 2022

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Taiwan Individual and International Business Organizations Charged with Criminal Conspiracy to Violate Iranian Sanctions

20 min read
<div>Chin Hua Huang, 42, a resident of Taiwan, was charged in the United States District Court for the District of Columbia with participating in a criminal conspiracy to violate U.S. export laws and sanctions against Iran.  Also charged was Taiwan business organization DES International Co., Ltd. (DES Int’l) and Brunei business organization Soltech Industry Co., Ltd. (Soltech).</div>

Chin Hua Huang, 42, a resident of Taiwan, was charged in the United States District Court for the District of Columbia with participating in a criminal conspiracy to violate U.S. export laws and sanctions against Iran.  Also charged was Taiwan business organization DES International Co., Ltd. (DES Int’l) and Brunei business organization Soltech Industry Co., Ltd. (Soltech).

Huang, DES Int’l, and Soltech were charged in a criminal complaint with conspiring to defraud the United States and to violate the International Emergency Economic Powers Act (IEEPA) and the Iranian Transactions and Sanctions Regulations (ITSRs).

“The defendants are charged with conspiring to violate American sanctions on Iran by buying goods from the United States, concealing the origin of those goods and sending them to Iran for use by the government and business,” said Assistant Attorney General for National Security John Demers.  “Violations of the sanctions diminish their effectiveness and delay the day when Iran will cease its belligerent activity.”

“Individuals or business organizations that violate U.S. laws by providing U.S. goods to Iran without a license will be prosecuted to the fullest extent of the law,” said Acting U.S. Attorney Sherwin.

“The FBI greatly appreciates the coordinated efforts with HSI, OFAC, DCIS, BIS, DC USAO, and DOJ CES to bring formal charges against DES International, it’s subsidiary Soltech Industry, and Ms. Chin Hua Huang. Together, they worked to relentlessly pursue every lead to ensure these individuals would face the charges detailed in the criminal complaint for their roles in illegally supplying U.S. technology to Iran,” stated FBI San Antonio Division Special Agent in Charge Christopher Combs.  “The items, which were allegedly delivered by DES International, its front companies and Ms. Huang to Iran, undermined our national security.  For me, the most impressive aspect of this investigative team’s diligent work was not only the criminal charges against these three entities, but also the addition of four individuals and more than six companies to the Department of Treasury Office of Foreign Asset Control’s Specially Designated Nationals and Blocked Persons List (SDN) surrounding this proliferation network located throughout the Middle East and Asia.”

“Today’s action is a tremendous example of Homeland Security Investigations’ (HSI) collaborative commitment to enforce the export laws of the United States.  These individuals and organizations are eroding our country’s national security and legitimate commerce by transshipping sensitive U.S. technology to Iran through various shell companies and affiliates,” said Special Agent in Charge, Shane Folden, HSI San Antonio.  “This effort demonstrates the U.S. Government’s enduring resolve to ensure significant consequences to violators.  HSI is uniquely positioned to use its wide ranging investigative authorities and global footprint to mitigate weaknesses within the U.S. trade and financial sectors by utilizing the full authorities of the U.S. Government.”

“This investigation underscores the Defense Criminal Investigative Service’s commitment to safeguarding our nation’s most sensitive technologies and preventing those technologies from getting into the hands of our adversaries,” said Michael Mentavlos, Special Agent in Charge of the DCIS Southwest Field Office.  “DCIS, in consort with our law enforcement partners, will continue to aggressively identify, disrupt, and bring to justice those who attempt to circumvent export control laws and threaten the integrity of U.S. military technology.” 

“Today’s action is the result of seamless coordination and collaborative counter proliferation efforts of a very dedicated multi-agency team of law enforcement professionals from the Office of Export Enforcement (OEE), Homeland Security Investigations, Defense Criminal Investigative Service, the FBI and the Department of Justice.  OEE and our partners will continue to prevent the illegal export of U.S. technologies and protect American businesses by combatting transnational criminal networks and violators of our export laws.” said P. Lee Smith, Performing the Nonexclusive Functions and Duties of the Assistant Secretary for Export Enforcement, Bureau of Industry and Security, US Department of Commerce.

The affidavit in support of the criminal complaint alleges that Huang was a sales agent for DES Int’l and Soltech, both of which procured goods from the United States for the benefit of Iranian government entities and business organizations.   DES Int’l and Soltech were affiliated with one another by virtue of common directors, employees, and customers.  Huang used her position as a sales agent to help an Iranian research center obtain U.S. goods without a license from the Department of the Treasury.  These goods included a power amplifier designed for use in electromechanical devices, and cybersecurity software.  Huang took steps to conceal the U.S. origin of the goods, including by removing serial number stickers with the phrase “Made in USA” from packages, and by causing the cybersecurity software to be downloaded onto a computer outside of Iran.  Huang shared developments regarding this illegal conduct with other employees and directors of DES Int’l and Soltech.

A concurrent action was taken by the Department of the Treasury, sanctioning Huang, DES Int’l, and Soltech, and seven related individuals and entities.

If convicted, Huang would face up to five years of imprisonment and a fine of up to $250,000, and Des Int’l and Soltech would each face a fine of up to $500,000.  The criminal charge in the complaint is an allegation, and criminal defendants are presumed innocent until proven guilty beyond a reasonable doubt.

The investigation was conducted by the FBI’s San Antonio, Texas, Field Office, HSI, DCIS, and DOC.  Assistant U.S. Attorney Michael J. Friedman and National Security Division Trial Attorney William Mackie are representing the United States.

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