On May 18, the U.S. Department of Justice announced the unsealing of an indictment against two individuals and a company for conducting financial transactions in violation of U.S. sanctions against Iran. The three defendants — Iranian Internet-based financial-services company Payment24, Payment24’s founder and Chief Executive Officer Seyed Sajjad Shahidian, and Payment24’s Chief Operating Officer Vahid Vali — were charged with conspiracy to commit offenses against and to defraud the United States, wire fraud, money laundering, and identity theft. Shahidian had previously been arrested in and extradited from the United Kingdom to the United States; Vali remains at large.
According to the Justice Department, Payment24, which had offices in Tehran, Shiraz, and Isfahan, Iran, had as its primary business
helping Iranian citizens conduct prohibited financial transactions with businesses based in the United States, including the unlawful purchase and exportation of computer software, software licenses, and computer servers from United States companies. According to PAYMENT24’s website, the company charged a fee to circumvent “American sanctions,” and claimed to have brought in millions of dollars of foreign currency into Iran.
The indictment alleged that beginning in or before 2009 through November 2018, Shahidian conspired with Vali and other individuals to commit federal criminal offenses by violating the restrictions on trade and exports from the United States to Iran. Payment24 sold on its website
a package to assist its Iranian clients with making online purchases from United States-based businesses, which included a PayPal account, a fraudulent “ID card and address receipt,” a remote IP address from the United Arab Emirates, and a Visa gift card. The PAYMENT24 website also offered its clients advice on how to create accounts with a foreign identity and how to avoid restrictions on foreign websites, including advising clients to “never attempt to log into those sites with an Iranian IP address.
As part of the scheme to violate sanctions restrictions, Shahidian and Vali allegedly made material misrepresentations and omissions to U.S.-based businesses regarding the destination of the U.S.-origin goods. To accomplish the transactions, Shahidian obtained payment processing accounts from U.S.-based companies using false residency information, fraudulent passport documents, and other false documents that were “fabricated using the identity and personally identifiable information of another person.”
Note: Iranian media have reportedly described Shahidian as “as a successful entrepreneur and a capable financial manager who earned $2.5 million in five years.” What is otherwise noteworthy about this case is that after Shahidian’s provisional arrest in the United Kingdom, Iranian Embassy officials met with him to offer consular support, but he reportedly refused the offer.
In any event, sanctions compliance officers should share this information about the indictment with senior executives, and incorporate the details as appropriate into their corporate sanctions training courses and materials.