California Resident Sentenced To Four Years In Prison For Conspiring To Violate U.S. Sanctions Against Iran

Damian Williams, the United States Attorney for the Southern District of New York, announced today that NILOUFAR BAHADORIFAR, a/k/a “Nellie Bahadorifar,” was sentenced to four years in prison for conspiring to violate the International Emergency Economic Powers Act (“IEEPA”) by providing services, including financial services, to Iran and the Government of Iran, in violation of U.S. sanctions against Iran, and for structuring.  BAHADORIFAR pled guilty on December 15, 2022, before U.S. District Judge Ronnie Abrams, who imposed today’s sentence.

U.S. Attorney Damian Williams said: “Niloufar Bahadorifar willfully violated sanctions and knowingly provided financial support to Iranian intelligence assets, who in turn were engaged in a plot to kidnap an Iranian human rights activist living in the United States whom the Iranian Government has sought to silence for years.  Assisting malign foreign governments by violating sanctions can have devastating consequences, including for those targeted by hostile regimes for retribution.  This Office will continue to prosecute efforts to subvert sanctions and is proud to protect victims from repressive regimes.”

According to the Indictment and other documents in the public record, as well as statements made in public court proceedings:

The IEEPA confers upon the President authority to deal with unusual and extraordinary threats to the national security and foreign policy of the United States.  Since 1979, the President has found that the situation in Iran constitutes an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States.  Among the Government of Iran’s malign practices, it has targeted and sought to repress, including through harassment, intimidation, and violence, those who defend human rights and criticize the regime.  Pursuant to the IEEPA, and applicable Executive Orders and regulations, U.S. persons are prohibited from exporting any services, including financial and banking services, to Iran or the Government of Iran without a license from the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”).

For years, the Government of Iran has targeted a prominent Iranian dissident living in New York City (“the Victim”).  The Victim is a journalist, author, and human rights activist who has publicized the Government of Iran’s human rights abuses and suppression of political expression.  Beginning in at least 2020, Iranian intelligence officials and assets, including co-defendant Mahmoud Khazein, plotted to kidnap the Victim from within the United States for rendition to Iran in an effort to silence the Victim’s criticism of the regime.  As part of that plot, on multiple occasions in 2020 and 2021, agents of the Government of Iran procured the services of private investigators to surveil, photograph, and video record the Victim and the Victim’s household members.  These agents of the Government of Iran, including Khazein, procured the surveillance by misrepresenting their identities and the purpose of the surveillance to the investigators and laundered money into the United States from Iran in order to pay for the surveillance, photos, and video recordings of the Victim. 

Beginning in approximately 2015, BAHADORIFAR, a U.S. citizen residing in California and originally from Iran, provided financial and other services, including access to the U.S. financial system and U.S. financial institutions, to Iranian residents and entities, including to Khazein.  BAHADORIFAR, who is not charged with participating in the kidnapping conspiracy, provided financial services that ultimately supported the plot.  Among other things, BAHADORIFAR caused a payment to be made to a private investigator for surveillance of the Victim on behalf of Khazein.  BAHADORIFAR’s payment obscured the origin of those who had hired the private investigator, who surveilled the Victim without knowing it was on behalf of Iranian intelligence services.  At no time did BAHADORIFAR obtain permission from OFAC to provide services to Iran. 

Beginning in approximately 2019, BAHADORIFAR also structured cash deposits totaling hundreds of thousands of dollars.  In total, BAHADORIFAR structured at least approximately $476,100 in more than 120 individual deposits.  All but two of the deposits were less than $10,000. 

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In addition to the prison term, BAHADORIFAR, 48, of Irvine, California, was sentenced to three years of supervised release.

Mr. Williams praised the outstanding efforts of the Federal Bureau of Investigation’s (“FBI”) New York Field Office Counterintelligence-Cyber Division and the New York FBI Iran Threat Task Force.  Mr. Williams also thanked the New York City Police Department (“NYPD”) and the NYPD Intelligence Bureau, the FBI’s Los Angeles Field Office Orange County Resident Agency, and the Department of Justice’s National Security Division, Counterintelligence and Export Control Section for their assistance.

This prosecution is being handled by the Office’s National Security and International Narcotics Unit.  Assistant U.S. Attorneys Michael D. Lockard, Jacob H. Gutwillig, and Matthew J.C. Hellman are in charge of the prosecution, with assistance from Trial Attorney Christopher Rigali of the Counterintelligence and Export Control Section.