Man and Co. Indicted in Plot to Export Military Equipment to Iran

On February 29, 2012, the Justice Department announced that Australian David Levick and his company, ICM Components Inc., have been indicted for conspiring to export sensitive military and other technology from the U.S. to Iran, including components with applications in missiles, drones, torpedoes and helicopters.

Purchased U.S.-Origin Parts with Military Application in Missiles, Drones, Etc. for Iranian Co.

According to the indictment, beginning as early as March 2007 and continuing through around March 15, 2009, Levick and ICM solicited purchase orders from a representative of a trading company in Iran for U.S.-origin aircraft parts and other goods. The indictment alleges that Levick and ICM then placed orders with U.S. companies on behalf of the Iranian company for aircraft parts and other goods that the Iranian company could not have directly purchased from the U.S. without U.S. government permission. Levick, ICM and other members of the conspiracy never obtained the required licenses from the Treasury or State Department for the export of any of these goods to Iran, according to the charges.

Among the items the defendants allegedly sought to procure from the United States are the following: VG-34 Series Miniature Vertical Gyroscopes; K2000 Series Servo Actuators designed for use on aircraft; Precision Pressure Transducers; Emergency Floatation System Kits; and Shock Mounted Light Assemblies.

Used U.S. Broker to Place Orders, Structured Payments to Conceal Operation

According to the charges, Levick and ICM, when necessary, used a broker in Florida to place orders for these goods with U.S. firms to conceal that they were intended for transshipment to Iran. The defendants also concealed the final end-use and end-users of the goods from manufacturers, distributors, shippers and freight forwarders in the U.S. and elsewhere, as well as from U.S. Customs and Border Protection. To further conceal their efforts, the defendants structured payments between each other for the goods to avoid restrictions on Iranian financial institutions by other countries.

Exported Goods to U.S. to Iran in Violation of the IEEPA

In addition to the conspiracy allegations, the indictment charges the defendants with exporting or attempting to export four specific shipments of goods from the U.S. to Iran in violation of the International Emergency Economic Powers Act (IEEPA). These include a shipment of 10 shock mounted light assemblies on January 27, 2007; a shipment of five precision pressure transducers on December 20, 2007; a shipment of 10 shock mounted light assemblies on March 17, 2008; and a shipment of one emergency floatation system kit on June 24, 2008.