United States Flag
Official Website of the Department of Homeland Security

Report Crimes: Email or Call 1-866-DHS-2-ICE


Civil complaint filed seeking forfeiture of Boeing 747 flight simulator destined for Iran

Simulator seized in 2008 at Port of Baltimore

BALTIMORE - A civil complaint was filed today seeking the forfeiture of a Boeing 747 flight simulator and spare parts that were seized on Aug. 26, 2008, at the Port of Baltimore where the property was being prepared for shipment to Dubai, United Arab Emirates, for alleged re-export to Iran, in violation of U.S. government export controls. The property is currently in the custody of U.S. Customs and Border Protection (CBP).

The civil complaint was announced by U. S. Attorney for the District of Maryland Rod J. Rosenstein; Special Agent in Charge William Winter of U.S. Immigration and Customs Enforcement (ICE; and CBP Commissioner Alan Bersin.

"The civil complaint alleges that Hojat Mahmoud Abadi secretly planned to transport the flight simulator to Iran, in violation of federal export regulations, and that he falsely declared that it would be shipped to Dubai," said U.S. Attorney Rod J. Rosenstein. "The flight simulator has remained in government custody since it was seized in 2008, and this complaint states the government's claim that it is subject to forfeiture because it was shipped unlawfully."

In 1995 the president of the United States issued an executive order to respond to the threat to national security, foreign policy and the economy of the United States by the government of Iran. The Iranian Transactions Regulation, 31 C.F.R. Part 560, was promulgated by the Department of Treasury Office of Foreign Assets Control to implement the president's executive order. The Iranian Transactions Regulation prohibits the exportation of any goods, technology or services from the United States to Iran or the government of Iran.

"The enforcement of Department of Treasury sanctions involving transactions with proscribed or embargoed countries is part of ICE's national security mission," said William Winter, special agent in charge of ICE in Baltimore. "ICE is committed to working with our law enforcement and regulatory partners, as well as affected industries, to identify and investigate individuals or companies who engage in illegal export schemes."

According to the complaint and supporting affidavit, on June 10, 2008, the Los Angeles ICE office contacted the ICE office in Baltimore with information that Hojat Mahmoud Abadi (Mahmoud), doing business as Sajad Free Zone Company (Sajad), purportedly purchased a Boeing 747-200 flight simulator from a company in Louisville, Ky. Mahmoud is an Iranian national holding an Iranian passport. ICE agents believed that Mahmoud intended to illegally ship the flight simulator to Iran.

The court documents further allege that an investigation revealed that no general authorizations or exemptions for exportation of the simulator had been found, and no applications were found for an export license issued under the name of Sajad. Thereafter, on July 11, 2008, ICE Baltimore agents executed a search warrant for an email account held by Mahmoud. A review of the emails allegedly revealed the negotiations between Mahmoud and the Louisville company selling the simulator, which ultimately resulted in Mahmoud buying the simulator for $100,000. Additionally, emails between Mahmoud and a shipping company based out of Dubai allegedly outlined plans to ship the simulator from the United States to Dubai and then re-export to Iran. A May 17, 2008, email from Mahmoud to the Dubai shipper stated that another shipping company based in Los Angeles which was contracted to ship the simulator from the United States to Dubai, "doesn't know that the equipments will be re-export to Iran [sic]," and that this was "the most important part of [the] project." On May 21, 2008, Mahmoud emailed the Dubai shipping company and explained to them that the California based shipping company was not supposed to know about the re-export of the simulator to Iran.

According to the court documents, on June 25, 2008, and Aug. 12, 2008, the supporting components for the simulator and the cockpit, respectively, were presented for export to the Port of Baltimore. On July 8, 2008, and July 29, 2008, CBP received two electronically filed records which declared that the simulator was ultimately destined for the United Arab Emirates.

Finally, it is alleged that other emails identified a pattern in which Mahmoud, using other business names and aliases, purchased an assortment of merchandise from the United States and shipped that merchandise to Dubai. Once in Dubai, Mahmoud directed that the merchandise be repackaged and shipped to Iran, using different company names.

The government will publish notice of its forfeiture action and any person with an interest in the flight simulator will have 30 days to file a claim contesting the forfeiture in federal court.

The civil complaint is not a finding of guilt. It is only an action to forfeit property purportedly used contrary to law.

U. S. Attorney Rod J. Rosenstein commended the ICE office in Los Angeles for their assistance in the investigation.

U. S. Attorney Rod J. Rosenstein thanked Assistant U. S. Attorney Stefan D. Cassella and senior law clerk Lauri Waldman, who are prosecuting the case.