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Wniteb states t!listrict Qi:ourt l!listrict of ~e\J:J 3f erscp UNITED STATES OF AMERICA CRIMINAL COMPLAINT v. Magistrate No. 18-3573 JOYCE MARIE ELIABACHUS, a/k/a "Joyce Marie Gundran Manangan" I, Brian T. McCormick, the undersigned complainant being duly sworn, state the following is true and correct to the best of my knowledge and belief. SEE A'ITACHMENT A I further state that I am a Special Agent with the United States Department of Homeland Security, Homeland Security Investigations, and that this complaint is based on the following facts: SEE A'ITACHMENT B continued on the attached page and made a part hereof. rian T. cCormick, Special Agent U.S. Dept. of Homeland Security Homeland Security Investigations Sworn to before me and subscribed in my presence, April23,2018 at Date Honorable Mark Falk United States Magistrate Judge Name & Title of Judicial Officer Signature of Judicial Officer 1 ATTACHMENT A Count One (Conspiracy to Violate the Iranian Transactions and Sanctions Regulations) From in or about November 2013 through in or about April 2018, in Morris County, in the District of New Jersey and elsewhere, defendant JOYCE MARIE ELIABACHUS a/k/a "Joyce Marie Gundran Manangan" did knowingly and intentionally conspire and agree with others known and unknown to export, re-export, sell and supply, and attempt to export, re­ export, sell and supply, goods, to wit: aircraft components, directly or indirectly from the United States to Iran, without first obtaining the required export control licenses from the Office of Foreign Assets Control, in violation of Title 50, United States Code, Sections 1702 and 1705; and Title 31, Code of Federal Regulations, Sections 560.203, 560.204, 560.205_, and 560.208. 1 Count Two (Conspiracy to Commit Money Laundering) From in or about November 2013 through in or about April 2018, in Morris County, in the District of New Jersey and elsewhere, defendant JOYCE MARIE ELIABACHUS a/k/ a "Joyce Marie Gundran Manangan" did knowingly and intentionally conspire and agree with others known and unknown to transmit and transfer monetary instruments and funds from a place outside the United States, to wit, Turkey and Iran, to a place in the United States, to wit, New Jersey, with the intent to promote the carrying on of specified unlawful activity, namely the smuggling of aircraft components from the United States contrary to Title 18, United States Code, Section 554(a), and contrary to Title 18, United States Code, Section 1956(a)(2)(A), in violation of Title 18, United States Code, Section 1956(h). 2 Count Three (Conspiracy to Smuggle Goods from the United States} From in or about November 2013 through in or about April 2018, in Morris County, in the District of New Jersey and elsewhere, defendant JOYCE MARIE ELIABACHUS a/k/ a "Joyce Marie Gundran Manangan" did knowingly and intentionally conspire and agree with others known and unknown to fraudulently export and send from the United States merchandise, articles, and objects, including aircraft components, contrary to Title 13, United States Code, Section 305, and to receive, conceal, buy, sell and in any manner facilitate the transportation, concealment, or sale of such merchandise, articles and objects, prior to exportation, knowing the same to be intended for exportation, contrary to Title 18, United States Code, Section 554(a}. In furtherance of the conspiracy and to effect its unlawful objects, the above-listed defendant and her co-conspirators committed and caused to be committed the overt acts, among others, in the District of New Jersey and elsewhere, as set forth in Attachment B below, in violation of Title 18, United States Code, Section 371. 3 ATTACHMENT B I, Brian T. McCormick, am a Special Agent with the United States Department of Homeland Security, Homeland Security Investigations ("HSI"). I am fully familiar with the facts set. forth herein based on my own investigation, my conversations with other law enforcement officers, and my review of reports, documents, and other pertinent items of evidence. Where statements of others are related herein, they are related in substance and in part. Because this complaint is being submitted for a limited purpose of establishing probable cause to support the issuance of a complaint and arrest warrant, I have not necessarily included each and every fact that I know or that other law enforcement agents know concerning this investigation. Where I assert that an event took place on a particular date, I am asserting that it took place on or about the day alleged. The Defendant and Co-Conspirators 1. Joyce Marie Eliabachus a/k/a "Joyce Marie Gundran Manangan" ("Eliabachus") is a naturalized U.S. citizen and a resident of Morristown, New Jersey. Eliabachus serves as the principal officer and operator of a privately held, New Jersey business entity known as Edsun Equipments LLC, a/k/a Edsun Equipment LTD ("Edsun Equipments"), a purported aviation equipment parts trading company. Edsun Equipment's headquarters is co-located at Eliabachus' personal residence ("the New Jersey Address"}, which has no commercial or manufacturing facilities or capabilities. 2. A·co-conspirator ("CC-1") is a citizen and resident of Iran. CC-1 is the operations and sales manager, and is otherwise affiliated with, purported foreign aviation supply and engineering companies including, among others: (a) an entity referred to herein as "Business #1," located in Tehran, Iran, and Istanbul, Turkey; (b) Blue Clouds Aviation, located in Tehran, Iran; (c) Sun Bright Havacilik Ic Ve Dis Tic, also known as Sun Bright Aviation, located in Tehran, Iran; (d) Pelikano Gida le Ve Dis Ticaret, located in Istanbul, Turkey; and (e) Tango le Ve Dis Tic LTD, located in Istanbul, Turkey (collectively, the "Iranian Network"). Summruy of Investigation 3. A joint investigation conducted by HSI and the U.S. Department of Commerce ("DOC") has revealed that defendant Eliabachus and CC-1, together with others known and unknown (collectively, the "defendants"), are part of an 4 illicit, international procurement network that is designed to surreptitiously acquire large quantities of aircraft components from United States · manufacturers and vendors, and to unlawfully export those parts to entities in Iran. Over approximately the last four years, this network has obtained and exported over $2 million worth of aircraft components from the United States to Iranian business entities in violation of export control laws, as further described herein. 4. Law enforcement officials have determined that the defendants' Iranian- based conspirators were responsible for obtaining initial requests for quotes ("RFQs") for U.S.-manufactured aircraft components from various Iranian entities. Several of those entities included Iranian airline companies officially designated by the U.S. government as posing a threat to this country's national security, foreign policy, or economic interests. The foreign RFQs were then submitted by the defendants electronically through an online aircraft parts database located in the U.S. The RFQ's were intended to solicit bids from various U.S.-based manufacturers and distributors for the requested aircraft components. The defendants established and used an access account affiliated with its New Jersey entity, Edsun Equipments, to submit the RFQs in order to conceal the foreign nexus of each request. Using Edsun Equipments, the defendants finalized the purchase and acquisition of the requested components from the various U.S.-based companies, and in each instance concealed the true identity of the ultimate end-user1 of the aircraft components in Iran. 5. Upon receipt of the components at the New Jersey Address, defendant Eliabachus prepared the parts for export using various U.S.-based shipping companies. In each instance, the defendants systematically concealed the true destination of the parts they were exporting by directing that the shipments be sent to various freight-forwarding companies located in the United Arab Emirates ("UAE") and Turkey. On several occasions, defendant Eliabachus falsely diminished the true value of the exported items on shipping documents in order to evade the legal requirement of filing an Electronic Export Information ("EEI") via the Automated Export System ("AES"), 2 thereby further 1 The DOC requires that certain forms (i.e., 'end-user agreements1 be properly executed in connection with the export of license-controlled items. The DOC requires that a completed form BIS-711 ("Statement by Ultimate Consignee and Purchaser") be included as part of an application for authorization to export certain controlled items, subject to the parameters of 15 C.F.R. §§ 748, et. seq. 2 Criminal penalties for unlawful export information activities as they pertain to EEi's (formerly known as Shipper's Export Declaration ("SEO") forms) are prescribed by 13 U.S.C. § 305. Generally, a DOC Form 7525-V (referred to herein as an "SEO Form") is required for all shipments sent to foreign countries regardless of the method of transportation, subject to certain restrictions. As it applies to the instant 5 concealing the network's unlawful export activities from law enforcement authorities. In other instances, defendant Eliabachus falsified the value, destination, and/or end-user of the exported aircraft components, thereby deceiving customs officials of the true nature of the shipment. Upon arrival of the parts at the UAE and Turkish-based freight forwarders, defendant CC-1 arranged for trans-shipment of the items through the Iranian Network to various locations and end-users in Iran. The defendants failed to obtain a single export license for any of the aircraft components purchased or exported during the relevant timeframe of this investigation. 6. As further detailed herein, the funds for the defendants' illicit transactions were obtained from overseas sources through international wire transfers. Through numerous Turkish-based bank accounts held in the name of companies comprising the Iranian Network, CC-1 directed millions of dollars into the defendants' U.S.-based accounts.

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