Between 2013 and 201 4, an Australia-incorporated company (the "Australian Company") shut down and decommissioned a polypropylene plant with an approximate capacity of 150,000 tons of polypropylene per year (the " Plant"). The Australian Company hired a U.S. company (the "U.S. company") as a broker to resell the Plant and remove it from its site in Australia. In or around 2015, the U.S. Company identified Aiotec as a purchaser and, to effect the sale and the U. S. Company entered into an agreement with Aiotec on 27 November, 2015 to sell the Plant for (unspecified which dollars)9.7 million (the "Sale Agreement"). Once the Sale Agreement was signed, the Australian Company and the U.S. Company entered into an Asset Purchase Agreement on 14 December, 2015, whereby the Australian Company agreed to sell the Plant to the U.S. Company. The U.S. Company was contractually obliged to dismantle and remove the Plant from its site- which the Australian Company owned- but delegated much of that responsibility to Aiotec in the Sale Agreement. The U.S. Company and Australian Company therefore remained engaged in the Plant dismantling and removal process.

The Sale Agreement between the U.S. company and Aiotec contained a provision stating
that Aiotec would not resell the Plant '' to any country, person or entity or for shipment to any
destination, which is subject to sanctions or embargo by the United States Government or is
otherwise a prohibited destination under United States law .. ." Prior to purchasing the Plant,
Aiotec's managing director ("Managing Director I ") represented to the U.S. Company in an
email on 19 October, 2015 that:
(I) the Plant was to be operated in Turkey;
(2) Aiotec intended to operate the Plant as a joint venture with an Istanbul, Turkey-headquartered company ("the Turkish Company"); and
(3) Aiotec had no other partners, and was not considering any other location to install the Plant. Aiotec also sent the U.S. Company au end-user certificate dated 26 October, 2015 signed by Aiotec 's other managing director ("Managing Director 2"), representing that the Plant would be shipped to Van, Turkey.

While Aiotec was representing to the U.S. Company that it intended to export the Plant to
Turkey, it was simultaneously conspiring with its Iranian subsidiary Aiotec Middle East Co.
("Aiotec ME") and Iranian petrochemical development company Petro-Iranian Downstream
Industries Development Co. ("PIDID") to divert the Plant to Iran. Unbeknown to the U.S. Company, on 29 November, 2015, two days after signing the Sale Agreement, Aiotec, Aiotec ME , and PIDID entered into a second agreement (the "Aiotec PIDID Agreement"), to resell the Plant to PTDID and transport the Plant to Bandar Abbas, Iran. Both Managing Director 2 and the managing director for Aiotec ME signed the Aiotec PIDID Agreement. Under this agreement, Aiotec ME was responsible for accepting advanced payment from PIDID on behalf of A io tec and guaranteeing delivery to PIDID.

Aiotcc initiated the Export of the Plant and concealed its intended destination of Iran.

Following the execution of the Sale Agreement and Aiotec PIDID Agreement, Aiotec began
dismantling the Plant in 2016 and ultimately shipped the entire Plant in parts from the port of
Newcastle, north of Sydney, to the port of Bandar Imam Khomeini (BIK), Iran between 4 August, 2017 and 14 April , 2019. In doing so, Aiotec entered into contracts with two freight forwarders to transport the Plant in parts to Iran. At Aiotec's behest, both contracts stipulated that the respective forwarders could not register the end user's name and address as " Iran" with Australia's customs office and should instead report the final destination as either the United Arab Emirates (UAE) or Turkey.

The story, in full, is here:https://ofac.treasury.gov/media/933666/download?inline

The US Treasury's final word is this:
"Persuant to the Sale Agreement, Aiotec agreed to pay the U.S. Company $9.7 million for the
Plant to be paid in instalments. Aiotec ultimately remitted 1l payments originating in euros
between 4 December, 2015 and 23 May, 2019, totalling approximately $9,457,642. Aiotec made nine such payments to the U.S. Company's dollar denominated account at a U.S. bank (the "U.S. Bank") and two such payments to the U.S. Company's euro-denominated account at the U.S. Bank's London branch."