U.S. Alleges Pistachio Grower Failed to Disclose Foreign Account

At all times relevant to this Information:

1. Primex International Trading Company, Inc. ("Pitco") was a California corporation located in Los Angeles, California, within the Central District of California. Pitco was in the business of distributing dried fruit and nut products to domestic and international markets. Defendant ALI AMIN ("defendant AMIN") wholly owned and operated Pitco.

2. Amin Padidar Limited ("Amin Padidar") was based in Tehran, Iran, and in the business of processing and distributing pistachios grown by producers in the region, including pistachio farms in Iran owned by defendant AMIN and his immediate and extended family.

B. The Money Transmittal Business

4. At certain times, Pitco purchased wholesale pistachios from Amin Padidar for certain domestic and foreign customers who desired Iranian pistachios. Pitco could not, however, send United States dollars directly to accounts of Amin Padidar at financial institutions in Iran to pay for the product. Therefore, Pitco maintained a running account payable to Amin Padidar for all purchases of product from Iran. Amin Padidar maintained a corresponding running account receivable to track what was owed to Amin Padidar by Pitco for product.

5. In order for Pitco to pay Amin Padidar for product, Amin Padidar would "buy dollars" from individuals in Iran who wished to transfer funds to relatives, friends, or themselves, in the United States. Upon receipt of Iranian rials from individuals in Iran, Amin Padidar would issue a "credit note" to Pitco via email with instructions for Pitco to send an equivalent amount of United States dollars to the individual in the United States designated as the beneficiary by the person who deposited the rials with Amin Padidar in Iran. This deposit of rials with Amin Padidar, and corresponding transfer by Pitco in the United States, would reduce the amount owed by Pitco to Amin Padidar.

6. At times, the "buying dollars" transfers between Amin Padidar and Pitco described above utilized the Imavel account at Hyposwiss, rather than the Pitco account in the United States, in order to effect wire transfers of dollars to individuals in the United States.

7. As the owner of Pitco, defendant AMIN had to, and did, approve of any "buying dollar" transactions related to the Pitco account payable to Amin Padidar. Defendant AMIN engaged in this money transmittal activity knowing that it was unlawful. Neither defendant AMIN nor Pitco had a license from the state of California or any other state or the United States to operate a money transmittal business.

8. For example, defendant AMIN approved the transfer of approximately $600,000 from Iran to the United States as follows:

10. From in or about 2007 through in or about 2011, defendant AMIN approved and caused the transfer of approximately $17.15 million from Iran to individuals in the United States through the money transmittal operation described above.

11. Beginning in or about 2007 and continuing through in or about 2011, in Los Angeles County, within the Central District of California, and elsewhere, defendant AMIN, together with others known and unknown to the United States Attorney, aiding and abetting each other, knowingly conducted, controlled, managed, supervised, directed, and owned all or part of an unlicensed money transmitting business, which affected interstate and foreign commerce and which was: (a) operated in California, where such unlicensed operation was punishable as a misdemeanor or felony under California law; and (b) failed to comply with the money transmitting business registration requirements under Title 18, United States Code, Section 5330, and the regulations proscribed under that section.

13. On or about June 30, 2010, in Los Angeles County, within the Central District of California, and elsewhere, defendant ALI AMIN knowingly and willfully failed to file with the Commissioner of the Internal Revenue Service a Form TD F 90-22.1 Report of Foreign Bank and Financial Accounts disclosing that defendant ALI AMIN had a financial interest in, and signature and other authority over, account number xxxxxxx.254, in the name of Imavel Corporation, at Hyposwiss Private Bank in Zurich, Switzerland, which account had an aggregate value exceeding $10,000 during the calendar year 2009, that is, approximately $2.9 million in September 2009, and defendant ALI AMIN did so (a) while violating other laws of the United States, namely, operation of an unlicensed money transmittal business, in violation of 18 U.S.C. § 1960; and (b) as part of a pattern of illegal activity involving more than $100,000 in a 12-month period.

15. On or about June 25, 2010, in Los Angeles County, within the Central District of California, and elsewhere, defendant ALI AMIN, a resident of Los Angeles, California, willfully made and subscribed, by a written declaration verifying that he was doing so under penalty of perjury, and filed with the Internal Revenue Service, a U.S. Individual Income Tax Return, Form 1040, for the calendar year 2009, which defendant ALI AMIN did not believe to be true and correct as to every material matter, in that the tax return reported total income of -$1,127,331 on line 22, whereas, as defendant ALI AMIN then knew and believed, his total income for the year 2009 was in excess of -$1,127,331, specifically, defendant ALI AMIN concealed unreported income of approximately $1,926,742.47.