Landmark DOJ Case: Suez Rajan Limited’s Guilty Plea and Fine for Iranian Oil Sanctions Violation

The U.S. Department of Justice (DOJ) announced a significant corporate criminal resolution on September 8, 2023, which involved the illicit sale and transport of Iranian oil in violation of U.S. sanctions. This case represents the first-ever corporate criminal resolution of its kind and underscores the U.S. government’s commitment to enforcing sanctions and export control regulations.

Here are the key details of the case:

1. Violation of U.S. Sanctions: Suez Rajan Limited, a company involved in international commerce, was charged with conspiring to violate the International Emergency Economic Powers Act (IEEPA) by smuggling sanctioned Iranian crude oil. The oil was being transported by Empire Navigation, the operating company of the vessel involved.
2. Guilty Plea and Fine: On April 19, 2023, Suez Rajan Limited pleaded guilty to the charges. As part of the plea agreement, the company was ordered to pay a fine of $2.46 million, which was twice the gross gain derived from the 980,000 barrels of contraband crude oil.
3. Corporate Probation: In addition to the fine, Suez Rajan Limited was sentenced to three years of corporate probation.
4. Deferred Prosecution Agreement (DPA): Empire Navigation, the operator of the vessel carrying the Iranian oil, entered into a deferred prosecution agreement (DPA) with the DOJ. This agreement required the company to cooperate and transport the contraband Iranian oil to the United States.
5. Civil Forfeiture Action: The 980,000 barrels of contraband crude oil are now the subject of a civil forfeiture action in the U.S. District Court for the District of Columbia. The DOJ alleges that the oil is subject to forfeiture based on U.S. terrorism and money laundering statutes. The complaint alleges that the oil constitutes property of a designated foreign terrorist organization (FTO), that the oil scheme facilitated money laundering, and that the profits from the sale of the oil supported the IRGC’s terroristic activities.
6. Evidence and Investigation: The DOJ’s case was supported by satellite images that showed the transfer of Iranian oil between the Suez Rajan and another vessel, the Virgo. Falsified paperwork was also obtained, which indicated that the oil onboard the Suez Rajan came from an initial exchange with a different vessel, the CS Brilliance.
7. Use of the U.S. Financial System: The case highlights the use of the U.S. financial system to charter the vessel and facilitate the transportation of Iranian oil, which subjected the participants, including the unnamed charter company, to U.S. jurisdiction.
8. DOJ’s Emphasis on Sanctions Enforcement: This case is part of the DOJ’s broader focus on economic sanctions and export control enforcement. The U.S. government is committed to preventing Iranian-backed agencies and entities from evading U.S. sanctions and using the U.S. financial system for illicit activities that fund terrorist operations.
9. Compliance Measures for Companies: Companies involved in international commerce should be vigilant about compliance with national security laws, including sanctions and export control regulations. Screening customers, intermediaries, and counterparties against U.S. government sanctions lists and conducting risk-based due diligence are essential practices. It’s also crucial for companies to develop, implement, and update compliance policies and procedures based on their individual risk profiles.

This case serves as a significant example of the U.S. government’s efforts to enforce sanctions and export control regulations rigorously and underscores the importance of compliance for companies engaged in international business.