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Singaporean National Sentenced to 40 Months in Prison for Scheme Involving Illegal Exports to Iran

A Singaporean national accused of taking part in a conspiracy to illegally export thousands of radio frequency modules from the U.S. to Iran was sentenced on April 27, 2017 to 40 months in prison.  Lim Yong Nam, also known as Steven Lim, was indicted in June 2010 for conspiring to illegally export U.S. made radio frequency modules through Singapore to Iran.  At least 14 of the illegally exported radio frequency modules were later found in unexploded improvised explosive devices (IEDs) in Iraq, according to a U.S. Department of Justice statement.

Lim was extradited to the U.S. in 2016 after being detained in Indonesia since October 2014 as he contested the U.S. request for extradition.  Lim pleaded guilty on December 15, 2016 to a charge of conspiracy to defraud the U.S. by dishonest means. 

As a part of his plea, Lim admitted that between August 2007 and February 2008, he and others purchased 6,000 radio frequency modules from a Minnesota-based company and illegally exported the modules through Singapore to Iran.  Lim and his co-conspirators made false statements to the Minnesota firm that the modules were destined to Singapore and made no mention of Iran.  They likewise filed false documents with the U.S. government, in which they declared Singapore was the final destination of the modules, according to the statement of offense.

Although the case was principally investigated by U.S. law enforcement authorities, the U.S. investigators received substantial assistance from the governments of Singapore and Indonesia over the course of the investigation.

This case represents another example of the growing international cooperation in export control investigations and prosecutions.  U.S. law enforcement authorities increasingly have leveraged the resources of and coordinated investigation efforts with their foreign counterparties in recent years and we expect this trend to continue in the foreseeable future.

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About this Author

Gwen Green, Holland Hart, international trade attorney, corporate compliance law
Of Counsel

Gwen Green is Of Counsel in the Washington, D.C. office where she concentrates her practice on international trade and regulatory compliance matters that facilitate clients' efficient trade with and from the U.S. Gwen advises clients how to develop and implement corporate compliance programs in the areas of U.S. export controls, U.S. economic sanctions, anti-boycott regulations, foreign investment in the U.S., and the Foreign Corrupt Practices Act. She also assists clients with due diligence investigations, audits, and risk assessments.