February 2020 – Page 12 – Law Enforcement, Military, and Terrorism News

Iranian National Charged with Bank Fraud and Lying to Federal Agents in Connection with a Scheme to Use the U.S. Financial System to Send More Than $115 Million to Iranian Individuals and Entities

Bahram Karimi was charged with conspiring to commit bank fraud, bank fraud, and making false statements in connection with his involvement in a joint project initiated by the Governments of Iran and Venezuela

The Department of Justice announced that Bahram Karimi was charged with conspiring to commit bank fraud, bank fraud, and making false statements in connection with his involvement in a joint project initiated by the Governments of Iran and Venezuela in which more than $115 million was illegally funneled through the U.S. financial system for the benefit of various Iranian individuals and entities.

The case is assigned to U.S. District Judge Alison J. Nathan.

“Karimi allegedly conspired in an infrastructure project initiated by the Governments of Iran and Venezuela,” said Assistant Attorney General for National Security John C. Demers. “He then lied to banks about Iranian involvement and took advantage of the U.S. financial system to benefit Iranian parties. The Department of Justice will continue to prosecute those who misuse our financial system in violation of U.S. sanctions.”

“As alleged, Bahram Karimi knowingly and willfully facilitated the circumventing of sanctions against Iran, and then lied about it to FBI agents,” said U.S. Attorney Geoffrey S. Berman for the Southern District of New York. “Karimi allegedly enabled the concealed transfer through U.S. banks of more than $100 million from a Venezuelan state-owned company to an Iranian construction firm, and when questioned, told the agents he didn’t know that was prohibited by the sanctions.”

“At the end of the day, these charges reflect the use of our financial system to generate U.S. dollars for Iranians and Iranian entities. That’s why our government has robust sanctions in place against Iran and Iranian entities who seek to use the U.S. banking system for their own benefit,” said Assistant Director-in-Charge William F. Sweeney, Jr of the New York Field Office of the Federal Bureau of Investigation (FBI).

As alleged in the Superseding Indictment and statements made in court filings and proceedings:

In August 2004, the Governments of Iran and Venezuela entered into a Cooperation Framework Agreement, whereby they agreed to cooperate in certain areas of common interest. The following year, both governments supplemented the Cooperation Framework Agreement by entering into a Memorandum of Understanding regarding an infrastructure project in Venezuela (the “Project”), which was to involve the construction of thousands of housing units in Venezuela.

The Project was led by Stratus Group, an Iranian conglomerate with international business operations in the construction, banking, and oil industries. In December 2006, Stratus Group incorporated a company in Tehran, which was then known as the Iranian International Housing Corporation (IIHC).

IIHC was responsible for construction for the Project.

Thereafter, IIHC entered into a contract with a subsidiary of a Venezuelan state-owned energy company (the VE Company), which called for IIHC to build approximately 7,000 housing units in Venezuela in exchange for approximately $475,734,000. Stratus Group created the Venezuela Project Executive Committee to oversee the execution of the Project. Karimi was a member of the committee and was responsible for managing the Project in Venezuela.

In connection with his role on the Project, Karimi worked with others to defraud U.S. banks by concealing the role of Iranian parties in U.S. dollar payments sent through the U.S. banking system. Specifically, between April 2011 and November 2013, the VE Company made approximately 15 payments to IIHC through two front companies, which were created to conceal the Iranian nexus to the payments, in violation of U.S. economic sanctions. These 15 payments totaled approximately $115 million.

In January 2020, Karimi was interviewed by, among other people, two FBI agents. During that interview, Karimi falsely stated that, during the course of the Project, he believed that international sanctions against Iran did not apply to Iranian companies or persons.

Karimi, 53, of Canada, is charged with (1) conspiring to commit bank fraud, which carries a maximum sentence of 30 years in prison; (2) bank fraud, which carries a maximum sentence of 30 years in prison; and (3) making false statements, which carries a maximum sentence of five years in prison. The maximum potential sentences in this case are prescribed by Congress and are provided here for informational purposes only, as any sentencing of the defendant will be determined by the judge.

Mr. Demers and Mr. Berman praised the outstanding investigative efforts of the New York County District Attorney’s Office and the FBI. Mr. Berman also thanked the New York County District Attorney’s Office for their ongoing assistance in this investigation.

The prosecution of this case is being handled by the Office’s Terrorism and International Narcotics Unit. Assistant U.S. Attorneys Jane Kim, Michael Krouse, and Stephanie Lake, and Special Assistant U.S. Attorney Garrett Lynch, Deputy Chief of the Major Economic Crimes Bureau at the New York County District Attorney’s Office, are in charge of the prosecution, with assistance from Trial Attorney Scott Claffee of the National Security Division’s Counterintelligence and Export Control Section.

The charges contained in the Superseding Indictment are merely allegations, and the defendant is presumed innocent unless and until proven guilty.

Justice.gov (Jan. 31, 2020). Iranian National Charged with Bank Fraud and Lying to Federal Agents

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Wannabe Mass Shooters Sentenced

In 2018, they traveled to Columbine High School to visit the site of the 1999 school shooting, where they took pictures of themselves dressed like the shooters and posing with weapons.

Couple’s Obsession Led Them to Plan Attack

Elizabeth Lecron and Vincent Armstrong were obsessed with mass shooters

The Toledo, Ohio, couple immersed themselves in online subculture dedicated to the topic. In 2018, they traveled to Columbine High School to visit the site of the 1999 school shooting, where they took pictures of themselves dressed like the shooters and posing with weapons.

Lecron also wrote to one notorious mass shooter in prison to express her admiration for him.

But investigators say it wasn’t just a morbid fascination.

The couple, led by Lecron, wrote detailed plans making it clear they intended to become mass shooters themselves. They expressed violent, anti-government beliefs and their plans to act on them.

“Unfortunately, we address these types of threats frequently,” said Special Agent Ryan Presley, who oversaw this investigation out of the FBI’s Cleveland Field Office. “The challenge is figuring out who is just talking and who is making serious plans.”

In this case, the would-be shooters documented their violent plans.

Thankfully, a concerned citizen who became aware of their activity called the Toledo Police Department, which shared the tip with Detective Louie Espinosa and FBI Special Agent Sara Pedersen of the Bureau’s Joint Terrorism Task Force (JTTF).

The JTTF learned that the couple’s plans were serious and that they had stockpiled weapons and bomb-making materials.

Lecron and Armstrong had scouted out venues for their attacks. One was a Toledo business the couple frequented. They knew the business had few entrances and exits, which they thought would make it difficult for potential victims to escape. They discussed details down to the type of shoes they would wear and how to create a diversion at the scene.

With the overwhelming evidence against them, Lecron and Armstrong both pleaded guilty. Lecron admitted to providing material support to terrorism and was sentenced in November 2019 to 15 years in prison. Armstrong pleaded guilty to a lesser conspiracy charge and was sentenced in December 2019 to six years.

Lecron’s prosecution is believed to be the first time a material support charge—a very serious charge usually brought against international terrorism suspects—has been used in a domestic terrorism case. Presley attributed this to the work of the investigative team and partnership with the U.S. Attorney’s Office in the Northern District of Ohio.

And without the tip from the concerned citizen, this story could have ended in a mass shooting—instead, the two would-be shooters are behind bars.

“I can’t say enough good things about the Toledo Police Department,” Presley said. “They have created an environment in which citizens feel comfortable bringing these types of things forward. This is an example of why the JTTF model works—everyone worked together to keep our community safe from a potentially dangerous threat.”

Resources

FBI.gov (Jan. 2020). Would-Be Mass Shooters Sentenced

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DOD to Require Cybersecurity Certification in Some Contract Bids

By the end of September 2020, the Department of Defense (DOD) will require at least some companies bidding on defense contracts to certify that they meet at least a basic level of cybersecurity standards when responding to a request for proposals.

DOD released its new Cybersecurity Maturity Model Certification on Friday, billed by the undersecretary of defense for acquisition and sustainment as “Version 1.0.”

By June, the department plans to publish as many as 10 requests for information on contracts that include CMMC requirements, Ellen M. Lord said during a Pentagon news conference announcing the certification effort. By September, she said, the department will also publish corresponding requests for proposals that include those requirements. By fiscal year 2026, all new DOD contracts will contain the CMMC requirements, Lord said.

“I believe it is absolutely critical to be crystal clear as to what expectations for cybersecurity are, what our metrics are, and how we will audit for those expectations,” Lord said. “CMMC is a critical element of DOD’s overall cybersecurity implementation.”

Lord said cybersecurity risks threaten the defense industry and the national security of the U.S. government, as well as its allies and partners. About $600 billion, or 1% of the global gross domestic product, is lost through cyber theft each year, she noted.

“Adversaries know that in today’s great-power competition environment, information and technology are both key cornerstones,” she said. “Attacking a sub-tier supplier is far more appealing than a prime [supplier].”

The CMMC gives the department a mechanism to certify the cyber readiness of the largest defense contractors — those at the top who win contracts are called “primes” — as well as the smaller businesses that subcontract with the primes.

The new CMMC provides for five levels of certification in both cybersecurity practices and processes.

“Something … simple in Level 1 would be, ‘Does your company have antivirus software? Are you updating your antivirus software? Are you updating your passwords?'” said Katie Arrington, DOD’s chief information security officer for acquisition. “CMMC Level 1 is the basic cyber hygiene skills we should be doing every day. They are there to protect yourself, your company and your own information.”

By CMMC Level 2, Arrington said, the department will also begin looking at cybersecurity processes as well, to ensure cybersecurity is not just practiced, but that a company is effectively documenting, managing, reviewing and optimizing its practices across its entire enterprise.

Arrington said that for the roughly 10 requests for information and requests for proposals DOD is expected to publish later this year for potential contracts, she expects a mix of CMMC certification levels will be required.

“We’ll have some CMMC Level 3, CMMC Level 1, and there may be one or two with the 4 or 5 CMMC levels going out,” Arrington said.

The department will not be certifying potential defense contractors for CMMC on its own. Instead, Lord explained, a series of CMMC “third-party assessment organizations” or C3PAOs, will conduct those assessments. The C3PAOs will also not be paid by the department, Lord said. “That’s a private transaction between industrial base companies and those of certification bodies,” she added.

No C3PAOs have been designated to conduct the assessments yet, Lord said, noting that while multiple companies are interested, DOD has not yet designated who is qualified.

A newly created 13-member CMMC accreditation body, made up of members of the defense industrial base, the cybersecurity community and the academic community will oversee the training, quality and administration of the C3PAOs, Lord said.

Meanwhile, she said, the department is drafting a memorandum between DOD and the CMMC accreditation body to outline its roles, responsibilities and rules. She said one area of concern will be to ensure no conflicts of interest are involved in accreditation. For example, a C3PAO would not be able to accredit itself for CMMC.

No existing contracts with the department will have CMMC requirements inserted into them, Arrington said.

Subcontractors to a prime contractor will not all need to have the same level of CMMC certification to win a contract, Arrington said.

“Security is not one size fits all,” she added. Instead, she said, depending on how controlled unclassified information flows between those parties involved in a contract, subcontractors might need only be a CMMC Level 1 company.

CMMC will ensure a more level and fair playing field for companies bidding on DOD contracts, Arrington said. Today, she said, some small businesses bidding on work might self-attest that they meet requirements to handle certain kinds of information, but in fact only are planning to meet those requirements, while another business might actually be meeting the requirements. CMMC, she said, will ensure that only companies that actually meet requirements can compete for contracts.

“We need to make sure our industry partners are prepared to take on the work, and our third-party auditors will ensure that they are implementing the practices that we need in place to secure that national defense and our industrial base,” Arrington said.

Lord said the department is aware that CMMC requirements could be a burden to some smaller companies and that DOD is working with primes and smaller companies to help them overcome that burden.

“We need small and medium businesses in our industrial base, and we need to retain them,” she said. “We will continue to work to minimize impacts, but not at the cost of national security.”

Defense.gov (2020). DOD to Require Cybersecurity Certification in Some Contract Bids

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