What is treason?
But what does that really mean, in practice?
Ghomi is a successful businessman, living in a $35 million California mansion; you might think he’d be grateful enough to our American system to obey our laws. But he also owns an Iran-based computer company, Faraz Pardaz Rayaneh Co. Ltd., and used his U.S. business interests to arrange disguised transactions, buying goods that are not allowed to be transferred to Iran, and using additional middlemen in the United Arab Emirates and elsewhere to deliver them to the Iranian military over at least a fifteen-year period.
His U.S. vendors were obligated by law to keep these goods out of Iran’s clutches, but American businesses are often unaware of their full obligations in this regard, or simply don’t realize the severity of the matter.
The currency of modern warfare is technology itself; wars are won not by flooding the battlefields with more infantry, but by commanding the skies with missiles, drones, bunker-buster bombs, and potentially even nuclear warheads. The United States of America possess the most powerful military on earth, but only as long as our most cutting-edge technology remains secret. It is critical that we all ensure that such knowledge is not transferred to terrorists, sponsors of terror, and other rogue states.
There is an entire field of business law covering this arena, generally known as the U.S. Export Controls, which apply to all American individuals, organizations, and businesses, and apply also to all goods and technology made or sold by Americans, not just on the first transaction, but throughout the life of the goods. It is an over-arching, omnipresent body of law.
Different aspects of the U.S. Export Controls are administered by different branches of the government; Treasury, War, Commerce, State, Justice, and sometimes others can be involved as well.
These export controls can be very broadly divided into three general buckets — countries, entities, and products — as follows:
- There are several countries that have almost absolute bans; no American individual, organization or company can have any dealings with them at all; we can’t give, sell or loan them any goods or information, and we must ensure that our goods and information are not indirectly routed to them in any way, either. This group of absolutely banned countries has included Iran and North Korea for generations, and the restrictions on similar nations like Syria and Venezuela have only recently begun to be slightly relaxed. As a general rule, no American person or business can have any dealings with these heavily sanctioned countries without first seeking and obtaining an export license for the transaction from the appropriate branch of our federal government.
- There are thousands of individuals, organizations, and businesses that appear on the many sanctions lists compiled by various federal agencies. All Americans and American businesses are required to ensure that they don’t violate this requirement. Most companies comply through a combination of internal training of sales, purchasing, and other staff, and the integration of robust “Restricted Party Screening” programs in their computer systems. Just like the country rules above, if a company discovers that any entity on such a restricted list appears in the supply chain of any transaction, whether as a customer, consignee, middleman, carrier, bank, distributor, or anything else, the transaction must be immediately halted, and cannot move forward until a federal export license is obtained (as you might imagine, the odds are against such a license being granted).
- Finally, and most complex, are the product controls, which are actually about much more than just physical goods. The government has identified anything that would be dangerous to fall into the wrong hands, from certain raw materials to specific components, from blueprints and material mill analyses to dies and molds. (The product controls area covers not only products that can be shipped, but information that can be emailed or discussed in a phone call or meeting; transmitting export-controlled information, even in person in your office here in the USA, constitutes a “deemed export,” so if you aren’t allowed to ship a thing to someone, you can’t discuss it with him either). Not everything is export-controlled, but the lists are surprisingly long, covering missile and space technology, munitions, chemical and biological weapons, nuclear power, and much more. The primary legislation covering this area is found in the U.S. Munitions List and the Export Administration Regulations, and it is generally presumed (incorrectly) that if a company deals in goods covered by these regs, they will know what they need to do to secure them. In fact, the lack of awareness of the business community’s legal obligations in this arena is disturbing. And yes, like the other two aspects of the export controls, before a company with any of these goods or information can share it with any people, companies, or countries from which they are forbidden, they must seek and receive an export license (which will rarely be granted).
The Export Controls do include a bit more than the above (such as the anti-boycott rules and the Russia sanctions), but this gives you the general flavor of the issue at hand.
America’s business community needs to understand that most attempts to circumvent the rules will be clever, and will include middlemen and shell companies, just as Jamshid Ghomi’s scheme did. It’s easy to understand that “we can’t ship guidance system parts to Tehran.” But sanctions are useless if they only ban direct transactions, so our sanction programs cover indirect transactions as well, and that’s the tricky part.
Every American individual, organization and business is expected to make a reasonable attempt to know the ultimate consignee of every order, and if the product or technology is controlled, then a reasonable attempt isn’t enough; absolute certainty is required.
We are obligated to lock in our foreign customers, distributors, and other agents, mandating that they too must honor the U.S. Export Controls on all American goods and technology that they may buy or represent.
If we sell to Company A in Italy, and he resells to Company B in Greece, and he resells it to Company C in the UAE, and he resells it to Company D in Iran… then our government will hold us responsible, and ask Why our system didn’t keep our customer’s customer from rejecting his own Iranian customer? If we are judged to have failed to take enough precautions, then we’ll be found responsible for supplying Iran with the materiel with which to attack the United States and our allies. And this issue hits home, now that we’re in the long-expected shooting war with them at last.
The case of Jamshid Ghomi may be the only case of its kind in the news today, but it is much like the proverbial tip of an iceberg. There are millions of companies in the United States, and the percentage in a position to share critical technology with our enemies, whether wittingly or unwittingly, is surprisingly high.
We must be on our guard at all times. It’s bad enough that chemical, biological, nuclear, and other such high tech weapons exist in the world; it’s terrifying that an enemy might be able to wield such weapons due to either the carelessness or treason of a fellow American.
Copyright 2026 John F. Di Leo
This article was originally published in The American Thinker, here.
John F. Di Leo is a Chicagoland-based international transportation and trade compliance trainer, speaker, and consultant. A President of the Ethnic American Council in the 1980s and Chairman of the Milwaukee County Republican Party in the 1990s, his book on vote fraud (The Tales of Little Pavel), his political satires on the Biden-Harris administration (Evening Soup with Basement Joe, Volumes I, II, and III), and his first nonfiction book, “Current Events and the Issues of Our Age,” are all available in either eBook or paperback, only on Amazon. His trade compliance training practice is available either in person or by webinar.
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