On March 20, 2015, AAG Makina, a Turkish equipment manufacturer, settled one charge of aiding an unauthorized export to Iran with the U.S. Commerce Department’s Bureau of Industry and Security (BIS). According to the charge, in 2011, Satco Corporation, a Canadian company, ordered $47,334 worth of valve parts and a pressure transmitter, which were shipped from the United States to AAG Makina. The shipped goods were subject to the Export Administration Regulations. AAG Makina forwarded the items to two Iranian petrochemical companies without U.S. government authorization. The Turkish company agreed to pay a civil penalty of $23,000 without either admitting or denying the allegations.
According to BIS, AAG Makina operated as part of a larger procurement ring led by Saeed Talebi. Talebi was the individual who purchased the controlled items from U.S. companies and sent them, via transshipment through Germany and Turkey, to Iran. Talebi established businesses in the U.A.E., Germany, and Canada to facilitate his scheme. AAG Makina employee Murat Paeker worked with Talebi to facilitate the shipments by providing false end-user information to the U.S. government.
On September 26, 2012, Talebi pleaded guilty to one count of conspiracy to violate the International Emergency Economic Powers Act in connection with the export of $390,000 worth of electrical components and industrial hardware to Iranian petrochemical companies. He was sentenced to 12 months and 1 day in prison on February 13, 2013. In his plea allocution, Talebi identified one of the end-users in Iran as Fajr Petrochemical, a subsidiary of Iran’s state-owned National Petrochemical Company.
In December 2013, seven members of this procurement ring—Talebi, Satco, Satco Corporation, Satco GmbH, Kadin Satco FZE, AAG Makina, and Peker—were added to the BIS Entity List.
 “Order Relating to AAG Makina,” United States Department of Commerce, Bureau of Industry and Security, March 20, 2015, available via PACER.
 Addition of Certain Persons to the Entity List; Amendment of Entity List Entries; and Removal of One Person From the Entity List Based on a Removal Request, United States Department of Commerce, Bureau of Industry and Security, Federal Register, 78 FR 75458, December 12, 2013, available at https://federalregister.gov/a/2013-28663
 Information – Felony, United States of America v. Saeed Talebi, United States District Court, Southern District of New York, Case Number 1:12-cr-00295-LTS, September 26, 2012, available via PACER.
 Transcript, United States of America v. Saeed Talebi, United States District Court, Southern District of New York, Case Number 1:12-cr-00295-LTS, September 26, 2012, available via PACER.
 Amended Judgment, United States of America v. Saeed Talebi, United States District Court, Southern District of New York, Case Number 1:12-cr-00295-LTS, May 29, 2013, available via PACER.