Mani Erfan, Conspiracy to Violate Sanctions Laws, Texas 2024

A Houston-based private equity firm and one of its affiliated acquisition entities have escaped prosecution after self-disclosing sanctions and related offenses committed by a Texas-based company it acquired.

White Deer Management LLC and its affiliated acquisition entities were notified by the Justice Department’s National Security Division (NSD) and U.S. Attorney’s Office for the Southern District of Texas (SDTX) that they would not face prosecution for violating U.S. sanctions laws, export controls, and related offenses committed by Unicat Catalyst Technologies LLC, a Texas-based company it acquired.

NSD and SDTX announced that the Department of Justice (DOJ) entered into a non-prosecution agreement (NPA) with Unicat. This agreement comes after Mani Erfan, Unicat’s former co-founder and CEO, pleaded guilty in SDTX to conspiring to violate U.S. sanctions against Iran and other countries and foreign governments, as well as to concealment and international promotional money laundering.

As part of his plea, Erfan agreed to pay a money judgment in the amount of $1.6 million.

According to court documents and DOJ agreements from approximately 2014 to 2021, Mani Erfan conspired with others, including a Unicat employee, to illegally sell products to customers in Iran, Venezuela, Syria, and Cuba in violation of U.S. sanctions.

Erfan directed Unicat to make 23 unlawful sales of chemical catalysts used in oil refining and steel production, generating about $3.33 million in revenue.

The scheme surfaced in June 2021 after White Deer acquired Unicat and a second U.K.-based firm. Once travel restrictions eased, Unicat’s new CEO visited the United States to begin integrating operations and discovered Unicat had a pending transaction with an Iranian customer, which he immediately canceled.

Over the following month, White Deer and the new CEO hired outside counsel and launched an internal investigation, which led to the discovery of Unicat’s misconduct and the voluntary disclosure of the conduct to the NSD.

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