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Sanctions Violations Land Private Equity Firm in Hot Water
Houston, Texas – In a shocking turn of events, White Deer Management LLC, a private equity firm, has been let off the hook for self-disclosing sanctions and related offenses committed by an entity it acquired.
The Justice Department’s National Security Division (NSD) and U.S. Attorney’s Office for the Southern District of Texas (SDTX) announced they have declined prosecution of White Deer Management LLC and its affiliated acquisition entities. The decision follows the firm’s discovery and voluntary self-disclosure to NSD of criminal violations of U.S. sanctions laws, export controls and related offenses that Unicat Catalyst Technologies LLC, a Texas-based company it acquired, had committed.
According to court documents and DOJ agreements from approximately 2014 to 2021, Mani Erfan, former co-founder and CEO of Unicat, conspired with others 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 involved exports from the United States and also violated U.S. export control laws. To cover up the scheme, the conspirators falsified export documents and financial records, misrepresenting the identities and locations of customers. They also assured some Unicat employees that the company’s business dealings were lawful.
Mani Erfan 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 judgement in the amount of $1.6 million.
White Deer Management LLC and Unicat Catalyst Technologies LLC will not face prosecution. The company’s new CEO discovered Unicat’s hidden history of sanctions violations during an internal investigation and immediately canceled a deal with an Iranian customer.
Assistant Attorney General for National Security John A. Eisenberg praised White Deer Management LLC for uncovering the misconduct and quickly reporting it to the government. The NSD’s strong commitment to rewarding responsible corporate leadership was on full display in this case.
Special Agent in Charge Chad Plantz of Immigration and Customs Enforcement – Homeland Security Investigations (ICE-HSI) Houston emphasized the importance of enforcing U.S. sanctions laws and export controls to protect national security.
Mani Erfan’s plea and the imposition of a $3 million fine serve as a reminder of the consequences of violating U.S. sanctions laws.
Defendant: Mani Erfan, Conspiring to Violate U.S. Sanctions, Export Control Laws, Texas 2024
Criminal Charges: Conspiring to Violate U.S. Sanctions against Iran and other countries and foreign governments, Concealment, International Promotional Money Laundering
City and State: Houston, Texas
Exact Date: Approximately 2014 to 2021
Sentence or Outcome: Pleaded guilty, agreed to pay $1.6 million in restitution
Dollar Amounts: $3.33 million in revenue, $1.66 million loss in duties, taxes, and fees, $3 million fine
Key Facts
- State: Texas
- Category: White Collar Crime|Fraud & Financial Crimes
- Source: DOJ Press Release â†â€â€
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