8. After a Department of Commerce special agent instructed VOISSEM and sons
on or about August 4, 2016, not to export the rebreathers while a license determination was
pending, VOISSEM and SOnS continued to communicate with Individuals 2 and 3 to arrange for
them to have a shipping company identified by Individuals 2 and 3 pick up the rebreathers and
ship to Libya.
.................
10. On or about August 9, 2016, knowing that the rebreathers were being exported to
Libya, VOISSEM provided the four rebreathers to a transportation company that picked them up
from Add Helium and transported them to a shipping company in Miami, Florida for export to
Libya.
11. On or about August 1 7, 2016, during a phone conversation about the rebreathers
with a Department of Commerce special agent, VOISSEM and sons concealed the fact that the
rebreathers had already been shipped to Libya.