Statement of ANHAM FZCO on Actions by the U.S. Department of Justice

November 28, 2018. Background: Today, the United States Department of Justice indicted a

former employee of ANHAM FZCO and two employees of companies who used to serve as

subcontractors. In response, ANHAM made the following statement:

We are extremely disappointed that the Justice Department took this action, which is based on

a mistaken reading of both the facts and the law, and which is contradicted in critical respects

by positions the department itself has taken in past proceedings where it defended ANHAM

against some of the same allegations it is now making. ANHAM has saved U.S. taxpayers $1.4

billion through its contract to provide food to U.S. troops serving in Afghanistan, and in

preparing for that contract it made good faith efforts to meet aggressive construction timelines

in one of the most difficult environments in the world. At no time did ANHAM’s former

employee or subcontractors cause any loss to the federal government – the government

received exactly what it was promised at the price it was promised, a price significantly below

that of ANHAM’s main competitor. In meeting that contract, ANHAM has provided sustenance

including fresh fruit and vegetables, frozen, chilled and dry goods and water to feed and

support American warfighters in active war zones since 2013.

ANHAM and its related subcontracting companies first self-reported shipments made through

Iran in 2013, and have been cooperating with the Justice Department since the onset of its

investigation. This investigation has been pushed by ANHAM’s chief competitor, a company

that itself pled guilty to defrauding the United States, and which now seeks to profit through

false accusations it has made in a civil case against ANHAM. Though we believe the Justice

Department’s actions against a former employee of the company and employees of former

subcontractors are without merit, we will continue to cooperate with that investigation and

work towards a reasonable resolution.

There are three allegations made by the government: sanctions violations, fraud against the

government, and money laundering. In each case, the government’s allegations are without

merit.

Sanctions Violations: As ANHAM has voluntarily self-reported to the government, a Jordanian

subsidiary of the company did ship material through Iran on a small number of occasions. To be

clear, ANHAM did not do business with any sanctioned individual or sell any prohibited

materials to Iran. The sole allegation of the government is that out of many hundreds of

shipments it made to Afghanistan of construction and other materials, a small number were

routed through Iran. U.S. law actually permits non-U.S. companies like ANHAM to make such

shipments, but even cases involving U.S. companies usually are resolved with a warning letter

from the Department of Commerce – in fact, no company or individual has ever been criminally

prosecuted for a violation of this nature – and we are puzzled why the Justice Department has

decided to handle this case differently than any prior case.