sanctions regimen and intent; undermining the prosecutor's case against Banki as not being in line with the practices of OFAC or the intent of the sanctions. Nor were the charges in line with the agency's approach while Richard Newcomb was head of the agency: Arrest, indictment, and charges On January 7, 2010, U.S. Immigration and Customs Enforcement (ICE) agents authorized by a grand jury with a search and arrest warrant entered the residence of Mahmoud Reza Banki in New York City and arrested him. He was arraigned before Judge John F. Keenan on an indictment charging him with three counts: 1. Conspiracy to violate the U.S.-imposed Iran sanctions and conspiracy to run an unlicensed money transmittal system, 2. Violation of the Iran sanctions, and 3. Running of an unlicensed money transmittal business. The indictment accused Banki of receiving $4.7 million in violation of the Iran sanctions. Prosecutors filed a superseding indictment later changing the amount to $3.4 million and adding two false statement charges to the three initial charges. Banki was denied bail. He was held in high and maximum security detention facilities pending trial. Trial at the district court and forfeiture The indictment charging Banki argued that Banki should have gotten authorization in the form of a license for the money he received: "(vi) Under the ITR, any United States person who wishes to engage in a transaction otherwise prohibited by the ITR must first file an application for a license and receive approval from OFAC. 31 C.F.R. §§ 56.600, 560.501, and 501.801.". On May 10, 2010, a three-week trial commenced where Second Circuit District judge John F. Keenan presided. The trial concluded on June 4 when the jury returned a guilty verdict on all five counts, albeit, guilty on a lesser charge of aiding and abetting rather than running a sanctions violation money transmittal system. On June 7, 2010, despite the superseding indictment charge of $3.4 million, the same jury agreed to forfeit one bank account associated with a $6,000 transaction as the proceeds of the charges and the guilty verdict. The jury ruled that Mahmoud Reza Banki's other assets including the apartment he had purchased with the family funds he had received was not forfeitable nor was it a direct proceed of any crime. Judge Keenan overruled the jury only in the case of the forfeiture verdict on the basis that the jury might have been "confused"