Zach Dorfman is senior fellow at the Carnegie Council for Ethics in International Affairs.

On May 13, 2012, Afsaneh Azadeh, an Iranian-American living in Dubai, touched down at Imam Khomeini International Airport in Tehran. Azadeh, who had returned to Iran to help her elderly mother convalesce from cataract surgery, tried to visit Tehran frequently, despite a punishing work schedule. At the time, she was employed as general manager of HeavyLift International, a private, United Arab Emirates-based cargo airline run by Farhad Azima, a politically connected Iranian-born American aviation magnate based in Kansas City, Missouri. Smart, loyal and ambitious, she had established herself as one of Azima’s key employees.

Azadeh deplaned, exited customs and collected her bags. Suddenly, according to Azadeh, she was encircled by five agents of Iran’s Revolutionary Guard (IRGC), who informed her of her arrest on national security grounds. Her belongings were confiscated. She was handcuffed, blindfolded and pushed into the back seat of a car, where a female IRGC agent forced her to rest her head in the agent’s lap to avoid detection. “Where are we going?” Azadeh asked, as they sped through Tehran. “Evin Prison,” her captor replied. And here began Azadeh’s months-long nightmare in the fetid dungeons of the Islamic Republic.


Azadeh claims that during her captivity—which she describes in a lawsuit she has since filed against the Iranian government in the U.S. District Court for the District of Columbia—she was whipped, beaten and tortured; drugged daily and poisoned; and subjected to mock executions and other forms of extreme psychological abuse. (It does not appear that Iran has responded to the allegations; since the United States and Iran do not maintain diplomatic relations, the lawsuit was delivered to the Iranian foreign ministry via the Embassy of Switzerland in Tehran.)

Iran has a sordid history of jailing and torturing American citizens—especially those of dual citizenship—for allegedly spying on behalf of the United States. Superficially, at least, Azadeh’s case follows this script. But there is a key difference: In her court filings, as well as subsequently leaked emails of Azima’s, Azadeh says her captors’ core interest was not in her own activities and contacts, but in those of her boss, Azima. (Azima claims those emails were hacked and dumped online by agents of the United Arab Emirates, and he is currently suing a UAE sheikdom in a D.C. federal court over the matter.)

Why would the Iranian government be so interested in Azima’s activities that it would allegedly torture an American citizen? Both he and Azadeh declined to comment for this article through their shared lawyer, Kirby Behre. But the answer to that question might lie in Azima’s extraordinary, decades-long career in the private airline business. It’s a tale that could be ripped from a Hollywood thriller—including his entanglement with three Iranians whom the U.S. Treasury Department later sanctioned for their activities on behalf of Iranian banks and whom U.S. officials, in a 2014 civil forfeiture case, also linked to an Iranian money-laundering scheme to evade U.S. sanctions.

Now that the Trump administration is withdrawing from the Obama-era Iran nuclear deal and plans to re-impose all the sanctions lifted as part of the agreement, the story of these three Iranians’ buying spree and Azima’s involvement in it—based on a review of thousands of Azima’s leaked emails and text messages, documents from five separate court cases, and conversations with individuals with knowledge of Azima’s and the three Iranians’ activities—might preview a not-too-distant future in which the regime’s sanctions-evasion and money-laundering schemes will kick back into high gear. Azadeh’s account of her detention and torture, meanwhile, spotlights the rigid, febrile core at the heart of the Islamic Republic, and its willingness to punish and extort those who run afoul of it.

This is also, fundamentally, a tale about power. For years, Azima seemed to perform an impressive tightrope act, working with the U.S. military and intelligence complex, according to various media reports, while leaping at opportunities with international business partners operating on the margins. Wavering to one side, he always regained his balance. Until, perhaps, he didn’t.



***

Who is Farhad Azima? According to reports in the Kansas City Star, the Associated Press and elsewhere, Azima’s planes delivered weapons to Pakistan during the anti-Soviet jihad in Afghanistan; to Egypt after the Camp David Accords; and to Iran, where they a sent arms to the Islamic Republic during the Iran-Contra scandal. (Azima has confirmed, to the Star, the arms shipments to Pakistan and Egypt, but he has denied any connection to the delivery of weapons to Iran.) Azima’s alleged connections to the CIA ran so deep that in the 1980s, when federal investigators were looking into whether a bank he was affiliated with had financial ties to the mob, he was considered to have a sort of “get-out-of-jail-free card” that put a halt to the probe, one former federal prosecutor told the AP last year.

Indeed, Azima is comfortable in rarified circles, close to billionaire businesspeople and powerful politicians. FEC filings show he has contributed generously to both Democratic and Republican candidates, but particularly to Bill and Hillary Clinton. In 1999, the Washington Post reported that Azima had promised to donate at least $1 million toward Bill Clinton’s presidential library. He also has donated at least $250,000 to the Clinton Foundation, according to its website, and he has hosted Hillary Clinton “many times” at his home for high-dollar fundraisers, according to the Star.

At the time of Azadeh’s arrest, HeavyLift was working openly with the Defense Department “to support U.S. troops in Afghanistan and Iraq,” according to Azadeh’s declaration in her D.C. court case against the Iranian government. Azadeh says she told her captors that HeavyLift supplied troops with foodstuffs; IRGC agents, she says, instead claimed the company was fomenting revolution on behalf of the CIA. (A Pentagon spokesperson declined to comment on HeavyLift’s contracts in Iraq and Afghanistan.)

But in a 2012 email sent while she was under house arrest in Tehran, Azadeh told Azima that the IRGC appeared to have placed him under broad surveillance. And the year before, outside his work with the U.S. government, Azima had done significant business with three Iranians who later were identified by the U.S. Treasury Department as working on behalf of Iran. It was a complicated relationship that ran hot and cold, and was centered on Azima brokering the sale of a Tbilisi, Georgia, hotel from a United Arab Emirates sheikhdom to the three Iranians. The deal soured before Azadeh’s arrest, landed Azima in legal battle with the sheikhdom, which he alleges is responsible for hacking his emails, and eventually attracted the scrutiny of federal U.S. investigators.

Yet those leaked emails, independently located online and downloaded by Politico Magazine, indicate that Azima’s interactions with the Iranians did not end after the hotel deal. (Azima’s own lawsuit in the D.C. federal court repeatedly refers to the emails as “stolen data,” without questioning their validity.) In fact, Azima’s interactions with some of the Iranians appear to resume after the failed deal, and stretched much further into the present—including after U.S. federal prosecutors had claimed the three men masterminded a billion-dollar international money-laundering and sanctions evasion scheme; and after the Treasury Department had sanctioned the three Iranians as agents of the Iranian regime.

Azima’s relationship with the Iranians dates to 2011. That year, the Dubai- and Tbilisi-based businessmen—Houshang Farsoudeh, Houshang Hosseinpour and Pourya Nayebi—seemed to materialize out of the ether, with tens of millions of dollars to invest. They bought up land, a bank, an airline and a shipping company, and founded a money-exchange business and an oil trading business, all in the nation of Georgia alone, according to reporting and congressional testimony by Emanuele Ottolenghi, an illicit finance expert and senior fellow at the Foundation for the Defense of Democracies, a Washington think tank. The three Iranians’ conspicuous activities there appeared to arouse the attention of Treasury Department investigators, who, according to a June 2013 Wall Street Journal article, traveled to that country multiple times to look into the Iranians’ businesses. (That article was co-authored by reporter Jay Solomon, who was fired from the Journal last year for what the newspaper said were ethical lapses in his dealings with Azima as a source. Solomon, who denied engaging in business with Azima as an AP story had suggested, has said that Azima fed him key information about the three Iranians, which Azima’s leaked emails corroborate.)

The three Iranians’ dealings were far more extensive than Georgia, however. In 2015, a report from Sayari Analytics, an American investigative firm specializing in financial risk, identified 263 business entities and 148 individuals from more than a dozen countries, including the United States, with ties to what Sayari calls the “Nayebi Network.” None of these entities was listed by the Treasury Department in February 2014, when the department sanctioned the three Iranians and eight companies associated with them, for helping Iran to avoid economic sanctions.

And then there are the Iranian trio’s dealings with Kenneth Zong. The three businessmen were accused of conspiring to undertake a fraudulent scheme over the course of 2011 and 2012—with Zong, a Korean-American, working as the Seoul-based intermediary—that freed more than $1 billion in restricted Iranian funds from South Korean state-owned banks, and involved bribing South Korean state banking officials along the way. The three Iranians were named in Zong’s 2014 civil forfeiture case, and individuals matching their description are referred to as unindicted co-conspirators in Zong’s 2016 indictment; Zong is currently serving a prison sentence in South Korea, where he was separately charged.

Reached by phone, Nayebi denied working on behalf of the Iranian government. He also said that he and his partners’ transactions with Zong were carried out according to “the basis of law at the time,” and declined to comment further on his business with Zong. Nayebi also denies any links to Azadeh’s imprisonment; he says Azadeh was jailed because of her connections to Azima and Azima’s potential connections, in turn, to the CIA. Hosseinpour did not respond to repeated requests for comment; Farsoudeh could not be reached for comment.

When the Iranians first connected with Azima in the fall of 2011, relations were chummy. Azima introduced them to the UAE sheikdom Ras al-Khaimah (RAK), with which he had “an extensive history of commercial dealings,” according to a 2017 memorandum from Azima’s legal team filed in a D.C. federal court. The filings also say RAK’s ruler was Azima’s guest at the Clinton Global Initiative in 2011, and Azima arranged for the sheik to become a CGI member. Azima even hosted an October 2011 meeting between Hosseinpour and Farsoudeh at the ruler’s palace to discuss the hotel deal, according to the same court documents.

A May 2016 photograph of businessman Farhad Azima at his home in Kansas City, Missouri. | Jill Toyoshiba/The Kansas City Star/AP

According to Azima’s prior public statements, U.K. court filings and emails contained in the leaked cache, the Iranians paid a $20 million deposit to RAK for the Sheraton hotel, in a deal initially brokered by Azima. Azima eventually exited the deal. In the past, he has maintained that after checking with the State Department, he withdrew in late 2011 due to concerns about the Iranians’ activities. Solomon, who declined to comment for this article beyond what he has written about the topic, has said that Azima told him he withdrew because he learned the three Iranians were connected to the IRGC, which Solomon’s own diplomatic and intelligence sources confirmed to him. The deal, in any case, was never completed, collapsing altogether by 2013.

Azima is still dealing with the fallout today. RAK sued him in a U.K. court in 2016, accusing him of taking a “secret commission” for the sale of the hotel, and of bribing a senior RAK official in connection with the deal; Azima denies those allegations, and the case is ongoing. And since 2016, Azima’s lawyers have been in legal proceedings against RAK in Washington, claiming that RAK agents hacked Azima’s emails and text messages and subsequently posted them online. In its July 2017 feature about Azima, the AP also reported that federal investigators had examined whether his role in the original Sheraton sale had violated the Foreign Corrupt Practices Act, which prohibits the bribery of foreign officials. The Justice Department declined to comment on the status of any investigation into Azima. But in response to queries about the three Iranians, Azima and the Sheraton deal, a spokesperson for the U.S. Embassy in Tbilisi referred in a March 2018 email to an “ongoing investigation” that the embassy could not comment on “after consult[ing] with our law enforcement colleagues.”

Azima’s business with the three Iranians went beyond the hotel deal. According to more leaked emails and affidavits contained within them, in October 2011, the Iranians entered into a deal with Azima to buy 40 percent of the shares in HeavyLift, the UAE-based cargo airline owned by Azima and RAK, for $1.5 million. Azima, however, received $500,000 less than what the Iranians had agreed to pay for their share in the airline, and the deal does not appear to have been completed. The emails also show that, in December 2011, Azima agreed to sell Hosseinpour a $600,000 share in his yacht, which was then berthed in the French Mediterranean. (Hosseinpour moved it to a posh marina in Dubai; according to a December 2012 email Azadeh sent to Azima, the Iranians wanted the boat close to the UAE prime minister’s son’s yacht.) Hosseinpour paid for the shipping costs to bring the boat to the UAE, but then appeared to fail to actually buy the boat, though the Iranians continued to use it, according to Azima’s emails and affidavits.

Both Farsoudeh and Hosseinpour, whom Nayebi told me are no longer his partners, were “cheated” by Azima regarding the yacht, Nayebi says. He also says that Azima and RAK, whom he calls “the robbers”—conspired to defraud him on a number of business deals, including for the Sheraton. “All the sides tried to rob us, to take our money,” he told me.

In any case, by early 2012, Azima’s own patience was wearing thin. “You have made certain commitments,” Azima wrote to Hosseinpour and Farsoudeh in February of that year, “yet have not honored any of your words. … You wasted 100 days of my time. ... You asked me to get the Airline established in Georgia. … You asked me to buy a privet [sic] Jet. … You formed a company [in the British Virgin Islands, which was at one point supposed to buy the hotel in Georgia] and didn’t pay the legal fees. … Is this the way to do business?” In the email, Azima wrote that he made a half-dozen trips to Georgia, Britain and the UAE to assist with transactions on the Iranians’ behalf, all on his own dime. To add insult to injury, he wrote, the three men still had not paid him for their share of his boat.

After this email, relations between Azima and the three Iranians appear to have entered a deep chill.



***

It was less than four months later that Azadeh found herself speeding through the streets of Tehran, blindfolded, disoriented and accused of being a spy.

The bright blue light in Azadeh’s tiny concrete cell was never turned off. There was a filthy rug, swarming with biting insects, and nothing else; no toilet, no bed, no chair. The interrogations, Azadeh says in court documents, had already begun. “We have enough documents to keep you here 10 years,” the guard told her. “And if we prove you are a spy, we will execute you.” She claims she was interrogated for up to 12 hours a day, every day, for the first six weeks of her captivity.

Once, she says, they made her sit tied to a chair, facing the wall; if her interrogator was displeased by her answer to their queries, they kicked the chair, slamming her face against the concrete. Another time, they made her stand for hours, whipping her when her knees buckled. She was pushed, blindfolded, down a flight of stairs.

Then there were the “truth” pills—ostensibly to “relax” Azadeh for her interrogations—that she says were administered three times a day for the duration of her imprisonment.

Her captors also poisoned her. After dinner one night, she began to cough uncontrollably, and developed a blistering rash. Her chest tightened. She became unable to breathe. Finally, after desperate minutes trying to get the guard’s attention, she was transferred to the prison hospital and aided by the doctor there. The next day, she says, she was visited by one of her captors. “Evin Prison was not a good place to die,” he told her, but if she cooperated, she might not meet that fate.

She was sentenced to death, twice. Blindfolded and handcuffed, she was forced to stand against a wall, facing a firing squad. Her executioners chanted prayers for the dying from the Quran, then barraged her with bullets, apparently missing her on purpose. She fainted both times, and awoke again in the hospital.

Finally, she claims, she broke down and signed papers admitting, falsely, that she was an agent of the CIA. She was released pending trial, and ordered to two months under house arrest in Tehran.

On September 4, 2012, Azima received a distressed email from Azadeh, according to the online trove. It was the first time he seemed to have heard from her in months. She was under house arrest in Tehran, she told him. She had been detained and imprisoned months before, she wrote, accused of spying for Azima, on behalf of the United States, and was held by the Revolutionary Guard. For much of her captivity, she told him, she had been interrogated for nine hours a day. To secure her own release, she had been forced to sign over the rights to her home in Tehran.

Do not answer any calls from numbers associated with me, she urged Azima, as Iranian agents had been calling her contacts, posing as family members. She said they had also been tapping her phone, and Azima’s phone in Dubai, and that they had audio recordings and photographs of meetings he had had in his apartment. (Azima did not appear surprised about being under Iranian surveillance. “I’ve been watched all my life,” he wrote to Azadeh in response. “I am used to it.”)

The cause for Azadeh’s detention is opaque. In that same email from September 2012, by which point relations between Azima and the three Iranians had reached their nadir, she wrote: “your clowns and mine … are heavily infected and involve[d] in this matter.” Azadeh’s emails never explicitly named Farsoudeh, Hosseinpour or Nayebi in connection to her kidnapping, but in multiple emails spanning years, Azima had referred to the three men as “the clowns” as a term of disparagement.

It is possible that there’s no direct link between Azadeh’s kidnapping, and Azima’s soured business dealings with at least some of the three Iranians. But according to Azadeh’s own legal filing, her interrogators were acutely focused on using her as “a possible source of information about her employer.” Indeed, Azadeh wrote to Azima in a September 2012 email found in the cache, “From the day one, they accused me of … working for you, that is why people are afraid of their name to be engaged in any activity with me.” And in a March 2013 email, Azima wrote to Azadah about her imprisonment being the result of “a personal van data [sic].”

According to court documents, Azadeh did not believe her trial would ever take place; it seemed as if the Iranian government was purposefully keeping her in legal purgatory. Her house arrest was lifted by November 2012. But she was forbidden to leave the country, and was still closely watched and continually harassed by agents of the IRGC. One day, while walking down a street in Tehran, she says, a car ran her down, fracturing her pelvis. “I told you to stay at home,” she says an Iranian prosecutor subsequently told her. “You don’t know the city, and it can be very dangerous.”

Then, in May 2013, nearly a year after her Borgesian nightmare began, Azadeh—still in shock and disbelief—was told she would soon be granted back her passport. That month, she boarded a plane in Tabriz, Iran, and, without incident, flew to Tbilisi. She was free.



***

It was around this same time that Azima seems to have reached at least a superficial détente with the Iranians. Exactly when he reestablished contact with them is unclear, but the emails show that Azima and Nayebi had a long dinner together in Tbilisi in early May 2013—over the same few days that Azadeh was released from and left Iran. According to the leaked emails, Azima flew to Georgia to meet Azadeh there once she had successfully exfiltrated herself. Nayebi appeared to orchestrate the trip: On May 8, 2013, he sent Azima an itinerary booking Azima on a flight from Dubai to Tbilisi the next day. (The flight was on Fly Georgia, an airline controlled by the three Iranians.) That same day, May 8, Azadeh emailed Azima, telling him she was in Tabriz, awaiting her final flight out of the country the next morning. Azima at least seemed back on good terms with Nayebi, who at their dinner in Tbilisi “complained all night” about Farsoudeh and Hosseinpour, with whom he was clashing, according to an email Azima wrote.

Once released from prison, Azadeh began to work again for Azima; she had done so while under house arrest in Iran, and continued from Dubai and the United States after she was freed. On February 6, 2014, the Treasury Department sanctioned the three Iranians, and Azima appeared pleased by that news. “The other shoe just dropped!” he wrote to Azadeh on that day, with apparent schaudenfraude. “Welcome to Washington.” (The Journal’s Solomon has suggested that by feeding him information about the trio, which led to the public exposure of their regime links, Azima probably played a role in precipitating their sanctioning in the first place; indeed, the day after the Journal article about the three Iranians was published, Georgian authorities froze 150 Iran-linked bank accounts in that country. Solomon has written that U.S. officials told him Azima had provided them with information about the three Iranians, including “mapping out their direct ties to the Iranian regime.” As Solomon wrote in the Columbia Journalism Review, “The Revolutionary Guard, presumably, was not happy.” Nayebi, for his part, believes Azima used alleged CIA connections “to make problems” for him and his former partners. Azima was “not my friend,” he told me.)

But by December 2014, months after the Treasury designation had been made, Azima was on (outwardly) friendly terms with Hosseinpour—enough to refer him to his own lawyer, Kirby Behre, to help Hosseinpour be removed from the sanctions list, according to the email tranche. (Azima confirmed this interaction in a previous Politico Magazine story; he also said, and his emails show, that Hosseinpour ultimately declined to have Behre lobby to delist him.) In December 2015, Azima gave a similar reference to Nayebi, who had gotten in touch about a livestock shipping business and wanted to gauge Azima’s interest in the venture. Azima was cautiously encouraging. “Perhaps later in 2016,” he told Nayebi. “Once the obstacles are removed, we can discuss such opportunities.” This was a reference to the Iran nuclear deal, which would begin to lift sanctions on Iran, including the three “clowns,” in January 2016, in exchange for Tehran freezing its nuclear program. The emails show that Nayebi ultimately declined Azima’s counsel’s services.

Soon afterward, the abortive 2011 hotel deal came back into focus. Azima has said in U.K. court documents, and in prior public statements, that he disavowed any financial interest in the hotel deal when he became concerned about the three Iranians’ regime connections. But while business with these Iranians was still explicitly proscribed in 2015 and early 2016, he took a keen personal interest, at least, in the legal avenues for recovering the Iranians’ $20 million deposit to RAK for the hotel. (Because of a longstanding U.S. embargo, most types of business with Iran were still forbidden outright for U.S. persons, even after the implementation of the Iran deal, says Erich Ferrari, founder and principal of Ferrari & Associates and an expert on sanctions law.) During this period, there were a number of email discussions among Azima, Azadeh and Marc-Milo Lube, a business associate of Azima’s and the head of a Vienna-based investment firm called VI2 Partners, about the $20 million; there also were emails, forwarded to Azima, among Azadeh, Lube and Hosseinpour about recovering these funds. (Multiple attempts to reach Lube by phone and email were unsuccessful.)

After the three Iranians had been sanctioned, VI2 purchased the $20 million claim—that is, the right to at least some of the proceeds, in the event of a legal victory against RAK—according to news outlets and correspondence in the email cache; a power of attorney agreement between VI2 and Hosseinpour obtained by Politico Magazine suggests that the purchase took place in November 2014. Emails show that Azima was consistently updated about the claim’s status throughout 2015 and 2016. On one occasion, in an August 2015 email to Azima, Lube referred to “our Tbilisi venture.” And in a February 2016 email Lube sent to Azadeh and Hosseinpour after a temporary victory against RAK in a Georgia court, he wrote, “Dear Afsanah and Hooshang [sic] … We have successfully arrested some of the assets of our counterparty.” Lube forwarded the email to Azima. (Nayebi told me he has initiated legal proceedings against Lube and VI2 regarding the claim on the hotel, and that Hosseinpour was “disloyal” to him by working with Lube to recover the funds.)

There’s no indication that Azima himself was party to the claim, and Azima was not directly in touch with Hosseinpour about retrieving the funds, according to his leaked emails. But in those emails, Azima sometimes appeared at least to be advising the effort to recover the $20 million. In March 2015, Behre sent him an email registering concerns about the prospect of his U.S.-based firm also working on the claim purchased by VI2. “As I mentioned,” Behre wrote, “the VI2 agreement buying the claim is not well-written, and the seller may retain some rights in the claim. [RAK’s lawyers] picked up on that, and [noted] that a U.S. firm can’t handle this matter because the prohibited person”—that is, Hosseinpour—“may retain some interest” in the hotel funds. Behre recommended using a British firm, which he said was not subject to the same regulations. Behre asked Azima for his advice: “How does this sound to you?” Lube subsequently forwarded emails to Azima that show VI2 working with the British firm Behre had recommended. In another instance, in July 2015, Lube forwarded to Azima for review a draft email that was written to a top RAK official rejecting a settlement offer regarding the $20 million hotel deposit. Azima returned a draft to Lube with edits.

Rendering legal or other services to sanctioned individuals is a high-risk endeavor, says Ferrari, the sanctions law expert. “If there is a sanctioned party somewhere in the world, and you are a U.S. person providing advice to that person—even if uncompensated—that could run afoul of U.S. laws, absent license authorization from the Treasury Department,” Ferrari says. It is not clear in the emails if such a license was obtained, and licenses issued by the Office of Foreign Assets Control—the Treasury agency that administers sanctions—are not public.



***

The three Iranians’ status is currently uncertain. Following President Donald Trump’s decision to withdraw from the Iran deal, the Treasury Department announced that sanctions on individuals who were delisted as part of the agreement—like Farsoudeh, Hosseinpour and Nayebi—could be reinstated by November. But the situation is murky. “An OFAC designation”—to sanction an individual or entity—“has to at least allege or assert that the prohibited behavior is recent or ongoing,” Ferrari says. “It’s unclear how the Treasury Department is going to be able do that for some of these parties.”

In a sense, Farsoudeh, Hosseinpour and Nayebi have been hiding in plain sight, even after they were added to the U.S. sanctions list in 2014, says Emmanuele Ottolenghi, the illicit finance expert. Ottolenghi—who has reviewed Georgia’s corporate registries, as well as social media accounts associated with the three Iranians, their family members and employees—says that, within weeks of the 2014 Treasury designations, the three Iranians were “busy reconstituting their network. … New businesses sprung up in Tbilisi to replace the sanctioned ones—including, crucially, a money exchange house and a financial holding with links to Azerbaijan. They continue to operate to this day.” The trio’s overseas network was likely maintained partly as a hedge against potential future U.S. sanctions, Ottolenghi says. Dimitri Aleksidze, a Georgia-based lawyer who has been involved in a lawsuit involving a Nayebi-linked foundation, told me Nayebi still maintains significant business interests in that country. Nayebi, who said he lives today in Georgia, disputes this characterization, claiming that U.S. sanctions, and fallout from his business dealings with the UAE and Azima, have had a deleterious effect on his finances.

As for Azima, his lawyers won a recent ruling in a D.C. federal court against RAK, which will allow Azima’s case about his hacked emails to move forward. He is still listed online as the chairman of ALG Transportation Group, his main Kansas City-based airline. Azadeh is listed as a consultant to an Azima-affiliated company, and her lawsuit against Iran is ongoing. Lube is still identified on his own website as president of VI2.

Whatever the current status of any probe into Azima, there is at least one recorded instance in his leaked emails in which his relationship with the three Iranians piqued the interest of federal investigators. On July 15, 2015—the day after the Iran deal was signed—Azima emailed an FBI agent based in Anchorage, Alaska. The Alaska FBI office had helped to investigate the Zong case involving Farsoudeh, Hosseinpour and Nayebi. This particular agent had gotten in touch with Azima previously, requesting an in-person meeting with him, according to Azima’s emails.

“Greetings from France,” Azima wrote the FBI agent, cheerfully. “Did you have a chance to see page 102 of the Iran Deal?” Azima was “astonished,” he wrote to the agent, “to see the cast of characters that are off the hook,” including “the clown subject of our previous call.”

The only individual listed on that particular page of the Iran deal—all the rest are businesses—is Hosseinpour. Lest one get the spins, the cardinal rule of tightrope walking is to never, ever, ever, look down.