[SDNY] In January 2009, Mahmoud Reza Banki, a management consultant for a major New York consulting firm, was charged with violating the Iran Trade Embargo and with operating an unlicensed money transfer business between the United States and Iran. According to the indictment, Banki, provided money transmitting services to residents of Iran by operating a "hawala," which is a type of informal value-transfer system in which money does not physically cross international boundaries through the banking system.