At the time of the alleged events, Peter Gromacki was a U.S. citizen who lived and worked in Orange County, U.S. From at least 2006 until 2012, Gromacki operated alongside others in attempts to export and to re-export carbon fibre from the United States to the People’s Republic of China (PRC) in violation of the relevant sections of the United States International Emergency Economic Powers Act and the Export Administration Regulations. Gromacki exported the goods to the PRC via Belgium, by making false statements on the Shippers Declaration form regarding the end user and whether or not an export licence was required.