Working on contract to the U.S. chemical company Purolite, Sabzali traveled to Cuba numerous times between 1991 and 1995 and sold $2 million worth of Welsh-made water purification chemicals to hospitals and factories on the island. He was later promoted to an administrative position at Purolite's main office in Philadelphia.

After a five-year investigation, the U.S. Justice Department brought a 76-count indictment against Sabzali and three other company executives in October 2000. He now faces trial and the prospect of a long prison sentence.

Thirty-four of the charges are for business transactions conducted while Sabzali was working for a registered Canadian company in Hamilton, Ontario. He argues that while in Canada he was legally barred from complying with the U.S. embargo under Canada's 1992 Foreign Extraterritorial Measures Act.

Canadian authorities have not leaped to Sabzali's defense. "Mr. Sabzali knew pretty well when he moved to the U.S. that he might run the risk of getting indicted," said Foreign Affairs spokesman Reynald Doiron.

"Where we do object, of course, is for his being charged for activities that he did while he was residing in Canada, which is a different ball game," Doiron added. The indictment on the 34 charges "is objectionable under our laws." He noted that his government has "always objected to U.S. attempts at asserting jurisdiction extraterritorially in Canada of their own laws to enforce their embargo of Cuba." It remains to be seen which charges will eventually be used against Sabzali.

Another Canadian citizen, Claude Gauthier, who took over Sabzali's trade missions to Cuba after the latter moved to Philadelphia, was subpoenaed and threatened with prosecution by assistant U.S. attorney Joseph Poluka. But Canadian authorities objected, and Washington backed off and withdrew the court order. Unlike Sabzali, Gauthier has not set foot in the United States.

Meanwhile, as Sabzali awaits trial he is prohibited from traveling more than an hour from his home in Bala Cynwyd, Pennsylvania, without written permission. If convicted he faces 10 years in prison for each violation of the Trading with the Enemy Act and a $250,000 fine.

With the U.S. government holding the passports of his entire family and the deed to his house, Sabzali pointed out, "I'm a hostage here."

The "extraterritorial" character of the U.S. embargo laws against Cuba has added to the trade frictions between the imperialist governments of Washington and Ottawa. While hostile to the Cuban Revolution, Ottawa maintains diplomatic and trade relations with the island. The Cuban Democracy Act of 1992, known as the Torricelli law, prohibits foreign subsidiaries of U.S. companies from trading with Cuba. The 1996 Cuban Liberty and Democratic Solidarity (Libertad) Act, or "Helms-Burton" law, allows U.S. businessmen whose property on the island was confiscated to sue companies abroad that invest in those properties.

One Canadian mining company, Sherritt International, has been found by U.S. authorities to have infringed the Helms-Burton law's provisions prohibiting foreign corporations from "trafficking" in property that Cuba's workers and farmers expropriated from U.S. capitalists.

In response to the U.S. embargo laws, Ottawa passed its Foreign Extraterritorial Measures Act, which prohibits Canadian citizens from complying with U.S. measures that infringe upon Canadian businessmen's "sovereign" ability to trade with other countries.
 
 
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Venezuela is Cuba's biggest trading partner
 
 
 
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