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complaint.amended - Approved ’{x‘ GLEN A 5” Assistant...

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Unformatted text preview: Approved: . ,. ’{x‘ GLEN A. 5” Assistant Un’ted States Attorneys Before: HONORABLE MICHAEL H. DOLINGER United States Magistrate Judge Southern District of New York r r r r r ' —.~ r — — - r * ~ — — — X SEALED AMENDED COMPLAINT UNITED STATES OF AMERICA Violations of — v. - : 18 U.S.C. §§ 1117, . 1958, 2, 2332a, 2332b MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” and COUNTY OF OFFENSE: GHOLAM SHAKURI, : NEW YORK a/k/a “Ali Gholam Shakuri,” Defendants. w _ _ _ _ _ _ _ _ _ ~ _ _ _ _ _ __.X SOUTHERN DISTRICT OF NEW YORK, 88.: O. Robert Woloszyn, being duly sworn, deposes and says that he is a Special Agent with the Federal Bureau of Investigation (“FBI”), and charges as follows: ' COUNT ONE Conspiracy to Murder A Foreign Official 1. From at least in or about the spring of 2011, up to and including in or about October 2011, in the Southern District of New York and elsewhere, MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” and GHOLAM SHAKURI, a/k/a “Ali Gholam Shakuri,” the defendants, and others known and unknown, knowingly and intentionally combined, conspired, confederated and agreed together and with each other to violate Section 1116 of Title 18, United States Code. 2. It was a part and an object of the conspiracy that MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” and GHOLAM SHAKURI, a/k/a “Ali Gholam Shakuri,” the defendants, and others known and unknown, would and did agree to kill a foreign official, to wit, ARBABSIAR and SHAKURI agreed with each other and with others to kill the Ambassador to the United States of Saudi Arabia, while the Ambassador was in the United States. Overt Acts 3. In furtherance of the conspiracy'and to effect the illegal object thereof, the following overt acts were committed, in the Southern District of New York and elsewhere: a. On or about August 1, 2011, MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” the defendant, caused an overseas wire transfer of approximately $49,960 to be sent by a foreign entity from a bank located in a foreign country to an FBI undercover bank account (the “UC Bank Account”). Before reaching the UC Bank Account, the funds were transferred through a bank in Manhattan, New York. b. On or about August 9, 2011, ARBABSIAR caused an overseas wire transfer of approximately $49,960 to be sent by a foreign entity from a bank located in a foreign country to the UC Bank Account. Before reaching the UC Bank Account, the funds were transferred through a bank in Manhattan, New York. c. In or about the spring of 2011, GHOLAM SHAKURI, a/k/a “Ali Gholam Shakuri,” the defendant, provided thousands of dollars to ARBABSIAR, in Iran to pay for expenses related, to furthering the plot to kill the Ambassador to the United States of Saudi Arabia. (Title 18, United States Code, Section 1117.) COUNT TWO Foreign Travel and Use of Interstate and Foreign Commerce Facilities in the Commission of MMrder-For—Hire 4. From at least in or about the spring of 2011, up to and including September 29, 2011, in the Southern District of New York and elsewhere, MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” the defendant, willfully and knowingly traveled in foreign commerce and used, and caused another to use, a facility of interstate and foreign commerce, to wit, bank wire transfers to an account in the United States from foreign entities, with the intent that a murder be committed in violation of the laws of the United States, to wit, Title 18, United States Code, Sections 1116 and 1117, as consideration for the receipt of, and as consideration for a promise and agreement to pay anything of pecuniary value, as those terms are defined in Title 18, United States Code, Section 1958(b), to wit, ARBABSIAR caused to be wired approximately $100,000 into the United States, as partial consideration for the murder of the Ambassador to the United States of Saudi Arabia. (Title 18, United States Code, Sections 1958 and 2.) COUNT THREE conspiracy to Engage in Foreign Travel and Use Interstate and Foreign Commerce Facilities In the Commission of Murder—For—Hire 5. From at least in or about the spring of 2011, up to and including in or about October 2011, in the Southern District of New York and elsewhere, MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” and GHOLAM SHAKURI, a/k/a “Ali Gholam Shakuri,” the defendants, and others known and unknown, willfully and knowingly combined, conspired, confederated.and agreed together and with each other to violate Title 18, United States Code, Section 1958. 6. It was a part and an object of the conspiracy that MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” and GHOLAM SHAKURI, a/k/a “Ali Gholam Shakuri,” the defendants, and others known and unknown, would and did agree together and with each other to use travel in foreign commerce and the facilities of interstate and foreign commerce, to wit, bank wire transfers to an account in the United States from foreign entities, with the intent that a murder be committed in violation of the laws of the United States, to wit,- Title 18, United States Code,‘ Sections "1116 and 1117, as consideration. for the receipt of, and as consideration for a promise and agreement to pay anything of pecuniary value, to wit, ARBABSIAR, SHAKURI, and others known and unknown, caused to be wired approximately $100,000 into the United States as partial conSideration for the murder of the Ambassador to the United States of Saudi Arabia. Overt Acts 7. In furtherance of the conspiracy and to effect the illegal objects thereof, MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” and GHOLAM SHAKURI, a/k/a “Ali Gholam Shakuri,” the defendants, and others known and unknown, committed in the Southern District of New York and elsewhere, the acts set forth in Paragraph 3 above. (Title 18, United States Code, Section 1958.) COUNT FOUR Conspiracy To Use A Weapon of Mass Destruction 8. From at least in or about the spring of 2011, up to and including in or about October 2011, in the Southern District of New York and elsewhere, MANSSOR ARBABSIAR, a/k/a _3_ “Mansour Arbabsiar,” and GHOLAM SHAKURI, a/k/a “Ali Gholam Shakuri,” the defendants, and others known and unknown, willfully and knowingly combined, conspired, confederated and agreed together and with each other to violate Title 18, United States Code, Section 2332a(a)(2)(A) and (C). 9. It was a part and an object of the conspiracy that MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” and GHOLAM SHAKURI, a/k/a “Ali Gholam Shakuri,” the defendants, and others known and unknown, would use a weapon of mass destruction, namely, a destructive device as that term is defined in Title 18, United States Code, Section 921, against a person within the United States, where a facility of interstate and foreign commerce was used in furtherance of the offense, to wit, bank wire transfers to an account in the United States from foreign entities, and where a perpetrator of the offense traveled in foreign commerce in furtherance of the offense, to wit, ARBABSIAR and SHAKURI agreed with each other and with others to use an explosive device against the Ambassador to the United States of Saudi Arabia. Overt Acts 10. In furtherance of the conspiracy and to effect the illegal objects thereof, MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” and GHOLAM SHAKURI, a/k/a “Ali Gholam Shakuri,” the defendants, and others known and unknown, committed in the Southern District of New York and elsewhere, the acts set forth in Paragraph 3 above. (Title 18, United States Code, Section 2332a(a)(2)(A) and (C).) COUNT FIVE Conspiracy to Commit An Act of Terrorism Transcending National Boundaries 11. From at least in or about the spring of 2011, up to and including in or about October 2011, in the Southern ‘ District of New York and elsewhere, MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” and GHOLAM SHAKURI, a/k/a “Ali Gholam Shakuri,” the defendants, and others known and unknown, willfully and knowingly combined, conspired, confederated and agreed together and with each other to violate Title 18, United States Code, Sections 2332b(a)(1)(A), (a)(1)(B), (b)(1)(A) and (b)(l)(B)- 12. It was a part and an object of the conspiracy that MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” and GHOLAM SHAKURI, a/k/a “Ali Gholam Shakuri,” the defendants, and others known and -4- unknown, would kill and maim persons within the United States and would create a substantial risk of serious bodily injury to others by destroying and damaging structures, conveyances and other real and personal property within the United States, in violation of the laws of the United States, including Title 18, United States Code, Sections 1116 and 1117, where interstate and foreign commerce is used in furtherance of the offense, to wit, bank wire transfers to an account in the United States from foreign entities, and where the offense would have obstructed, delayed and affected interstate commerce had it been consummated, to wit, ARBABSIAR and SHAKURI, during meetings outside the United States, agreed with each other and with others to kill the ‘ Ambassador to the United States of Saudi Arabia, while the Ambassador was in the United States. Overt Acts 13. In furtherance of the conspiracy and to effect the illegal objects thereof, MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” and GHOLAM SHAKURI, a/k/a “Ali Gholam Shakuri,” the defendants, and others known and unknown, committed in the Southern District of New York and elsewhere, the acts set forth in Paragraph 3 above. (Title 18, United States Code, Section 2332b(a)(1)(A), (a)(l)(B), (a)(2), (b)(1)(A), (b)(1)(Bi-) The bases for my knowledge and the foregoing charges are, in part, as follows: 14. I have'been a Special Agent with the FBI since March of 1999. I have participated in the investigation of this matter, and have spoken with other individuals, including other law—enforcement officials, about this investigation. The facts and circumstances of this investigation have been summarized for the specific purposes of the instant affidavit. No attempt has been made to set forth the complete factual history of this investigation or all of its details. 15. I make this affidavit based on, among other things, my personal review of evidence obtained in the course of the investigation, as well as information and belief. The sources of my information and belief include, but are not limited to, conversations with other law-enforcement officers; reviews of reports and other documents prepared by law—enforcement personnel; reviews of business records; draft transcripts and translations of recordings, as well as the underlying recordings themselves; and the defendant's post—arrest statements. Where the actions, statements and conversations of others, or the -5... contents of documents, are recounted or described herein, they are related in substance and in part, unless otherwise indicated. 1—. OVERVIEW 16. As set forth more fully below, MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” the defendant, is a naturalized citizen of the United States who holds both a United States and an Iranian passport. ARBABSIAR and his Iran—based co~ conspirators, including GHOLAM SHAKURI, a/k/a “Ali Gholam Shakuri,” the defendant, a member of the Qods Force, see infra I 17, have been plotting the murder of the Ambassador to the United States of Saudi Arabia (“Ambassador”). In furtherance of this conspiracy, ARBABSIAR has met on a number of occasions in Mexico with a Drug Enforcement Administration confidential source (“CS— 1”). In the course of these meetings, CS—l has posed as an associate of a sophisticated and violent international drug~ trafficking cartel. See infra n.2. ARBABSIAR arranged to hire CS~l and his purported criminal associates to murder the Ambassador, and SHAKURI and other Iran—based co~conspirators were aware of and approved the plan. With SHAKURI’S approval, ARBABSIAR caused approximately $100,000 to be wired into a bank account in the United States for CS—l — as a down—payment to CS~1 for his anticipated killing of the Ambassador. II. BACKGROUND: THE IRANIAN ISLAMIC REVOLUTIONARY GUARD CORPS AND THE QODS FORCE 17. During the course of my investigation, I have become familiar with the Iranian Islamic Revolutionary Guard Corps (the “IRGC") and the Qods Force. Based in part on my review of publicly—available information, including findings and statements by the United States Department of State, the United States Department of Treasury, and other “open source” information, I have learned the following: the IRGC is an arm of the Iranian military; the IRGC is suspected of having been involved in a number of foreign operations; the IRGC is composed of a number of branches, one of which is the Qods Force. The Qods Force conducts sensitive covert operations abroad, including terrorist attacks, assassinations, and kidnappings, and provides weapons and training to Iran’s terrorist and militant allies. Among many other things, the Qods Force is believed to sponsor attacks against Coalition Forces in Iraq, and in October 2007, the United States Treasury Department designated the Qods Force, pursuant to Executive Order 13224, for providing material support to the Taliban and other terrorist organizations. III. THE INVESTIGATIO A. MAY 2011: ARBABSIAR MEETS CS—l AND DISCUSSES WITH HIM THE POSSIBILITY OF AN ATTACK 18. On or about May 24, 2011, according to travel records, MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” the defendant, traveled back and forth from Texas to Mexico. In Mexico, ARBABSIAR met with CS-l.1 During this May 24 meeting, and all others with ARBABSIAR, CS—l posed as an associate of a drug—trafficking cartel (“Drug Cartel #1”).2 After the May 24 meeting with ARBABSIAR, CS—l described to lawvenforcement agents what had transpired. CS~1 explained that, at the meeting, ARBABSIAR inquired as to CS—l’s knowledge, if any, with respect to exploSives. According to CS—l, ARBABSIAR explained to CS—l that he was interested in, among other things, attacking an embassy of Saudi Arabia. In response, and to further the discussion, CS—l told ARBABSIAR that he was knowledgeable with respect to C~4 explosives.3 19. On or about May 30, 2011, according to travel records, MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” the defendant, traveled internationally, by plane from Houston, Texas. 1 CS~1 is a paid confidential source. Previously, CS—l was charged in connection with a narcotics offense by authorities of a certain U.S. state (“State”). In exchange for CS~1's cooperation in various narcotics investigations, the State charges were dismissed. CS-l has previously provided reliable and independently corroborated information to federal law— enforcement agents; this information has led to numerous seizures of narcotics. In addition, CS—l has been paid by federal law— enforcement officials in connection with the work he has done. 2 Drug Cartel #1 is a large, sophisticated, and violent drug—trafficking cartel. It is well—known throughout North America, and its principal places of operation are Mexico and the United States. According to published reports, Drug Cartel #1 has access to military—grade weaponry and explosives, and has engaged in numerous acts of violence, including assassinations and murders. 3 “C—4" is a type of plastic explosive. Like other plastic explosives, C—4 can generally be molded, so that it can be shaped and formed with a certain degree of precision. -7- B. JUNE AND JULY 2011: ARBABSIAR RETURNS TO MEXICO AND HIRES CS-l TO KILL THE UNITED STATES—BASED AMBASSADOR OF SAUDI ARABIA 20. On or about June 23, 2011, MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” the defendant, who had traveled internationally, see supra I 19, returned by plane to Mexico. 21. According to CS—l, MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” the defendant, again met with CS—l in Mexico in late June and July. Over the course of a series of meetings, ARBABSIAR explained to CS—l that his associates in Iran had discussed a number of violent missions for CS—l and CS—l’s purported criminal associates to perform. These included, among others, the murder of the Ambassador. " 22. On or about July 14, 2011, MANSSOR ARBABSIAR, a/k/a “Mansour Arbabsiar,” the defendant, met with CS~1 in Mexico. At the direction of law~enforcement agents, CS—l made an audio recording of the meeting. CS—l and ARBABSIAR spoke English during the meeting. Based on my review of draft transcripts of the July 14 recorded meeting, I learned that at this meeting the following occurred, among other things:4 a. CS~1 told ARBABSIAR that CS—l would need to use “[a]t least four guys” and that CS~1 was “talking to one of the guys” and would “take the one point five for the Saudi Arabia.” I understand this to mean that CS—l would need to use four men to assassinate the Ambassador and that the cost to ARBABSIAR of conducting the assassination would be $1.5 million.5 CS-I told ARBABSIAR that he would “go ahead and work on Saudi Arabia, get all the information that we can”; ARBABSIAR agreed that the assassination of the Ambassador should be handled first.6 After CS—l stated, “you just want the, the main guy,” 4 In his postwarrest statement, see infra Part IV, ARBABSIAR has admitted that he participated in each of the recorded meetings described in this Complaint, and he has confirmed that he agreed to pay CS*1 to kill-the Ambassador. 5 Both above, and throughout, the quoted language is taken from the draft transcripts. My understanding of the meaning of those quoted terms, where supplied, is based on my training, experience and participation in this investigation. 6 Prior to the July 14, 2011 meeting, CS—l had reported that he and ARBABSIAR had discussed the possibility of attacks on _8_ I, i 2 i 1 ARBABSIAR confirmed that he just wanted the “[A]mbassador” ~ which I understand to mean that ARBABSIAR wanted CS—l to arrange for the assassination of the Ambassador before executing the other attacks they had discussed. b. CS—l and ARBABSIAR then discussed how ARBABSIAR would pay CS—l. ARBABSIAR asked CS-l what bank he planned to use, and CS—l stated that he would give ARBABSIAR “an account number.” At a later time during the same conversation, ARBABSIAR stated that the “money is [in] Iran,” and that he (ARBABSIAR) had received a call indicating that the money would be at the house of a certain individual (“Individual #1”). When ARBABSIAR called Individual #1, “he [Individual #1] said he had it there” and that he (Individual #1) had received “the money at nine in the morning.” ARBABSIAR said the “money’s a hundred thousand” but that he (ARBABSIAR) would have.to “send a hundred . . ten thousand, ten thousand, ten thousand“ I don’t wanna send it to one guy, one shot.” I understand ARBABSIAR to mean that he had $100,000 in Iran to pay CS—l as a first payment toward the assassination of the Ambassador, but that ARBABSIAR wanted to send the money to CS—l in installments and not in a single transfer. c. During their July 14 meeting, CS—l asked ARBABSIAR about ARBABSIAR’S cousin, who, according to ARBABSIAR, was located in Iran and had requested that ARBABSIAR find someone (ultimately, CS—l) who could carry out the attack on the Ambassador described above. ARBABSIAR explained that his cousin was “wanted in America,” had been “on the CNN,” and was a “big general in [the] army.” ARBABSIAR further explained that there were a number of parts to the army of Iran and that his cousin “work[s] in outside, in other countries for the Iranian government[.]” ARBABSIAR further explained that his cousin did not wear a uniform or carry a gun, and had taken certain unspecified actions related to a bombing in Iraq. Compare supra i 17. In the portions of the July 14 meeting referenced in this sub~paragraph, I understand ARBABSIAR to be saying that his cousin works for the military of Iran, in particular, for the Qods Force, and that his cousin focuses on matters outside of Iran. ‘ d. At the end of the July 14 meeting, CS—l told ARBABSIAR, “[w]e’re gonna start doing...
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