iran terror complaint

8/3/2019 Iran Terror Complaint

http://slidepdf.com/reader/full/iran-terror-complaint 1/21

Approved:

Ass is tan t

Before: HONORABLE MICHAEL H. DOLINGER

United Sta tes Magis t ra te Judge

Southern D is t r i c t of New York

-----XUNITED STATES OF AMERICA

- v. -

MANSSOR ARBABSIAR,

a /k /a "Mansour Arbabsia r , " and

GHOLAM SHAKURI,

a /k /a "Al i Gholam Shakuri ,"

Defendants .

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SOUTHERN DISTRICT OF NEW YORK, s s . :

SEALED AMENDED COMPLAINT

Viola t ions of

18 u.s.c. § § 1117,

1958, 2, 2332a, 2332b

COUNTY OF OFFENSE:

NEW YORK

0 . Robert Woloszyn, being duly sworn, deposes and says

t ha t he i s a Specia l Agent with the Federa l Bureau o f Inves t iga t ion

("FBI") , and charges as fo l lows:

COUNT ONE

Conspiracy to Murder A Foreign O f f ic i a l

1. From a t l e a s t in or about the spr ing of 2011, up to

and inc luding in or about October 2011, in the Southern D is t r i c t ofNew York and elsewhere , MANSSOR ARBABSIAR, a /k /a "Mansour

Arbabs ia r , " and GHOLAM SHAKURI, a /k /a "Al i Gholam Shakur i , " the

defendants , and others known and unknown, knowingly and

i n t e n t i o n a l l y combined, conspired, confederated and agreed t oge the r

and with each othe r to v io la t e Sect ion 1116 of Ti t l e 18, United

Sta tes Code.

2. I t was a p a r t and an ob jec t of the conspiracy t ha t

MANSSOR ARBABSIAR, a /k /a "Mansour Arbabs ia r , " and GHOLAM SHAKURI,

a /k /a "Al i Gholam Shakuri ," th e defendants , and othe rs known andunknown, would and did agree to k i l l a fore ign o f f i c i a l , to wit ,

ARBABSIAR and SHAKURI agreed with each o ther and with others to

k i l l the Ambassador to the United Sta tes o f Saudi Arabia , whi le the

Ambassador was in the United Sta tes .

Overt Acts

3. In fu r therance of the conspi racy and to e f fec t the



i l l e g a l objec t the reof , the fol lowing ove r t ac ts were committed, in

th e Southern D i s t r i c t of New York and elsewhere:

a . On or about August 1, 2011, MANSSOR ARBABSIAR,

a /k / a "Mansour Arbabsia r , " the defendant , caused an overseas wiret r a n s fe r of approximately $49,960 to be sen t by a fo re ign e n t i t y

from a bank loca ted in a foreign country to an FBI undercover bankaccount ( the "UC Bank Account") . Before reach ing th e UC Bank

Account , th e funds were t r a n s fe r r e d through a bank in Manhattan,

New York.

b. On or about August 9, 2011, ARBABSIAR caused anoverseas wire t r a n s fe r of approximately $49,960 to be sen t by a

fo re ign e n t i t y from a bank loca ted in a foreign count ry to the UC

Bank Account. Before reaching the UC Bank Account , th e funds were

t r an s f e r r ed through a bank in Manhattan, New York.

c . In or about the sp r ing o f 2011, GHOLAM SHAKURI,

a /k /a "Al i Gholam Shakuri ," th e defendant , provided thousands ofd o l l a r s to ARBABSIAR in I ran to pay fo r expenses re l a t ed to

fu r the r ing the p l o t to k i l l th e Ambassador t o . the Uni ted Sta te s of

Saudi Arabia .

(T i t l e 18, United Sta tes Code, Sect ion 1117.)

COUNT TWO

Foreign Trave l and Use o f In ters ta te

and Foreign Commerce Fac i l i t i e s

in the Commission o f Murder-For-Hire


and inc lud ing September 29, 2011, in th e Southern D is t r i c t of New

York and elsewhere , MANSSOR ARBABSIAR, a /k /a "Mansour A rb ab s i a r , "

th e defendant , w i l l fu l l y and knowingly t r ave led in fo re ign commerce

and used, and caused ano ther to use, a f a c i l i t y of i n t e r s t a t e andforeign commerce, to wit , bank wire t r a n s fe r s to an account in the

United Sta tes from fo re ign e n t i t i e s , with th e i n t e n t t ha t a murderbe committed in v io l a t i o n of the laws of the Uni ted Sta tes , to wit ,

Ti t l e 18, United Sta te s Code, Sect ions 1116 and 1117, ascons idera t ion for the r ece ip t of , and as cons idera t ion fo r a

promise and agreement to pay anything o f pecuniary value , as those

te rms are def ined in Ti t l e 18, Uni ted Sta tes Code, Sect ion 1958(b) ,to wit , ARBABSIAR caused to be wired approximately $100,000 in to

the United Sta tes , as p a r t i a l cons idera t ion fo r the murder of th e

Ambassador to the United Sta te s of Saudi Arabia .

(T i t l e 18, United Sta te s Code, Sec t ion i 1958 and 2 .)

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COUNT THREE

Conspiracy to Engage in Foreign Trave l

and Use In t e r s ta t e and Foreign Commerce Fac i l i t i e s

In the Commission o f Murder-For-Hire


and including in or about October 2011, in the Southern D is t r i c t ofNew York and elsewhere , MANSSOR ARBABSIAR, a /k /a "Mansour

Arbabsia r , " and GHOLAM SHAKURI, a /k /a "Al i Gholam Shakur i , " the

defendants , and othe rs known and unknown, w i l l fu l l y and knowinglycombined, conspired, confederated and agreed toge ther and with eachother to v io la t e Ti t l e 18, United Sta tes Code, Sect ion 1958.

6. I t was a p a r t and an objec t of the conspiracy t ha t

MANSSOR ARBABSIAR, a /k /a "Mansour Arbabs ia r , " and GHOLAM SHAKURI,

a /k /a "Al i Gholam Shakur i , " the defendants , and others known and

unknown, would and did agree toge ther and with each othe r to uset r a v e l in fo re ign commerce and th e f a c i l i t i e s of i n t e r s t a t e andforeign commerce, to wit , bank wire t r a n s fe r s to an account in the

United Sta tes from fo re ign en t i t i e s , with the i n t e n t t ha t a murderbe committed in v io la t ion of the laws of the United Sta tes , to wit ,Ti t l e 18, United Sta tes Code, Sect ions '1116 and 1117, ascons idera t ion for the rece ip t of, and as cons ide ra t ion fo r a

promise and agreement to pay anything of pecuniary value, to wit ,ARBABSIAR, SHAKURI, and othe rs known and unknown, caused to bewired approximately $100, 000 in to the United Sta tes as p a r t i a l

cons idera t ion for the murder o f the Ambassador to th e United Sta tes

of Saudi Arabia.

Overt Acts

7. In fur therance of the conspiracy and to e f f e c t thei l l e g a l objec t s the reof , MANSSOR ARBABSIAR, a /k /a "Mansour

Arbabs ia r , " and GHOLAM SHAKURI, a /k /a "Al i Gholam Shakur i , " the

defendants , and othe rs known and unknown, committed in th e

Southern D is t r i c t o f New York and elsewhere , th e ac t s s e t fo r th

in Paragraph 3 above.

(T i t l e 18, United Sta tes Code, Sect ion 1958.)

COUNT FOURConspiracy To Use A Weapon o f Mass Destruc t ion

8. From a t l ea s t in or about the spr ing of 2011, up

to and including in or about October 2011, in the SouthernD is t r i c t of New York and elsewhere, MANSSOR ARBABSIAR, a /k /a

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"Mansour A rb ab s i a r , " and GHOLAM SHAKURI, a /k / a "Al i Gholam

Shakur i , " the defendan ts , and others known and unknown, wi l l fu l ly

and knowingly combined, conspired, confedera ted and agreed

toge ther and with each o t h e r to v io la te Ti t l e 18, United St a t e s

Code, Sect ion 2332a(a) (2 ) (A) and (C).

9. I t was a p a r t and an o b j ec t o f th e consp i racy t h a t

MANSSOR ARBABSIAR, a / k / a "Mansour Arbabs iar , ,. and GHOLAM SHAKURI,

a /k /a "Al i Gholam Shakur i , " the defendants , and othe rs known and

unknown, would use a weapon o f mass des t ruc t ion , namely, a

des t ruc t ive device as t h a t term i s def ined in T i t l e 18, UnitedSt a t e s Code, Sect ion 921, ag a i n s t a person with in th e United

Sta te s , where a f a c i l i t y o f i n t e r s t a t e and fo re ign commerce was

used in fu r therance o f th e offense , to wi t , bank wire t r ans fe r s

to an account in th e United Sta te s from fo re ign e n t i t i e s , and

where a p e r p e t r a to r o f th e offense t r ave led in fo re ign commerce

in fu r therance o f the o f fense , to wi t , ARBABSIAR and SHAKURI

agreed with each othe r and with others to use an exp los ive device

aga ins t the Ambassador to the United Sta te s o f Saudi Arabia .

Overt Acts

10. In fu r therance of the consp i racy and to e f f e c t the

i l l e g a l objec t s t he reof , MANSSOR ARBABSIAR, a /k /a " M a n s o u ~ Arbabsia r , " and GHOLAM SHAKURI, a /k /a "Al i Gholam Shakur i , " the

defendants , and others known and unknown, committed in the

Southern D is t r i c t o f New York and elsewhere , th e ac t s s e t for th


(T i t l e 18, United Sta te s Code, Sect ion 2332a (a ) (2) (A) and (C) . )

COUNT FIVE

Conspiracy to Commit An Act o f Terrorism

Transcending National Boundaries

11. From a t l e a s t in or about the sp r ing o f 2011, up

to and inc lud ing in o r about October 2011, in th e SouthernD i s t r i c t of New York and elsewhere , MANSSOR ARBABSIAR, a /k /a

"Mansour Arbabsia r , " and GHOLAM SHAKURI, a /k / a "A l i Gholam

Sh ak u r i , " the defendan ts , and others known and unknown, w i l l fu l l y

and knowingly combined, conspired, confederat .ed and agreed

toge ther and with each o t h e r to v io l a t e Ti t l e 18, United Sta tesCode, Sect ions 2332b (a) (1 ) (A), (a) (1 ) (B), (b ) (1 ) (A) and

(b) (1) (B) .

12. I t was a p a r t and an objec t o f th e conspiracy t h a t

MANSSOR ARBABSIAR, a /k / a "Mansour Arbabsia r , " and GHOLAM SHAKURI,

a /k /a "Al i Gholam Shakur i , " the defendants , and others known and

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unknown, would k i l l and maim persons with in the United Sta tes and

would c rea te a s ubs t a n t i a l r i sk of se r ious bodi ly in ju ry to

others by des t roying and damaging s t ruc tures , conveyances and

other r e a l and persona l proper ty wi th in the United Sta tes , in

vio la t ion of the laws of th e United Sta tes , i nc lud ing T i t l e 18,

United Sta tes Code, Sec t ions 1116 and 1117, where i n t e r s t a t e and

fore ign commerce i s used in fur therance of the offense , to wit ,

bank wire t r a ns f e r s to an account in the United Sta tes from

fore ign e n t i t i e s , and where the of fense would have obs t ructed ,

delayed and a f fec ted i n t e r s t a t e commerce had · i t been consummated,

to wi t , ARBABSIAR and SHAKURI, during meetings outs ide the United

Sta tes , agreed wi th each o ther and with others to k i l l the

Ambassador to the United Sta tes of Saudi Arabia , whi le the

Ambassador was in the United Sta tes .

Overt Acts

13.In

fur therance of the consp i racy and to e f f ec t the

i l l e g a l ob jec t s thereof , MANSSOR ARBABSIAR, a /k / a "Mansour

Arbabs iar , " and GHOLAM SHAKURI, a /k /a "Al i Gholam Shakur i , " the

defendants , ·and o ther s known and unknown, committed in the

Southern D i s t r i c t of New York and e lsewhere , th e ac t s s e t for th


(Ti t le 18, United Sta tes Code, Section 2332b (a) (1) (A), (a) (1) (B),

(a) ( 2 ) , (b) (1) (A ) , (b) (1) (B ) . )

The bases fo r my knowledge and the foregoing chargesare , in pa r t , as fo l lows:

14. I have been a Spec ia l Agent with the FBI s ince

March of 1999. I have par t i c ipa t ed in the inves t iga t ion of th i s

mat ter , and have spoken with other ind iv idua l s , inc luding other

law-enforcement o f f i c i a l s , about t h i s i nves t iga t ion . The f ac t s

and circumstances of t h i s inves t iga t ion have been summarized fo r

the spec i f i c purposes of th e i n s t a n t a f f i d a v i t . No a t tempt has

been made to s e t fo r th the complete f ac tua l hi s tory of t h i s

inves t iga t ion or a l l of i t s d e t a i l s .

15. I make t h i s a f f i dav i t based on, among o ther

th ings , my pe r sona l review of evidence obta ined in th e course of

the inves t iga t ion , as wel l as in fo rmat ion and b e l i e f . Thesources of my in format ion and b e l i e f inc lude , bu t a re no t l im i t ed

to , conversa t ions with o ther law-enforcement ~ f f i c e r s ; reviews of

r epor t s and o ther documents prepared by law-enforcement

personnel; reviews of bus iness records ; d r a f t t r ans c r ip t s and

t r a ns l a t i ons of record ings , as well as the under lying record ings

themselves; and the defendant ' s pos t - a r r e s t s ta tements . Where

the act ions , s ta tements and conversa t ions of o the r s , or the

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content s o f documents, a re recounted or descr ibed here in , theyare re l a t ed in subs tance and in par t , unless o therwise indica ted .

.L__ OVERVIEW

16. As s e t for th more fu l ly below, MANSSOR ARBABSIAR,a /k /a "Mansour Arbabsia r , " the defendant , i s a na tu ra l i zed

c i t i z e n of th e Uni ted Sta t e s who holds both a Uni ted Sta t e s andan I ranian passpor t . ARBABSIAR and h is I ran-based coconsp i ra to r s , inc luding GHOLAM SHAKURI, a /k / a "Al i Gholam

Shakur i , " the defendant , a member of th e Qods Force, see i n f r a <JI

17, have been p lo t t ing the murder of the Ambassador to the UnitedSta t e s of Saudi Arabia ("Ambassador"). In fur therance of t h i s

con$piracy, A R B ~ B S I A R has met on a number of occas ions in Mexico

with a Drug Enforcement Adminis t ra t ion conf iden t ia l source ("CS-

1" ) . In th e course of these meet ings , CS-1 has posed as an

assoc ia t e o f a soph is t i ca ted and v io len t i n t e rna t iona l drugt r a f f i c k i n g c a r t e l . See i n f r a n .2 . ARBABSIAR arranged to h i re

CS-1 and h is purpor ted cr imina l assoc ia t e s t o murder the

Ambassador, and SHAKURI and ot he r Iran-based co-conspi ra tors were

aware of and approved the p lan . With SHAKURI's approva l ,ARBABSIAR caused approximately $100,000 to be wired in to a bankaccount in th e United Sta t e s fo r CS-1 - as a down-payment to CS-1

fo r h is an t ic ipa ted k i l l i ng of the Ambassador.

I I . BACKGROUND: THE IRANIAN ISLAMIC REVOLUTIONARY GUARD CORPS

AND THE QODS FORCE

17. During th e course of my i n v es t i g a t i o n , I have

become fami l i a r with the I ranian Is lamic Revolu t ionary GuardCorps ( the "IRGC") and th e Qods Force . Based in p a r t on my

review of pub l ic ly -ava i lab le in fo rmat ion , inc luding f indings ands ta tements by th e United Sta t e s Department of S ta t e , th e UnitedSta t e s Department o f Treasury, and ot he r "open source"in fo rmat ion , I have l ea rned the fol lowing: th e IRGC i s an arm of

the I ranian mil i t a ry ; th e IRGC i s suspec ted o f having beeninvolved in a number of fore ign opera t ions ; t 'he IRGC i s composed

of a number of branches , one of which i s the Qods Force. The

Qods Force conducts sens i t ive cover t opera t ions abroad, inc luding

t e r r o r i s t a t tacks , a s sas s ina t ions , and kidnappings , and providesweapons and t ra in ing to I r a n ' s t e r r o r i s t and m i l i t a n t a l l i e s .

Among many ot he r t h ings , th e Qods Force i s be l ieved to sponsora t t acks aga ins t Coa l i t i on Forces i n I raq , and in October 2007,the United Sta t e s Treasury Department des igna ted th e Qods Force,pursuant to Execut ive Order 13224, fo r prov id ing mate r i a l suppor tto the Tal iban and o the r t e r r o r i s t organiza t ions .

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I I I . THE INVESTIGATION

A. MAY 2011:

ARBABSIAR MEETS CS-1 AND DISCUSSES WITH HIM THE

POSSIBILITY OF AN ATTACK

18. On or about May 24, 2011, according to t r a v e l

records , MANSSOR ARBABSIAR, a /k / a "Mansour Arbabs ia r , " · the

defendant , t r ave led back and fo r th from Texas to Mexico. InMexico, ARBABSIAR met with CS-1. 1 During t h i s May 24 meeting ,

and a l l others with ARBABSIAR, CS-1 posed as an assoc ia t e of adrug- t r a f f i ck ing c a r t e l ("Drug Car t e l #1") . 2 Afte r th e May 24

meeting with ARBABSIAR, CS-1 descr ibed to law-enforcement agents

what had t r ansp i red . CS-1 explained t ha t , ai th e meeting ,ARBABSIAR inqu i red as to CS-1 's knowledge, if any, with r e sp ec t

to exp los ives . According to CS-1, ARBABSIAR exp la ined to CS-1

t h a t he was i n t e r e s t e d in , among other t h ings , a t t ack ing an

embassy of Saudi Arabia . In response , and t o f u r th e r thediscuss ion , CS-1 t o ld ARBABSIAR t h a t he was knowledgeable withrespec t to C-4 exp los ives . 3

19. On or about May 30, 2011, according t o t r a v e l

records, MANSSOR ARBABSIAR, a /k / a "Mansour A rb ab s i a r , " the

defendant , t r ave led i n t e rna t iona l ly , by plane from Houston,

Texas.

1 CS-1 i s a paid conf iden t ia l source. Prev ious ly , CS-1 was

chargedin

connect ion with ana rco t i c s offense

byau thor i t i e s

ofa cer t a in U.S. s t a t e ("Sta te" ) . In exchange ' for CS-1' s

cooperat ion in var ious na rco t i c s inves t iga t ions , th e Sta te

charges were dismissed. CS-1 has prev ious ly provided r e l i a b l e

and independent ly cor robora ted in fo rmat ion to fede ra l law

enforcement agen t s ; t h i s informat ion has led to numerous se izures

of narco t ics . In add i t ion , CS-1 has been paid by fede ra l law

enforcement o f f i c i a l s in connect ion wi th th e work he has done.

2 Drug Car te l #1 i s a l a rge , soph is t i ca ted , and v i o l e n t

drug- t r a f f i ck ing c a r t e l . I t i s well-known th roughout North

America, and i t s p r in c ip a l places of opera t ion a re Mexico and the

United S ta t e s . According to publ i shed r epor t s , Drug Car t e l #1

has access t o mi l i t a ry -g rade weaponry and exp los ives , and has

engaged in numerous ac t s o f v i o l e n c ~ , inc lud ing assa ss ina t ions

and murders.

3 "C-4" i s a type of p la s t i c exp los ive . Like othe r p l a s t i c

exp los ives , C-4 can gene ra l ly be molded, so t 'hat it can be shaped

and formed with a cer t a in degree of prec i s ion .

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B. JUNE AND JULY 2011:

ARBABSIAR RETURNS TO MEXICO AND HIRES CS-1 TO KILL

THE UNITED STATES-BASED AMBASSADOR OF SAUDI ARABIA

20. On or about June 23, 2011, MANSSOR ARBABSIAR,

a /k /a "Mansour A rb ab s i a r , " th e defendant , who had t r ave led

i n t e rna t iona l ly , see supra 19, re turned by plane to Mexico.

21. According to CS-1, MANSSOR ARBABSIAR, a /k /a

"Mansour Arbabsia r , " th e defendant , again met with CS-1 in Mexico

in l a t e June and Ju ly . Over th e course of a se r i e s of meet ings ,ARBABSIAR exp la ined to CS-1 t h a t hi s a s soc ia t e s in I ran had

discussed a number o f v io len t miss ions fo r CS-1 and CS-1 'spurpor ted cr imina l assoc ia t e s to perform. These inc luded , among

othe rs , th e murder of the Ambassador.

22. On o r about July 14, 2011, MANSSOR ARBABSIAR,

a /k / a "Mansour Arbabs ia r , " the defendant , met with CS-1 in

Mexico. At th e d i r ec t i o n of law-enforcement agen t s , CS-1 made an

audio record ing of the meeting. CS-1 and ARBABSIAR spoke Engl ishdur ing th e meet ing . Based on my review of d ra f t t r a n sc r i p t s ofth e Ju ly 14 recorded meet ing , I learned t h a t a t t h i s meeting thefol lowing occurred, among other th ings : 4

a . CS-1 to ld ARBABSIAR t h a t CS-1 would need to

use " [ a ] t l e a s t four guys" and t h a t CS-1 was " ta lk ing to one ofth e guys" and would " take the one poin t f ive fo r th e SaudiArab ia . " I unders tand t h i s to mean t h a t CS-1 would need to usefour men to as sas s ina te the Ambassador and t ha t the cos t to

ARBABSIAR of conduct ing the assa ss ina t ion would be $1.5 mil l ion . 5

CS-1 to ld ARBABSIAR t h a t he would "go ahead and work on SaudiArabia , get a l l th e in fo rmat ion t h a t we can";. ARBABSIAR agreedt ha t th e as sas s ina t ion of the Ambassador should be handledf i r s t . 6

Afte r CS-1 s t a t ed , "you j u s t want the , th e main guy,"

4 In h is pos t - a r r e s t s ta tement , see i n f r a Par t IV ,

ARBABSIAR has admit ted t h a t he p a r t i c ip a t ed in each o f th e

recorded meet ings descr ibed in t h i s Complaint , and he hasconfirmed t ha t he agreed to pay CS-1 to k i l l · the Ambassador.

5 Both above, and throughout , the quoted language i s taken

from the dra f t t r a ns c r ip t s . My unders tanding of th e meaning ofthose quoted terms, where suppl ied , i s based on my t r a in in g ,

exper ience and p a r t i c i p a t i o n in t h i s i n v es t i g a t i o n .

Pr io r t o the Ju ly 14, 2011 meeting, CS-1 had reported

t ha t he and ARBABSIAR had discussed th e poss i .b i l i ty of a t tacks on

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ARBABSIAR conf i rmed t ha t he j u s t wanted th e "[A]mbassador"which I unders tand to mean t h a t ARBABSIAR wanted CS-1 to ar rangefo r the as sas s ina t ion of the Ambassador before execu t ing the

othe r a t tacks they had discussed .

b. CS-1 and ARBABSIAR then discussed how

ARBABSIAR would pay CS-1. ARBABSIAR asked CS-1 what bank he

planned to use, and CS-1 s ta ted t h a t he would give ARBABSIAR "anaccount number." At a l a t e r t ime during th e same conversa t ion ,

ARBABSIAR s t a t ed t ha t th e "money i s [ in] I r a n , " and t h a t he(ARBABSIAR) had rece ived a c a l l ind ica t ing t h a t the money would

be a t th e house o f a cer t a in indiv idua l ( " Ind iv idua l #1") . When

ARBABSIAR ca l l ed Ind iv idua l #1, "he [ Ind iv idua l #1] sa id he had

it the re" and t h a t he ( Individual #1) had rece ived "the money a t

nine in the morning." ARBABSIAR sa id th e "money's a hundredthousand" bu t t h a t he (ARBABSIAR) would have to "send a hundred .

. ten thousand, ten thousand, ten thousand. . I d o n ' t wanna sendit to one guy, one s h o t . " I unders tand ARBABSIAR to mean t h a t hehad $100,000 i n I ran to pay CS-1 as a f i r s t payment toward the

as sas s ina t ion of the Ambassador, but t h a t ARBABSIAR wanted to

send th e money to CS-1 in ins ta l lments and no t in a s ingle

t r a n s fe r .

c . During t h e i r Ju ly 14 meet ing , CS-1 askedARBABSIAR about ARBABSIAR's cous in, who, accord ing to ARBABSIAR,

was loca ted i n I ran and had reques ted t h a t ARBABSIAR f ind someone

(u l t imate ly , CS-1) who could car ry out the a t t a ck on th e

Ambassador descr ibed above. ARBABSIAR exp la ined t ha t h is cous inwas "wanted in America," had been "on the CNN," and was a "big

genera l in [the] army." ARBABSIAR fu r ther exp la ined t h a t the re

were a number of p a r t s to the army of I ran and t ha t h is cous in"work[s] in out s ide , in other coun t r i es fo r the I ranian

government [ . ] " ARBABSIAR fu r ther exp la ined t h a t h is cous in d id

no t wear a uniform or carry a gun, and had taken cer t a in

unspec i f i ed ac t ions re l a t ed to a bombing in I raq . Compare supra17. In t he por t ions of th e July 14 meet ing re fe renced in t h i s

sub-paragraph, I unders tand ARBABSIAR to be saying t h a t h is

cous in works fo r the mil i t a ry of I ran , in pa r t i c u l a r , fo r th e

Qods Force, and t h a t h is cous in focuses on mat te rs ou t s ide of

I ran .

d.At the end of the Ju ly 14

meet ing ,CS-1 to ld

ARBABSIAR, " [w]e ' r e gonna s t a r t doing the guy," which I

a number of othe r t a rg e t s . These t a rg e t s inc luded foreign

government f a c i l i t i e s assoc ia ted with Saudi Arabia and withanother count ry , and these t a rge t s were loca ted within andouts ide o f th e United Sta tes .

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understand to mean t h a t CS-1 and ARBABSIAR conf irmed t h a t CS-1

would proceed to plan the assa ss ina t ion of the Ambassador.

23. On or about Ju ly 17, 2011, MANSSOR ARBABSIAR,

a /k /a "Mansour Arbabsia r , " th e defendant , met with C S - 1 - again,see supra 22, in Mexico. At the d i rec t ion o f law-enforcementagen ts , CS-1 recorded the meeting . CS-1 and ARBABSIAR spoke

Engl ish during th e meeting . Based on my review of d r a f t

t r a n sc r i p t s of the Ju ly 17 meeting , I l ea rned t h a t a t t h i s

meeting th e fol lowing occurred, among othe r th ings :

a. CS-1 made re fe rence to "my guy over the re .

. h e ' s a l ready in Washington," which I unders tand to be a

re fe rence to th e f ac t that . one of CS-1 's workers had purportedly

a l ready t r ave led to Washington, D.C. to s u r v e i l the Ambassador.

CS-1 then asked , " I go t t h i s on th e computer .· . i s t h i s the

guy r i g h t h e r e ? " - to which ARBABSIAR r ep l ied , "Yeah, t h a t ' s

him." Based, among othe r th ings , on my discuss ions with other

agen ts , I unders tand t h a t during t h i s por t ion of the

conversa t ion , CS-1 showed ARBABSIAR a photograph of th e

Ambassador.

b. CS-1 descr ibed what he had purpor ted ly begun

to l e a rn about the Ambassador, s t a t i n g t h a t th e Ambassador has

"e igh t to seven secur i ty people around him . [h]e goes outand ea t l i ke two t imes a week in a r e s t au r an t . [m]y guy i s

a l ready over t he re . doing s u r v e i l l an ce . " CS-1 thenr e f l e c t ed , " I d o n ' t know what exac t ly your co"usin [see supra

22(c) 7] wants me to do. " After some fu r ther conversa t ion ,

ARBABSIAR r ep l ied : " [h ]e wants you to k i l l t h i s guy." CS-1 thenexp la ined , " t h e r e ' s gonna be l i ke American people t he re . in

th e r e s t au r an t . You want me to do it outs ide or in th e

re s t au ran t? " ARBABSIAR answered: " [d ]o e sn ' t mat te r how you do

it. I mean, if you do it by himsel f , k i l l i s be t t e r , but .

sometime, you know, you have no choice , i s t h a t r igh t?" I

unders tand ARBABSIAR and CS-1 to have been discuss ing how the

Ambassador should be k i l l ed , and ARBABSIAR to be saying t h a t h is

cousin wanted th e Ambassador k i l l ed ; withou t bys tander casua l t i e s

if poss ib le ("by himself , k i l l i s be t te r " ) bu t not if o p e ra t i o n a l

necess i t i e s d ic t a t ed otherwise ("sometime, you know, you have no

7 During th e course of the July 17 conversa t ion , ARBABSIAR

fu r the r descr ibed h is cousin . ARBABSIAR sa id t h a t h is cousin was

"working fo r [ the] government [o f Iran] but h e ' s working outs ide .

. . He's working l i ke . [ l ] ike [a named, non-Iranian

i n t e l l igence agency] ."

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choice") . 8

c . On a number o f occas ions , ARBABSIAR re

assured CS-1 t h a t CS-1 and h is (CS-1 's) men would indeed be paid

fo r k i l l ing th e Ambassador. ARBABSIAR t o ld CS-1 to t e l l th e

people working fo r him (CS-1) t h a t he (ARBABSIAR) could

"guarantee the money

...I [ARBABSIAR] got the money coming."

ARBABSIAR emphasized t h a t " th i s i s po l i t i c s , ok ... it's notl i ke , eh, persona l . . . This i s po l i t i c s , so these people[ARBABSIAR's co-conspi ra tors in Iran] they pay t h i s

government ... he ' s got [ARBABSIAR's cousin has got] the , gotthe government behind him . . . . . he ' s n ot paying from h is

pocket . " To f a c i l i t a t e payment, a t one p o i n t dur ing the July 17

meeting , CS-1 gave ARBABSIAR " the account number ... in [a U.S.

bank] ... and th e U.S. rou t ing number" -the unique number

assoc ia ted with th e United Sta te s bank account in to which

ARBABSIAR could arrange fo r payment to be made to CS-1 for the

as sas s ina t ion of th e Ambassador.

d. ARBABSIAR exp la ined t h a t h is cousin and an

indiv idua l who worked fo r h is cousin had paid h is (ARBABSIAR's)

expenses re l a t ed to the assa ss ina t ion p l o t . ARBABSIAR s t a t ed , " I

t e l l him [ARBABSIAR's cousin] , give me j u s t ano ther f i f t e e n .

Jus t ... nex t morning they send one guy, you know, t h a t work

fo r him [ARBABSIAR's cousin ] . He's l i ke a colonel , the guy."CS-1 asked, "Did th e co lonel take the money, the money to you?"

ARBABSIAR responded, "Yes, man. He opened th e door fo r me, th e

colonel , he br ing the envelope. He p ut the envelope the re fo r

me." Based on my t r a in in g , experience and p a r t i c i p a t i o n in t h i s

inves t iga t ion , inc lud ing my p a r t i c i p a t i o n in the p o s t - a r r e s t

in te rv iew of ARBABSIAR, I understand t ha t the "co lone l" t h a t

ARBABSIAR r e fe r red to i s GHOLAM SHAKURI, a /k / a "Al i Gholam

Shakuri ," th e defendant , and t h a t ARBABSIAR was s t a t i ng t h a t

a f t e r he rece ived expense money from h is cousin , he rece ived an

add i t iona l expense payment from SHAKURI, see· i n f r a n.13.

e . At the end of the Ju ly 17 meet ing, ARBABSIAR

8 On numerous occasions during the Ju ly 17 meet ing,

ARBABSIAR made it c l e a r t h a t th e as sas s ina t ion needed to go

forward, evenif

doing so would cause mass c a su a l t i e s . Forexample, ARBABSIAR sa id : "They want t h a t guy [ the Ambassador]

done [k i l l e d ] , if th e hundred go with him, fuck ' em." In a

s imi l a r vein , ARBABSIAR and CS-1 a lso discussed the means by

which the Ambassador would be k i l l ed . CS-1 s.aid: "I 'm gonna blow

him [ the Ambassador] up or shoot him, whatever you want ."

ARBABSIAR responded: "Yeah, it doesn ' t mat te r [w]hatever i s

easy fo r ... how i s poss ib le fo r you."

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declared " [ l ) e t it h i t the r es tau ran t . I f , if you can do it

outs ide , do it. I f not , r es tau ran t , h i t it, it's ok ," by which I

unders tand ARBABSIAR to mean t h a t if CS-1 could not assa ss ina te

the Ambassador outs ide the r es tau ran t , he should " h i t " or bomb

th e r e s t au r an t . In response , CS-1 then noted t ha t t he re were"from a hundred, a hundred and f i f t y [people th e r es tau ran t ) "

and "bui ld ings on the s ides , " and "sena tors [U.S. Senators who

dine t he r e ) , " a l l of which ARBABSIAR dismissed as "no problem" or"no big dea l , " meaning t h a t th e p o t e n t i a l fo r such cas u a l t i e s

should not d issuade CS-1 from k i l l i n g th e Ambassador.

C. JULY AND AUGUST 2011:

PAYMENTS ARE MADE TO CS-1

24. According to t r a v e l records , MANSSOR ARBABSIAR,

a /k /a "Mansour Arbabs ia i , " th e defendant , t r ave led from Mexico,

depar t ing fo r a foreign count ry , on or about Ju ly 20, 2011. 9

25. As noted above, see supra 23, a t th e July 17

meet ing , CS-1 provided MANSSOR ARBABSIAR, a /k /a "Mansour

Arbabsia r , " the defendant , wi th a bank account and rou t ing

number, so t h a t payment could be made fo r th e as sas s ina t ion of

the Ambassador. The account in fo rmat ion cs-1· provided was in

f ac t assoc ia t ed with the UC Bank Account .

26. On or about August 1, 2011, an overseas wiret r a n s fe r of approximately $49,960 was sen t by a fo re ign e n t i t y

("Foreign Ent i ty -1") from a bank loca ted in a fo re ign country( the "Foreign Bank") through a bank in Manhattan to th e UC Bank

Account .

27. On or about August 6, 2011, MANSSOR ARBABSIAR,

a /k /a "Mansour Arbabsia r , " the defendant , spoke with CS-1 on the

t e lephone . CS-1 recorded th e conversa t ion . Based on my reviewof d r a f t t r a ns c r ip t s of the recorded conversa t ion , I know tha t .

during the c a l l , CS-1 asked ARBABSIAR whether he (ARBABSIAR) had"a l ready f in i shed the o t h e r ha l f of . . the money." ARBABSIAR

rep l i ed , " I sen t it yes te rday." I unders tand t h a t ARBABSIAR was

acknowledging t h a t th e prev ious day he sent to CS-1 the secondh a l f of the approximately $100,000 down-payme.nt, see supra22(b) , fo r th e murder of th e Ambassador. I unders tand t h a t " the

o t h e r ha l f " of the $100,000 was received on o r about August 9,

9 Three days p r i o r to ARBABSIAR's Ju ly 20 f l i g h t , during

the Ju ly 17 meeting with CS-1, see supra , ARBABSIAR indica ted to

CS-1 t ha t ARBABSIAR would be t r av e l i n g t o Ira·n on Ju ly 20 to seeh is cous in .

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2011, see i n f ra 28, and t ha t the f i r s t "ha l f " was rece ived on

o r about August 1, 2011, see supra 26.

28. On o r about August 9, 2011, an overseas wiret r a n s fe r o f approximately $49,960 was sen t by another fore ign

e n t i t y ("Foreign Ent i ty-2") from the Foreign Bank through a bankin Manhattan to the UC Bank Account .

29. On o r about August 11, 2011, MANSSOR ARBABSIAR,a /k / a "Mansour Arbabsia r , " the defendant , spoke with CS-1 on the

te lephone . CS-1 recorded the conversa t ion . Based on my reviewo f d r a f t t r a ns c r ip t s o f th e recorded conversa t ion , I know t h a t

dur ing the ca l l , ARBABSIAR asked CS-1, "Did you check th e bank?"CS-1 responded in th e af f i rmat ive , " I check in th e bank,everything i s t h e re . " I unders tand t h a t ARBABSIAR was conf i rmingt h a t CS-1 received the $49,960 t ha t a r r ived in th e UC Bank

Account on or about August 9, 2011, see supra 28.

D. SEPTEMBER 2011:

ARBABSIAR RETURNS TO MEXICO

30. On o r about September 2, 2011, MANSSOR ARBABSIAR,a /k /a "Mansour Arbabs i a r , " t he defendant , spoke with CS-1 on the

t e l ephone . CS-1 recorded the conversa t ion . .Based on my reviewo f d r a f t t r a ns c r ip t s of the recorded conversa t ion , I know t h a t

during th e ca l l , ARBABSIAR asked CS-1 if the "bui ld ing i s ge t t ing

pa i n t ed" and CS-1 responded "we ' re still doing t h a t . " Iunders tand t h a t by asking t ha t ques t ion , ARBABSIAR was askingCS-1 whether th e arrangements to k i l l the Ambassador were still

underway.

10

ARBABSIAR then s t a t ed , "once we do t h i s one, yougonna open a [U/I] l i k e , uh . . you got the number fo r the

sa fe" and " [o ]nce you' open th e door, t h a t ' s it. You know what Imean? . . [y ] ou d o n ' t have to worry about a·nything." Iunders tand t h a t ARBABSIAR was expla in ing to CS-1 t h a t a f t e r CS-1

and h is team assa ss ina t ed th e Ambassador, CS-1 would make money

from t ha t and o the r p r o j ec t s with ARBABSIAR and h is as soc ia tes ,

see supra n .6 .

31. On o r about September 12, 2011, MANSSOR ARBABSIAR,a /k / a "Mansour Arbabsia r , " the defendant , spoke with CS-1 on the

10 Based on my t ra in ing and in my exper ience , i nd iv idua l s

who speak e xp l i c i t l y about c r i mi na l a c t iv i t y during in-person

meet ings , see , supra 22, 23, of ten speak in codedlanguage during t e lephone conversa t ions , in an e f f o r t to concea lth e subjec t mat te r o f t he i r di scuss i ons in the event t h a t theyare overheard or in te rcep ted .

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t e lephone . CS-1 recorded th e te lephone c o n v ~ r s a t i o n . Based on

my review of a d r a f t t r a ns c r ip t of th e recording, I l ea rned t ha t

ARBABSIAR t o ld CS-1 t h a t " the number i s gonna s t ay the same th ing

[o]ne and a h a l f . " I unders tand ARBABSIAR was s t a t ing

t h a t CS-1 would rece ive the same amount of money (" [o ]ne and a

ha l f " : $1.5 mil l ion) fo r th e assa ss ina t ion t h a t ARBABSIAR and CS-

1 had previous ly d i scussed. See s u p r a ~ 22(a) . ARBABSIAR a l so

r e fe r red to " the number we did" and to ld CS-1 t h a t he could"prepare fo r those too . . but we need to a t l e a s t one of

them." I unders tand ARBABSIAR to have been informing CS-1 t h a t

in th e fu ture CS-1 could prepare for the add i t iona l a t t acks

previous ly mentioned, see supra n.6 , but t h a t CS-1 f i r s t neededto as sas s ina te th e Ambassador. ARBABSIAR promised CS-1 t h a t i fhe does " a t l e a s t one . . I'll send th e balance fo r you," whichI unders tand to mean t h a t CS-1 would rece ive the remainder of h is

$1.5 mil l ion payment a f t e r th e Ambassador has been assa ss ina t ed .

ARBABSIAR a l so s t a t ed , " [ t ]h e f i r s t one they j u s t want it ...fo r t e s t , " which I unders tand to mean t h a t C ~ - 1 ' s f i r s t t a sk was

des igned as a t e s t run, with fu ture ass ignments to fol low if the

as sas s ina t ion was success fu l .

32. On or about September 20, 2011, MANSSOR ARBABSIAR,

a /k /a "Mansour Arbabs ia r , " th e defendant , spoke with CS-1 on thet e lephone . CS-1 recorded the te lephone conversa t ion . Based on

my review of a dra f t t r a ns c r ip t of th e recording, I l ea rned t ha t

CS-1 to ld ARBABSIAR, "I 'm ready fo r th e . .· for the th ing, fo r

th e house, man, to be pa in ted bu t . . I need to , I need, e i t h e r

I need you or I need h a l f of the . . of th e check t h a t we' re

gonna rece ive to . . so I can go ahead and . . be f in i shed

with the job ." I unders tand CS-1 to have been reques t ing t h a t

ARBABSIAR e i t h e r pay one-ha l f of th e agreed upon pr ice ($1.5mil l ion , see s u p r a ~ 22(a)) fo r the murder of the Ambassador orgo persona l ly to Mexico to serve h imsel f as c o l l a t e r a l fo r th e

f i n a l payment of th e fee fo r the assass inat io_n. 11 Based on my

t ra in ing and exper ience , I know t h a t t h i s form of persona l

guarantee i s common fo r l a rge sca le illicit t r an s ac t i o n s .

Ult imately, based on my review of th e t r a ns c r ip t of the September

20, 2011 c a l l , I be l i eve t h a t ARBABSIAR agreed to t r a v e l to

Mexico per CS-1's r eques t to guarantee payment fo r th e murder ofthe Ambassador ("I 'm gonna go over t he re [in] two [or] three

days, I'll go over the re . Don't wai t fo r me . Get ready,

bu tI'll

be overt h e r e . " ) . Later

duringth e n igh t of

September20, CS-1 re turned a c a l l from ARBABSIAR. At th e d i r ec t i o n of

law-enforcement agent s , CS-1 recorded th e t e lephone conversa t ion .

11 CS-1 i n i t i a l l y requested t ha t ARBABSIAR send someone to

Mexico as c o l l a t e r a l in a recorded c a l l between CS-1 andARBABSIAR on or about August 28, 2011.

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During the c a l l , ARBABSIAR inqui red as to "how long [he) need[s)to s tay in Mexico.n I unders tand ARBABSIAR to have been askinghow long he would have to s tay in Mexico to supply a s u f f i c i en t

guarantee fo r payment to CS-1 and CS-1's assoc ia te s fol lowingcomplet ion of the p l o t to murder th e Ambassador.

E. THE ARREST AND SEARCH

33. On or about September 28, 2011, MANSSOR ARBABSIAR,

a /k / a "Mansour Arbabs ia r ,n the defendant , flew to Mexico.

ARBABSIAR was denied en t ry in to Mexico, and then flew on to JohnF. Kennedy In t e rna t iona l Airpor t ("JFKn), in New York City .

During the f l i g h t , law-enforcement o f f i c i a l s aboard conductedsurvei l lance of the defendant wi thout a l e r t i ng him to t h e i r

presence . Afte r ARBABSIAR exi ted th e plane a t JFK, lawenforcement agents a r res ted ARBABSIAR.

34. Afte r he was p laced under a r re s t , law-enforcementagents recovered numerous i t ems from MANSSOR ARBABSIAR, a /k /a

"Mansour Arbabs ia r ,n the defendant , and from h is luggage. (The

luggage was searched pursuan t to a warrant i s sued by a UnitedSta tes Magis t ra te Judge.) These i t ems inc luded , among o ther

th ings : approximately $3,900 in United Sta tes cur rency , composed

of one-hundred do l l a r b i l l s ; a sum of I r an i an cur rency ; anI r an i an passpor t ; a United Sta tes passpor t ; and a t r ave l

i t i ne r a r y r e f l ec t i ng a f l i gh t depar t ing Mexico during October of

2011, with an ul t imate des t ina t ion of Tehran, I ran .

IV. ARBABSIAR'S CONFESSION

35. Severa l hours a f t e r h is a r re s t , MANSSOR ARBABSIAR,

a /k / a "Mansour Arbabs ia r ,n the defendant , was advised of h is

Miranda r igh t s and h is r i gh t to a speedy presentment . ARBABSIAR

agreed to waive those r igh t s and to speak with law-enforcementagents . As s e t for th more fu l ly below in the paragraphs t ha t

fol low, dur ing a s e r i e s of Mirandized in terv iews , ARBABSIAR

confessed to h is pa r t i c i pa t i on in the p l o t descr ibed above. 12 Inpa r t i cu l a r , and as descr ibed more fu l l y below, ARBABSIAR admit tedt h a t he had ar ranged fo r CS-1 to murder the Ambassador; t ha t he

12 The i n t e rv iews were conducted pr i nc i pa l l y in Engl i sh .Occas iona l ly , ARBABSIAR spoke in Fa r s i . One of t he lawenforcement agen ts who conducted the in te rv iews i s f luent in

Far s i . A smal l por t ion of the substance of ARBABSIAR's o r a l

s ta temen t i s descr ibed in the i n s t a n t Complaint . In addi t ion to

providing an ora l s ta tement , the defendant s igned a typewri t t en

s ta temen t admit t ing to th e conduct t ha t forms the bas i s fo r the

charges here in .

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(ARBABSIAR) had discussed with CS-1 the means by which CS-1 andh is cr imina l assoc ia t e s would commit the murder; and t h a t he

(ARBABSIAR) made a down-payment to CS-1 fo r the murder by caus inga t o t a l o f $100,000 to be depos i ted in th e UC Bank Account .Furthermore, ARBABSIAR admit ted t ha t in connect ion with t h i s

p lo t , he (ARBABSIAR) was r ec ru i ted , funded, and d i rec ted by men

he unders tood to be sen io r of f i c i a l s in th e Qods Force, see supra! 17. ARBABSIAR fu r the r explained t h a t men he unders tood to besenior Qods Force o f f i c i a l s were aware of and approved, among

ot he r t h ings , th e use o f CS-1 in connect ion with th e p lo t ;

payments to CS-1; and the means by which th e Ambassador would be

k i l l ed in th e United Sta t e s and th e cas u a l t i e s t ha t would l i ke ly

r e s u l t .

36. MANSSOR ARBABSIAR, a /k /a "Mansour Arbabs i a r , " th e

defendant , exp la ined t ha t h is cous in, see supra , approachedARBABSIAR in th e ear ly spr ing of 2011, while ARBABSIAR was in

I r an , and asked ARBABSIAR to work with him (ARBABSIAR's cousin) .

ARBABSIAR had long unders tood t ha t h is cous in (he re inaf te r

" I ran ian O ff i c i a l #1") , was a high-ranking member of the Qods

Force . ARBABSIAR to ld I ran ian O ff i c i a l #1 t h a t as a r e s u l t ofh is business in both Mexico and th e United S ta t e s , he (ARBABSIAR)

knew a number of people who t r ave led between th e two count r ies ,

and some o f those people , he (ARBABSIAR) be l i eved , were na rco t i c s

t r a f f i c ke r s . I ranian O ff i c i a l #1 to ld ARBABSIAR t ha t he wantedARBABSIAR to h i r e someone who could kidnap th e Saudi ArabianAmbassador to th e United Sta t e s and t h a t ARBABSIAR should f ind

someone in the na rco t i c s bus i ness , because people in t h a t

business a re w i l l i ng to undertake cr imina l ac t i v i t y in exchangefo r money.

37. MANSSOR ARBABSIAR, a /k / a "Mansour Arbabs i a r , " th e

defendant , fu r the r acknowledged t ha t I ran ian O ff i c i a l #1

subsequent ly provided ARBABSIAR with thousands o f d o l l a r s fo r

expenses . 13 ARBABSIAR t h e re a f t e r t r ave led to Mexico, where he

met CS-1. 14

13 In the course of h is discuss ions with I ran ian O ff i c i a l

#1, I ranian O ff i c i a l #1 i nd ica t ed t h a t ano ther i nd iv idua l , GHOLAM

SHAKURI, a /k /a "Al i Gholarn Shakur i , " the defendant , worked fo rhim ( tha t i s , fo r I ranian O ff i c i a l #1) as h is ( I ranian O f f i c i a l

#1 's) deputy . Af t e r I ran ian O f f i c i a l #1 provided ARBABSIAR withthousands of d o l l a r s fo r expenses , SHAKURI separa te ly providedARBABSIAR with thousands of do l la r s fo r expenses .

14 During the course of h is in te rv iews, ARBABSIAR expla inedhow he carne to meet CS-1.

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38. MANSSOR ARBABSIAR, a /k /a "Mansour Arbabsia r , " th e

defendant , admit ted t h a t , while he was in Mexico, he (ARBABSIAR)

and CS-1 discussed , among other th ings , a plan to k i l l the

Ambassador by bombing a re s t au ran t the Ambassador f requented, fo r

which CS 1 sa id he would charge $1.5 mil l ion . ARBABSIAR thenre tu rned to I ran from Mexico.

39. MANSSOR ARBABSIAR, a /k /a "Mansour Arbabsia r , " thedefendant , s t a t ed t h a t upon hi s re tu rn to I ran , he (ARBABSIAR)

met toge ther on a number of occas ions in Tehran with GHOLAM

SHAKURI, a /k /a "Al i Gholam Shakuri ," the defendan t , and a t h i rd

i nd iv idua l , who ARBABSIAR unders tood was a high-ranking member ofthe Qods Force (here inaf te r "Iranian O ff i c i a l #2") . 15 ARBABSIAR

s t a t ed he a l so met rou t ine ly on a one-on-one bas i s with SHAKURI.

During these meet ings , th e fol lowing occurred, among o t h e r

th ings :

a . ARBABSIAR indica ted t h a t he (ARBABSIAR) had

loca ted a drug dea le r in Mexico ( refer r ing to CS-1) . ARBABSIARwas asked to have CS-1 kidnap or k i l l the Ambassador of SaudiArabia to the Uni ted Sta tes , and t o ld t h a t it would need to bedone f a s t . ARBABSIAR was a lso asked whether CS-1 would t r a v e l

in te rna t iona l ly , so t h a t CS-1 could speak f ace- to - face with other

opera t ives . ARBABSIAR indica ted t h a t CS-1 would not do so.

b. ARBABSIAR s t a t ed tha t the p lan was to blow up

a r es tau ran t in th e United Sta tes f requented by th e Ambassadorand t h a t in l i g h t o f t h a t plan numerous people , in addi t ion to

the Ambassador, could be k i l l ed . This plan was approved.

c. ARBABSIAR was in s t ruc ted ·to use code wordswhen communicating with SHAKURI. For example, ARBABSIAR was

in s t ruc ted to use th e code word "Chevrole t " for the Ambassador

p l o t .

d. A down-payment of $100,000 to CS-1 fo r th e

15 ARBABSIAR has been shown an a r ray of seven photographs .Amongst these seven photographs were one photograph of each of

two men known t o the United Sta tes to be sen io r members of the

Qods Force . I t i s bel ieved t h a t these tw o photographs are notpubl i c ly av a i l ab l e . ARBABSIAR i d e n t i f i e d one of these

photographs as depic t ing I ranian O ff i c i a l #2. The persondepicted in the photograph t h a t ARBABSIAR i de n t i f i e d i s known to

the United Sta tes to have used the a l i a s by which ARBABSIAR knew

I ranian O ff i c i a l #2.

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murder of the Ambassador was approved. 16

e . SHAKURI advised ARBABSIAR t ha t an ind iv idua l

whom ARBABSIAR understood to be the l eader of the Qods Force

(he re ina f t e r " I ran ian Off ic i a l #3") , was aware o f what ARBABSIAR

was doing and t h a t he (ARBABSIAR) could meet with I ran ian

Off ic i a l #3 in th e fu tu re .

40. In or about l a t e September 2011, MANSSOR

ARBABSIAR, a /k / a "Mansour Arbabsiar ," the defendan t , met withGHOLAM SHAKURI, a /k /a "Al i Gholam Shakuri ," the defendant , in

Tehran. ARBABSIAR exp la ined t h a t CS-1 wanted e i t h e r to receive

h a l f of the money prev ious ly promised fo r the complet ion o f th e

murder, o r to have ARBABSIAR t r av e l babk to Mexico as a guarantee

of payment, see supra <J[ 32. SHAKURI s t a t ed t ha t no more money

would be given t o CS-.1 , .. and_ advised ARBABSIAR aga ins t t r ave l ing

back to Mexico. SHAKURI sa id t h a t ARBABSIAR was responsib le fo r

himsel f if he did t r a v e l . SHAKURI then t o ld ARBABSIAR to get in

co n t ac t with him (SHAKURI) v ia te lephone a f t e r ARBABSIAR'Sa r r iva l in Mexico so t h a t he (SHAKURI) could be sure ARBABSIAR

was wel l .

OCTOBER 2011: RECORDED TELEPHONE CALLS

BETWEEN SHAKURI AND ARBABSIAR

41. Following th e a r r e s t o f MANSSOR ARBABSIAR, a /k /a

"Mansour Arbabsia r , " the defendant , ARBABSIAR agreed to place a

recorded c a l l to GHOLAM SHAKURI, a /k /a "Al i Gholam Shakur i , " the

defendant . On October 4, 2011, a t the d i r ec t i o n of federa l law

enforcement agen t s , ARBABSIAR placed a c a l l to an I ranian

te lephone number (" I ranian Phone Number"). Agents monitored and

recorded the c a l l . 17 Following the ca l l , .ARBABSIAR indica ted

t ha t th e person he was speaking with was SHAKURI. Based on my

review of the d ra f t t r a n s l a t i o n of t h a t recording I know t h a t

SHAKURI asked, " [a ] r e you ok, ... are you wel l?" to which

ARBABSIAR responded, "Yes, I wanted to see how you ' re doing and

to t e l l you I am w el l . " SHAKURI responded, "Okay, thank God,

s tay wel l . " SHAKURI then added, " I was wai t ing , " and asked,

16 Subsequent ly , Ind iv idua l #1 t o ld ARBABSIAR t h a t he

( Individual #1) had rece ived a del ivery of money from SHAKURI.

ARBABSIAR then arranged fo r t h i s money to be sen t from Tehran to

th e United S ta t e s .

17 On t h i s c a l l and the c a l l s re fe renced in paragraphs 42

and 43, ARBABSIAR and SHAKURI spoke in Fars i . I have reviewed

d ra f t t r a n s l a t i o n s of these three ca l l s .

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"what news . . what d id you do about the bti i lding?" Based on myt r a in ing , exper ience and par t i c ipa t ion in t h i s i nves t iga t ion , I

unders tand the quest ion about "the bui ld ing" to be a reference to

the plo t to murder the Ambassador and a quest ion about i t s

s ta tus . supra 30.

42. On October 5, 2011, MANSSOR ARBABSIAR, a /k/a"Mansour Arbabs i a r , " the defendant , placed another monitored and

recorded c a l l to the I ran ian Phone Number. Following the ca l l ,

ARBABSIAR indica ted t ha t the person he was speaking with was

GHOLAM SHAKURI, a /k /a "Ali Gholam Shakur i , " the defendant . Based

on my review of a draf t t r ans la t ion of the recorded conversa t ion,I know t ha t dur ing the ca l l , the fol lowing occurred, among other

th ings :

a . ARBABSIAR s t a t ed , " I wanted to te]_l you, t h ~ - _

Chevrolet i s ready, it's ready, uh, to be done. I shouldcontinue , r igh t?" See supra 39 (c) (not ing ' t ha t "Chevrolet" was

the agreed-upon code for the plo t to murder the Ambassador) .SHAKURI responded, "Yes. Yes, yes ." SHAKURI l a t e r asked, "You

mean you are buying a l l of i t ? " ARBABSIAR responded, " I don ' t

know fo r now, it's ready, okay?" SHAKURI rep l i ed , "So buy it,

buy it." ARBABSIAR confirmed, "Buy i t ? Okay." SHAKURI thens t a t ed , "Buy it, yes, buy a l l of it." Based on my t r a in ing ,

exper ience and par t i c ipa t ion in t h i s i nves t iga t ion , I unders tandt ha t SHAKURI confirmed by these s ta tements t ha t ARBABSIAR should

move forward with the p l o t to murder the Ambassador.

b. ARBABSIAR then s t a t ed t ha t " t h i s boy wants ,

uh, some money, he wants some expendi ture . What do you say,

should we give him some more? He wants another 50," and SHAKURIresponded, "With you, no, you . t h a t amount i s f ine , [UI]

brought me another car . Tel l him to f in i sh h is work, then we ' l l

give him the r e s t . He should buy the car for us f i r s t . " Based

on my t r a i n ing , exper ience and pa r t i c ipa t i on i n t h i s

i nves t iga t ion , I unders tand t ha t on t h i s ca l l , SHAKURI was

i n s i s t ing t h a t CS-1 should not receive any addi t ibna l money un t i l

he had k i l l ed the Ambassador.

c . Thereaf ter , SHAKURI urged ARBABSIAR " [ j ]u s t

do it quickly , it's l a t e , j u s t buy it fo r me and br ing it

a l r eady ." I understand t ha t SHAKURI i s urging ARBABSIAR to

accomplish the agreed upon task - the murder .o f the Ambassador -as quickly as poss ib le .

43. On October 7, 2011, MANSSOR

"Mansour Arbabsiar ," the defendant , placed

recorded c a l l to the I ran ian Phone Number.

ARBABSIAR indica ted t ha t the person he was

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ARBABSIAR, a /k/a

another monitored and

Following the ca l l ,

speaking with was



GHOLAM SHAKURI, a /k /a ~ A l i Gholam Shakuri ," the defendant . Based

on my review of a d ra f t t r ans la t ion of the r ~ c o r d e d conversat ion ,

I know t ha t dur ing the ca l l , the fol lowing occurred, among other

th ings :

a. ARBABSIAR s t a t ed , ... t h i s Mexican,

. keeps on i n s i s t i ng on the th ing . He says , 'If - I needmoney, 50. I won' t do the job if you don ' t pay . ' And

every th ing ' s ready." SHAKURI responded, ~ o k a y . " ARBABSIARasked, ~ w h a t do you say now?" SHAKURI r ep l ied , don ' t know.

You guaranteed t h i s yourse l f . . . of course , if we give it,

w e ' l l give it to you. Okay? I f he gives i t , f ine; if not wemust provide the 100 [or] 50. Tel l him, [U/I] ." ARBABSIAR thens t a t ed , ~ w e l l , yeah. Now, I - what do you say? What should I

do? [U/I]" SHAKURI r e s p o n d e ~ , "How much i s he t a lk ing about?"ARBABSIAR sa id , ~ · I d o n ' t know. He's saying, f o r i n s t a nc e , Wf.=:}.]_

- - - - - ~ n o w - = - ne .s-ays w-ell - so, ::t ThOught, so t ha t the Ioo we--gave won' t

go to waste ; t h a t ' s why. On the othe r hand, we gave a 100 and

t ha t would go to waste as wel l . " See supra 26-28 (noting t h a tCS-1 was paid $100,000 as a down-payment fo r ki l l ing th e

Ambassador). SHAKURI r ep l ied , ~ w e l l , yeah, but what if you givet h i s one it goes to waste as well?" Based on my par t ic ipa t ion in

t h i s i nves t iga t ion , I unders tand t ha t SHAKURI was quest ioning

whether add i t iona l payments should be made to CS-1 ( ~ t h i s Mexican") , in l i g h t of the f ac t t ha t CS-1 had not yet ki l led theAmbassador, and had already been paid $100,000 ( ~ 1 0 0 " ) .

b. Short ly t he r e a f t e r ARBABSIAR s t a t ed ,

r e f e r r i n g to CS 1, ~ T h a t ' s what the Mexican ... wants .

What can I do?" and SHAKURI responded, ~ o k a y , today I'll discuss

it to see what they say ." Based on my exper ience andpa r t i c ipa t ion in th i s inves t iga t ion , I unders tand t ha t SHAKURI i s

expla in ing t ha t he would consul t with h is super iors regardingwhether they would be wil l ing to pay CS-1 add i t iona l money.

c. Thereaf te r , SHAKURI s t a t ~ d , ~ Y o u sa id t h a t

fo r sure they ' re saying t ha t much. We d i d n ' t discuss it though,we - in any case, he needs to d e l iv e r it to us, okay?" to which

ARBABSIAR responded, ~ c o m p l e t e l y . Yeah, yeah, I know what you ' re

saying." SHAKURI then sa id : ~ Y o u guaranteed i t " and ARBABSIAR

responded, ~ w e l l , I guaranteed it, but they ... t hey ' re notord inary people ... t hey ' re not law abiding ... people ." See

supra 32, 33 (CS-1 asked ARBABSIAR to t r a ve l persona l ly toMexico as a guarantee t h a t CS-1 would be paid in f u l l upon th e

k i l l i ng of the Ambassador; ARBABSIAR the reaf t ·e r t r ave led to

Mexico). Based on my t ra in ing , exper ience and par t ic ipa t ion in

th i s i nves t iga t ion , I unders tand t ha t SHAKURI was remindingARBABSIAR t ha t he (ARBABSIAR) t r ave led to Mexico to serve as apersonal guarantee of f u l l payment to CS-1 upon th e k i l l i ng of

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th e Ambassador.

d. SHAKURI then s ta ted : "You sa id it yourse l f ,

they - from our poin t o f view o f - when we ge t our merchandise ,

we g e t our merchandise." SHAKURI added, "We have guaran teed the

r e s t . You were our guarantee ." Based on my t r a i n i n g , exper ience

and p a r t i c i p a t i o n in t h i s inves t iga t ion , I unders tand t h a tSHAKURI was s t a t i n g t h a t "we", meaning himsel f and othe rs

involved in th e p lo t , had "guaranteed" f u l l payment to CS-1 fo r

th e k i l l i ng of th e Ambassador by ARBABSIAR's presence in Mexico

("You were our guaran tee") . See supra CJICJI 32, 33.

WHEREFORE, deponent r espec t fu l ly reques t s t ha t MANSSOR

ARBABSIAR, a /k / a "Mansour Arbabs ia r , " the defendan t , be

imprisoned, or ba i l ed , as th e case may be, and t h a t a warran ti s sue fo r th e a r r e s t o f GHOLAM SHAKURI, a /k /a "Al i Gholam

- ~ - s n a R : u r i ; - " - : C : f i e c f e f e n d a i i t ~ - - a n c t - F h a E ~ h e - be ar res ted and imprisone-d, - ·-

o r ba i l ed , as th e case may be.

0. Robert Woloszyn

Specia l Agent

Federa l Bureau o f Inves t iga t ion

Sworn to before me t h i s

11th· d a ~ c t o b e r , 2 011

. / LZ : - . - -H O N O R A ~ L E MICHAEL H. DOLINGER

UNITED STATES MAGISTRATE JUDGE

SOUTHERN DISTRICT OF NEW YORK

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iran terror complaint

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