COUNT TWO
(Conspiracy to Provide Material Support to a Foreign Terrorist Organization)
3.
From at least in or about 2019, up to and including the date of this Complaint, in an offense begun and committed out of the jurisdiction of any particular State or district of the United States, MOHAMMAD BAQER SAAD DAWOOD AL-SAADI, the defendant, and others known and unknown, at least one of whom is expected to be first brought to and arrested in the Southern District of New York, knowingly and intentionally combined, conspired, confederated, and agreed together and with each other to provide “material support or resources,” as that term is defined in Title 18, United States Code, Section 2339A(b)(1), to a FTO, namely, the Islamic Revolutionary Guard Corps (“IRGC”), which was designated by the U.S. Secretary of State as a foreign terrorist organization on or about April 15, 2019, and is currently designated as such as of the date of the filing of this Complaint.
4. It was a part and an object of the conspiracy that MOHAMMAD BAQER SAAD DAWOOD AL-SAADI, the defendant, and others known and unknown, would and did knowingly provide the IRGC with material support and resources, including property, services, lodging, weapons, personnel, training, facilities, explosives, and transportation, knowing that the IRGC was a designated terrorist organization (as defined in Title 18, United States Code, Section 2339B(g)(6)), that the IRGC s engages and has engaged in terrorist activity (as defined in Section 212(a)(3)(B) of the Immigration and Nationality Act), and that the IRGC engages and has engaged in terrorism (as defined in Section 140(d)(2) of the Foreign Relations Authorization Act, Fiscal Years 1988 and 1989), in violation of Title 18, United States Code, Section 2339B.
(Title 18, United States Code, Sections 2339B(a)(1), (d)(1)(C), (d)(1)(D), (d)(1)(E), and (d)(1)(F), and 3238.)
COUNT THREE
(Conspiracy to Provide Material Support for Acts of Terrorism)
5.
From at least on or about February 28, 2026, up to and including the date of this Complaint, in an offense begun and committed out of the jurisdiction of any particular State or district of the United States, MOHAMMAD BAQER SAAD DAWOOD AL-SAADI, the defendant, and others known and unknown, at least one of whom is expected to be first brought to and arrested in the Southern District of New York, knowingly and intentionally combined, conspired, confederated, and agreed together and with each other to provide “material support or resources,” as that term is defined in Title 18, United States Code, Section 2339A(b)(1), including property, services, lodging, weapons, personnel, training, facilities, explosives, and transportation, knowing and intending that they were to be used in preparation for and in carrying out one or more of the following violations of Title 18, United States Code: (a) attempting and conspiring to murder nationals of the United States, in violation of Title 18, United States Code, Section 2332(b), and (b) bombing and conspiring to bomb a place of public use, in violation of Title 18, United States Code, Section 2332f.
(Title 18, United States Code, Sections 2339A and 3238.)
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