USA v. Farahani, Alireza, et al.
Manhattan, NY

Iran

Farahani is an Iranian intelligence official who resides in Iran. Khazein, Sadeghi, and Noori are Iranian intelligence assets who also reside in Iran. Since at least June 2020, Farahani, and the intelligence network he manages – including Khazein, Sadeghi, and Noori – have plotted to kidnap a U.S. citizen of Iranian origin ("Victim-1") from within the United States in furtherance of the Government of Iran's efforts to silence Victim-1's criticisms of the regime. Victim-1 is a journalist, author, and human rights activist, residing in Brooklyn, New York, who has publicized the Government of Iran's human rights abuses. Prior to the plot to kidnap Victim-1 on U.S. soil, the Government of Iran attempted to lure Victim-1 to a third country in order to capture Victim-1 for rendition to Iran. In approximately 2018, Iranian government officials attempted to induce relatives of Victim-1, who reside in Iran, to invite Victim-1 to travel to a third country for the apparent purpose of having Victim-1 arrested or detained and transported to Iran for imprisonment. Victim-1's relatives did not accept the offer. Iranian intelligence services have previously lured other Iranian dissidents from France and from the United States for the purposes of capturing and imprisoning regime critics and have publicly claimed responsibility for these capture operations. An electronic device used by Farahani contains, among other things, a photo of Victim-1 alongside photos of two other individuals, both of whom were captured by Iranian intelligence, with one later executed and the other imprisoned in Iran, and a caption in Farsi stating, "Gradually the gathering gets bigger... Are you coming, or should we come for you?" On multiple occasions in 2020 and 2021, as part of the plot to kidnap Victim-1, Farahani and his network procured the services of private investigators to surveil, photograph, and video record Victim-1 and Victim-1's household members in Brooklyn. As part of the kidnapping plot, the Farahani-led intelligence network also researched methods of transporting Victim-1 out of the United States for rendition to Iran.

Bahadorifar is originally from Iran and is currently a California resident. Bahadorifar has provided financial and other services from the United States to Iranian residents and entities, including to Khazein, since at least in or about 2015, including access to the U.S. financial system and U.S. financial institutions through the use of card accounts, and has offered to manage business interests in the United States on Khazein's behalf. Among other things, Bahadorifar caused a payment to be made to a private investigator for surveillance of Victim-1 on Khazein's behalf. Bahadorifar is not charged with participating in the kidnapping conspiracy, but is alleged to have provided financial services that supported the plot and is charged with conspiring to violate sanctions against Iran, to commit bank and wire fraud, and to commit money laundering. Bahadorifar is also charged with structuring cash deposits totaling more than approximately $445,000.

Alireza Shavaroghi Farahani, 50, Mahmoud Khazein, 42, Kiya Sadeghi, 35, and Omid Noori, 45, all of Iran, have each been charged with: (1) conspiring to kidnap, which carries a maximum sentence of life in prison (Count One), (2) conspiring to violate the International Emergency Economic Powers Act and sanctions against the Government of Iran, which carries a maximum sentence of 20 years in prison (Count Two), (3) conspiring to commit bank and wire fraud, which carries a maximum sentence of 30 years in prison (Count Three), and (4) conspiring to launder money, which carries a maximum sentence of 20 years in prison (Count Four). Niloufar Bahadorifar, 46, of California, is charged in Counts Two, Three, and Four, and is further charged with structuring (Count Five), which carries a maximum sentence of 10 years in prison.

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