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Farhad Shakeri

Farhad Shakeri, 51, of Iran; Carlisle Rivera, also known as Pop, 49, of Brooklyn, New York; and Jonathon Loadholt, 36, of Staten Island, New York, were charged November 8, 2024 in a criminal complaint in connection with their alleged involvement in a plot to murder a U.S. citizen of Iranian origin in New York. Rivera was arrested in Brooklyn, New York, and Loadholt was arrested in Staten Island, New York, yesterday. Shakeri remains at large and is believed to reside in Iran.

The Government of the Islamic Republic oflran (the "Government oflran") is actively targeting nationals of the United States and its allies living in countries around the world for attacks, including assault, kidnapping, and murder. The Government of Iran, and particularly the IRGC and its external operations force, the IRGC-Qods Force ("IRGC-QF"), 1 has a history of targeting individuals that the Government oflran perceives as enemies, including dissidents living outside Iran and political adversaries. The Government oflran engages in these activities to silence dissidents, and, in the case of political enemies, to seek revenge and sow discord. The regime also seeks to target nationals of the United States in retaliation for the death of Qasem Soleimani, the head of the IRGC-QF who was killed by a U.S. military strike in Baghdad on or about January 3, 2020.

In recent years, the threat posed by the Government of Iran and its intelligence services has evolved. Rather than solely engaging in lethal operations themselves, Iranian intelligence services have outsourced certain assassination plots to organized crime groups and violent criminals. IRGC-QF is the Government of Iran's primary arm for executing its policy of supporting terrorist and insurgent groups. The IRGC-QF provides material, logistical assistance, training and financial support to militants and terrorist operatives throughout the Middle East and South Asia.

FARHAD SHAKERI, the defendant, is an IRGC asset residing in Tehran, Iran. SHAKERI is an Afghan national who immigrated to the United States as a child. In or about 2008, SHAKERI was deported from the United States after serving approximately 14 years in New York State prisons following his 1994 conviction for robbery. SHAKERI has used a network of criminal associates that he met during his time in prison to supply the IRGC with operatives to conduct surveillance and assassinations of IRGC targets (collectively, the "Shakeri Network"). The Shakeri Network of criminal associates includes CARLISLE RIVERA, a/k/a "Pop," the defendant; JONATHAN LOADHOLT, the defendant, who is an associate of RIVERA; an uncharged co-conspirator not named as a defendant ("CC-1 "); and a second uncharged co-conspirator not named as a defendant ("CC-2").

According to SHAKERI, in approximately mid-to-late September 2024, IRGC Official-I asked SHAKERI to put aside his other efforts on behalf of the IRGC and focus on surveilling, and, ultimately, assassinating, former President of the United States, Donald J. Trump ("Victim-4" herein). SHAKERI indicated to IRGC Official-I that this would cost a "huge" amount of money. In response, IRGC Official-I said that "we have already spent a lot of money .. . [s]o the money's not an issue," which SHAKERI understood to mean that the IRGC previously had spent a significant sum of money on efforts to murder Victim-4 and was willing to continue spending a lot of money in its attempt to procure Victim-4's assassination.

According to SHAKERI, during his meeting with IRGC Official-I on or about October 7, 2024, IRGC Official-I directed SHAKERI to provide a plan within seven days to kill Victim-4. If SHAKERI was unable to put forth a plan within that timeframe, IRGC Official-I continued, the IRGC would pause its plan to kill Victim-4 until after the U.S. Presidential elections, because IRGC Official-I assessed that Victim-4 would lose the election and, afterward, it would be easier to assassinate Victim-4. During the interview, SHAKERI claimed to the FBI that he did not intend to propose a plan to murder Victim-4 within the timeframe set by IRGC Official-I.

On behalf of the IRGC, FARHAD SHAKERI, the defendant, and his network have targeted or been instructed to target Victim-1 , an Iranian American journalist, author, and political activist, and an outspoken critic of the Iranian regime's human rights abuses and corruption. Victim-1 has long been a high-priority target of the Iranian regime. In exchange for SHAKERI's promise of a payment of $100,000, CARLISLE RIVERA, a/k/a "Pop," and JONATHAN LOADHOLT, the defendants, repeatedly sought to locate Victim-I in approximately 2024 in order to murder Victim-I. According to statements made by SHAKERI in recorded interviews with law enforcement agents, the IRGC has also tasked SHAKERI with carrying out other assassinations against U.S. and Israeli citizens located in the United States and elsewhere.

For the last several years, the Government oflran has targeted Victim-I. In July 2021 , an indictment returned by a grand jury in the Southern District of New York was unsealed charging an Iranian intelligence officer and three Iranian intelligence assets with kidnapping conspiracy and other offenses based on their participation in a plot on behalf of the Government of Iran to kidnap Victim-I for rendition to Iran. See United States v. Farahani, et al., 21 Cr. 430 (RA) (S.D.N.Y.). After the exposure of the Farahani plot, the IRGC directed another attempt to assassinate Victim-I in New York City by paying members of the Russian mob to monitor and kill Victim-I at Victim-1 's home. See United States v. Amirov, et al. , S8 22 Cr. 438 (CM) (S.D.N.Y.).

From at least in or about December 2023, up to and including the date of the Complaint, in Iran, the Southern District of New York, and elsewhere, and in an offense begun and committed out of the jurisdiction of any particular State or district of the United States, F ARHAD SHAKERI, the defendant, and others known and unknown, at least one of whom will be first brought to and arrested in the Southern District of New York, knowingly and willfully 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)(l), to a foreign terrorist organization ("FTO"), namely, the Islamic Revolutionary Guard Corps ("IRGC"), which was designated by the U.S. Secretary of State as an FTO on or about April 15, 2019, and is currently designated as such as of the date of the filing of the Complaint.

It was a part and an object of the conspiracy that FARHAD SHAKERI, the defendant, and others known and unknown, would and did knowingly provide the IRGC with material support and resources, including services, property, and personnel (including himself), knowing that the IRGC was a designated terrorist organization ( as defined in Title 18, United States Code, Section 2339B(g)(6)), that the IRGC 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.

From at least in or about December 2023, up to and including the date of the Complaint, in Iran, the Southern District of New York and elsewhere, and in an offense begun and committed out of the jurisdiction of any particular State or district of the United States, F ARHAD SHAKERI, 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 provided, attempted to provide, and aided and abetted the provision of "material support or resources," as that term is defined in Title 18, United States Code, Section 2339A(b), including, among other things, services, property, and personnel (including himself), to a FTO, namely, the IRGC, which was designated by the U.S. Secretary of State as an FTO on or about April 15, 2019, and is currently designated as such, as of the date of the filing of the Complaint, knowing that the IRGC was a designated FTO (as defined in Title 18, United States Code, Section 2339B(g)(6)), that the IRGC engages and has engaged in terrorist activity (as defined in Section 212(a)(3)(B) of the Immigration and Nationality Act ("INA")), 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). (Title 18, United States Code, Sections 2339B(a)(l), (d)(l)(C), (E), and (F), 2, and 3238.)

From at least in or about December 2023, up to and including the date of the Complaint, in Iran, the Southern District of New York, and elsewhere, and in an offense begun and committed out of the jurisdiction of any particular State or district of the United States, FARHAD SHAKERI, CARLISLE RIVERA, a/k/a "Pop," and JONATHAN LOADHOLT, the defendants, 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, traveled in and caused another to travel in interstate and foreign commerce, and used and caused another to use the mail and a facility of interstate and foreign commerce, with intent that a murder be committed in violation of the laws of the State of New York or the United States as consideration for the receipt of, and as consideration for a promise or agreement to pay, a thing of pecuniary value, and attempted to commit and aided and abetted the same, to wit, SHAKERI, RIVERA, and LOADHOLT used cellphones and electronic messaging applications to communicate with each other in furtherance of a plot for RIVERA and LOADHOLT to kill an individual ("Victim-I") in New York City in exchange for payment.