MIL Security Engine-1

Note: View the complaint here.

A Pakistani citizen residing in Canada, Muhammad Shahzeb Khan, 20, also known as Shahzeb Jadoon, was arrested on Sept. 4 in Canada in connection with a complaint filed in the Southern District of New York. Khan was charged with attempting to provide material support and resources to a designated foreign terrorist organization (FTO), the Islamic State of Iraq and al-Sham (ISIS).

“The defendant is alleged to have planned a terrorist attack in New York City around October 7th of this year with the stated goal of slaughtering, in the name of ISIS, as many Jewish people as possible,” said Attorney General Merrick B. Garland. “Thanks to the investigative work of the FBI, and the quick action of our Canadian law enforcement partners, the defendant was taken into custody. As I said to Canada’s Minister of Public Safety yesterday, we are deeply grateful to our Canadian partners for their critical law enforcement actions in this matter. Jewish communities — like all communities in this country — should not have to fear that they will be targeted by a hate-fueled terrorist attack. The Justice Department will continue to work closely with our domestic and international partners to aggressively counter the threat posed by ISIS and other terrorist organizations and their supporters.”

“The defendant was allegedly determined to kill Jewish people here in the United States, nearly one year after Hamas’ horrific attack on Israel. This investigation was led by the FBI, and I am proud of the terrific work by the FBI team and our partners to disrupt Khan’s plan.” said FBI Director Christopher Wray. “The FBI will continue to work closely with our partners to investigate and hold accountable those who seek to commit violence in the name of ISIS or other terrorist organizations. Fighting terrorism remains the FBI’s top priority.”

As alleged in the complaint, Khan, who resided in Canada, attempted to travel from Canada to New York City, where he intended to use automatic and semi-automatic weapons to carry out a mass shooting in support of ISIS at a Jewish center in Brooklyn, New York. Khan began posting on social media and communicating with others on an encrypted messaging application about his support for ISIS in or about November 2023, when, among other things, Khan distributed ISIS propaganda videos and literature. Subsequently, Khan began communicating with two undercover law enforcement officers (collectively, the UCs).

During those conversations, Khan confirmed that he and a U.S.-based ISIS supporter (Associate-1) had been planning to carry out an attack in a particular U.S. city (City-1). Among other things, Khan said that he had been actively attempting to create “a real offline cell” of ISIS supporters to carry out a “coordinated assault” in City-1 using AR-style rifles to “target[] Israeli Jewish chabads . . . scattered all around [City-1].” During subsequent conversations, Khan repeatedly instructed the UCs to obtain AR-style assault rifles, ammunition, and other materials to carry out the attacks, and identified the specific locations in City-1 where the attacks would take place. Khan also provided details about how he would cross the border from Canada into the United States to conduct the attacks. During these conversations with the UCs, Khan emphasized that “Oct 7th and oct 11th are the best days for targeting the jews” because “oct 7 they will surely have some protests and oct 11 is yom.kippur.”

On or about Aug. 20, Khan changed his target location from City-1 to New York City. After initially suggesting certain neighborhoods in New York City to the UCs, Khan decided to target Location-1, a Jewish center located in Brooklyn, New York. Khan told the UCs that he planned to carry out this attack on or around Oct. 7, 2024 — which Khan recognized as the one-year anniversary of the brutal terrorist attacks in Israel by Hamas, a designated FTO, which, on Oct. 7, 2023, launched a wave of violent, large-scale terrorist attacks in Israel. In support of his choice of New York City as his target location, Khan boasted that “New york is perfect to target jews” because it has the “largest Jewish population In america” and therefore, “even if we dont attack a[n] Event[,] we could rack up easily a lot of jews.” Khan proclaimed that “we are going to nyc to slaughter them,” and sent a photograph of the specific area inside of Location-1 where he planned to carry out the attack. 

Thereafter, Khan continued to urge the UCs to acquire AR-style rifles, ammunition, and other equipment for his attack, including “some good hunting [knives] so we can slit their throats.” Khan repeatedly reiterated his desire to carry out the attack in support of ISIS, and discussed planning for the attack, including by identifying rental properties close to Location-1 and paying for a human smuggler to help him reach and cross the border from Canada into the United States. During one communication, Khan noted that “if we succeed with our plan this would be the largest Attack on US soil since 9/11.”

On or about Sept. 4, as Khan said he planned to do in connection with his attack, Khan attempted to reach the U.S-Canada border. To do so, Khan used three separate cars to travel across Canada towards the United States, before he was stopped in or around Ormstown, Canada, approximately 12 miles from the U.S.-Canada border.

Khan is charged with one count of attempting to provide material support and resources to a designated foreign terrorist organization. If convicted, he faces a maximum sentence of 20 years in prison. A federal district court judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.

The FBI New York, Chicago, and Los Angeles Field Offices are investigating the case. The Justice Department is grateful to Canadian law enforcement for their actions in this matter. The Office of International Affairs of the Department of Justice’s Criminal Division is seeking the extradition of Khan from Canada. 

Assistant U.S. Attorneys Kaylan E. Lasky and David J. Robles for the Southern District of New York and Trial Attorney Kevin C. Nunnally of the Justice Department’s National Security Division’s Counterterrorism Section are prosecuting the case.

A complaint is merely an allegation. All defendants are presumed innocent until proven guilty beyond a reasonable doubt in a court of law.

Note: View the indictment here. 

An indictment charging Russian nationals Kostiantyn Kalashnikov, 31, also known as Kostya, and Elena Afanasyeva, 27, also known as Lena, with conspiracy to violate the Foreign Agents Registration Act (FARA) and conspiracy to commit money laundering was unsealed today in the Southern District of New York. Kalashnikov and Afanasyeva are at large. 

“The Justice Department has charged two employees of RT, a Russian state-controlled media outlet, in a $10 million scheme to create and distribute content to U.S. audiences with hidden Russian government messaging,” said Attorney General Merrick B. Garland. “The Justice Department will not tolerate attempts by an authoritarian regime to exploit our country’s free exchange of ideas in order to covertly further its own propaganda efforts, and our investigation into this matter remains ongoing.”

“Our approach to combating foreign malign influence is actor-driven, exposing the hidden hand of adversaries pulling strings of influence from behind the curtain,” said Deputy Attorney General Lisa Monaco. “As alleged in today’s indictment, Russian state broadcaster RT and its employees, including the charged defendants, co-opted online commentators by funneling them nearly $10 million to pump pro-Russia propaganda and disinformation across social media to U.S. audiences. The Department will not tolerate foreign efforts to illegally manipulate American public opinion by sowing discord and division.”

“Covert attempts to sow division and trick Americans into unwittingly consuming foreign propaganda represents attacks on our democracy,” said FBI Director Christopher A. Wray. “Today’s actions show that as long as foreign adversaries like Russia keep engaging in hostile influence campaigns, they are going to keep running into the FBI. We will continue to do everything we can to expose the hidden hand of foreign adversaries like Russia and disrupt their efforts to meddle in our free and open society.”

“The Russian government has long sought to sow discord and chaos in the United States through propaganda and foreign malign influence campaigns,” said Assistant Attorney General Matthew G. Olsen of the Justice Department’s National Security Division. “As alleged, the covert operations by RT employees exploited our free and open press and targeted millions of Americans as unwitting victims of Russia’s psychological warfare.”

“As alleged, the Russian state broadcaster RT orchestrated a massive scheme to influence the American public by secretly planting and financing a content creation company on U.S. soil,” said U.S. Attorney Damian Williams for the Southern District of New York. “The instruments of the scheme were RT employees Kostiantyn Kalashnikov and Elena Afanasyeva, who managed the operation from Moscow using fake personas and shell companies, and the victims of the scheme were the American people, who received Russian messaging without knowing it. As the charges unsealed today demonstrate, this Office will work with our law enforcement partners to unmask and hold accountable all those who conduct malign influence campaigns in the United States, no matter how hard they try to hide their tracks.”

According to the court documents, RT, formerly known as Russia Today, is a state-controlled media outlet funded and directed by the Government of Russia. Over at least the past year, RT and its employees, including Kalashnikov and Afanasyeva, deployed nearly $10 million to covertly finance and direct a Tennessee-based online content creation company (U.S. Company-1). In turn, U.S. Company-1 published English-language videos on multiple social media channels, including TikTok, Instagram, X, and YouTube. Since publicly launching in or about November 2023, U.S. Company-1 has posted nearly 2,000 videos that have garnered more than 16 million views on YouTube alone. Many of the videos posted by U.S. Company-1 contain commentary on events and issues in the U.S., such as immigration, inflation, and other topics related to domestic and foreign policy. While the views expressed in the videos are not uniform, most are directed to the publicly stated goals of the Government of Russia and RT — to amplify domestic divisions in the United States. 

In order to carry out RT’s secret influence campaign in the United States, Kalashnikov and Afanasyeva operated under covert identities at U.S. Company-1. Posing as an outside editor, Kalashnikov edited U.S. Company-1 content, monitored U.S. Company-1’s funding and hiring, and introduced Afanasyeva as a member of his purported editing team. Using the fake personas Helena Shudra and Victoria Pesti, Afanasyeva posted and directed the posting by U.S. Company-1 of hundreds of videos. Afanasyeva also collected information from and gave instructions to U.S. Company-1  staff. For example, after the March 22, 2024, terrorist attack on a music venue in Moscow, Afanasyeva asked one of U.S. Company-1’s founders to blame Ukraine and the United States for the attack, writing: “I think we can focus on the Ukraine/U.S. angle. . . . [T]he mainstream media spread fake news that ISIS claimed responsibility for the attack yet ISIS itself never made such statements. All terrorists are now detained while they were heading to the border with Ukraine which makes it even more suspicious why they would want to go to Ukraine to hide.” 

Between in or about October 2023 and in or about August 2024, RT sent wire transfers to U.S. Company-1 totaling approximately $9.7 million, which represented nearly 90% of U.S. Company-1’s bank deposits from all sources combined. The wires were sent from shell companies in Turkey, the United Arab Emirates, and Mauritius, and were often accompanied by wire notes ascribing the payments to the purchase of electronics. For example, the wire note for a $318,800 wire payment from a shell entity in Turkey to U.S. Company-1 on March 1, read: “BUYING GOODS-INV.013-IPHONE 15 PRO MAX 512GB.” 

U.S. Company-1 never disclosed to its viewers that it was funded and directed by RT. Nor did U.S. Company-1 or its two founders register with the Attorney General as an agent of a foreign principal.

Kalashnikov and Afanasyeva both of Russia, are charged with conspiracy to violate FARA, which carries a maximum sentence of five years in prison, and conspiracy to commit money laundering, which carries a maximum sentence of 20 years in prison. If convicted, a federal district court judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.

The FBI is investigating the case.

Assistant U.S. Attorneys Alexander Li and Juliana Murray for the Southern District of New York and Trial Attorney Brett Reynolds of the Justice Department’s National Security Division Counterintelligence and Export Control Section are prosecuting the case.

An indictment is merely an allegation. All defendants are presumed innocent until proven guilty beyond a reasonable doubt in a court of law.

Note: View the affidavit here. 

The Justice Department today announced the ongoing seizure of 32 internet domains used in Russian government-directed foreign malign influence campaigns colloquially referred to as “Doppelganger,” in violation of U.S. money laundering and criminal trademark laws. As alleged in an unsealed affidavit, the Russian companies Social Design Agency (SDA), Structura National Technology (Structura), and ANO Dialog, operating under the direction and control of the Russian Presidential Administration, and in particular First Deputy Chief of Staff of the Presidential Executive Office Sergei Vladilenovich Kiriyenko, used these domains, among others, to covertly spread Russian government propaganda with the aim of reducing international support for Ukraine, bolstering pro-Russian policies and interests, and influencing voters in U.S. and foreign elections, including the U.S. 2024 Presidential Election.  

In conjunction with the domain seizures, the U.S. Treasury Department announced the designation of 10 individuals and two entities as part of a coordinated response to Russia’s malign influence efforts targeting the 2024 U.S. presidential election. This announcement follows the designation of actors involved in Doppelganger announced by the Treasury Department in March.

“The Justice Department is seizing 32 internet domains that the Russian government and Russian government-sponsored actors have used to engage in a covert campaign to interfere in and influence the outcome of our country’s elections,” said Attorney General Merrick B. Garland. “As alleged in our court filings, President Vladimir Putin’s inner circle, including Sergei Kiriyenko, directed Russian public relations companies to promote disinformation and state-sponsored narratives as part of a campaign to influence the 2024 U.S. Presidential Election. An internal planning document created by the Kremlin states that a goal of the campaign is to secure Russia’s preferred outcome in the election. The sites we are seizing today were filled with Russian government propaganda that had been created by the Kremlin to reduce international support for Ukraine, bolster pro-Russian policies and interests, and influence voters in the United States and other countries. Our actions today make clear that the Justice Department will be aggressive in countering and disrupting attempts by the Russian government, or any other malign actor, to interfere in our elections and undermine our democracy.”

“The Department’s seizure of 32 internet domains secretly deployed to spread foreign malign influence demonstrates once again that Russia remains a predominant foreign threat to our elections,” said Deputy Attorney General Lisa Monaco. “At Putin’s direction, Russian companies SDA, Structura, and ANO Dialog used cybersquatting, fabricated influencers, and fake profiles to covertly promote AI-generated false narratives on social media. Those narratives targeted specific American demographics and regions in a calculated effort to subvert our election. Our republic depends on elections that are free from foreign interference, and we will not rest in our efforts to expose foreign malign influence operations and protect our democracy, without fear or favor.”

“Today’s announcement exposes the scope of the Russian government’s influence operations and their reliance on cutting-edge AI to sow disinformation,” said FBI Director Christopher Wray. “Companies operating at the direction of the Russian government created websites to trick Americans into unwittingly consuming Russian propaganda.  By seizing these websites, the FBI is making clear to the world what they are, Russian attempts to interfere in our elections and influence our society.  The FBI will continue to work with our partners to expose and shutdown these covert influence campaigns.”

“This seizure illustrates vividly what the U.S. government and private sector partners have warned for months: the Russian government and its proxies are aggressively accelerating the Kremlin’s covert efforts to seed false stories and amplify disinformation directed at the American public,” said Assistant Attorney General Matthew G. Olsen of the Justice Department’s National Security Division. “Today’s announcement reveals Russia is willing to impersonate our free and open press in its egregious schemes. This is our third disruption of Russian foreign malign influence operations in two months, and the Justice Department remains relentless in protecting Americans from such unacceptable conduct. To Russia, and any other government seeking to stoke discord in our society: know that we will spare no effort and use every available tool to disrupt and expose this malign activity and defend our democratic institutions.”

“Protecting our democratic processes from foreign malign influence is paramount to ensure enduring public trust,” said U.S. Attorney Jacqueline C. Romero for the Eastern District of Pennsylvania. “As America’s adversaries continue to spew propaganda and disinformation towards the American electorate, we’ll use every tool at our disposal to expose and dismantle their insidious foreign influence campaigns.”

The propaganda did not identify, and in fact purposefully obfuscated, the Russian government or its agents as the source of the content. The perpetrators extensively utilized “cybersquatted” domains, a method of registering a domain intended to mimic another person or company’s website (e.g., registering washingtonpost.pm to mimic washingtonpost.com), to publish Russian government messaging falsely presented as content from legitimate news media organizations. In other instances, the perpetrators sought to create their own unique media brands to promote Doppelganger content (e.g., Recent Reliable News). Among the methods Doppelganger used to drive viewership to the cybersquatted and unique media domains was the deployment of “influencers” worldwide, paid social media advertisements (in some cases created using artificial intelligence tools), and the creation of social media profiles posing as U.S. (or other non-Russian) citizens to post comments on social media platforms with links to the cybersquatted domains, all of which attempted to trick viewers into believing they were being directed to a legitimate news media outlet’s website.

Overview

The affidavit describes the perpetrators’ own internal strategy meeting notes, project proposals, and other records obtained during the course of the investigation. Several notable propaganda project proposals directed against the United States included:

• Good Old USA Project: Attachments 8A, 8B
• The Guerilla Media Campaign: Attachments 9A, 9B
• U.S. Social Media Influencers Network Project: Attachments 10A, 10B

Doppelganger’s foreign malign influence efforts were not directed solely against audiences in the United States. Other targets of the perpetrators’ propaganda included Germany, Mexico, and Israel, among others. Doppelganger’s influence campaigns sought to influence the citizenry of those countries to support Russian government objectives, including by undermining the United States’ relationship with those countries.

Doppelganger’s use of the U.S.-based domain names at the direction and control of, and for the benefit of, sanctioned persons, including Sergei Vladilenovich Kiriyenko, SDA, and Structura, violates the International Emergency Economic Powers Act (IEEPA). As a result, the accompanying payments for Doppelganger’s online infrastructure violate federal money laundering laws. In addition, Doppelganger’s publication of content on cybersquatted domains with names and content that mimic legitimate media outlets violates federal criminal trademark laws because those domains feature trademarks registered on the Principal Register maintained by the U.S. Patent and Trademark Office.

The FBI Philadelphia Field Office is investigating the case.

The U.S. Attorney’s Office for the Eastern District of Pennsylvania, the National Security Division’s Counterintelligence and Export Control Section and National Security Cyber Section are prosecuting the case, with valuable assistance from the Criminal Division’s Computer Crime and Intellectual Property Section.

Note: The complaint was unsealed on Sept. 3 and can be viewed here. 

The Justice Department announced today the unsealing of terrorism, murder conspiracy, and sanctions-evasion charges against six senior leaders of Hamas, a designated foreign terrorist organization. The charges relate to the defendants’ central roles in planning, supporting, and perpetrating the terrorist atrocities that Hamas committed in Israel on Oct. 7, 2023 (the October 7 Hamas Massacres), involving the murders and kidnappings of countless innocent civilians, including American citizens, which was the culmination of Hamas’s decades-long campaign of terrorism and violence against Israel and its allies, including American citizens. The defendants are either deceased or remain at large. 

“The Justice Department has charged Yahya Sinwar and other senior leaders of Hamas for financing, directing, and overseeing a decades-long campaign to murder American citizens and endanger the national security of the United States,” said Attorney General Merrick B. Garland. “On October 7^th, Hamas terrorists, led by these defendants, murdered nearly 1200 people, including over 40 Americans, and kidnapped hundreds of civilians. This weekend, we learned that Hamas murdered an additional six people they had kidnapped and held captive for nearly a year, including Hersh Goldberg-Polin, a 23 year old Israeli American. We are investigating Hersh’s murder, and each and every one of Hamas’ brutal murders of Americans, as an act of terrorism. The charges unsealed today are just one part of our effort to target every aspect of Hamas’ operations. These actions will not be our last.”

“Yahya Sinwar and the other senior leaders of Hamas are charged today with orchestrating this terrorist organization’s decades-long campaign of mass violence and terror — including on October 7th. On that horrible day, Hamas terrorists viciously massacred nearly 1,200 innocent men, women, and children, including over 40 Americans, kidnapped hundreds more, and used sexual violence as a weapon of brutality,” said Deputy Attorney General Lisa Monaco. “Since that horrific day, we have worked to investigate and hold accountable those responsible, and we will not rest until all those who kidnapped or murdered Americans are brought to justice. Our thoughts continue to be with the families of all the victims of this barbaric terrorist attack.”

“From the moment Hamas launched its horrific attack on October 7, the FBI has been dedicated to identifying and charging those responsible for these heinous crimes,” said FBI Director Christopher Wray. “The FBI has and will continue to relentlessly investigate these attacks on civilians, including Americans. Hamas is a Foreign Terrorist Organization with a long history of violence, and the group’s actions have resulted in increased terrorism threats in the U.S. and against American interests throughout the world. Countering terrorism remains our number one priority, and our work continues.”

“The core mission of the National Security Division is to protect Americans from violent terrorists and extremist organizations like Hamas,” said Assistant Attorney General Matthew G. Olsen of the Justice Department’s National Security Division. “The atrocities committed by Hamas in Israel on October 7 are intolerable, and the Justice Department will not rest in our pursuit to hold Hamas accountable for perpetrating its campaign of terror, death, and destruction.”

“For decades, Hamas and its leadership have dedicated themselves to the eradication of the State of Israel, and to murdering, maiming, and brutalizing anyone — including dozens of Americans — who stood in their way,” said U.S. Attorney Damian Williams for the Southern District of New York. “The October 7 Hamas Massacres – in which over 40 American citizens were murdered – is only the latest act of savagery carried out by Hamas. This office has long been dedicated to serving as a bulwark against terrorism, and striking blows against its leaders. Our commitment is clear: if you hurt one member of our community, you hurt all of us — and we stand with all victims of Hamas’ reign of terror. We will bring justice to this terrorist organization from the top down for the atrocities they have committed.”  

According to court documents, Harakat al-Muqawamah al-Islamiyya, commonly known as Hamas, is a terrorist organization that was founded in 1987, and has been designated as a foreign terrorist organization (FTO) by the United States since 1997. From its inception, Hamas’ stated purpose has been to create an Islamic Palestinian state throughout Israel by eliminating the State of Israel through violent holy war, or jihad. Hamas also promotes attacks against the U.S. and its citizens and, over more than two decades, Hamas has murdered and injured dozens of Americans as part of its campaign of violence and terror. 

The defendants charged in the complaint are all senior leaders of Hamas who have orchestrated, overseen, and supported Hamas’s decades-long campaign of terrorism, including the October 7 Hamas Massacres. They and their co-conspirators control all aspects of the terrorist organization, including its political and military branches, known as the Politburo and Izz al-Din al-Qassam Brigades (al-Qassam Brigades).

Ismail Haniyeh was the chairman of Hamas’s Politburo from 2017 until his reported death on or about July 31. Prior to 2017, Haniyeh was the deputy chairman of the Politburo and the leader of Hamas in the Gaza Strip. Haniyeh was based principally in Turkey and Qatar.

Yahya Sinwar, also known as Abu Ibrahim, 61, is the leader of Hamas. Previously, beginning in approximately 2017, he was the leader of Hamas in the Gaza Strip, and is one of the founders of the al-Qassam Brigades. Sinwar is based principally in the Gaza Strip.   

Mohammad Al-Masri, also known as Mohammed Deif and al Khalid al-Deif, was the commander in chief of the al-Qassam Brigades, a position he held from in or about 2002 until his reported death on or about July 13. Al-Masri was based principally in the Gaza Strip.

Marwan Issa, also known as Abu Baraa, was the deputy commander of the al-Qassam Brigades from approximately 2007 until his reported death on or about March 10.  Issa was based principally in the Gaza Strip.   

Khaled Meshaal, also known as Abu al-Waleed, 68, was the chairman of Hamas’ Politburo from approximately 2004 to 2017 and is now the head of Hamas’ diaspora office — effectively responsible for Hamas’ official presence outside of the Gaza Strip and the West Bank. Meshaal is based principally in Qatar.   

Ali Baraka, 57, has been Hamas’ head of National Relations Abroad since approximately 2019, and was previously Hamas’s representative in Lebanon. Baraka is based principally in Lebanon. 

Hamas has pursued its objectives through innumerable acts of brutal terrorist violence, including launching thousands of rockets specifically targeting civilian populations; suicide bombings of restaurants, markets, public transportation systems, and other public spaces; and military-style attacks on towns and residential communities. Hamas’s campaign of terrorism has killed and wounded citizens of Israel, the U.S., and many other countries. 

On Oct. 7, 2023, Hamas committed its most violent, large-scale terrorist attack to date — the October 7 Hamas Massacres. Hamas targeted civilian populations with a barrage of rockets, before waves of Hamas terrorists breached the border between the Gaza Strip and Israel, infiltrated Israel, and launched attacks on civilians, by land, sea, and air. Hamas sent thousands of armed fighters into southern Israel, where they carried out the massacres of over a thousand people and the kidnappings of more than 200 others. Hamas terrorists attacked civilians, firing handguns, assault rifles, and handheld rocket launchers, in small residential communities in Kfar Aza, Be’eri, Nir Oz, Nahal Oz, Re’im, Holit, Zikim, Kerem Shalom, Sufa, and others; the Israeli town of Sderot; and a music festival held near Re’im; among other places. Armed Hamas operatives attacked and shot civilians, including children, sometimes with machineguns and sometimes at point blank range, and weaponized sexual violence against Israeli women, including through rape and genital mutilation. Hundreds of civilians, including Americans, and Israeli soldiers, were killed and wounded; other victims, including Americans, were kidnapped, taken hostage, and brought into Gaza by Hamas. As of the date of the complaint, over 40 American citizens were among those murdered, and at least eight American citizens were taken hostage or remain unaccounted for. Most recently, Hamas executed a U.S. citizen who was taken hostage by Hamas during the October 7 Hamas Massacres and remained in captivity until he was murdered.

Throughout Hamas’ existence, the organization’s ability to carry out acts of terrorism, including the October 7 Hamas Massacres, has been fueled in part by the Government of Iran, particularly the Islamic Revolutionary Guard Corps (IRGC) and its Qods Force (IRGC-QF) — the element of the IRGC responsible for conducting external terrorism operations and providing support to terrorist groups — which has supported, supplied, and trained Hamas, and by the Lebanon-based Shia Islamic terrorist organization Hizballah. Hamas’ attacks have played a significant role in the Government of Iran’s regional and global campaign of supporting terrorism to weaken and ultimately destroy both the United States and Israel. Hamas’ leaders, including the defendants, have been instrumental in Hamas’ relationship with the Government of Iran, including through personal communications with leaders in the Iranian regime. Emblematic of this close relationship, Ismail Haniyeh, who had been the chairman of Hamas’s Politburo since 2017, was reported killed in Iran on or about July 31, while visiting Tehran to attend the swearing-in of Iran’s President. Hamas’ leaders, including the defendants, have acknowledged the importance of the support from the Government of Iran and Hizballah to Hamas’ ability to carry out the October 7 Hamas Massacres, including the IRGC-QF providing Hamas, among other things, rockets and technical assistance necessary to build rockets, and extensive funding for Hamas’ terror wing. 

Hamas raises money to fund its terrorist activities through a variety of methods, including by soliciting and receiving cryptocurrency payments, advertising the ostensible anonymity of such transactions. Since 2019, Hamas’ military wing has used social media and other platforms to call for cryptocurrency contributions from supporters abroad, including in the United States, to Hamas-controlled virtual wallets, explicitly acknowledging that those payments would be used to fund Hamas’ campaign of violence. Through these mechanisms, Hamas has received tens of millions of dollars in cryptocurrency payments to fund its activities. 

The complaint unsealed today charges each of the defendants with: conspiring to provide material support to a foreign terrorist organization resulting in death, which carries a maximum penalty of life in prison; conspiring to provide material support for acts of terrorism resulting in death, which carries a maximum penalty of life in prison; conspiring to murder U.S. nationals outside the United States, which carries a maximum penalty of life in prison; conspiring to bomb a place of public use resulting in death, which carries a maximum penalty of death or life in prison; conspiring to use weapons of mass destruction resulting in death, which carries a maximum penalty of death or life in prison; conspiring to finance terrorism, which carries a maximum penalty of 20 years in prison; and conspiring to violate the International Emergency Economic Powers Act, which carries a maximum penalty of 20 years in prison. A federal district court judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.

The FBI is investigating the case.

Assistant U.S. Attorneys Sam Adelsberg, Jacob H. Gutwillig, Sarah L. Kushner, Michael D. Lockard, Ben Arad, and Samuel L. Raymond for the Southern District of New York and Trial Attorneys Alicia Cook and C. Alexandria Bogle of the Justice Department’s National Security Division’s Counterterrorism Section are prosecuting the case.

A complaint is merely an allegation. All defendants are presumed innocent until proven guilty beyond a reasonable doubt in a court of law.