A criminal complaint against an Iranian agent and two U.S. citizens charged with plotting to assassinate Donald Trump and other enemies of the Iranian regime was unsealed Friday.

The 26-page document details how Farhad Shakeri, an Afghan national who spent 14 years in New York State prisons, conspired with his former prison buddies at the behest of Iran's Revolutionary Guards. Shakeri was deported in 2008 after completing that prison sentence for burglary, and currently lives in Tehran. Two of his co-conspirators, Carlisle Rivera and Jonathan Loadholt, were charged in the complaint and made their first appearances Thursday.

From the Southern District of New York's press release:

According to the complaint and other public statements and filings, the Government of the Islamic Republic of Iran (the Government of Iran) is actively targeting nationals of the United States and its allies living in countries around the world for attacks, including assault, kidnapping, and murder, both to repress and silence dissidents critical of the Iranian regime and to take vengeance for the January 2020 death of then-Commander of the Islamic Revolutionary Guard Corps (IRGC) Qods Force (IRGC-QF), Qasem Soleimani, who was killed by a U.S. drone strike in Baghdad. 

Trump is referenced in the complaint as Victim 4, and the complaint outlines the plot to assassinate Donald Trump:

Also 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.

Attorney General Merrick Garland said:

“There are few actors in the world that pose as grave a threat to the national security of the United States as does Iran. The Justice Department has charged an asset of the Iranian regime who was tasked by the regime to direct a network of criminal associates to further Iran’s assassination plots against its targets, including President-elect Donald Trump. We have also charged and arrested two individuals who we allege were recruited as part of that network to silence and kill, on U.S. soil, an American journalist who has been a prominent critic of the regime. We will not stand for the Iranian regime’s attempts to endanger the American people and America’s national security.”

The entire complaint can be read below.

Criminal Complaint Iranian ... by Jennifer Van Laar