‘A091 (Rew 1111) Criminal Complaint
UNITED STATES DISTRICT COURT
for the
District of Columbia
United States of America
7, Case: 1:18-mj-00087
Assigned To : Magistrate Judge Harvey, G. Michae!
‘Anmadreza Mohammadi Doostdar ‘Assign. Date - 8/8/2018
Description: Criminal Complaint & Arrest
Dejendanis)
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
‘On or about the date(s) of ___March 2017 tothe present __ in the county of __ inthe
District of| Columbia the defendant(s) violated:
Code Section Offense Description
18USC.§371 Conspiracy
USS. District and Bankruptcy Courts
far the District of Columbia
‘This criminal complaint is based on these facts:
‘See attached Affidavit which is incorporated by reference as if fully stated herein
® Continued on the attached sheet.
"Complainant's signature
______ Mikel Wier, Special Agent
Prined name andl
‘Swom to before me and signed in my presence
Date: ___ 08/08/2018 2
ssenaney
City and state ___Washington, D.C. Magistrate Judge G. Mictdel Harvey
Printed name and ileAFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT
I, Mikel Wier, being first duly sworn, state as follows:
Introduction and Agent Background
1 Tam a Special Agent with the Federal Bureau of Investigation (FBI) and have
been so employed for approximately eight years. | am currently assigned to the Washington
Field Office to a squad responsible for investigating extraterritorial counterterrorism matters. |
began my career at the FBI in the counterterrorism section of the San Diego Field Office. For
approximately the last three years, I was assigned to the Critical Incident Response Group. In
May 2018, I was assigned to my current squad. Through the course of my duties, I have
participated in numerous subject and witness interviews and reviewed electronic and other
materials seized pursuant to search warrants in terrorism cases. I am familiar with the facts and
circumstances set forth below from my participation in the investigation; my review of the
investigative file; and information provided to me by other agents and law enforcement officials;
and information otherwise obtained by credible and reliable sources. As a federal agent, 1 am
authorized to investigate violations of laws of the United States, and as a law enforcement officer
1 am authorized to execute warrants issued under the authority of the United States.
This affidavit is being submitted in support of a criminal complaint alleging that
Ahmadreza Mohammadi DOOSTDAR (DOOSTDAR), Majid GHORBANI (GHORBAND), and
others known and unknown to the United States (collectively, “the defendants”), conspired to (1)
willfully and knowingly act as agents of a foreign government, specifically the Government of
Iran, without prior notification to the Attomey General, as required by law, and (2) provide
services to Iran, without having first obtained the required license from OFAC, as required by