The criminal complaint alleges that, from the spring of 2011 to October 2011, Arbabsiar and his Iran-based co-conspirators, including Shakuri of the Qods Force, have been plotting the murder of the Saudi Ambassador to the United States. In furtherance of this conspiracy, Arbabsiar allegedly met on a number of occasions in Mexico with a DEA confidential source (CS-1) who has posed as an associate of a violent international drug trafficking cartel. According to the complaint, Arbabsiar arranged to hire CS-1 and CS-1’s purported accomplices to murder the Ambassador, and Shakuri and other Iran-based co-conspirators were aware of and approved the plan. With Shakuri’s approval, Arbabsiar has allegedly caused approximately $100,000 to be wired into a bank account in the United States as a down payment to CS-1 for the anticipated killing of the Ambassador, which was to take place in the United States.

According to the criminal complaint, the IRCG is an arm of the Iranian military that is composed of a number of branches, one of which is the Qods Force. The Qods Force conducts sensitive covert operations abroad, including terrorist attacks, assassinations and kidnappings, and is believed to sponsor attacks against Coalition Forces in Iraq. In October 2007, the U.S. Treasury Department designated the Qods Force for providing material support to the Taliban and other terrorist organizations.