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, knowingly and willfully did combine,
conspire, confederate, and agree together and with each other to commit murder-for-hire, in
violation of Title 18, United States Code, Section 1958.
6. It was a part and an object of the conspiracy that FARHAD SHAKERI,
CARLISLE RIVERA, a/k/a “Pop,” and JONATHAN LOADHOLT, and others known and
unknown, would and did knowingly travel in and cause others to travel in interstate and foreign
commerce, and would and did use and cause another to use 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 anything of pecuniary value, to wit, SHAKERI, RIVERA, and LOADHOLT
participated in an agreement whereby RIVERA and LOADHOLT would kill Victim-1 in exchange
for payment, and used cellphones and electronic messaging applications to communicate in
furtherance of the scheme.
(Title 18, United States Code, Sections 1958 and 3238.)
COUNT FIVE
(MONEY LAUNDERING CONSPIRACY)
7. From at least in or about December 2023, up to and including the date of
this 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, knowingly and willfully did combine,
conspire, confederate, and agree together and with each other to commit money laundering, in
violation of Title 18, United States Code, Section 1956.
8. It was further a part and an object of the conspiracy that FARHAD
SHAKERI, CARLISLE RIVERA, a/k/a “Pop,” and JONATHAN LOADHOLT, the defendants,
and others known and unknown, in an offense involving and affecting interstate and foreign
commerce, knowing that the property involved in certain financial transactions represented the
proceeds of some form of unlawful activity, would and did conduct and attempt to conduct such
financial transactions which in fact involved the proceeds of specified unlawful activity, to wit,
the proceeds of the murder-for-hire offenses charged in Counts Three and Four of this Complaint,
knowing that the transactions were designed in whole and in part to conceal and disguise the
nature, location, source, ownership, and control of the proceeds of said specified unlawful activity,
in violation of Title 18, United States Code, Section 1956(a)(1)(B)(i).
9. It was further a part and an object of the conspiracy that FARHAD
SHAKERI, CARLISLE RIVERA, a/k/a “Pop,” and JONATHAN LOADHOLT, the defendants,
and others known and unknown, would and did transport, transmit, and transfer, and attempt to
transport, transmit, and transfer, monetary instruments and funds to a place in the United States
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