Defendant Worked on Behalf of the IRGC to Hire Persons in the United States to Carry Out the Murder, Likely in Retaliation for the January 2020 Death of Qasem Soleimani

On Nov. 9, 2021, Poursafi contacted the CHS on an encrypted messaging application, and then directed the CHS to a second encrypted messaging application for further communications. Poursafi offered the CHS $250,000 to hire someone to “eliminate” the former National Security Advisor. This amount would later be negotiated up to $300,000. Poursafi added that he had an additional “job,” for which he would pay $1 million.

Poursafi directed the CHS to open a cryptocurrency account to facilitate payment, but stipulated that the CHS would likely have to carry out the murder before he/she could be paid. He further explained to the CHS that if he/she was paid and the murder was not completed, Poursafi’s “group” would be angry. A later search of one of Poursafi’s online accounts revealed pictures of Poursafi wearing a uniform with an IRGC patch. During their communications, the CHS made several references to Poursafi being associated with IRGC-QF. Poursafi never denied his involvement with IRGC-QF.

On April 28, 2022, the CHS told Poursafi that he/she would not continue to work without being paid. Poursafi agreed to send the CHS $100 in cryptocurrency to a virtual wallet the CHS created earlier that day, to prove payment could be made. Later that day, the cryptocurrency wallet received two payments totaling $100.