COUNT ONE

(Conspiracy to Act as an Unregistered Foreign Agent)

In or about and between January 2007 and January 2021, both dates being approximate and inclusive, within the Eastern District of New York and elsewhere, the defendant KAVEH LOTFOLAH AFRASIABI, also known as “Lotfolah Kaveh Afrasiabi,” together with others, did knowingly and willfully conspire to act and cause others to act in the United States as an agent of a foreign principal, to wit: the government of the Islamic Republic of Iran, without prior registration with the Attorney General of the United States, as required by law, contrary to Title 22, United States Code, Sections 612 and 618(a)(1).

(Title 18, United States Code, Section 371)

COUNT TWO

(Acting as a Foreign Agent Without Registration)

In or about and between January 2007 and January 2021, both dates being approximate and inclusive, within the Eastern District of New York and elsewhere, the defendant KAVEH LOTFOLAH AFRASIABI, also known as “Lotfolah Kaveh Afrasiabi,” together with others, did knowingly and willfully act as an agent of a foreign principal, to wit: the government of the Islamic Republic of Iran, without prior registration with the Attorney General of the United States, as required by law.

(Title 22, United States Code, Sections 612 and 618(a)(1))

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