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INDICTMENT
The Grand Jury charges that, at all times material to this Indictment, on or about the dates
and times stated below:
INTRODUCTION
I. Beginning in or around January 2020, and continuing through at least September 2024, malicious cyber actors employed by the Islamic Republic of Iran's ("Iran") Islamic Revolutionary Guard Corps ("IRGC"), Masoud Jalili ("JALILI"), Seyyed Ali Aghamiri ("AGHAMIRI"), Yaser Balaghi ("BALAGHI''), and other persons known and unknown to the Grand Jury (collectively, "Conspirators"), prepared for and engaged in a wide-ranging hacking campaign that used spearphishing and social engineering techniques to target and compromise the accounts of current and former U.S. government officials, members of the media, nongovernmental organizations, and individuals associated with U.S. political campaigns. Such activity is part of Iran's continuing efforts to stoke discord, erode confidence in the U.S. electoral process, and unlawfully acquire information relating to current and former U.S. officials that could be used to advance the malign activities of the IRGC, including ongoing efforts to avenge the death of Qasem Soleimani, the former commander of the IRGC- Qods Force ("IRGC-QF").
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