THE GRAND JURY CHARGES THAT:

GENERAL ALLEGATIONS

At all times material to this indictment:
1. On or about January 11, 2024, United States Central Command Navy forces, including Navy SEALs and members of the Coast Guard Maritime Safety and Security Team (the Boarding Team"), were operating in the Arabian Sea. That evening, the Boarding Team conducted an authorized flag verification in international waters of a non-United States maritime vessel, a dhow, named the “Yunus. On board the dhow, the Boarding Team discovered no flag indicating nationality and fourteen crewmembers, including dhow captain MUHAMMAD PAHLAWAN. Hidden in the net hold of PAHLAWAN’s dhow was Iranian-made advanced conventional weaponry, including a warhead and propulsion and guidance components for medium-range ballistic missiles and anti-ship cruise missiles. During the interdiction. PAHLAWAN threatened other crewmembers to lie to the Boarding Team and ultimately lied himself about his role as the captain and other material facts. Two Navy SEALs on the Boarding Team, C.C. and N.I., went overboard and died during the interdiction.

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