1. The charges in this Indictment arise out of a scheme by the Government of the Islamic Republic of Iran to target dissidents who oppose the regime's violations of human rights, suppression of democratic participation and freedom of expression, and corruption. The regime has targeted such individuals for harassment, intimidation, and incarceration, among other tactics. In recent years, the regime has also targeted its perceived opponents residing outside Iran for kidnapping and capture. As described more fully below, in at least the last two years, Iranian intelligence services have lured Iranian expatriates lawfully residing in other countries to travel to locations where they could be captured, imprisoned in Iran, and executed.

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