On August 19, U.S. authorities unsealed a complaint charging Ali Chawla, Asim Mujtaba Naqvi, and Muzzamil Husnain Zaidi with violating the International Emergency Economic Powers Act (IEEPA). The three are accused of orchestrating a campaign to collect donations in the United States on behalf of Iranian Supreme Leader Ali Khamenei, and Zaidi faces the additional charge of operating as an unregistered agent of Iran in the United States. The U.S. Treasury Department imposed sanctions on Khamenei on June 24, 2019, and the purported scheme would also be a violation of other aspects of the U.S. embargo on Iran.

Chawla, Naqvi, and Zaidi only managed to collect sums in the tens of thousands of dollars according to the U.S. Justice Department. Their alleged ties to Khamenei, however, raise the profile of the case. A Justice Department press release also describes the trio as having connections to the Islamic Revolutionary Guard Corps (IRGC), an arm of the Iranian military designated as a “foreign terrorist organization” by the U.S. State Department on April 8, 2019. The tactics that Chawla, Naqvi, and Zaidi appear to have used to move money from the United States to Iran, namely dividing the donations into sums of less than $10,000 and transferring the funds through a third country, provide insight into how Khamenei and the IRGC acquire hard currency.

The Network

Of the three defendants, Zaidi seems to have the most substantial ties to Iranian officials. An affidavit filed by the Federal Bureau of Investigation (FBI) alleges that Zaidi traveled to Syria on an Iranian military aircraft in 2018. The affidavit claims that he met with Khamenei’s envoy in Damascus, Abolfazl Tabatabai, and visited military bases in Deir Ezzor controlled by the IRGC and one of its subunits, the Quds Force. The FBI believes that Zaidi, who holds one U.S. passport and two Pakistani passports, received training from an Iranian intelligence agency.

According to the affidavit, Zaidi was born in 1984 in Karachi, Pakistan, became a U.S. citizen in 2005, and worked as a branch manager at two different U.S. banks between 2006 and 2010. He spent much of his time in the United States until 2014, when he relocated to Qom, Iran, to attend al-Mustafa International University. The affidavit purports that, at that time, he began work for Islamic Pulse, a website aligned with the worldview of the Iranian government. Zaidi often returned to the United States and stayed in Houston, Texas, making his most recent trip in June 2020.

Zaidi’s two co-defendants seem to have their own links to Iran and the United States. Chawla, born in Pakistan in the same year as Zaidi, appears to have served as Zaidi’s primary contact in Iran. The affidavit states that Chawla, like Zaidi, resided in the United States on and off until 2014, when he moved abroad before settling in Qom. According to the FBI, Chawla was also affiliated with al-Mustafa International University and directed Islamic Pulse, but it remains unclear where he met Zaidi.

For his part, Naqvi seems to have offered support to Chawla and Zaidi from the United States. The affidavit states that Naqvi, also born in Karachi in 1984, received U.S. citizenship in 2010 and worked at a pair of U.S. banks between 2006 and 2011; though Naqvi and Zaidi’s employment at U.S. banks overlapped by several years, the affidavit makes no mention of how and where the two met. Naqvi resided in Houston, Texas, and was working for the University of Houston when the charges against him were made public. Unlike the Justice Department press release, the affidavit mentions no connections between Chawla, Naqvi, and the IRGC.

The Scheme

The Justice Department alleges that, between December 2018 and December 2019, Chawla, Naqvi, and Zaidi conspired to collect donations from residents of the United States on behalf of Khamenei. The affidavit describes a scheme in which the conspirators solicited donations online, employed couriers to transport the funds, divided the cash into sums under $10,000 to avoid scrutiny at U.S. airports, and routed some of the money through Iraq.

According to the affidavit, Chawla and Zaidi collected much of the money under the pretext of providing humanitarian aid to Yemen through an online campaign organized by Islamic Pulse. The FBI said that the campaign claimed to have the support of Khamenei and a prominent Iraqi cleric, Ali al-Sistani. The affidavit also mentions a pair of letters from Ayatollah Mohsen Araki, a member of the Assembly of Experts in Iran and a former representative of Khamenei, telling the members of Islamic Pulse that Khamenei and al-Sistani had authorized the group to spend half the proceeds of their campaign on the people of Yemen. The FBI interpret Araki’s message as implying that the other half of the money would go to Araki and Iranian officials.

The FBI accused Chawla and Zaidi of using several techniques to ensure the transfer of donations from the United States to Iran. The affidavit claims that the defendants recruited couriers—including some of Zaidi’s own U.S.-based family members— to collect money from donors in the United States, then bring the funds to Iran in cash in sums under $10,000 to avoid having to file a “currency and monetary instrument report” with U.S. authorities. The Justice Department asserted that the couriers, coordinated by Zaidi with support from Naqvi, lied to U.S. Customs and Border Protection about the origin and purpose of the money, using various cover stories. In one example outlined by the affidavit, several couriers traveled to Iraq saying that they would participate in the Arbaeen Pilgrimage there, only to go onward to Iran.

According to the FBI, Zaidi’s couriers transported $9,500 to Iran in August 2019, $13,160 to Iran in September 2019, $4,000 to Iran in October 2019, and $18,900 to Iraq in October 2019; messages between Naqvi and Zaidi intercepted by the FBI suggest that Zaidi sent as much as $45,000 with a group heading to Iraq. The affidavit notes that Zaidi himself flew from the United States to Iraq in October 2019 and discussed transporting money on behalf of a donor during that trip, but the amount of money that Zaidi was carrying on that journey, if any, remains unclear.

Though the charges against Chawla, Naqvi, and Zaidi focus on their activities in the United States, the affidavit portrays their campaign as an international endeavor. According to an Islamic Pulse video described in the affidavit, the organization had collected $90,000 in donations from Australia, Canada, Iran, Ireland, Pakistan, the United Kingdom, and the United States by June 2019, $60,000 of which had already made its way to Iran at that time. The FBI asserted that Chawla and Zaidi always solicited donations in dollars and euros rather than other currencies, and the affidavit mentions Islamic Pulse having access to a bank account in the United Kingdom.

Case Status

American authorities arrested Naqvi and Zaidi on August 18, 2020. Both were released to home detention in Texas, pending trial.

Under the terms of his supervised release, Naqvi is forbidden from contacting Ahmed Raza Zaidi, Akbar Husnain Zaidi, Burhan Haider Naqvi, Fakhar Zaidi, Feroza Zaidi, Mustafa Husnain Zaidi, Sayedda Palwasha Zaidi, Syed Hani Mehdi Naqvi, and a dozen other people. Nonetheless, the role of these individuals in the alleged scheme and their relationship with the defendants is not publicly known. The court ordered Zaidi’s mother and brothers to surrender their passports and said that Zaidi “must refrain from contacting or entering any consulate or embassy.”

Chawla remains at large.