'1 . . - . US. DISTRICT COURT . A0 91 (Rev. 12/10) Criminal Complaint I - NORTHERN DISTRICT OF TEXAS Saga? 53.251 United States'DiStrict Court 2315 I NORTHERN DISTRICT or - UNITED STATES OF AMERICA By Dem?? V. COMPLAINT EILAL ABOOD A CASE NUMBER: 3i l, the undersigned complainant being duly sworn state the following is true and correct to the best of my knowledge and belief. On or abOut April 14, 2,015, in the Dallas Division of the Northern District of Texas, defendant(s) did, make a materially false, ?ctitious and fraudulent statement and representation, in. a matter within the jurisdiction of the Federal Bureau of Investigation, in Violation of Title United States Code, Section(s) 1001 . I further state that I am a(n) Special Agent with the Federal Bureau of Investigation (FBI 2 and that this complaint is based on the following facts: See attached Af?davit of Special Agent (FBI) which is incorporated and made a part hereof by reference. Continued on the attached Sheet and made a part hereof: XX Yes No Signature of Comkp'la?inant Special Agent, (FBI) Sworn to before me and subscribed in my pres?r?ce. on this 13th @ay of May, 2015, at Dallas, Texas. UNITED STATES MAGISTRATE JUDGE . -V. .. Name a Title of Judicial Officer Signature of iudicin Of?cer AFFIDAVIT I, a Special Agent with the Federal Bureau of Investigation (FBI), being ?rst duly sworn, hereby depose and state as follows: AGENT BACKGROUND I have been a Special Agent with the FBI for over 19 years, and I am currently assigned to the FBI ?3 North Texas Joint Terrorism Task Force (ITTF). I have worked on counterterrorism matters for over two years. As a member of the JTTF, I work closely with agents and task force of?cers from other federal and local law enforcement agencies on a daily basis. FOREIGN TERRORIST ORGANIZATIONS On October 15, 2004, the United States Secretary of State designated Al??Qaida in Iraq (AQI), then known as Jam?at al Tawhid wa?al?Jihad, as a Foreign Terrorist Organization (PTO) under Section 219 of the Immigration and Nationality Act and as a Specially Designated Global Terrorist entity under section l(b) of Executive Order 13224. On December ll, 2012, the Secretary of State amended the Foreign Terrorist Organization (F TO) and Executive Order 13224 designations to include the . following new aliases: alnNusrah Front,.Jabhat al~Nusrah, Iabehet al?Nusra, The Victory Front, and Al-Nusrah Front for the People of the Levant (ANF). On May 15, 2014, the Secretary of State amended the designatiOn of AQI as ?a Foreign Terrorist Organization (F TO) under Section?219 of the Immigration and Nationality Act and as a Specially Designated Global Terrorist entity under section 1(b) of Executive Order 13224 to add the alias Islamic State of Iraq and the Levant as its primary name.The Secretary also added the following. aliases to the ISIL listing: the Islamic State of Iraq and al?Sham, the Islamic State of Iraq and Syria (ISIS), ad-Dawla al- Islamiyya ti al??Iraq wa?sh?Sham, Daesh, Dawla al Islamiya, and AlnFurqan Establishment for Media ProduCtion. To date, ISIL remains a designated FTO. In addition, on May 15, 2014, the Secretary of State, in response to the evolving nature of the relationships between ANF and AOL amended the TO designation of AQI to remove all aliases associated with al?Nusrah Front. Separately, the Secretary of State then designated al? Nusrah Front, also known as Jabhat al?Nusrah, also known as Jabhet al?Nusra, also known as The Victory Front, also known as Aleusrah Front for the People of the Levant, also known as Al?Nusrah Front in Lebanon, also known as Support Front for the People of the Levant, and also known as Iabaht al?Nusra li~Ahl al~Sham min Mujahedi al-Sham ti Sahat al~Jihad, as a Foreign Terrorist Organization under Section 219 of the Immigration and Nationality Act and as a Specially Designated Global Terrorist entity under section 1(b) of Executive Order 13224. ANF remains designated as an FTO. BACKGROUND The FBI is investigating numerous individuals who have traveled or are attempting to travel to Syria in order to involve themselves in the ?ghting that has 2 consumed Syria for more than three years. A variety of armed groups are operating in Syria, including groups that are ?ghting against the Syrian regime led by President Bashar Al Assad. Reports indicate that Ass-ad?s regime took violent action against individuals who protested against the regime and the current civil war ensued. The'Free Syrian Army (FSA) formed as a secular opposition force to tight the Assad regime. In addition, terrorist groups are ?ghting in Syria and Iraq, including (formerly known as AQI) and ANF. The self?proclaimedleader of is Abu Bakr al~Bagdahdi FACT OF THE INVESTIGATIGN Bilal Abood is an Iraqi-born naturalized US citizen, .who migrated to the United States in 2009. He speaks fluent English and Arable On March 29, 2013, Abood attempted to depart the United States at Dallas Fort Worth International Airport (DFW), but was denied boarding on an international ?ight. ?At the airport, FBI agents interviewed Abood and asked about his travel plans. Abood stated that he was merely planning to travel to Iraq to visit with family, and that he did not understand why he was prohibited from ?ying on that date. - On April 4, 2013, in Mesquite, Texas, FBI agents interviewed Abood again. They - asked Abood if on March 29, 2013 at DFW airport, he intended to go to Syria to ?ght, and Abood stated he did not. Later in the interview, Abood' admitted that his intent on March 29, 2013, was to go to Syria to tight Assad?s regime. Abood claimed he wanted to tight with the FSA. On or about ?April 17?19, 2013, the FBI learned that Abood was in San Antonio, Texas, planning to leave the United States to. go and ?ght in Syria. A con?dential human source (CHS) reported that Abood was watching Al?Qaida videos on social media, along with videos about the creation of ISIL. The videos referenced leader, Abu Bakr al?Baghdadi, and discussed obedience to orders given by Al-Qaida. Abood teld the CHS he wanted to help build the Islamic State of Iraq. On or about April 29, 2013, Abood left the United States through Mexico and traveled through various countries into Turkey. on September is, 2013, upon Abood?s return to the United States, the FBI interviewed him. Abood admitted traveling to Syria through Turkey, and claimed he went there to ?ght with the FSA. He described his trip to Deir Ezzour (Syria), and he claimed to have stayed in an SA camp, but also claimed that the FSA and ANF actively collaborated in achieving objectives, exchanging equipment, and committing attacks. Abood said he became frustrated with a lack of action, and he wanted to return to the United States. Abood denied ever providing ?nancial support to ANF, ISIL or any other terrorist organization. A search warrant was conducted on Abood?s computers on July 9, 2014. A review of Abood?s computer revealed Abood pledged an oath to Abu Bakr al~Baghdadi, the leader 'of ISIL, on June 19, 2014. The search warrant also revealed Abood had been on the internet viewing ISIS atrocities such as beheadings, and using his twitter account to tweet and retweet information on al?Baghdadi. On June 19, 2014, using ibn alislaam 4 Abood tweeted, pledge obediencetoItheiCaliphate Abu Bakr al?B aghdadir Here we renew our pledge to the Caliphate Abu Bakr al? Baghdadi come on supporter where is the pledger.? That post was retweeted by others. The twitter. account also revealed a tweet by Abood on I uly l, 2014, wherein he stated, ?Advice from Sheikh al?Hatari to the Elders of Al?Qaida God save On April I4, 2015, FBI agents went to Aboo?d?s residence in order to return his computer that was, seized in the 2014 search warrant. Abood admitted to the agents knowing that it was a crime to lie to an FBI agent, and Abood denied to the agents that he had ever pledged allegiance to Abu Bakr alquaghdadi. CONCLUSIGN Based on the foregoing facts and circumstances, there is probable cause to believe that on April 14, 2015, Bilal Abood, did knowingly and willfully make and cause to be made materially false, fictitious and fraudulent statements and representations in a matter within the jurisdiction of the Federal Bureau of Investigation, that is a counter?terrorism investigation, by falsely stating to federal law enforcement agents that he had never I pledged allegiance to Abu Bakr almBaghdadi (the leader of ISIL), in violation of 18? use. ?1001. Special Agent Federal Bureau of Investigation SUBSCRIBED AND SWORN TO BBEQREWN THIS MAY, 015. t, I 1 UNITED STATES MAGISTRATE JUDQE