Abdulrahman Mohammed Hafedh Alqaysi, an Iraqi refugee, was charged with conspiracy to provide material support to ISIS. Also charged are his cousin Mohammed (aka Moe) Amer Faisal Al Qaysi, another former Iraqi refugee, and Hami Jamshid aka Jamshid Ahmadzai, a naturalized U.S. citizen. Hafedh Al Qaysi, Faisal Al Qaysi and Jamshid resided in Richmond, Houston and Sugar Land, respectively. Hafedh Al Qaysi did unlawfully and knowingly conspire and agree with others known and unknown to provide material support and resources to the Islamic State of Iraq and al-Sham (ISIS), according to the charges. The Secretary of State has defined ISIS as a foreign terrorist organization. Hafedh Al Qaysi is also charged with three counts of making a false statement in a naturalization application. it is alleged that he falsely answered "no" when asked if he had ever been a member of or in any way associated, either directly or indirectly, with a terrorist organization, or if he was ever a part of any group or ever helped any group, unit or organization that used a weapon against any person or threatened to do so. The naturalization application also asks whether the applicant had ever committed, assisted with, or attempted to commit a crime or offense for which they were not arrested. Hafedh Alqaysi, Faisal Al Qaysi and Jamshid all falsely answered "no" to that question. It is also alleged that Jamshid procured citizenship or naturalization unlawfully. The three men face additional charges of conspiracy to commit wire fraud. Beginning on or about Jan. 1, 2015, through on or about March 10, 2017, they conspired together to devise a scheme to defraud and to obtain money and property by means of false and fraudulent pretenses, representations, and promises. It is further alleged that Hafedh Alqaysi also committed aggravated identity theft in relation to that scheme.