AO 91 (Rev.

11/1I) Criminal Complaint FILED

UNITED STATES DISTRICT COURT DEC 04 2024
for the
PETER~R., CL!:RK
US DI J URT, EDNC
Eastern District of North Carolina [:] BY _ _.._c..:....___ _ DEP CLK

United States of America )

v. )
)
ALEXANDER JUSTIN WHITE )
a/k/a "Sulaiman AI-Atnriki'' )
)
)
Defendant(s)

CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of December 4, 2024 in the county of Wake in the
Eastern District of North Carolina . the defendant(s) violated:

Code Section Offense Description

18 USC § 2339B Providing, Attempting, and Conspiring to Provide Material Support to a
Designated Foreign Terrorist Organization.

This criminal complaint is based on these facts:

See Attached Affidavit

~ Continued on the attached sheet.

Monika Van Hooser, Special Agent, FBI

Printed name and title
Attested to by the complainant in accordance with
the requirements of Fed. R. Crim. P. 4.1 by
telephone (reliable electronic means).

Cjty and state: Raleigh, North Carolina BRIAN S. MEYERS, U.S. Magistrate Judge
Printed name and title

(jJ2)
Case 5:24-mj-02541-BM Document 1 Filed 12/04/24 Page 1 of 30
 IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA

UNITED STATES OF AMERICA

V.

ALEXANDER JUSTIN WHITE Filed Under Seal

a/k/a "Sulaiman Al-Amriki"

AFFIDAVIT IN SUPPORT OF
CRIMINAL COMPLAINT

I, Monika Van Hooser, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of a criminal complaint charging ALEXANDER

JUSTIN WHITE, also known as "Sulaiman Al-Amriki" (hereinafter "WHITE"), with knowingly

attempting to provide material support and resources, as defined in 18 U.S.C. Section

2339A(B)(l), including personnel (including himself) and services to a foreign terrorist

organization (FTO), namely the Islamic State of Iraq and al-Sham (ISIS), which at all relevant

times was designated by the Secretary of State as a foreign terrorist organization, knowing that

ISIS was a designated foreign terrorist organization and that ISIS had engaged in and was engaging

in terrorist activity and terrorism - all violation of 18 U.S.C. § 2339B (Providing, Attempting, and

Conspiring to Provide Material Support to a Designated FTO).

2. I have been Special Agent with the Federal Bureau of Investigation (FBI) since

January 2017. I have been assigned to the FBI Charlotte Division, Raleigh Resident Agency Joint

Terrorism Task Force (JTTF) since May 2020. Prior to May 2020, I was assigned to the FBI

Washington Field Office's Counterterrorism Extraterritorial Unit as well as the JTTF. I have been

trained in and have extensive experience with matters related to domestic and international

Case 5:24-mj-02541-BM Document 1 Filed 12/04/24 Page 2 of 30

terrorism as well as the use of the internet, cellular smart phones, social media, and encrypted

messaging applications (EMAs) to communicate with others engaged in criminal activity. My

training and experience have provided me with an understanding of the criminal laws of the United

States regarding national security and I am familiar with various ideologies supporting violence to

achieve their goals to suppress others. I have conducted and participated in several investigations

resulting in a wide variety of criminal charges, including many of which have involved persons

conducting potential or actual acts of terrorism.

3. I have personally conducted this investigation and have witnessed many of the facts

and circumstances described herein. These facts come from my personal observations, my training

and experience, and information obtained from other agents and witnesses. This affidavit is

intended to show merely that there is sufficient probable cause for the requested criminal complaint

and does not set forth all of the facts or all of my knowledge about this matter.

FACTS IN SUPPORT OF PROBABLE CAUSE

4. On October 15, 2004, the United States Secretary of State designated al-Qaeda in

Iraq ("AQI"), then known as Jam' at al Tawhid wa' al-Jihad, as a Foreign Terrorist Organization

("FTO") under section 219 of the Immigration and Nationality Act and as a Specifically

Designated Global Terrorist entity under section l(b) of Executive Order 13224.

5. On or about May 15, 2014, the Secretary of State amended the designation of AQI

as an FTO under Section 219 of the Immigration and Nationality Act and as a Specifically

Designated Global Terrorist entity under section l(b) of Executive Order 13224 to add the alias

Islamic State of Iraq and the Levant ("ISIL") as its primary name. The Secretary of State also

added the following aliases to the FTO listing: The Islamic State of Iraq and al-Sham ("ISIS" -

which is how the FTO will be referenced herein), The Islamic State of Iraq and Syria, ad-Dawla

Case 5:24-mj-02541-BM Document 1 Filed 12/04/24 Page 3 of 30

al-Islamiyya fi al-Iraq wa-sh-Sham, Daesh, Dawla al Islamiya, and Al-Furquan Establishment for

Media Production. On September 21 , 2015 , the Secretary of State added the following aliases to

the FTO listing: Islamic State, ISIL, and ISIS. On February 28, 2018, the Secretary of State added

ISIS-West Africa to the FTO listing with the following aliases: ISIS West Africa Province, Islamic

State of Iraq and Syria West Africa Province, Islamic State of Iraq and the Levant-West Africa

(ISIL-WA), and Islamic State West Africa Province (ISWAP). To date, ISIS and ISIS West Africa

remain designated FTOs.

6. Abu Bakr al-Baghdadi ("al-Baghdadi") was the emir (leader) ofISIS until his death

on or about October 27, 2019. The current emir ofISIS is Abu Hafs al-Hashirni al-Qurashi.

SUBJECT BACKGROUND

7. ALEXANDER JUSTIN WHITE, also known as "Sulaiman Al-Amriki,"

("WHITE") is a 29-year-old United States Citizen, born June 5, 1995, who currently lives at 4600

University Drive, Apt 516, Durham, North Carolina, and who utilizes the phone number 423-744-

4148 and email address alecw651995@gmail.com.

8. WHITE's primary social media account Facebook, UID 100001226275103 1 is

represented by the name "Sulaiman Al-Amriki," however investigation discovered that the name

on the Facebook page had previously been listed as "Alec White" as recently as June 2024. This

is consistent with the act of using a "kunya" which is an Arabic term relating to the practice of

referring to parents by the names of their children; however, your affiant knows the term to

commonly be used by Islamic extremists as representing their taking on of a nom de guerre for

1
Through the course of the investigation this UID was assessed to be WHITE's through IP address, phone and
messaging activity, as well as GPS pings in combination with surveillance.

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clandestine purposes. Here, WHITE took on the kunya "Sulaiman Al-Amriki" which translates to

"Sulaiman the American."

WffiTE'S SOCIAL MEDIA POSTINGS DISPLAY SUPPORT FOR ISIS

Between May and October 2024, WHITE frequently used his Facebook account to make

posts supporting ISIS and jihad. For example:

9. In May 2024, WHITE shared a post on his Facebook timeline of an ISIS

propaganda video depicting ajihadist2 singing a nasheed3 during the Battle ofBaghouz. The Battle

of Baghouz is commonly referred to as the last stand of ISIS in Syria, resulting in the territorial

defeat of the ISIS-declared Caliphate. 4 Your affiant is aware that this video is a popular video

among ISIS supporters and is frequently circulated online to attract new members and generate a

passion for fighting.

• ••
ay 7 ~

2
"Jihad' is an Arabic term commonly used by ISIS supporters and extremists to mean violence against non-Muslims.
A ''jihadist" is an individual waging jihad.
3
"Nasheed' is an Arabic tenn generally understood to mean a chant which may or may not be accompanied with
instruments. Nasheeds are often used by Islamic Extremists to spread propaganda.
4
The "Caliphate" (from the Arabic "Khilafah") is a political institution led by a caliph, or leader, in the Muslim
community; ISIS declared the establishment of an Islamic caliphate in June 2014 and the term is used to refer to the
ISIS goal of establishing a physical religious state for the Islamic community.

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 10. In June 2024, WHITE shared a post on his Face book timeline, from a channel on

an EMA that focuses on fundraising for people in the camps in eastern Syria. The post included a

video created by the "Green Blrds" propaganda network. The term green birds or green birds of

Jannah (heaven) as a reference to martyrs 5 , and is commonly used by Islamic extremists to laud

their fighters who have died through violent jihad.

5
This arises from a "hadith" (a form oflslamic oral tradition) which states the souls of the believers are in the
shape of a bird in paradise and as for the souls of martyrs, they are inside green birds.

Case 5:24-mj-02541-BM Document 1 Filed 12/04/24 Page 6 of 30

 11. In July 2024, WHITE posted a video on his timeline glorifying what is assessed to

be ISIS and commented with a pointer finger raised emoji 6 next to the word "Baqiyah." 7

12. On September 8, 2024, WHITE posted a quote stating, "The one who fights in the

cause of Allah has a guarantee from Allah. Either he will raise him to his forgiveness and mercy,

or he will send him back with reward and spoils of war."

Su l aiman A I -Amriki
< Gm· .&&

The P..-ophet ~ said:

"The one vvho fights in the cause o f Allah has a

gua..-antee f..-om Allah . Eithe..- he vvill ..-aise him to his
forgiveness and mercy.. or he will send him back vvith
..-evva..-d and spoi l s of vva..-. The likeness o f the one vvho
fights in the cause o f Allah is that o f one vvho fasts
and p..-ays at night vvithout ceasing , until he ..-etu..-ns . "

[Sunan l bn - Majah 2754]

~ Lik e C::) Comm e nt {9 S e nd

6
The raised index finger gesture, or "tawhid," is often used to denote one' s belief in monotheism which is a key
component of the Muslim faith and part of daily Islamic prayers. The "tawhid" finger is commonly used by ISIS
militants to affirm their ideology and to signal their support for acts of terrorism toward anything against Allah.
7
"Baqiyah" is a common phrase that is expressed, similar in nature to the commonly referenced term "A llahuah
Akbar," in which individuals in this context show support for ]SIS.

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 13. In text communications with an FBI Online Covert Employee (hereinafter "OCE")

WHITE sent the OCE a screenshot of a pro-ISIS EMA channel claiming to fund.raise for detained

ISIS members and their dependents. The fundraising organizations, primarily run on pro-ISIS

EMA channels, claimed to support ISIS member dependents, including women and children, who

are detained at the Al Hol and Al Roj 8 camps. These camps are known to be used by ISIS to obtain

funds under the guise of humanitarian aid and are locations at which ISIS recruits for members. In

text communications with an FBI Online Covert Employee (hereinafter "OCE") on October 10,

2024, WHITE told the OCE about a "sister" in Al Hol who had a private EMA channel for ISIS

propaganda that had thousands of videos dating back to "Jihad in Iraq." According to WHITE,

this included videos on how to make IEDs and was where WHITE downloaded many of his videos

from.

14. WHITE's Facebook timeline also shows several posts and reposts in reference to

well-known ISIS supporters and scholars including Abu-Hudayfah Al-Ansari 9, Abdul Majeed al-

Hitari 10 , Ahmad Musa Jibril 11 , and Anwar Awlaki 12 depicting each in a positive light. One such

instance includes a post by WHITE that states "Al Wala wal Bara" and includes a video of quotes

from Anwar Awlaki. This Arabic phrase literally means "loyalty and disavowal" and is commonly

used by ISIS members in support of their extremist ideology towards violence.

8
Al-Hawl, also spelled Al-Hol, and Al-Roj are internally displaced people (IDP) camps located in Syria.
9
Abu-Hudayfah Al-Ansari is the recognized spokesman for ISIS.

10
Abdul Majeed al-Hitari is a Yemeni sheikh known for promoting ISIS on Facebook.

11
Ahmad Musa JibriJ is a Palestinian-American Islamic radical preacher who was convicted in the U.S. in relation to
money laundering.

12
Anwar Awlaki was an American-Yemeni jihadist who was killed in a 20 l l while in Yemen by a U.S. Government
drone strike.

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 15. Between at least May and August 2024 WHITE discussed with approximately

seven different Facebook users his ability to send financial aid to them. Of those, at least five

indicated they were in the Al Hol or Al Roj camps. On several occasions, WHITE expressed to

the individuals on Facebook that the "kuffar" took down his online money transfer account and he

could only support them using one specific money transfer application. He then explained that he

sent money through the European Union (EU) first and then it would get to those individuals.

WHITE'S SOCIAL MEDIA INTERACTIONS DISPLAY INTENT TO JOIN ISIS

WHITE openly discussed his desire and intention to travel overseas to join ISIS with

various individuals on Facebook and over EMAs:

16. Between June and August 2024, WHITE engaged in direct message conversations

with a Facebook user (USER 1) claiming to be from Morocco. WHITE disclosed to USER 1 that

he is from the United States, which he called the country of "kuffar" 13

and "dar al-harb ," 14 and

indicated that he had plans for "hijrah" 15 to "somewhere in Sahel." 16 On June 23 , 2024, USER 1

asked WHITE if he wanted to travel to where the Islamic State is, to which WHITE replied, "Yes

InshaAllah ." 17 USER 1 then asked if WHITE had someone to facilitate his travel and WHITE

13
"Kuffar" (also spelled kufr or kafir) is an Arabic term meaning "non-believer" typicaJly in reference to the non-
belief in Allah' s teachings, however among extremist jihadists it is used to denote blasphemy, evilness, or identify
non-Muslims or "infidels" in an extreme derogatory nature.
14
"Dar al-harb" is an Arabic term meaning enemy territory or house of war.

15
"Hijrah" is an Islamic term that is used to reference the Islamic Prophet Muhammad' s migration from Mecca to
Medina in order to escape persecution. The term is frequently used by extremists and foreign fighters in reference to
leaving their own country and traveling to a terrorist-held country to join the ranks of the militants.

16
The "SaheI'' is a geographical area Africa spanning across the Sahara from the Atlantic Ocean to the Red Sea. 1n
2022, ISIS declared a new faction, ISIS-Sahel, which encompassed areas in the already designated FTO ISIS factions
of West Africa and the Greater Sahara.

17
"lnshaA /lah" is an Arabic term meaning "God willing" often used to denote hope that a certain future event will
come about favorably.

Case 5:24-mj-02541-BM Document 1 Filed 12/04/24 Page 9 of 30

replied "I have." Also, on June 23 , 2024, WHITE disclosed to USER 1 that he met someone

through an EMA who spoke with him about making hijrah, and that WHITE had told that

individual that he wanted to go to an ISIS-controlled location and specifically noted "the strength

is more in Africa." He further told USER 1 that he was trying to ensure he did not do anything

suspicious in order to travel safely.

17. On July 10, 2024, USER 1 informed WHITE about a social media application

where he could find individuals to help with travel to "the brothers." 18 During that conversation,

WHITE asked USER 1 which areas they thought had more strength, to which USER 1 replied,

"Mozambique, Mali and Nigeria are also lands of jihad." WHITE followed up by stating that he

had originally wanted to go to Sinai. On July 17, 2024, while still in conversation with USER 1

about how to coordinate travel overseas, WHITE told USER 1, "Really I need to know some

muwahideen 19 brothers living here maybe I could meet even they some distance away."

18. Between April and September 2024, WHITE engaged in direct message

conversations with a Facebook user (USER 2) claiming to be a Moroccan living in Syria after

making hijrah. On September 8, 2024, WHITE disclosed to USER 2 that he was planning to do

hijrah to the Sahel. When USER 2 asked if WHITE wanted to become a mujahid20 , WHITE

responded in the affirmative stating, "InshaAllah. " USER 2 asked for WHITE's EMA handle

shortly following a conversation about which group WHITE was interested in joining because

USER 2 could provide more information about them, and the direct Facebook messages stopped

thereafter.

18
Islamic extremists such as ISIS typically refer to members or supporters of their ideology as "brothers."

19
An Arabic term referring to those who believe in Tawhid.
20
A "Mujahicf' (or Mujahideen) an Arabic term meaning one who commits jihad. Your affiant knows this to be used
by extremists to mean fighters and those who carry out terrorist attacks.

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 19. On September 20, 2024, WHITE received a private message from a Face book user

(USER 3). Following basic greetings, USER 3 indicated he was with the "real brothers" earlier

that day and followed with the pointer finger raised emoji, also known as the Tawhid gesture, and

a black flag emoji. USER 3 then asked if WHITE was a supporter as well, to which WHITE

replied, "Yes brother" followed by the pointer finger raised emoji and a black flag emoji. Shortly

after, USER 3 asked if WHITE agreed with fighting the kuffar, to which WHITE stated he did.

A summary of this portion of the conversation is as follows:

USER 3: I was with the brothers this morning at the mosque

WIDTE: MashAllah
USER 3: naam real brothers
WHITE: Yes
USER 3: !!! fla
WHITE: Alhumdullilah
USER 3: Do you support too?
WHITE: Yes brother (J,.
USER 3: masha Allah ... that' s the real Islam ... we must fights the kufrs
WHITE: InshaAllah
USER 3: do you agree?
WHITE: Yes brother

20. Also, while in conversation with USER 3, WHITE noted that he was trying to

make hijrah. USER 3 disclosed to WHITE that he was in Europe with many others doing "work"

successfully and expressed that "this is a holy fight ... that' s why we must support" followed by a

pointer finger raised emoji and a black flag emoji. WHITE continued to agree with USER 3' s

sentiments throughout the entirety of the conversation.

21. On September 20, 2024, WHITE received a private message from a different

Facebook user (USER 4), who referenced WHITE by his actual first name rather than his kunya.

USER 4 told WHITE that WHITE could potentially be prosecuted for material support to a

terrorist organization because WHITE had shared terrorist propaganda, and he should seek legal

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advice to rectify his situation. Although WHITE was active on Facebook at the time of the

messages and thereafter, he never responded to USER 4' s message.

WHITE'S CONTACT WITH FBI OCE FURTHER DISPLAYS DESIRE TO JOIN ISIS

In conversations between September and October 2024 with the FBI OCE over EMAs 21 ,

WHITE expressed his interest and intent to join ISIS on numerous occasions including pledging

allegiance to the leader of ISIS, discussing fighting against U.S. military members and citizens,

and becoming a mujahid. For example:

22. On September 10, 2024, the OCE contacted WHITE by posing as an ISIS facilitator

located overseas. Based on WHITE's expressed intentions elsewhere, the OCE questioned

whether WHITE still intended to join them overseas, to which WHITE stated he did.

23. On September 11 , 2024, WHITE responded to a questionnaire presented by the

OCE, intended to be a purported application for joining ISIS. The OCE asked WHITE, "what

skills do u have that will support the IS [meaning the Islamic State, an alias for ISIS]?" WHITE

was initially non-specific but later on stated he owned guns and knew how to shoot them, take

them apart, and clean them. In the same line of questions, the OCE asked WHITE who his

emergency contact would be if WHITE was martyred. WHITE replied with his grandfather's

name and phone number.

21
The OCE and WHITE messaged over various platforms throughout the course of the investigation. WHITE's
known usemames based on these conversations were Sulaiman AI-Amriki, Sulaiman, and Sulaiman95.

11

Case 5:24-mj-02541-BM Document 1 Filed 12/04/24 Page 12 of 30

 24. On September 13, 2024, WHITE told the OCE that he had saved enough money

to travel for hijrah and that he had no obligations left at home before leaving, stating, "No family

matters no debts." The OCE asked when would he be ready to travel, to which WIDTE responded,

"I look straight at this and my heart starts pounding fast. .. [from] the good excitement." The OCE

asked what WIDTE's intentions were upon his arrival and WIDTE stated, "To be a Mujahid

InshaAllah."

When u get here akhi, what does your

heart tell you to do. Do u want to earn
the highest reward as a mujhadeen or
something else ?

To be a Mujahid lnshaAllah 9 42 PM

25. On September 18, 2024, WHITE sent OCE a recorded video of himself2 2 greeting

the Emir. 23 Specifically, in the video WHITE pledged his bayat24 to ISIS emir Abu Hafs al-

22
Based on facial comparisons between the person in the video and WHITE's known DMV and passport photos, as
well as surveillance during the investigation, your affiant believes the person in this video to be an accurate
depiction of WHITE.

23
An "Emir" is the Arabic term for a commander or ruler. Based on the context of the conversation, your affiant
assesses this to be in reference to the Emir ofISIS.

24
" Bayaf' is an Islamic term used to indicate an oath or allegiance to a specific leader.

12

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Hashimi al-Qurashi, expressed his desire to be in the Dawla 25 soon, indicated he was preparing

for hijrah, and further expressed his excitement to make hijrah.

C> k a y b r o th e r

4•F¥CC:-

Mashallah brother yes. Please make

quick video if u can. Pledge bayat is
good or inshallah just speak to why u
want to come to Sham and make bayat
later akhi. I think Emir just want to see
video first to make sure u are good
brother who on proper deen. oo:o7 ✓/

26. On September 14, 2024, the OCE stated, "The brothers are working on special

opportunity for you to speak with Emir Soon, Does this interest you akhi ["my brother]?" White

responded, "It very well does brother."

27. On September 24, 2024, believing that he was going to talk to the ISIS Emir of the

battalion where the OCE was supposedly located, WHITE told the OCE throughout the day, "I'm

very excited at (sic) shy as well ... ," and," ... my heart races when I think ofit [smiling face emoji],"

and also, "Yes big day ... I've been thinking all night about talking with Emir ... please give him

Salam 26 from me and that it is a honor to speak with him," and finally, "I can' t wait until tonight. ..

I'm excited."

28. That evening, a video call was initiated and an FBI confidential human source

(CHS) posed as the Emir' s spokesperson so that they could speak in English. During the

approximately 27-minute video call, WHITE was asked if he prayed istikhara 27 about making

hijrah to join ISIS. WHITE responded that he did and felt as though this was for him. He also

25
Your affiant assesses "Daw/a" to be a shortened version of "Dalwa al lslamiya" which is another term used to
mean the Islamic State I ISIS.

26
"Salam" is Arabic for "peace" and is used as a general greeting within Muslim communities.
27
"lstikhara" is a common prayer for guidance often performed before making a big decision.

13

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told the CHS that in the past when a lot of brothers were making hijrah to Syria, WHITE was

afraid that he would be talking to the wrong people, those pretending to be Dawla, and get in

trouble. WHITE stated he felt guilty for remaining here. At one point, while discussing whether

WHITE had any firearms experience, WHITE noticed the CHS sitting beside a weapon and

pointed out that it was an AKM 7.62 x 39 style rifle.

29. Following the call, WHITE told the OCE that he was glad to have had the

opportunity even though he was shy and had difficulty speaking, but loved talking to the Emir' s

spokesperson and could not wait to meet everyone.

30. On September 24, 2024, when OCE asked if WHITE was ok with killing members

of the U.S. Military or other U.S. citizens, WHITE stated, " .. .if it was a family member I would

still fight back with them ... There is no us troops love for homeland or any of this thing."

Also - might ask how u feel about

jihad. Specially if you ok with killing us
military and maybe even us citizens or
other kuffar in the name of spreading
Islam and when commanded by
Allah(SWT) to do so. Better to know this
now - hen in middle of battle later.
~ e what are your thoughts on
this matter?

sulaiman95

ll if it was a family member I would

g t back with them 02:33

There is no us troops love for homeland or

any of this thing 02:35

31. On September 27, 2024, in a conversation with the OCE regarding placement of

arriving mujahideen to Dawla, WHITE was asked what his top choice of units would be given

14

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the option of several possible units including computer operations, money matters, food work, and

military/fighting. WHITE replied, "Military units .. ." The next day when WHITE was told that

he would be assigned to the fighter unit, as was his choice, in the ISIS-West Africa division and

would be on the battle line, WHITE replied, "Alhumdilillah [praise be to God] everything that I

wished for and dreamed about is happening in front of me."

Akhi the brothers and - have discussed

this matter and I am joyed to inform you
that alhumdullah Allah(SWT) has blessed
you and has granted you with your choice
of fighter unit in IS-West Africa division.
lnshallah, may u arrive safely and train
under command of Amirul Jaish. U then
go to battle line with others in english
speaking unit and be tip of arrow in spread
of Sharia across continent. I know of at
least 3 other american brothers in this
unit. lnshallah 100 years from now may
nasheeds be sung about our battles and
heroism as mujhadis. I so very excited at
this moment brother. Your mission in this
dunya is now clear and your wait has been
with purpose akhi. 17:24

What u think? 17:24

sulaiman95
Alhumdulillah everything that I wished for
and dreamed about is happening in front
me 1738

32. WHITE disclosed to the OCE that he owned guns and knew how to shoot them,

take them apart, and clean them. Additionally, WHITE regularly sent the OCE videos depicting

fuefights, death, and even the adoration of children training to fight with ISIS. Further, WHITE

would often have dreams about fighting with ISIS and would describe them to the OCE in detail

saying things like, "I saw brothers who were prisoners there and men standing guard .. . I was then

handed a weapon and we all rode in the direction of this place," and "there were so many

brothers ... and everyone was preparing themselves loading magazines," and also, "me and many

15

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other brothers were sitting around and one brother that looked like Abu Wahib 28 ," followed by an

image of a fighter holding a rifle.

In approximately October 2024, WHITE's Facebook profile picture had been changed to the

photo of Abu Wahib shown above.

33 . On September 28, 2024, WHITE told the OCE that he had not been to the range in

a while and intended to go shoot that day. When asked what he planned to train with, WHITE

sent the OCE a photo of a wall of guns with a specific one circled. He then explained that all of

the guns were available to rent to shoot but if you had a special license you could purchase that

one, likely referring to the automatic rifle circled in the picture. WHITE went on to state, "all the

ones around it they make semiautomatic versions of those and technically I could buy those around

it ... the red labels on them means they are selective fire ... or automatic in general."

28
Abu Wahib, otherwise spelled Abu Waheeb, was an Iraqi militantjihadist who served as the leader ofISIS in Iraq
until he was killed in a US-led coalition airstrike in 2016. Abu Waheeb was also a former member of al-Qaeda and
appeared in a nwnber ofISIS execution videos.

16

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 34. A review ofWHITE's firearms-related records revealed that since 2019, WHITE

obtained multiple weapons permits and made several purchases and sales of firearms. Specifically,

WHITE purchased an ATI FX45 1911 pistol in February 2019, an AM-15 Optic Ready rifle in

June 2019, and a Glock 19 pistol in March 2021. WHITE was also found to have sold a Beretta

92Al pistol in March 2021 , which he bought in January 2021 , and a Riley Defense AK-47 rifle in

April 2022, which he bought in November 2021.

35. Pursuant to information received during the course of the investigation, in July 2024

photos of WHITE training with firearms were obtained. Of the photos viewed, two pictures were

identified which appeared to be WHITE at an indoor firing range shooting a pistol at a target. The

firearm being used in the photos appears to be a firearm known to be owned by WHITE.

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 WHITE'S DESIRE TO JOIN ISIS IS NOT RECENT

WHITE expressed his frustration about missing his opportunity to join ISIS in the past on

numerous occasions to various individuals. For example:

36. As previously described, WHITE told USER 1 in a Facebook private message that

his intention in the past was to join ISIS in Sinai. Travel records between 2018 and 2024 indicate

that WHITE traveled internationally several times, to include a trip to Egypt in 2018. On

September 11 , 2024, WHITE told the OCE that he had at one time planned to move to Egypt. He

went on to tell the OCE that he wanted to join ISIS back then but did not have contact with anyone

and did not know where to go, so he stayed quiet in fear of getting in trouble. WHITE further

expressed his frustration for missing his opportunity saying, "I have missed a lot I should have

18

Case 5:24-mj-02541-BM Document 1 Filed 12/04/24 Page 19 of 30

been in Sham after I took my Shahadah." Your affiant is aware that during the time ofWHITE's

shahada, or profession of the Muslim faith, in approximately 2015 , ISIS in Syria, or Al-Sham, was

heavily active in terrorist activity and fighting.

I had no contact with Dawla then I

didn't know really where to go because
I remembered that a lot of brothers and
sisters got in trouble because they were
talking to people that were pretending to
be Dawla

Were you scammed or get in trouble?

922 PM ✓/

No just I stayed quiet because I didn't

know who to go to

I understand akhi. Better to play it safe.

Those were surly dangerous times .. things
are better now.. 924PM ✓/

Just sometimes I get frustrated with

myself because I have missed a lot I
should have been in Sham after I took my
Shahadah

37. In May 2024, WHITE told a Facebook user (USER 5), from Morocco, that he

supported ISIS and had wanted to make hijrah in the past. A summary of this portion of the

conversation is as follows:

USER 5: You support dawlaa brother

WIDTE: Yes
USER 5: Mashallah how long you support them
WHITE: Since for long time
USER 5: Do you thought about making hijra to sham before
WHITE: I was thinking at one point for the land of the two rivers 29

29
"The land of two rivers" is a reference to Iraq.

19

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 38. WHITE went on to explain to USER 5 that it was hard to get information on ISIS

in Syria but that he thought about going to Iraq or Syria previously. USER 5 told WHITE that the

situation in Syria was not like it was in the past, to which WIDTE expressed his understanding

that the strength was now in Africa.

39. On another occasion WHITE discussed his current and historical intentions to join

ISIS with a Facebook user (USER 6) who claimed to be from Mali and who told WHITE they

could help facilitate his travel to Mali. On July 13, 2024, WHITE told USER 6 that he was a

supporter ofISIS, "For a long time but over time I kept quiet because I didn't know who to contact

to guide me through hijrah. I was scared of mistakenly talking to people that were pretending to

be Dawla ... That is how many brothers and sisters got into trouble." WHITE also disclosed to

USER 6 that he had a plan to get to Dawla and was "in contact with the jamaat 30 in Africa" who

were "coming up with plan so that I can remain safe while on Hijrah."

WHITE'S ONGOING CONCERNS WITH GETTING CAUGHT

40. Throughout the course of the investigation, WHITE constantly mentioned his

concerns with traveling to join ISIS and discussed ways to obfuscate his true intentions from law

enforcement and from those around him in conversations with others. Additionally, as described

in more detail above, WHITE was aware that others "got into trouble" when they talked to people

pretending to be ISIS members and who were attempting to travel to join ISIS.

41. On September 13, 2024, the OCE asked what WHITE's fears were in regard to

traveling for hijrah. WHITE replied that traveling now would be different than in the past when

many people were traveling to join ISIS in Syria through Turkey. WHITE believed that Turkey

was once seen as a tourist destination and therefore people traveling that route were not questioned

30
" Jamaaf' is an Arabic term meaning group.

20

Case 5:24-mj-02541-BM Document 1 Filed 12/04/24 Page 21 of 30

about their travel intentions. WHITE then told the OCE that upon return from his trip to Egypt,

he was questioned about his trip and he believed it was because the government thought he was

trying to join "wilayat Sinai," also known as the Islamic State in the Sinai Province. WHITE told

the OCE he was worried that he would be questioned about the intentions of his trip.

Alhumdu l lah akhi . Te l l me your fears

then ✓/

It's different with how it was back in the

day when many were going to Sham
they go to Turkey and tawagheet new
it's a possibility that there are many
doing that but also they see Turkey as a
big tourist destination s o they would be

big tourist des tination s o th e y would b e

like okay th y might com e for th a t . But
I' m worried if they s k m e ques tion s

I think back in the day they thought w as

goi ng for wilayat Sinai

When I came back Homeland security

was asking me questions like where I
was stuff like that

But Morocco no prob l em both times

854PM

42. Similarly, on the September 24, 2024, video call with the CHS, WHITE told the

CHS that he was nervous about traveling. WHITE opined that when everyone was going to Sham

in the past and they traveled through Turkey, the people at the airport overlooked those individuals

assuming they were traveling to Turkey for tourism rather than to join ISIS. WHITE further

expressed his concern about how people at the airport would react and what kind of questions they

would ask him about where he was traveling to because now things were different.

43. On September 28, 2024, while discussing travel plans, WHITE asked the OCE,

"How do I make it where nobody looks into that I left" and followed up by telling the OCE he was

concerned that once he left people would "start looking into the matter that I'm gone and figuring

21

Case 5:24-mj-02541-BM Document 1 Filed 12/04/24 Page 22 of 30

it out then questioning every person that I ever knew here." WHITE then withdrew his question

and told the OCE that he was just overthinking the situation.

44. On October 2, 2024, again while discussing travel plans with the OCE, WHITE

voiced his concerns about traveling through the airport and wondering if law enforcement would

be aware that people were trying to make their way to ISIS from there. Specifically, WHITE

asked, "Are the others at the airport and authorities aware that there is a big possibility that many

will make their way to Dawla from there".

45. On October 8, 2024, WHITE sent the OCE a screenshot related to an EMA' s recent

change in posture regarding responses to legal orders from authorities. He followed up by asking

"Honestly ... do you think I'm good with everything ... Should I go and deactivate right now".

After discussing whether WHITE should post less jihadi material online out of precaution,

WHITE asked the OCE, "If they were going to try anything would they wait to intercept me at

airport." The OCE guessed that would not be the case and WHITE replied, "So if they were

suspicious, they would have probably already came to arrest me." Your affiant assesses the

reference to "they" in this context to mean law enforcement.

WHITE MAKES PLANS TO TRAVEL TO AFRICA TO JOIN ISIS

46. Although WHITE frequently voiced his concern about traveling overseas to join

ISIS and getting caught by law enforcement authorities, WHITE continued making plans to leave.

47. On September 29, 2024, the OCE asked WHITE when he would be ready to travel,

to which he told OCE, "Maybe by early December ... InshaAllah." The following day, WHITE

told the OCE that nothing was keeping him from "just packing up right now and driving to

airport ... And as I write this my heart is beating fast SubhanAllah [Glory be to Allah]."

22

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 sulaiman95

- how I'm gonna leave is just I will let

everything remain how it is and I just leave
out of here. 20:22

I don't try to make arrangements for

apartment or anything like that 20:25

Do you know what I mea~ zo:zs

So technically not really anything keeping

me from just packing up right now and
driving to airport

And as I write thi~ my heart is beating fast

SubhanAllah 20:31

48. On October 8, 2024, the OCE asked WHITE ifhe purchased a ticket yet, WHITE

replied by confirming the date of intended travel and later when discussing the need to book a

return flight to lower suspicions, WIDTE stated, " .. . I would rather die then [sic] to go back here."

WHITE also disclosed to the OCE that he had vacation time he could use so that his travel would

not look suspicious.

49. On October 16, 2024, WIDTE sent OCE a screenshot of a travel itinerary showing

a flight departing from Raleigh-Durham, International Airport (RDU) on December 4, 2024 to

Rabat, Morocco. WHITE told the OCE that "a lot of things [are] happening ... Alhumdulillah"

followed by the pointer finger raised emoji, depicting the tawhid gesture that ISIS militants

typically pose with and use.

23

Case 5:24-mj-02541-BM Document 1 Filed 12/04/24 Page 24 of 30

 A lot of things happening 0034

Raleigh to Raba

e :oo m
Amv Thu, Oec5
, United P rls, France (COG-
ti - o ssy-chartes d G ull )
Ti rmtnal 2E

Ti ·- · 2
7h 'IOm d\.nition
Ot!lt 8417 operatad by Alf" Fronce
Ea>nomy/Coach(E)
Layover. 2h 10m

10 :ioam 1:05pm
Amves Thu, D ec 6
~n~. F COG- Reba rocco (RBA-
Rosssy-Char1es de Gaulle) Sal4':I
Tennl 2F
2h 55m duration
Delta 8 695 tee! by Air France
£cociany I Coach (E)
To cwrat.lon:12h45m

Alhumduli llah 0 1:22

50. Investigatory review of airline records confirmed that flights had been booked by

WHITE for departure from RDU on December 4, 2024 at 6:20pm on Delta flight DL 8417,

traveling to Charles de Gaulle Airport in Paris, France, and then continuing to Rabat, Morocco on

Delta flight DL 8695. Return flights were booked departing Rabat, Morocco on December 18,

2024, traveling to Charles de Gaulle Airport in Paris, France, and then continuing on to RDU. The

records also indicated that the flights were booked through a third-party travel agency and that the

fare was $681.31 which WHITE paid for using his known debit card. Based on WHITE's

discussion with the OCE, and as is common for those seeking to join an FTO, your affiant assesses

that WHITE purchased round-trip airfare to avoid arousing suspicion by law enforcement.

24

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 ADDITIONAL PREPARATIONS MADE BY WHITE
51 . In other conversations in September and October 2024, WHITE and the OCE

discussed additional preparations for travel. Among the topics of discussion were WHITE's

considerations about what to do with his personal belongings as well as any necessary equipment

for personal use while overseas.

52. On October 11 , 2024, WHITE told the OCE, "I think I will go and sell my guns ...

Each at a different place InshaAllah." He further expressed that he thought he could sell his, "1911

probably around 200 and the Glock 19 probably 350 ... Or maybe even 400." During that same

conversation, WHITE asked the OCE about setting up a way to dispose of the remaining items in

his apartment after he is already gone.

sulaiman95
I think I will go and sell my guns brother 20;15

Each at a different place lnshaAllah 20 6

Also is it possible I can set up a way to

V
when I'm there I can tell someone to
t ake what you want from my things in my

ake what you want from my th ings m my

apartment
20 :19

53. WHITE additionally sought advice about good boots to purchase. WHITE

initially stated he could not make up his mind on boots and would likely go somewhere in person

to get a good fit however, WHITE later informed the OCE that he went with the boots he initially

found online and that the, "Boots and kit should be here by tomorrow InshaAllah." On October

14, 2024, WHITE sent the OCE a screenshot of the following pair of military style boots stating

these were the boots he purchased:

25

Case 5:24-mj-02541-BM Document 1 Filed 12/04/24 Page 26 of 30

 . . -. -
These are the boots I went with , 7 : 28

54. Amazon purchase history confirmed that WHITE m fact bought the

aforementioned boots and following a conversation between WHITE and the OCE about breaking

in the boots to avoid raising suspicion at the airport with new boots, surveillance photos captured

WHITE wearing the new boots as of October 23 , 2024.

26

Case 5:24-mj-02541-BM Document 1 Filed 12/04/24 Page 27 of 30

 55. The OCE and WHITE also discussed the need for a personal combat medical kit

for WHITE's use upon joining up with ISIS. On October 1, 2024, WHITE sent the OCE

screenshots of potential trauma kits:

sulaiman95
-..o
_ RHINO RESC\JE • •••
VWt the Sto-.
RHINO AESCUt FAX Traoma Rn:t Ald IC.It Molle Mt'dul PoUth A
lo, T>Ctk.tl 14,lltary C., Tr- Hi\Jng Color: Coyote

Camouflage Coyote
'109.. ,,09 ..
~ ~
lnSlod< lnSlodo

prime Unlock fast, free delfvery on millions

_ , of Prime ellglbu! Items. Jo Prime

....
Color.~

56. On October 17, 2024, WHITE informed the OCE that he received his kit. He went

on to tell the OCE he was concerned about the scissors in the kit and even ifhe packed them in his

checked bag, which would be allowed, he wanted to eliminate "all possibilities for them to look

into me gone." When the OCE asked about the contents of the kit WHITE purchased, WHITE

provided the following screenshot and Amazon purchase history confirmed that WHITE had

subsequently purchased it.

Oct 7 B , 2024-
sulaiman95

27

Case 5:24-mj-02541-BM Document 1 Filed 12/04/24 Page 28 of 30

 57. WHITE also told OCE that he needed to find a new luggage set. On October 14,

2024, WHITE sent the OCE an image of a duffel bag from Amazon and asked if that was a good

one. Upon seeing the image, OCE said, "Alhumdullah look good brother. But what we are doing

u won't need dress shoes [two laughing emojis and black flag emoji], to which WHITE replied,

"[two laughing emojis] ... You really gave me smile today ... "

58. The same day, WHITE sent the OCE two screenshots from Amazon of military

style chest rigs with attached pouches for AK-47 magazines. He told the OCE, "I know I can't but

wish I could bring like these ... Amazon has so many things ... "

llliCCMAWW. Oi&t Po&Khn ,.,., , rNg,T)n --..... ...-

,.,,ii:...,.. . . . . . , ~ . _ ....... """°"'-

• 11; Message removed 1517

I know I can"t but I wish I could bring like

these •
1512

w~~1ta.ea,ou~,;.,,...,.us,.,0nits,:. Amazon has so many things brother .

15 12
100. bough& In 1»U , _ .

WHITE'S ATTEMPT TO TRAVEL TO JOIN ISIS

59. On December 4, 2024, at approximately 3:30 PM, WHITE was observed entering

his known vehicle with 3 bags enroute to RDU Airport. At approximately 4:45 PM, FBI Agents

observed WIDTE check in for flight DL 8417 bound for Paris, France, and then proceed through

the security checkpoint. Upon clearing the gate and attempting to make his way to board the plane,

WHITE was arrested at approximately 7:50 PM.

28

Case 5:24-mj-02541-BM Document 1 Filed 12/04/24 Page 29 of 30

 CONCLUSION

60. WHITE' many online conversations with various persons. as well as his

communications with the CHS and the OCE. displa a longstanding intent and desire to join ISIS

which he prepared for and attempted on December 4, 2024. He expressly acknowledged awareness

of ISIS as a designated FTO and repeatedly expressed concern over bc1ng caught b Ja,v

enforcement and the efforts he was taking to avoid capture. Based on the foregoing facts, your

affiant submits that there is su111cicnt probable cause to believe that Alexander Justin WHITE

attempted to commit a federal offense under Title 18, United States Code, Section 2339B, by

conspiring to provide and attempting to provide material support and resources to ISIS, a

designated foreign terrorist organization.

Respectfully submitted

Monika Van Hooser

Special Agent
FBI

In accordance with Rule 4.1 (b) 2) A , the ffiant attested under oath to the contents of
th.is Affidavit via reliable electronic means. telephone, on this /.f':b day of December, 2024.;::b 9: 45 pvr-.,

m>UNITED STATES MAGISTRATE JUDGE

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