A Charlotte, North Carolina, man was arrested this morning on a federal complaint charging him with conspiring to provide material support to the Islamic State of Iraq and Levant (ISIL), a designated foreign terrorist organization.

Erick Jamal Hendricks, 35, tried to recruit people to train together and conduct terrorist attacks in the United States on behalf of ISIL, according to a criminal complaint unsealed today in U.S. District Court in the Northern District of Ohio.

The arrest was announced by Assistant Attorney General for National Security John P. Carlin, U.S. Attorney Carole S. Rendon of the Northern District of Ohio and Special Agent in Charge Stephen D. Anthony of the FBI’s Cleveland Office.

According to the complaint, in June 2015, an individual (CW-1) was arrested in the Northern District of Ohio after attempting to purchase an AK-47 assault rifle and ammunition from an undercover law enforcement officer. CW-1 had pledged allegiance to ISIL in social media and made statements expressing interest in conducting attacks in the United States.

Hendricks had contacted CW-1 over social media to recruit him in the spring of 2015, according to the complaint. Hendricks allegedly told CW-1 that he “needed people” and wanted to meet in person; that there were several “brothers” located in Texas and Mexico; that he was attempting to “get brothers to meet face to face;” and that he wanted “to get brothers to train together.”

According to the complaint, CW-1 said that Hendricks tested his religious knowledge and commitment, inquiring about his willingness to commit “jihad,” to die as a “martyr” and his desire to enter “jannah” (paradise). CW-1 understood these statements to mean that Hendricks was recruiting people to train together for the purpose of conducting a terrorist attack in the U.S. and to see if CW-1 was suitable for recruitment, according to the allegations. CW-1 allegedly believed that Hendricks and the “brothers in Texas and Mexico” may have been responsible for a thwarted terrorist attack in Garland, Texas, on May 3, 2015, and therefore CW-1 decided to stay away from social media for a period following the attack to minimize detection by law enforcement.

Hendricks also allegedly communicated over social media with several other people, including an undercover FBI employee (UCE-1). According to the complaint, on April 16, 2015, Hendricks instructed UCE-1 to download the document “GPS for the Ghuraba in the U.S.”, which included a section entitled “Final Advice” which advocated that “brothers and sisters” should not allow themselves to go to jail. This section also allegedly encouraged Muslims to die as a “Shaheed” (martyr), to “Boobie trap your homes,” to “lay in wait for them” and to “never leave your home without your AK-47 or M16.” According to the complaint, Hendricks also directed UCE-1 to communicate online with other people and stated “It’s hard to sift through brothers;” “Allah chooses only the few;” and “Everyday I do this day in and day out.”

Hendricks allegedly told another person that his goal was to create a sleeper cell to be trained and housed at a secure compound that would conduct attacks in the United States. He mentioned that potential targets included military members whose information had been released by ISIL and the woman who organized the “Draw Prophet Mohammad contest,” and he claimed to have 10 members signed up for his group, according to allegations in the complaint.

On April 23, 2015, Hendricks allegedly used social media to contact Elton Simpson, who, along with Nadir Hamid Soofi, was inspired by ISIL and launched the attack on the “First Annual Muhammad Art Exhibit and Contest” in Garland. Simpson and Soofi opened fire, wounding a security guard, before Garland police returned fire and killed both Simpson and Soofi. According to the complaint, Hendricks also connected UCE-1 with Simpson via social media; communicated with UCE-1 about the contest in Garland; and directed UCE-1 to go to the contest. Hendricks allegedly said: “If you see that pig (meaning the organizer of the contest) make your ‘voice’ heard against her.” According to the complaint, he also asked UCE-1 a series of questions related to security at the event, including: “How big is the gathering?” “How many ppl?” “How many police/agents?” “Do you see feds there?’ “Do you see snipers?” and “How many media?” Shortly thereafter, Simpson and Soofi committed the attack on the cartoon drawing contest.

A criminal complaint is merely an allegation, and the defendant is presumed innocent unless and until proven guilty beyond a reasonable doubt in a court of law.

If convicted, Hendricks faces a statutory maximum sentence of 15 years in prison. The maximum statutory sentence is prescribed by Congress and is provided here for informational purposes. If convicted of any offense, the sentencing of the defendant will be determined by the court based on the advisory Sentencing Guidelines and other statutory factors.

This case was investigated by the FBI’s offices in Cleveland; Columbia, South Carolina; Baltimore; and Charlotte, North Carolina, with assistance from the Justice Department’s National Security Division and the U.S. Attorney’s Offices in the Northern District of Ohio, District of Maryland, District of South Carolina and the Western District of North Carolina.