# United States v. Kalashnikov and Afanasyeva

| UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK | |
| UNITED STATES OF AMERICA v. KOSTIANTYN KALASHNIKOV, ELENa/k/a "Kostya," and ELENA AFANASYEVA, ELENa/k/a "Lena," Defendants. | SEALED INDICTMENT 24 Cr.   24 CRIM 519 |
The Grand Jury charges:
INTRODUCTION
* RT, formerly known as "Russia Today," is a state-controlled media outlet funded and directed by the Government of Russia. After Russia invaded Ukraine in February 2022, RT was sanctioned, dropped by distributors, and ultimately forced to cease formal operations in the United States, Canada, the United Kingdom, and the European Union. In response, RT created, in the words of its editor-in-chief, an "entire empire of covert projects" designed to shape public opinion in "Western audiences." One of RT's "covert projects," as described herein, is its funding and direction of a Tennessee-based online content creation company ("U.S. Company-1").
* Over at least the past year, RT and its employees, including KOSTIANTYN KALASHNIKOV, a/k/a "Kostya," and ELENA AFANASYEVA, a/k/a "Lena," the defendants, have deployed nearly $10 million, laundered through a network of foreign shell entities, to covertly fund and direct U.S. Company-1. U.S. Company-1 publishes English-language videos on multiple social media channels, including Tik Tok, Instagram, X, and YouTube. Using multiple fake personas, AFANASYEVA edited, posted, and directed the posting by U.S. Company-1 of hundreds of videos. Many of the videos published by U.S. Company-1 contain commentary on ​ events and issues in the United States, such as immigration, inflation, and other topics related to domestic and foreign policy. While the views expressed in the videos are not uniform, the subject matter and content of the videos are often consistent with the Government of Russia's interest in amplifying U.S. domestic divisions in order to weaken U.S. opposition to core Government of Russia interests, such as its ongoing war in Ukraine.
* Since publicly launching in or about November 2023, U.S. Company-1 has posted nearly 2,000 videos that have garnered more than 16 million views on YouTube alone. U.S. Company-1 never disclosed to its viewers that it was funded and directed by RT. Nor did U.S. Company-1 or its two founders and principal executives ("Founder-1" and "Founder-2") register with the Attorney General as an agent of a foreign principal, as required by law.
* KALASHNIKOV, AFANASYEVA, Founder-1, and Founder-2 also worked together to deceive two U.S. online commentators ("Commentator-1" and "Commentator-2"), who respectively have over 2.4 million and 1.3 million YouTube subscribers. Founder-1 and Founder-2 contracted with Commentator-1 and Commentator-2 to produce videos, using Commentator-1's and Commentator-2's own names and leveraging their existing audiences, for license and publication by U.S. Company-1. KALASHNIKOV, AFANASYEVA, Founder-1, and Founder-2 worked together to mask U.S. Company-1's true source of funding—i.e., RT—by falsely portraying to Commentator-1 and Commentator-2 that U.S. Company-1 was sponsored by a private investor named "Eduard Grigoriann." In truth and in fact, Grigoriann was a fictional persona. For example, during contract negotiations, Commentator-1 requested that Founder-1 provide a profile or article on "Eduard Grigoriann." In response, Founder-1 sent Commentator-1 a one-page profile, provided to Founder-1 by another fictional persona purporting to represent "Eduard Grigoriann," falsely describing "Eduard Grigoriann" as an "accomplished finance ​ professional" who had held various positions in Brussels and France at a multinational bank ("Bank-1"), including "Director of Private Banking [D]ivision and Wealth Management." After receiving the fictitious profile, Commentator-1 agreed to work with U.S. Company-1 and produced approximately 130 videos that were published on U.S. Company-1's platform.
BACKGROUND ON RUSSIAN INFLUENCE OPERATIONS
* RT is a Russian state-funded and state-directed media outlet. As RT's editor-in-chief has publicly acknowledged, "since RT receives budget from the state, it must complete tasks given by the state." For nearly two decades, RT has promoted the objectives of the Government of Russia by publishing disinformation and propaganda, leveraging its international network to amplify the Government of Russia's message to foreign audiences, and using its guise as a conventional media outlet to lend credibility to that message. RT's propaganda is most obvious when it reports on matters of importance to the Government of Russia, such as public opinion about Ukraine in the United States. When direct propaganda is not effective, however, RT has pursued malign influence campaigns in countries opposed to its policies, including the United States, in an effort to sow domestic divisions and thereby weaken opposition to Government of Russia objectives. For example, in discussing RT's coverage of the United Kingdom's exit from the European Union in 2016, an RT journalist recalled to an academic researcher: "I asked my editor, what is RT's line for this [Brexit], and he said: 'Anything that causes chaos is RT's line.'"
* In or about March 2022, following Russia's invasion of Ukraine in February 2022, the European Union, the United Kingdom, and Canada banned broadcasting by RT. That same month, RT also ceased its operations in the United States after major television distributors ​ dropped the network. But as RT itself has boasted, despite its post-March 2022 bans on broadcasting and lack of formal distribution channels in the United States, Canada, the United Kingdom, and the European Union, the Government of Russia continues to use RT to direct disinformation and propaganda at Western audiences. For example, on or about February 25, 2024, RT's editor-in-chief declared, during a Russian television appearance, that "public opinion in the West is changing, very rapidly and very cheerfully," due in part to RT. RT's editor-in-chief further explained that, despite being "banished everywhere on February 25"—referring to the start of Russia's invasion of Ukraine in February 2022—RT had built "an enormous network, an entire empire of covert projects that is working with the public opinion, bringing truth to Western audiences."
* As set forth below, U.S. Company-1 is one of RT's "covert projects" in the United States.
BACKGROUND ON CERTAIN INDIVIDUALS AND ENTITIES
* ↑ All statements and writings described in this Indictment are presented in substance and in part, and all descriptions of Russian-language communications are based on draft English translations.
* ↑ In order to use the Discord messaging platform, Discord users must first create or join a server. Servers are then broken down into sub-categories, or "channels," through which users can communicate with each other by chat, voice, or video. Among other things, users can send messages to an entire channel, which can be viewed or read by the full membership of that channel, or users can send direct messages to other Discord users, which can be viewed only by the recipient.
* ↑ Foreign banks often use U.S. banks, in which the foreign bank maintains a "correspondent account," to facilitate international money transfers involving the United States or denominated in U.S. Dollars.
This work is in the public domain in the United States because it is a work of the United States federal government (see 17 U.S.C. 105).
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