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Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 1 of 37 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

UNITED STATES OF AMERICA 

v. 

INTERNET RESEARCH AGENCY LLC 

A/K/A MEDIASINTEZ LLC A/K/A 

GLAVSET LLC A/K/A MIXINFO 

LLC A/K/A AZIMUT LLC A/K/A 

NOVINFO LLC, 

CONCORD MANAGEMENT AND 

CONSULTING LLC, 

CONCORD CATERING, 

YEVGENIY VIKTOROVICH 

PRIGOZHIN, 

MIKHAIL IVANOVICH BYSTROV, 

MIKHAIL LEONIDOVICH BURCHIK 

A/K/A MIKHAIL ABRAMOV, 

ALEKSANDRA YURYEVNA 

KRYLOVA, 

ANNA VLADISLAVOVNA 

BOGACHEVA, 

SERGEY PAVLOVICH POLOZOV, 

MARIA ANATOLYEVNA BOVDA 

A/K/A MARIA ANATOLYEVNA 

BELYAEVA, 

ROBERT SERGEYEVICH BOVDA, 

DZHEYKHUN NASIMI OGLY 

ASLANOV A/K/A JAYHOON 

ASLANOV A/K/A JAY ASLANOV, 

VADIM VLADIMIROVICH 

PODKOPAEV, 

GLEB IGOREVICH VASILCHENKO, 

IRINA VIKTOROVNA KAVERZINA, 

and 

VLADIMIR VENKOV. 

Defendants. 

CRIMINAL NO. 

(18 U.S.C. §§ 2, 371, 1349, 1028A) 
INDICTMENT 

The Grand Jury for the District of Columbia charges: 

Introduction 

1. The United States of America, through its departments and agencies, regulates the activities 

of foreign individuals and entities in and affecting the United States in order to prevent, disclose, 

and counteract improper foreign influence on U.S. elections and on the U.S. political system. U.S. 

law bans foreign nationals from making certain expenditures or financial disbursements for the 

purpose of influencing federal elections. U.S. law also bars agents of any foreign entity from 

engaging in political activities within the United States without first registering with the Attorney 

General. And U.S. law requires certain foreign nationals seeking entry to the United States to 

obtain a visa by providing truthful and accurate information to the government. Various federal 

agencies, including the Federal Election Commission, the U.S. Department of Justice, and the U.S. 

Department of State, are charged with enforcing these laws. 

2. Defendant INTERNET RESEARCH AGENCY LLC (“ORGANIZATION”) is a Russian 

organization engaged in operations to interfere with elections and political processes. Defendants 

MIKHAIL IVANOVICH BYSTROV, MIKHAIL LEONIDOVICH BURCHIK, ALEKSANDRA 

YURYEVNA KRYLOVA, ANNA VLADISLAVOVNA BOGACHEVA, SERGEY PAVLOVICH 

POLOZOV, MARIA ANATOLYEVNA BOVDA, ROBERT SERGEYEVICH BOVDA, 

DZHEYKHUN NASIMI OGLY ASLANOV, VADIM VLADIMIROVICH PODKOPAEV, GLEB 

IGOREVICH VASILCHENKO, IRINA VIKTOROVNA KAVERZINA, and VLADIMIR 

VENKOV worked in various capacities to carry out Defendant ORGANIZATION’s interference 

operations targeting the United States. From in or around 2014 to the present, Defendants 

knowingly and intentionally conspired with each other (and with persons known and unknown to 

Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 2 of 37 

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Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 3 of 37 

the Grand Jury) to defraud the United States by impairing, obstructing, and defeating the lawful 

functions of the government through fraud and deceit for the purpose of interfering with the U.S. 

political and electoral processes, including the presidential election of 2016. 

3. Beginning as early as 2014, Defendant ORGANIZATION began operations to interfere 

with the U.S. political system, including the 2016 U.S. presidential election. Defendant 

ORGANIZATION received funding for its operations from Defendant YEVGENIY 

VIKTOROVICH PRIGOZHIN and companies he controlled, including Defendants CONCORD 

MANAGEMENT AND CONSULTING LLC and CONCORD CATERING (collectively 

“CONCORD”). Defendants CONCORD and PRIGOZHIN spent significant funds to further the 

ORGANIZATION’s operations and to pay the remaining Defendants, along with other uncharged 

ORGANIZATION employees, salaries and bonuses for their work at the ORGANIZATION. 

4. Defendants, posing as U.S. persons and creating false U.S. personas, operated social media 

pages and groups designed to attract U.S. audiences. These groups and pages, which addressed 

divisive U.S. political and social issues, falsely claimed to be controlled by U.S. activists when, in 

fact, they were controlled by Defendants. Defendants also used the stolen identities of real U.S. 

persons to post on ORGANIZATION-controlled social media accounts. Over time, these social 

media accounts became Defendants’ means to reach significant numbers of Americans for 

purposes of interfering with the U.S. political system, including the presidential election of 2016. 

5. Certain Defendants traveled to the United States under false pretenses for the purpose of 

collecting intelligence to inform Defendants’ operations. Defendants also procured and used 

computer infrastructure, based partly in the United States, to hide the Russian origin of their 

activities and to avoid detection by U.S. regulators and law enforcement. 

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Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 4 of 37 

6. Defendant ORGANIZATION had a strategic goal to sow discord in the U.S. political 

system, including the 2016 U.S. presidential election. Defendants posted derogatory information 

about a number of candidates, and by early to mid-2016, Defendants’ operations included 

supporting the presidential campaign of then-candidate Donald J. Trump (“Trump Campaign”) and 

disparaging Hillary Clinton. Defendants made various expenditures to carry out those activities, 

including buying political advertisements on social media in the names of U.S. persons and 

entities. Defendants also staged political rallies inside the United States, and while posing as U.S. 

grassroots entities and U.S. persons, and without revealing their Russian identities and 

ORGANIZATION affiliation, solicited and compensated real U.S. persons to promote or disparage 

candidates. Some Defendants, posing as U.S. persons and without revealing their Russian 

association, communicated with unwitting individuals associated with the Trump Campaign and 

with other political activists to seek to coordinate political activities. 

7. In order to carry out their activities to interfere in U.S. political and electoral processes 

without detection of their Russian affiliation, Defendants conspired to obstruct the lawful functions 

of the United States government through fraud and deceit, including by making expenditures in 

connection with the 2016 U.S. presidential election without proper regulatory disclosure; failing 

to register as foreign agents carrying out political activities within the United States; and obtaining 

visas through false and fraudulent statements. 

COUNT ONE 

(Conspiracy to Defraud the United States) 

8. Paragraphs 1 through 7 of this Indictment are re-alleged and incorporated by reference as if 

fully set forth herein. 

9. From in or around 2014 to the present, in the District of Columbia and elsewhere, 

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Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 5 of 37 

Defendants, together with others known and unknown to the Grand Jury, knowingly and 

intentionally conspired to defraud the United States by impairing, obstructing, and defeating the 

lawful functions of the Federal Election Commission, the U.S. Department of Justice, and the U.S. 

Department of State in administering federal requirements for disclosure of foreign involvement 

in certain domestic activities. 

Defendants 

10. Defendant INTERNET RESEARCH AGENCY LLC (Агентство Интернет

Исследований) is a Russian organization engaged in political and electoral interference 

operations. In or around July 2013, the ORGANIZATION registered with the Russian government 

as a Russian corporate entity. Beginning in or around June 2014, the ORGANIZATION obscured 

its conduct by operating through a number of Russian entities, including Internet Research LLC, 

MediaSintez LLC, GlavSet LLC, MixInfo LLC, Azimut LLC, and NovInfo LLC. Starting in or 

around 2014, the ORGANIZATION occupied an office at 55 Savushkina Street in St. Petersburg, 

Russia. That location became one of the ORGANIZATION’s operational hubs from which 

Defendants and other co-conspirators carried out their activities to interfere in the U.S. political 

system, including the 2016 U.S. presidential election. 

a. The ORGANIZATION employed hundreds of individuals for its online operations, 

ranging from creators of fictitious personas to technical and administrative support. 

The ORGANIZATION’s annual budget totaled the equivalent of millions of U.S. 

dollars. 

b. The ORGANIZATION was headed by a management group and organized into 

departments, including: a graphics department; a data analysis department; a 

search-engine optimization (“SEO”) department; an information-technology (“IT”) 

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Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 6 of 37 

department to maintain the digital infrastructure used in the ORGANIZATION’s 

operations; and a finance department to budget and allocate funding. 

c. The ORGANIZATION sought, in part, to conduct what it called “information 

warfare against the United States of America” through fictitious U.S. personas on 

social media platforms and other Internet-based media. 

d. By in or around April 2014, the ORGANIZATION formed a department that went 

by various names but was at times referred to as the “translator project.” This 

project focused on the U.S. population and conducted operations on social media 

platforms such as YouTube, Facebook, Instagram, and Twitter. By approximately 

July 2016, more than eighty ORGANIZATION employees were assigned to the 

translator project. 

e. By in or around May 2014, the ORGANIZATION’s strategy included interfering 

with the 2016 U.S. presidential election, with the stated goal of “spread[ing] distrust 

towards the candidates and the political system in general.” 

11. Defendants CONCORD MANAGEMENT AND CONSULTING LLC (Конкорд

Менеджмент и Консалтинг) and CONCORD CATERING are related Russian entities with 

various Russian government contracts. CONCORD was the ORGANIZATION’s primary source 

of funding for its interference operations. CONCORD controlled funding, recommended 

personnel, and oversaw ORGANIZATION activities through reporting and interaction with 

ORGANIZATION management. 

a. CONCORD funded the ORGANIZATION as part of a larger CONCORD-funded 

interference operation that it referred to as “Project Lakhta.” Project Lakhta had 

multiple components, some involving domestic audiences within the Russian 

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Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 7 of 37 

Federation and others targeting foreign audiences in various countries, including 

the United States. 

b. By in or around September 2016, the ORGANIZATION’s monthly budget for 

Project Lakhta submitted to CONCORD exceeded 73 million Russian rubles (over 

1,250,000 U.S. dollars), including approximately one million rubles in bonus 

payments. 

c. To conceal its involvement, CONCORD labeled the monies paid to the 

ORGANIZATION for Project Lakhta as payments related to software support and 

development. To further conceal the source of funds, CONCORD distributed 

monies to the ORGANIZATION through approximately fourteen bank accounts 

held in the names of CONCORD affiliates, including Glavnaya Liniya LLC, 

Merkuriy LLC, Obshchepit LLC, Potentsial LLC, RSP LLC, ASP LLC, MTTs 

LLC, Kompleksservis LLC, SPb Kulinariya LLC, Almira LLC, Pishchevik LLC, 

Galant LLC, Rayteks LLC, and Standart LLC. 

12. Defendant YEVGENIY VIKTOROVICH PRIGOZHIN (Пригожин Евгений

Викторович) is a Russian national who controlled CONCORD. 

a. PRIGOZHIN approved and supported the ORGANIZATION’s operations, and 

Defendants and their co-conspirators were aware of PRIGOZHIN’s role. 

b. For example, on or about May 29, 2016, Defendants and their co-conspirators, 

through an ORGANIZATION-controlled social media account, arranged for a real 

U.S. person to stand in front of the White House in the District of Columbia under 

false pretenses to hold a sign that read “Happy 55th Birthday Dear Boss.” 

Defendants and their co-conspirators informed the real U.S. person that the sign 

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Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 8 of 37 

was for someone who “is a leader here and our boss . . . our funder.” PRIGOZHIN’s 

Russian passport identifies his date of birth as June 1, 1961. 

13. Defendant MIKHAIL IVANOVICH BYSTROV (Быстров Михаил Иванович) joined the 

ORGANIZATION by at least in or around February 2014. 

a. By approximately April 2014, BYSTROV was the general director, the 

ORGANIZATION’s highest-ranking position. BYSTROV subsequently served as 

the head of various other entities used by the ORGANIZATION to mask its 

activities, including, for example, Glavset LLC, where he was listed as that entity’s 

general director. 

b. In or around 2015 and 2016, BYSTROV frequently communicated with 

PRIGOZHIN about Project Lakhta’s overall operations, including through 

regularly scheduled in-person meetings. 

14. Defendant MIKHAIL LEONIDOVICH BURCHIK (Бурчик Михаил Леонидович) 

A/K/A MIKHAIL ABRAMOV joined the ORGANIZATION by at least in or around October 

2013. By approximately March 2014, BURCHIK was the executive director, the 

ORGANIZATION’s second-highest ranking position. Throughout the ORGANIZATION’s 

operations to interfere in the U.S political system, including the 2016 U.S. presidential election, 

BURCHIK was a manager involved in operational planning, infrastructure, and personnel. In or 

around 2016, BURCHIK also had in-person meetings with PRIGOZHIN. 

15. Defendant ALEKSANDRA YURYEVNA KRYLOVA (Крылова Александра Юрьевна) 

worked for the ORGANIZATION from at least in or around September 2013 to at least in or around 

November 2014. By approximately April 2014, KRYLOVA served as director and was the 

ORGANIZATION’s third-highest ranking employee. In 2014, KRYLOVA traveled to the United 

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Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 9 of 37 

States under false pretenses for the purpose of collecting intelligence to inform the 

ORGANIZATION’s operations. 

16. Defendant SERGEY PAVLOVICH POLOZOV (Полозов Сергей Павлович) worked for 

the ORGANIZATION from at least in or around April 2014 to at least in or around October 2016. 

POLOZOV served as the manager of the IT department and oversaw the procurement of U.S. 

servers and other computer infrastructure that masked the ORGANIZATION’s Russian location 

when conducting operations within the United States. 

17. Defendant ANNA VLADISLAVOVNA BOGACHEVA (Богачева Анна Владиславовна) 

worked for the ORGANIZATION from at least in or around April 2014 to at least in or around 

July 2014. BOGACHEVA served on the translator project and oversaw the project’s data analysis 

group. BOGACHEVA also traveled to the United States under false pretenses for the purpose of 

collecting intelligence to inform the ORGANIZATION’s operations. 

18. Defendant MARIA ANATOLYEVNA BOVDA (Бовда Мария Анатольевна) A/K/A 

MARIA ANATOLYEVNA BELYAEVA (“M. BOVDA”) worked for the ORGANIZATION from 

at least in or around November 2013 to at least in or around October 2014. M. BOVDA served as 

the head of the translator project, among other positions. 

19. Defendant ROBERT SERGEYEVICH BOVDA (Бовда Роберт Сергеевич) (“R. 

BOVDA”) worked for the ORGANIZATION from at least in or around November 2013 to at least 

in or around October 2014. R. BOVDA served as the deputy head of the translator project, among 

other positions. R. BOVDA attempted to travel to the United States under false pretenses for the 

purpose of collecting intelligence to inform the ORGANIZATION’s operations but could not 

obtain the necessary visa. 

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Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 10 of 37 

20. Defendant DZHEYKHUN NASIMI OGLY ASLANOV (Асланов Джейхун Насими

Оглы) A/K/A JAYHOON ASLANOV A/K/A JAY ASLANOV joined the ORGANIZATION by at 

least in or around September 2014. ASLANOV served as head of the translator project and 

oversaw many of the operations targeting the 2016 U.S. presidential election. ASLANOV was 

also listed as the general director of Azimut LLC, an entity used to move funds from CONCORD 

to the ORGANIZATION. 

21. Defendant VADIM VLADIMIROVICH PODKOPAEV (Подкопаев Вадим

Владимирович) joined the ORGANIZATION by at least in or around June 2014. PODKOPAEV 

served as an analyst on the translator project and was responsible for conducting U.S.-focused 

research and drafting social media content for the ORGANIZATION. 

22. Defendant GLEB IGOREVICH VASILCHENKO (Васильченко Глеб Игоревич) worked 

for the ORGANIZATION from at least in or around August 2014 to at least in or around September 

2016. VASILCHENKO was responsible for posting, monitoring, and updating the social media 

content of many ORGANIZATION-controlled accounts while posing as U.S. persons or U.S. 

grassroots organizations. VASILCHENKO later served as the head of two sub-groups focused on 

operations to interfere in the U.S. political system, including the 2016 U.S. presidential election. 

23. Defendant IRINA VIKTOROVNA KAVERZINA (Каверзина Ирина Викторовна) joined 

the ORGANIZATION by at least in or around October 2014. KAVERZINA served on the 

translator project and operated multiple U.S. personas that she used to post, monitor, and update 

social media content for the ORGANIZATION. 

24. Defendant VLADIMIR VENKOV (Венков Владимир) joined the ORGANIZATION by 

at least in or around March 2015. VENKOV served on the translator project and operated multiple 

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Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 11 of 37 

U.S. personas, which he used to post, monitor, and update social media content for the 

ORGANIZATION. 

Federal Regulatory Agencies 

25. The Federal Election Commission is a federal agency that administers the Federal Election 

Campaign Act (“FECA”). Among other things, FECA prohibits foreign nationals from making 

any contributions, expenditures, independent expenditures, or disbursements for electioneering 

communications. FECA also requires that individuals or entities who make certain independent 

expenditures in federal elections report those expenditures to the Federal Election Commission. 

The reporting requirements permit the Federal Election Commission to fulfill its statutory duties 

of providing the American public with accurate data about the financial activities of individuals 

and entities supporting federal candidates, and enforcing FECA’s limits and prohibitions, 

including the ban on foreign expenditures. 

26. The U.S. Department of Justice administers the Foreign Agent Registration Act (“FARA”). 

FARA establishes a registration, reporting, and disclosure regime for agents of foreign principals 

(which includes foreign non-government individuals and entities) so that the U.S. government and 

the people of the United States are informed of the source of information and the identity of persons 

attempting to influence U.S. public opinion, policy, and law. FARA requires, among other things, 

that persons subject to its requirements submit periodic registration statements containing truthful 

information about their activities and the income earned from them. Disclosure of the required 

information allows the federal government and the American people to evaluate the statements and 

activities of such persons in light of their function as foreign agents. 

27. The U.S. Department of State is the federal agency responsible for the issuance of nonimmigrant visas to foreign individuals who need a visa to enter the United States. Foreign 

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Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 12 of 37 

individuals who are required to obtain a visa must, among other things, provide truthful 

information in response to questions on the visa application form, including information about 

their employment and the purpose of their visit to the United States. 

Object of the Conspiracy 

28. The conspiracy had as its object impairing, obstructing, and defeating the lawful 

governmental functions of the United States by dishonest means in order to enable the Defendants 

to interfere with U.S. political and electoral processes, including the 2016 U.S. presidential 

election. 

Manner and Means of the Conspiracy 

Intelligence-Gathering to Inform U.S. Operations 

29. Starting at least in or around 2014, Defendants and their co-conspirators began to track and 

study groups on U.S. social media sites dedicated to U.S. politics and social issues. In order to 

gauge the performance of various groups on social media sites, the ORGANIZATION tracked 

certain metrics like the group’s size, the frequency of content placed by the group, and the level of 

audience engagement with that content, such as the average number of comments or responses to 

a post. 

30. Defendants and their co-conspirators also traveled, and attempted to travel, to the United 

States under false pretenses in order to collect intelligence for their interference operations. 

a. KRYLOVA and BOGACHEVA, together with other Defendants and coconspirators, planned travel itineraries, purchased equipment (such as cameras, 

SIM cards, and drop phones), and discussed security measures (including 

“evacuation scenarios”) for Defendants who traveled to the United States. 

b. To enter the United States, KRYLOVA, BOGACHEVA, R. BOVDA, and another 

co-conspirator applied to the U.S. Department of State for visas to travel. During 

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Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 13 of 37 

their application process, KRYLOVA, BOGACHEVA, R. BOVDA, and their coconspirator falsely claimed they were traveling for personal reasons and did not 

fully disclose their place of employment to hide the fact that they worked for the 

ORGANIZATION. 

c. Only KRYLOVA and BOGACHEVA received visas, and from approximately June 

4, 2014 through June 26, 2014, KRYLOVA and BOGACHEVA traveled in and 

around the United States, including stops in Nevada, California, New Mexico, 

Colorado, Illinois, Michigan, Louisiana, Texas, and New York to gather 

intelligence. After the trip, KRYLOVA and BURCHIK exchanged an intelligence 

report regarding the trip. 

d. Another co-conspirator who worked for the ORGANIZATION traveled to Atlanta, 

Georgia from approximately November 26, 2014 through November 30, 2014. 

Following the trip, the co-conspirator provided POLOZOV a summary of his trip’s 

itinerary and expenses. 

31. In order to collect additional intelligence, Defendants and their co-conspirators posed as 

U.S. persons and contacted U.S. political and social activists. For example, starting in or around 

June 2016, Defendants and their co-conspirators, posing online as U.S. persons, communicated 

with a real U.S. person affiliated with a Texas-based grassroots organization. During the exchange, 

Defendants and their co-conspirators learned from the real U.S. person that they should focus their 

activities on “purple states like Colorado, Virginia & Florida.” After that exchange, Defendants 

and their co-conspirators commonly referred to targeting “purple states” in directing their efforts. 

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Use of U.S. Social Media Platforms 

32. Defendants and their co-conspirators, through fraud and deceit, created hundreds of social 

media accounts and used them to develop certain fictitious U.S. personas into “leader[s] of public 

opinion” in the United States. 

33. ORGANIZATION employees, referred to as “specialists,” were tasked to create social 

media accounts that appeared to be operated by U.S. persons. The specialists were divided into 

day-shift and night-shift hours and instructed to make posts in accordance with the appropriate 

U.S. time zone. The ORGANIZATION also circulated lists of U.S. holidays so that specialists 

could develop and post appropriate account activity. Specialists were instructed to write about 

topics germane to the United States such as U.S. foreign policy and U.S. economic issues. 

Specialists were directed to create “political intensity through supporting radical groups, users 

dissatisfied with [the] social and economic situation and oppositional social movements.” 

34. Defendants and their co-conspirators also created thematic group pages on social media 

sites, particularly on the social media platforms Facebook and Instagram. ORGANIZATIONcontrolled pages addressed a range of issues, including: immigration (with group names including 

“Secured Borders”); the Black Lives Matter movement (with group names including 

“Blacktivist”); religion (with group names including “United Muslims of America” and “Army of 

Jesus”); and certain geographic regions within the United States (with group names including 

“South United” and “Heart of Texas”). By 2016, the size of many ORGANIZATION-controlled 

groups had grown to hundreds of thousands of online followers. 

35. Starting at least in or around 2015, Defendants and their co-conspirators began to purchase 

advertisements on online social media sites to promote ORGANIZATION-controlled social media 

groups, spending thousands of U.S. dollars every month. These expenditures were included in the 

budgets the ORGANIZATION submitted to CONCORD. 

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36. Defendants and their co-conspirators also created and controlled numerous Twitter 

accounts designed to appear as if U.S. persons or groups controlled them. For example, the 

ORGANIZATION created and controlled the Twitter account “Tennessee GOP,” which used the 

handle @TEN_GOP. The @TEN_GOP account falsely claimed to be controlled by a U.S. state 

political party. Over time, the @TEN_GOP account attracted more than 100,000 online followers. 

37. To measure the impact of their online social media operations, Defendants and their coconspirators tracked the performance of content they posted over social media. They tracked the 

size of the online U.S. audiences reached through posts, different types of engagement with the 

posts (such as likes, comments, and reposts), changes in audience size, and other metrics. 

Defendants and their co-conspirators received and maintained metrics reports on certain group 

pages and individualized posts. 

38. Defendants and their co-conspirators also regularly evaluated the content posted by 

specialists (sometimes referred to as “content analysis”) to ensure they appeared authentic—as if 

operated by U.S. persons. Specialists received feedback and directions to improve the quality of 

their posts. Defendants and their co-conspirators issued or received guidance on: ratios of text, 

graphics, and video to use in posts; the number of accounts to operate; and the role of each account 

(for example, differentiating a main account from which to post information and auxiliary accounts 

to promote a main account through links and reposts). 

Use of U.S. Computer Infrastructure 

39. To hide their Russian identities and ORGANIZATION affiliation, Defendants and their coconspirators—particularly POLOZOV and the ORGANIZATION’s IT department—purchased 

space on computer servers located inside the United States in order to set up virtual private 

networks (“VPNs”). Defendants and their co-conspirators connected from Russia to the U.S.-

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Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 16 of 37 

based infrastructure by way of these VPNs and conducted activity inside the United States— 

including accessing online social media accounts, opening new accounts, and communicating with 

real U.S. persons—while masking the Russian origin and control of the activity. 

40. Defendants and their co-conspirators also registered and controlled hundreds of web-based 

email accounts hosted by U.S. email providers under false names so as to appear to be U.S. persons 

and groups. From these accounts, Defendants and their co-conspirators registered or linked to 

online social media accounts in order to monitor them; posed as U.S. persons when requesting 

assistance from real U.S. persons; contacted media outlets in order to promote activities inside the 

United States; and conducted other operations, such as those set forth below. 

Use of Stolen U.S. Identities 

41. In or around 2016, Defendants and their co-conspirators also used, possessed, and 

transferred, without lawful authority, the social security numbers and dates of birth of real U.S. 

persons without those persons’ knowledge or consent. Using these means of identification, 

Defendants and their co-conspirators opened accounts at PayPal, a digital payment service 

provider; created false means of identification, including fake driver’s licenses; and posted on 

ORGANIZATION-controlled social media accounts using the identities of these U.S. victims. 

Defendants and their co-conspirators also obtained, and attempted to obtain, false identification 

documents to use as proof of identity in connection with maintaining accounts and purchasing 

advertisements on social media sites. 

Actions Targeting the 2016 U.S. Presidential Election 

42. By approximately May 2014, Defendants and their co-conspirators discussed efforts to 

interfere in the 2016 U.S. presidential election. Defendants and their co-conspirators began to 

monitor U.S. social media accounts and other sources of information about the 2016 U.S. 

presidential election. 

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43. By 2016, Defendants and their co-conspirators used their fictitious online personas to 

interfere with the 2016 U.S. presidential election. They engaged in operations primarily intended 

to communicate derogatory information about Hillary Clinton, to denigrate other candidates such 

as Ted Cruz and Marco Rubio, and to support Bernie Sanders and then-candidate Donald Trump. 

a. On or about February 10, 2016, Defendants and their co-conspirators internally 

circulated an outline of themes for future content to be posted to 

ORGANIZATION-controlled social media accounts. Specialists were instructed to 

post content that focused on “politics in the USA” and to “use any opportunity to 

criticize Hillary and the rest (except Sanders and Trump—we support them).” 

b. On or about September 14, 2016, in an internal review of an ORGANIZATIONcreated and controlled Facebook group called “Secured Borders,” the account 

specialist was criticized for having a “low number of posts dedicated to criticizing 

Hillary Clinton” and was told “it is imperative to intensify criticizing Hillary 

Clinton” in future posts. 

44. Certain ORGANIZATION-produced materials about the 2016 U.S. presidential election 

used election-related hashtags, including: “#Trump2016,” “#TrumpTrain,” “#MAGA,” 

“#IWontProtectHillary,” and “#Hillary4Prison.” Defendants and their co-conspirators also 

established additional online social media accounts dedicated to the 2016 U.S. presidential 

election, including the Twitter account “March for Trump” and Facebook accounts “Clinton 

FRAUDation” and “Trumpsters United.” 

45. Defendants and their co-conspirators also used false U.S. personas to communicate with 

unwitting members, volunteers, and supporters of the Trump Campaign involved in local 

community outreach, as well as grassroots groups that supported then-candidate Trump. These 

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individuals and entities at times distributed the ORGANIZATION’s materials through their own 

accounts via retweets, reposts, and similar means. Defendants and their co-conspirators then 

monitored the propagation of content through such participants. 

46. In or around the latter half of 2016, Defendants and their co-conspirators, through their 

ORGANIZATION-controlled personas, began to encourage U.S. minority groups not to vote in 

the 2016 U.S. presidential election or to vote for a third-party U.S. presidential candidate. 

a. On or about October 16, 2016, Defendants and their co-conspirators used the 

ORGANIZATION-controlled Instagram account “Woke Blacks” to post the 

following message: “[A] particular hype and hatred for Trump is misleading the 

people and forcing Blacks to vote Killary. We cannot resort to the lesser of two 

devils. Then we’d surely be better off without voting AT ALL.” 

b. On or about November 3, 2016, Defendants and their co-conspirators purchased an 

advertisement to promote a post on the ORGANIZATION-controlled Instagram 

account “Blacktivist” that read in part: “Choose peace and vote for Jill Stein. Trust 

me, it’s not a wasted vote.” 

c. By in or around early November 2016, Defendants and their co-conspirators used 

the ORGANIZATION-controlled “United Muslims of America” social media 

accounts to post anti-vote messages such as: “American Muslims [are] boycotting 

elections today, most of the American Muslim voters refuse to vote for Hillary 

Clinton because she wants to continue the war on Muslims in the middle east and 

voted yes for invading Iraq.” 

47. Starting in or around the summer of 2016, Defendants and their co-conspirators also began 

to promote allegations of voter fraud by the Democratic Party through their fictitious U.S. personas 

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and groups on social media. Defendants and their co-conspirators purchased advertisements on 

Facebook to further promote the allegations. 

a. On or about August 4, 2016, Defendants and their co-conspirators began purchasing 

advertisements that promoted a post on the ORGANIZATION-controlled Facebook 

account “Stop A.I.” The post alleged that “Hillary Clinton has already committed 

voter fraud during the Democrat Iowa Caucus.” 

b. On or about August 11, 2016, Defendants and their co-conspirators posted that 

allegations of voter fraud were being investigated in North Carolina on the 

ORGANIZATION-controlled Twitter account @TEN_GOP. 

c. On or about November 2, 2016, Defendants and their co-conspirators used the same 

account to post allegations of “#VoterFraud by counting tens of thousands of 

ineligible mail in Hillary votes being reported in Broward County, Florida.” 

Political Advertisements 

48. From at least April 2016 through November 2016, Defendants and their co-conspirators, 

while concealing their Russian identities and ORGANIZATION affiliation through false personas, 

began to produce, purchase, and post advertisements on U.S. social media and other online sites 

expressly advocating for the election of then-candidate Trump or expressly opposing Clinton. 

Defendants and their co-conspirators did not report their expenditures to the Federal Election 

Commission, or register as foreign agents with the U.S. Department of Justice. 

49. To pay for the political advertisements, Defendants and their co-conspirators established 

various Russian bank accounts and credit cards, often registered in the names of fictitious U.S. 

personas created and used by the ORGANIZATION on social media. Defendants and their coconspirators also paid for other political advertisements using PayPal accounts. 

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50. The political advertisements included the following: 

Approximate 

Date Excerpt of Advertisement 

April 6, 2016 “You know, a great number of black people support us saying that 

#HillaryClintonIsNotMyPresident” 

April 7, 2016 “I say no to Hillary Clinton / I say no to manipulation” 

April 19, 2016 “JOIN our #HillaryClintonForPrison2016” 

May 10, 2016 “Donald wants to defeat terrorism . . . Hillary wants to sponsor it” 

May 19, 2016 “Vote Republican, vote Trump, and support the Second Amendment!” 

May 24, 2016 “Hillary Clinton Doesn’t Deserve the Black Vote” 

June 7, 2016 “Trump is our only hope for a better future!” 

June 30, 2016 “#NeverHillary #HillaryForPrison #Hillary4Prison #HillaryForPrison2016 

#Trump2016 #Trump #Trump4President” 

July 20, 2016 “Ohio Wants Hillary 4 Prison” 

August 4, 2016 “Hillary Clinton has already committed voter fraud during the Democrat Iowa 

Caucus.” 

August 10, 2016 “We cannot trust Hillary to take care of our veterans!” 

October 14, 2016 “Among all the candidates Donald Trump is the one and only who can defend 

the police from terrorists.” 

October 19, 2016 “Hillary is a Satan, and her crimes and lies had proved just how evil she is.” 

Staging U.S. Political Rallies in the United States 

51. Starting in approximately June 2016, Defendants and their co-conspirators organized and 

coordinated political rallies in the United States. To conceal the fact that they were based in Russia, 

Defendants and their co-conspirators promoted these rallies while pretending to be U.S. grassroots 

activists who were located in the United States but unable to meet or participate in person. 

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Defendants and their co-conspirators did not register as foreign agents with the U.S. Department 

of Justice. 

52. In order to build attendance for the rallies, Defendants and their co-conspirators promoted 

the events through public posts on their false U.S. persona social media accounts. In addition, 

Defendants and their co-conspirators contacted administrators of large social media groups 

focused on U.S. politics and requested that they advertise the rallies. 

53. In or around late June 2016, Defendants and their co-conspirators used the Facebook group 

“United Muslims of America” to promote a rally called “Support Hillary. Save American Muslims” 

held on July 9, 2016 in the District of Columbia. Defendants and their co-conspirators recruited a 

real U.S. person to hold a sign depicting Clinton and a quote attributed to her stating “I think Sharia 

Law will be a powerful new direction of freedom.” Within three weeks, on or about July 26, 2016, 

Defendants and their co-conspirators posted on the same Facebook page that Muslim voters were 

“between Hillary Clinton and a hard place.” 

54. In or around June and July 2016, Defendants and their co-conspirators used the Facebook 

group “Being Patriotic,” the Twitter account @March_for_Trump, and other ORGANIZATION 

accounts to organize two political rallies in New York. The first rally was called “March for 

Trump” and held on June 25, 2016. The second rally was called “Down with Hillary” and held on 

July 23, 2016. 

a. In or around June through July 2016, Defendants and their co-conspirators 

purchased advertisements on Facebook to promote the “March for Trump” and 

“Down with Hillary” rallies. 

b. Defendants and their co-conspirators used false U.S. personas to send 

individualized messages to real U.S. persons to request that they participate in and 

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help organize the rally. To assist their efforts, Defendants and their co-conspirators, 

through false U.S. personas, offered money to certain U.S. persons to cover rally 

expenses. 

c. On or about June 5, 2016, Defendants and their co-conspirators, while posing as a 

U.S. grassroots activist, used the account @March_for_Trump to contact a 

volunteer for the Trump Campaign in New York. The volunteer agreed to provide 

signs for the “March for Trump” rally. 

55. In or around late July 2016, Defendants and their co-conspirators used the Facebook group 

“Being Patriotic,” the Twitter account @March_for_Trump, and other false U.S. personas to 

organize a series of coordinated rallies in Florida. The rallies were collectively referred to as 

“Florida Goes Trump” and held on August 20, 2016. 

a. In or around August 2016, Defendants and their co-conspirators used false U.S. 

personas to communicate with Trump Campaign staff involved in local community 

outreach about the “Florida Goes Trump” rallies. 

b. Defendants and their co-conspirators purchased advertisements on Facebook and 

Instagram to promote the “Florida Goes Trump” rallies. 

c. Defendants and their co-conspirators also used false U.S. personas to contact 

multiple grassroots groups supporting then-candidate Trump in an unofficial 

capacity. Many of these groups agreed to participate in the “Florida Goes Trump” 

rallies and serve as local coordinators. 

d. Defendants and their co-conspirators also used false U.S. personas to ask real U.S. 

persons to participate in the “Florida Goes Trump” rallies. Defendants and their 

co-conspirators asked certain of these individuals to perform tasks at the rallies. 

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For example, Defendants and their co-conspirators asked one U.S. person to build 

a cage on a flatbed truck and another U.S. person to wear a costume portraying 

Clinton in a prison uniform. Defendants and their co-conspirators paid these 

individuals to complete the requests. 

56. After the rallies in Florida, Defendants and their co-conspirators used false U.S. personas 

to organize and coordinate U.S. political rallies supporting then-candidate Trump in New York and 

Pennsylvania. Defendants and their co-conspirators used the same techniques to build and 

promote these rallies as they had in Florida, including: buying Facebook advertisements; paying 

U.S. persons to participate in, or perform certain tasks at, the rallies; and communicating with real 

U.S. persons and grassroots organizations supporting then-candidate Trump. 

57. After the election of Donald Trump in or around November 2016, Defendants and their coconspirators used false U.S. personas to organize and coordinate U.S. political rallies in support of 

then president-elect Trump, while simultaneously using other false U.S. personas to organize and 

coordinate U.S. political rallies protesting the results of the 2016 U.S. presidential election. For 

example, in or around November 2016, Defendants and their co-conspirators organized a rally in 

New York through one ORGANIZATION-controlled group designed to “show your support for 

President-Elect Donald Trump” held on or about November 12, 2016. At the same time, 

Defendants and their co-conspirators, through another ORGANIZATION-controlled group, 

organized a rally in New York called “Trump is NOT my President” held on or about November 

12, 2016. Similarly, Defendants and their co-conspirators organized a rally entitled “Charlotte 

Against Trump” in Charlotte, North Carolina, held on or about November 19, 2016. 

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Destruction of Evidence 

58. In order to avoid detection and impede investigation by U.S. authorities of Defendants’ 

operations, Defendants and their co-conspirators deleted and destroyed data, including emails, 

social media accounts, and other evidence of their activities. 

a. Beginning in or around June 2014, and continuing into June 2015, public reporting 

began to identify operations conducted by the ORGANIZATION in the United 

States. In response, Defendants and their co-conspirators deleted email accounts 

used to conduct their operations. 

b. Beginning in or around September 2017, U.S. social media companies, starting 

with Facebook, publicly reported that they had identified Russian expenditures on 

their platforms to fund political and social advertisements. Facebook’s initial 

disclosure of the Russian purchases occurred on or about September 6, 2017, and 

included a statement that Facebook had “shared [its] findings with US authorities 

investigating these issues.” 

c. Media reporting on or about the same day as Facebook’s disclosure referred to 

Facebook working with investigators for the Special Counsel’s Office of the U.S. 

Department of Justice, which had been charged with investigating the Russian 

government’s efforts to interfere in the 2016 presidential election. 

d. Defendants and their co-conspirators thereafter destroyed evidence for the purpose 

of impeding the investigation. On or about September 13, 2017, KAVERZINA 

wrote in an email to a family member: “We had a slight crisis here at work: the 

FBI busted our activity (not a joke). So, I got preoccupied with covering tracks 

together with the colleagues.” KAVERZINA further wrote, “I created all these 

pictures and posts, and the Americans believed that it was written by their people.” 

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Overt Acts 

59. In furtherance of the Conspiracy and to effect its illegal object, Defendants and their coconspirators committed the following overt acts in connection with the staging of U.S. political 

rallies, as well as those as set forth in paragraphs 1 through 7, 9 through 27, and 29 through 58, 

which are re-alleged and incorporated by reference as though fully set forth herein. 

60. On or about June 1, 2016, Defendants and their co-conspirators created and purchased 

Facebook advertisements for their “March for Trump” rally. 

61. On or about June 4, 2016, Defendants and their co-conspirators used 

allforusa@yahoo.com, the email address of a false U.S. persona, to send out press releases for the 

“March for Trump” rally to New York media outlets. 

62. On or about June 23, 2016, Defendants and their co-conspirators used the Facebook 

account registered under a false U.S. persona “Matt Skiber” to contact a real U.S. person to serve 

as a recruiter for the “March for Trump” rally, offering to “give you money to print posters and get 

a megaphone.” 

63. On or about June 24, 2016, Defendants and their co-conspirators purchased advertisements 

on Facebook to promote the “Support Hillary. Save American Muslims” rally. 

64. On or about July 5, 2016, Defendants and their co-conspirators ordered posters for the 

“Support Hillary. Save American Muslims” rally, including the poster with the quote attributed to 

Clinton that read “I think Sharia Law will be a powerful new direction of freedom.” 

65. On or about July 8, 2016, Defendants and their co-conspirators communicated with a real 

U.S. person about the posters they had ordered for the “Support Hillary. Save American Muslims” 

rally. 

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66. On or about July 12, 2016, Defendants and their co-conspirators created and purchased 

Facebook advertisements for the “Down With Hillary” rally in New York. 

67. On or about July 23, 2016, Defendants and their co-conspirators used the email address of 

a false U.S. persona, joshmilton024@gmail.com, to send out press releases to over thirty media 

outlets promoting the “Down With Hillary” rally at Trump Tower in New York City. 

68. On or about July 28, 2016, Defendants and their co-conspirators posted a series of tweets 

through the false U.S. persona account @March_for_Trump stating that “[w]e’re currently 

planning a series of rallies across the state of Florida” and seeking volunteers to assist. 

69. On or about August 2, 2016, Defendants and their co-conspirators used the false U.S. 

persona “Matt Skiber” Facebook account to send a private message to a real Facebook account, 

“Florida for Trump,” set up to assist then-candidate Trump in the state of Florida. In the first 

message, Defendants and their co-conspirators wrote: 

Hi there! I’m a member of Being Patriotic online community. Listen, 

we’ve got an idea. Florida is still a purple state and we need to paint 

it red. If we lose Florida, we lose America. We can’t let it happen, 

right? What about organizing a YUGE pro-Trump flash mob in 

every Florida town? We are currently reaching out to local activists 

and we’ve got the folks who are okay to be in charge of organizing 

their events almost everywhere in FL. However, we still need your 

support. What do you think about that? Are you in? 

70. On or about August 2, 2016, and August 3, 2016, Defendants and their co-conspirators, 

through the use of a stolen identity of a real U.S. person, T.W., sent emails to certain grassroots 

groups located in Florida that stated in part: 

My name is [T.W.] and I represent a conservative patriot community 

named as “Being Patriotic.” . . . So we’re gonna organize a flash 

mob across Florida to support Mr. Trump. We clearly understand 

that the elections winner will be predestined by purple states. And 

we must win Florida. . . . We got a lot of volunteers in ~25 locations 

and it’s just the beginning. We’re currently choosing venues for each 

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location and recruiting more activists. This is why we ask you to 

spread this info and participate in the flash mob. 

71. On or about August 4, 2016, Defendants and their co-conspirators created and purchased 

Facebook advertisements for the “Florida Goes Trump” rally. The advertisements reached over 

59,000 Facebook users in Florida, and over 8,300 Facebook users responded to the advertisements 

by clicking on it, which routed users to the ORGANIZATION’s “Being Patriotic” page. 

72. Beginning on or about August 5, 2016, Defendants and their co-conspirators used the false 

U.S. persona @March_for_Trump Twitter account to recruit and later pay a real U.S. person to 

wear a costume portraying Clinton in a prison uniform at a rally in West Palm Beach. 

73. Beginning on or about August 11, 2016, Defendants and their co-conspirators used the false 

U.S. persona “Matt Skiber” Facebook account to recruit a real U.S. person to acquire signs and a 

costume depicting Clinton in a prison uniform. 

74. On or about August 15, 2016, Defendants and their co-conspirators received an email at 

one of their false U.S. persona accounts from a real U.S. person, a Florida-based political activist 

identified as the “Chair for the Trump Campaign” in a particular Florida county. The activist 

identified two additional sites in Florida for possible rallies. Defendants and their co-conspirators 

subsequently used their false U.S. persona accounts to communicate with the activist about 

logistics and an additional rally in Florida. 

75. On or about August 16, 2016, Defendants and their co-conspirators used a false U.S. 

persona Instagram account connected to the ORGANIZATION-created group “Tea Party News” 

to purchase advertisements for the “Florida Goes Trump” rally. 

76. On or about August 18, 2016, the real “Florida for Trump” Facebook account responded to 

the false U.S. persona “Matt Skiber” account with instructions to contact a member of the Trump 

Campaign (“Campaign Official 1”) involved in the campaign’s Florida operations and provided 

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Campaign Official 1’s email address at the campaign domain donaldtrump.com. On 

approximately the same day, Defendants and their co-conspirators used the email address of a false 

U.S. persona, joshmilton024@gmail.com, to send an email to Campaign Official 1 at that 

donaldtrump.com email account, which read in part: 

Hello [Campaign Official 1], [w]e are organizing a state-wide event 

in Florida on August, 20 to support Mr. Trump. Let us introduce 

ourselves first. “Being Patriotic” is a grassroots conservative online 

movement trying to unite people offline. . . . [W]e gained a huge lot 

of followers and decided to somehow help Mr. Trump get elected. 

You know, simple yelling on the Internet is not enough. There should 

be real action. We organized rallies in New York before. Now we’re 

focusing on purple states such as Florida. 

The email also identified thirteen “confirmed locations” in Florida for the rallies and requested the 

campaign provide “assistance in each location.” 

77. On or about August 18, 2016, Defendants and their co-conspirators sent money via 

interstate wire to another real U.S. person recruited by the ORGANIZATION, using one of their 

false U.S. personas, to build a cage large enough to hold an actress depicting Clinton in a prison 

uniform. 

78. On or about August 19, 2016, a supporter of the Trump Campaign sent a message to the 

ORGANIZATION-controlled “March for Trump” Twitter account about a member of the Trump 

Campaign (“Campaign Official 2”) who was involved in the campaign’s Florida operations and 

provided Campaign Official 2’s email address at the domain donaldtrump.com. On or about the 

same day, Defendants and their co-conspirators used the false U.S. persona 

joshmilton024@gmail.com account to send an email to Campaign Official 2 at that 

donaldtrump.com email account. 

79. On or about August 19, 2016, the real “Florida for Trump” Facebook account sent another 

message to the false U.S. persona “Matt Skiber” account to contact a member of the Trump 

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Campaign (“Campaign Official 3”) involved in the campaign’s Florida operations. On or about 

August 20, 2016, Defendants and their co-conspirators used the “Matt Skiber” Facebook account 

to contact Campaign Official 3. 

80. On or about August 19, 2016, Defendants and their co-conspirators used the false U.S. 

persona “Matt Skiber” account to write to the real U.S. person affiliated with a Texas-based 

grassroots organization who previously had advised the false persona to focus on “purple states 

like Colorado, Virginia & Florida.” Defendants and their co-conspirators told that U.S. person, 

“We were thinking about your recommendation to focus on purple states and this is what we’re 

organizing in FL.” Defendants and their co-conspirators then sent a link to the Facebook event 

page for the Florida rallies and asked that person to send the information to Tea Party members in 

Florida. The real U.S. person stated that he/she would share among his/her own social media 

contacts, who would pass on the information. 

81. On or about August 24, 2016, Defendants and their co-conspirators updated an internal 

ORGANIZATION list of over 100 real U.S. persons contacted through ORGANIZATIONcontrolled false U.S. persona accounts and tracked to monitor recruitment efforts and requests. 

The list included contact information for the U.S. persons, a summary of their political views, and 

activities they had been asked to perform by Defendants and their co-conspirators. 

82. On or about August 31, 2016, Defendants and their co-conspirators, using a U.S. persona, 

spoke by telephone with a real U.S. person affiliated with a grassroots group in Florida. That 

individual requested assistance in organizing a rally in Miami, Florida. On or about September 9, 

2016, Defendants and their co-conspirators sent the group an interstate wire to pay for materials 

needed for the Florida rally on or about September 11, 2016. 

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83. On or about August 31, 2016, Defendants and their co-conspirators created and purchased 

Facebook advertisements for a rally they organized and scheduled in New York for September 11, 

2016. 

84. On or about September 9, 2016, Defendants and their co-conspirators, through a false U.S. 

persona, contacted the real U.S. person who had impersonated Clinton at the West Palm Beach 

rally. Defendants and their co-conspirators sent that U.S. person money via interstate wire as an 

inducement to travel from Florida to New York and to dress in costume at another rally they 

organized. 

85. On or about September 22, 2016, Defendants and their co-conspirators created and 

purchased Facebook advertisements for a series of rallies they organized in Pennsylvania called 

“Miners for Trump” and scheduled for October 2, 2016. 

All in violation of Title 18, United States Code, Section 371. 

COUNT TWO 

(Conspiracy to Commit Wire Fraud and Bank Fraud) 

86. Paragraphs 1 through 7, 9 through 27, and 29 through 85 of this Indictment are re-alleged 

and incorporated by reference as if fully set forth herein. 

87. From in or around 2016 through present, in the District of Columbia and elsewhere, 

Defendants INTERNET RESEARCH AGENCY LLC, DZHEYKHUN NASIMI OGLY 

ASLANOV, and GLEB IGOREVICH VASILCHENKO, together with others known and 

unknown to the Grand Jury, knowingly and intentionally conspired to commit certain offenses 

against the United States, to wit: 

a. to knowingly, having devised and intending to devise a scheme and artifice to 

defraud, and to obtain money and property by means of false and fraudulent 

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pretenses, representations, and promises, transmit and cause to be transmitted, by 

means of wire communications in interstate and foreign commerce, writings, signs, 

signals, pictures, and sounds, for the purposes of executing such scheme and 

artifice, in violation of Title 18, United States Code, Section 1343; and 

b. to knowingly execute and attempt to execute a scheme and artifice to defraud a 

federally insured financial institution, and to obtain monies, funds, credits, assets, 

securities and other property from said financial institution by means of false and 

fraudulent pretenses, representations, and promises, all in violation of Title 18, 

United States Code, Section 1344. 

Object of the Conspiracy 

88. The conspiracy had as its object the opening of accounts under false names at U.S. financial 

institutions and a digital payments company in order to receive and send money into and out of 

the United States to support the ORGANIZATION’s operations in the United States and for selfenrichment. 

Manner and Means of the Conspiracy 

89. Beginning in at least 2016, Defendants and their co-conspirators used, without lawful 

authority, the social security numbers, home addresses, and birth dates of real U.S. persons without 

their knowledge or consent. Using these means of stolen identification, Defendants and their coconspirators opened accounts at a federally insured U.S. financial institution (“Bank 1”), including 

the following accounts: 

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Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 32 of 37 

Approximate Date Account Name Means of Identification 

June 16, 2016 T.B. Social Security Number 

Date of Birth 

July 21, 2016 A.R. Social Security Number 

Date of Birth 

July 27, 2016 T.C. Social Security Number 

Date of Birth 

August 2, 2016 T.W. Social Security Number 

Date of Birth 

90. Defendants and their co-conspirators also used, without lawful authority, the social security 

numbers, home addresses, and birth dates of real U.S. persons to open accounts at PayPal, a digital 

payments company, including the following accounts: 

Approximate Date Initials of Identity 

Theft Victim Means of Identification 

June 16, 2016 T.B. Social Security Number 

Date of Birth 

July 21, 2016 A.R. Social Security Number 

Date of Birth 

August 2, 2016 T.W. Social Security Number 

Date of Birth 

November 11, 2016 J.W. Home Address 

January 18, 2017 V.S. Social Security Number 

Defendants and their co-conspirators also established other accounts at PayPal in the names of 

false and fictitious U.S. personas. Some personas used to register PayPal accounts were the same 

as the false U.S. personas used in connection with the ORGANIZATION’s social media accounts. 

91. Defendants and their co-conspirators purchased credit card and bank account numbers from 

online sellers for the unlawful purpose of evading security measures at PayPal, which used account 

numbers to verify a user’s identity. Many of the bank account numbers purchased by Defendants 

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Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 33 of 37 

and their co-conspirators were created using the stolen identities of real U.S. persons. After 

purchasing the accounts, Defendants and their co-conspirators submitted these bank account 

numbers to PayPal. 

92. On or about the dates identified below, Defendants and their co-conspirators obtained and 

used the following fraudulent bank account numbers for the purpose of evading PayPal’s security 

measures: 

Approximate Date Card/Bank Account 

Number 

Financial 

Institution 

Email Used to Acquire 

Account Number 

June 13, 2016 xxxxxxxxx8902 Bank 2 wemakeweather@gmail.com 

June 16, 2016 xxxxxx8731 Bank 1 allforusa@yahoo.com 

July 21, 2016 xxxxxx2215 Bank 3 antwan_8@yahoo.com 

August 2, 2016 xxxxxx5707 Bank 1 xtimwaltersx@gmail.com 

October 18, 2016 xxxxxxxxx5792 Bank 4 unitedvetsofamerica@gmail.com 

October 18, 2016 xxxxxxxxx4743 Bank 4 patriototus@gmail.com 

November 11, 2016 xxxxxxxxx2427 Bank 4 beautifullelly@gmail.com 

November 11, 2016 xxxxxxxxx7587 Bank 5 staceyredneck@gmail.com 

November 11, 2016 xxxxxxxx7590 Bank 5 ihatecrime1@gmail.com 

November 11, 2016 xxxxxxxx1780 Bank 6 staceyredneck@gmail.com 

November 11, 2016 xxxxxxxx1762 Bank 6 ihatecrime1@gmail.com 

December 13, 2016 xxxxxxxx6168 Bank 6 thetaylorbrooks@aol.com 

March 30, 2017 xxxxxxxxx6316 Bank 3 wokeaztec@outlook.com 

March 30, 2017 xxxxxx9512 Bank 3 wokeaztec@outlook.com 

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93. Additionally, and in order to maintain their accounts at PayPal and elsewhere, including 

online cryptocurrency exchanges, Defendants and their co-conspirators purchased and obtained 

false identification documents, including fake U.S. driver’s licenses. Some false identification 

documents obtained by Defendants and their co-conspirators used the stolen identities of real U.S. 

persons, including U.S. persons T.W. and J.W. 

94. After opening the accounts at Bank 1 and PayPal, Defendants and their co-conspirators 

used them to receive and send money for a variety of purposes, including to pay for certain 

ORGANIZATION expenses. Some PayPal accounts were used to purchase advertisements on 

Facebook promoting ORGANIZATION-controlled social media accounts. The accounts were also 

used to pay other ORGANIZATION-related expenses such as buttons, flags, and banners for 

rallies. 

95. Defendants and their co-conspirators also used the accounts to receive money from real 

U.S. persons in exchange for posting promotions and advertisements on the ORGANIZATIONcontrolled social media pages. Defendants and their co-conspirators typically charged certain U.S. 

merchants and U.S. social media sites between 25 and 50 U.S. dollars per post for promotional 

content on their popular false U.S. persona accounts, including Being Patriotic, Defend the 2nd, 

and Blacktivist. 

All in violation of Title 18, United States Code, Section 1349. 

COUNTS THREE THROUGH EIGHT 

(Aggravated Identity Theft) 

96. Paragraphs 1 through 7, 9 through 27, and 29 through 85, and 89 through 95 of this 

Indictment are re-alleged and incorporated by reference as if fully set forth herein. 

97. On or about the dates specified below, in the District of Columbia and elsewhere, 

34 
 

 

 

 

 

 

Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 35 of 37 

Defendants INTERNET RESEARCH AGENCY LLC, DZHEYKHUN NASIMI OGLY 

ASLANOV, GLEB IGOREVICH VASILCHENKO, IRINA VIKTOROVNA KAVERZINA, and 

VLADIMIR VENKOV did knowingly transfer, possess, and use, without lawful authority, a 

means of identification of another person during and in relation to a felony violation enumerated 

in 18 U.S.C. § 1028A(c), to wit, wire fraud and bank fraud, knowing that the means of 

identification belonged to another real person: 

Count Approximate Date Initials of Identity 

Theft Victim Means of Identification 

3 June 16, 2016 T.B. Social Security Number 

Date of Birth 

4 July 21, 2016 A.R. Social Security Number 

Date of Birth 

5 July 27, 2016 T.C. Social Security Number 

Date of Birth 

6 August 2, 2016 T.W. Social Security Number 

Date of Birth 

7 January 18, 2017 V.S. Social Security Number 

8 May 19, 2017 J.W. Home Address 

Date of Birth 

All in violation of Title 18, United States Code, Sections 1028A(a)(1) and 2. 

FORFEITURE ALLEGATION 

98. Pursuant to Federal Rule of Criminal Procedure 32.2, notice is hereby given to Defendants 

that the United States will seek forfeiture as part of any sentence in accordance with Title 18, 

United States Code, Sections 981(a)(1)(C) and 982(a)(2), and Title 28, United States Code, Section 

2461(c), in the event of Defendants’ convictions under Count Two of this Indictment. Upon 

conviction of the offense charged in Count Two, Defendants INTERNET RESEARCH AGENCY 

LLC, DZHEYKHUN NASIMI OGLY ASLANOV, and GLEB IGOREVICH VASILCHENKO 

35 
Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 36 of 37 

shall forfeit to the United States any property, real or personal, which constitutes or is derived from 

proceeds traceable to the offense of conviction. Upon conviction of the offenses charged in Counts 

Three through Eight, Defendants INTERNET RESEARCH AGENCY LLC, DZHEYKHUN 

NASIMI OGLY ASLANOV, GLEB IGOREVICH VASILCHENKO, IRINA VIKTOROVNA 

KAVERZINA, and VLADIMIR VENKOV shall forfeit to the United States any property, real or 

personal, which constitutes or is derived from proceeds traceable to the offense(s) of conviction. 

Notice is further given that, upon conviction, the United States intends to seek a judgment against 

each Defendant for a sum of money representing the property described in this paragraph, as 

applicable to each Defendant (to be offset by the forfeiture of any specific property). 

Substitute Assets 

99. If any of the property described above as being subject to forfeiture, as a result of any act or 

omission of any defendant -- 

a. cannot be located upon the exercise of due diligence; 

b. has been transferred or sold to, or deposited with, a third party; 

c. has been placed beyond the jurisdiction of the court; 

d. has been substantially diminished in value; or 

e. has been commingled with other property that cannot be subdivided without 

difficulty; 

36 
it is the intent of the United States of America, pursuant to Title 18, United States Code, Section 

982(b) and Title 28, United States Code, Section 246l(c), incorporating Title 21, United States 

Code, Section 853, to seek forfeiture of any other property of said Defendant. 

(18 U.S.C. §§ 98l(a)(l)(C) and 982; 28 U.S.C. § 2461(c)) 

t?(t-Jv/4.dl ~ Robert S. t1ueller, III __. 

Special Counsel 

U.S. Department of Justice 

A TRUE BILL: 

Foreperson 

Date: February _ , 2018 

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