FEDERAL ELECTION COMMISSION 

WASHINGTON, D.C. 20463 

STATEMENT OF REASONS OF COMMISSIONERS 

SHANA M. BROUSSARD AND ELLEN L. WEINTRAUB 

The Federal Election Commission has been tasked with overseeing the civil enforcement of the 

Federal Election Campaign Act, as amended (the “Act”).1 While enforcement of the Act can sometimes 

involve seeking civil penalties, the core of the Commission’s mission is to promote transparency and 

integrity in our elections. It is this aspect of our mission, the responsibility to ensure the accurate public 

disclosure of funds raised and spent to influence federal elections that is truly unique. Thus, the 

Commission has an obligation to ensure that the public has access to accurate and complete information 

concerning election spending.2 

In this matter, the Complaint alleged that Igor Fruman and Lev Parnas used Global Energy 

Producers, LLC (“GEP”), a company they jointly controlled,3and Aaron Investments I, LLC, a 

company controlled by Parnas and his wife,4

as conduits to make contributions to America First Action, 

Inc. (“AFA”). This was accomplished through the sale or refinancing of a Florida property owned by 

Seafront Properties LLC (“Seafront Properties”), an entity whose ownership and funding sources remain 

unclear, even after extensive criminal proceedings.5 Fruman and Parnas have individually been the 

subject of criminal trials, and have pleaded guilty or been convicted at trial of numerous charges, some 

unrelated to the allegations in this Complaint, and others related to violations under the Act.6

 

1 Enforcement, FEC.gov, https://www.fec.gov/legal-resources/enforcement/. 2 See Mission and History, FEC.gov, https://www.fec.gov/about/mission-and-history/. 3 Compl. ¶ 7 (July 26, 2018); GEP, Parnas and Fruman Resp. at 4 (Oct. 14, 2018) (“Joint Resp.”); Delaware Dep’t of 

State, Division of Corporations, https://icis.corp.delaware.gov/eCorp/EntitySearch/NameSearch.aspx (search for “Global 

Energy Producers”). 

4 Florida Dep’t of State, Division of Corporations, http://search.sunbiz.org/Inquiry/CorporationSearch/ByName

(search for “Aaron Investments I, LLC”) (indicating administrative dissolution in 2019); see also Supp. Compl. at 2 n.1 

(June 20, 2019). Parnas attests that he and his wife controlled the Aaron LLC account. See Joint Supp. Resp., Parnas Supp. 

Aff. ¶ 10. 

5 First General Counsel’s Report (“FGCR”) at 5 (noting that Fruman’s brother, Steven Fruman, is listed on loan 

documents as Seafront Properties’ “manager” but that its ultimate ownership remains unknown). 6 See generally, U.S. v. Parnas, No. 19 CR 725 (S.D.N.Y.); FGCR at 6-7 (summarizing criminal proceedings). As 

OGC noted, Fruman pleaded guilty to one count of soliciting a foreign national for contributions and donations in connection 

with federal and state elections. U.S. v. Parnas, Minute Entry, Change of Plea Hearing (Sept. 10, 2021), Judgment in a 

Criminal Case (Jan. 21, 2022) (sentencing Fruman to one year and one day and assessing a $10,000 fine). Parnas was 

convicted of conspiracy to make contributions by a foreign national, solicitation of a foreign national, aiding and abetting the 

BEFORE THE FEDERAL ELECTION COMMISSION 

In the Matter of 

Global Energy Producers, LLC, et al. 

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MUR 7442 

MUR744200285
MUR 7442 (Global Energy Producers, LLC, et al.)

Statement of Reasons 

Page 2 of 3

Our Office of General Counsel (“OGC”) reviewed all of the materials available to it from the 

criminal trial, and concluded that the Commission’s interests in transparency and disclosure had not 

been fully vindicated. OGC recommended that the Commission find reason to believe that GEP, Igor 

Fruman and Lev Parnas knowingly and willfully violated 52 U.S.C. § 30122 by making contributions in 

the name of another and permitting their names to be used to effect contributions.7It then proposed an 

extremely limited investigation into the ownership of Seafront Properties and the true source of the 

contributions made from the proceeds of the loan on the condo owned by Seafront Properties. OGC’s 

recommendation contained careful analysis of the violations at issue and what remained to be resolved, 

and we voted to support it. Unfortunately, the Commission failed to garner sufficient votes to find 

reason to believe, investigate the allegations, and complete the record.8 As a result, the public record 

will remain incorrect and inaccurate. AFA has never reported receiving contributions of funds from 

Fruman, Parnas, their siblings, Aaron Investments I, LLC, or Seafront Properties.9 The American public 

should not have to cross-check disclosure reports against criminal trial transcripts to ensure their 

accuracy.

Further, the evidence introduced at trial indicated the presence of additional contributions 

charged to an American Express card belonging to FD Import & Export Corp. (“FD Import”), a 

company with connections to Igor and Steven Fruman,10 which appear to have been later repaid not only 

with proceeds from the loan on the condo owned by Seafront Properties, but also with foreign funds 

provided by Andrey Muraviev,11 a foreign national described by the Department of Justice as a Russian 

oligarch.12 Communications introduced at trial between Muraviev, Fruman, and Parnas made it 

abundantly clear that the money being wired was intended to cover contributions made by Parnas and 

Fruman, and that it was coming from Muraviev, a foreign national.13 The Act’s clear prohibitions on 

contributions in the name of another and foreign national contributions are among the most serious 

violations within the Commission’s jurisdiction.14 Yet despite the information introduced at Parnas’s 

trial clearly indicating that Fruman and Parnas made contributions using funds that did not belong to 

them, the Commission failed to garner sufficient votes to take any further action.15 To be clear, this in 

making of contributions by a foreign national, conspiracy to make contributions in the name of another, making false 

statements, and falsification of records. U.S v. Parnas, Verdict Form (Oct. 22, 2021). 7 See FGCR at 25-30. 8 Certification (“Cert.”), ¶1. (May 24, 2022). 9 See FEC Receipts: Filtered Results, FEC.GOV, https://www.fec.gov/data/receipts/individualcontributions/?contributor_namew=igor+furman&committee_id=C00637512&contributor_name=Global+energy+producers

&contributor_name=Igor+fruman&contributor_name=aaron+llc&contributor_name=aaron%2C+llc&contributor_name=fru

man&contributor_name=igor+furman&contributor_name=lev+parnas&contributor_name=muraviev&contributor_name=par

nas&contributor_name=seafront&min_date=01%2F01%2F2018&max_date=12%2F31%2F2018. 10 See U.S. v. Parnas, No. 19 CR 725 (S.D.N.Y.), Trial Ex. 43-A-20 (showing a “Loan Agreement” that Steven 

Fruman signed on behalf of FD Import as “Manager” to secure $500,000 from Muraviev, as discussed further below); Trial 

Ex. 48-A-26 (same except Steven Fruman signed as “Director” of FD Import); Trial Transcript 949:8-10 (Espinoza, Direct) 

(“Trial Tr.”) (Steven Fruman is the primary cardholder on the FD Import corporate credit card); Trial Tr. 952:15-17 

(Espinoza, Direct) (Steven Fruman is the account holder for FD Import’s Chase bank account used to pay off 99% of FD 

Import’s credit card); Trial Ex. 1403 at 2 (summary exhibit showing “Sources of Payment on FD Import Export Amex Credit 

Card Balance”). 

11 FGCR at 37-42. 12 Press Release, U.S. Dep’t of Justice, Russian Oligarch Charged with Making Illegal Political Contributions 

(Mar. 14, 2022), https://www.justice.gov/usao-sdny/pr/russian-oligarch-charged-making-illegal-political-contributions. 13 See FGCR at 40-41. 14 52 U.S.C. §§ 30121, 30122. 15 Cert. ¶1. 

MUR744200286
MUR 7442 (Global Energy Producers, LLC, et al.) 

Statement of Reasons 

Page 3 of 3 

no way exonerates the respondents for the activities established at trial. But as a result, the record will 

remain undeveloped and unclear concerning the true sources of those funds. 

The prohibitions on foreign national contributions and contributions made in the name of 

another are integral to ensuring transparency and integrity in our elections. The violations at issue were 

sizable, the record clearly indicated that the Act had not only been violated but had been knowingly 

violated, and OGC had a clear and measured plan to use minimal resources to vindicate the 

Commission’s interests and clarify the public record. Sadly, yet unsurprisingly, these significant 

violations have been brushed aside, and vital information concerning the sources of funds affecting 

federal elections remains unavailable to the American public. 

______________________ __________________________ 

Date Shana M. Broussard 

Commissioner 

______________________ __________________________ 

Date Ellen L. Weintraub 

Commissioner 

July 1, 2022

July 1, 2022

MUR744200287