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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA V. KOSTIANTYN KALASHNIKOV, a/k/a "Kostya," and ELENA AF ANASYEV A, a/k/a "Lena," Defendants. The Grand Jury charges: SEALED INDICTMENT 24 Cr. 2 4CRIM INTRODUCTION 519 1. RT, formerly known as "Russia Today," is a state-controlled media ... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
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. domesti... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
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-I agreed to work with U. S. Company-I and produced approximately 130 videos that were pub... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
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... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
discussions of, among other things, U. S. Company-1 's funding, hiring, and contract negotiations with Commentator-I and Commentator-2. 9. ELENA AFANASYEV A, a/k/a "Lena," the defendant, is a citizen of Russia and an employee of RT. AFANASYEVA has identified herself on social media as "a producer at RT, dealing with ov... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
1 also wrote approximately 25 opinion articles that were published on RT's website, at least 19 of which Founder-1 billed to ANO TV-Novosti. None of Founder-1 's articles disclosed that Founder-1 was paid by RT to write them. b. To create content for RT pursuant to F ounder-1 's written contract, Founder-1 worked with ... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
2 on Discord: "also I say we bill the russians for the last month once we're done the extra opeds," referring to Founder-1 's paid opinion articles for RT. And on or about January 5, 2022, Founder-2 messaged an acquaintance on Discord about paid leave that "[t]he Russians" had offered to Founder-I. d. From in or about ... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
an array of social media channels, including You Tube, Tik Tok, X, Facebook, Instagram, and Rumble. To support the production and publication of its videos, U. S. Company-I employs three staff producers-Producer-I, Producer-2, and a third individual ("Producer-3 ")-and a purported outside editing firm staffed by, among... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
materials transmitted within the United States with a conspicuous statement disclosing that the materials are distributed by the agent on behalf of the foreign principal. RT'S COVERT OPERATIONS THROUGH U. S. COMPANY-1 Founder-I Scouts Influencers for "Eduard Grigoriann" 14. In or about December 2022, Founder-I began wo... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
Persona-I requested that Founder-I submit an invoice for Founder-1 's "consultation services" to Czech Shell Entity-I, which Persona-I described as "our Czech sister company. " Czech Shell Entity-I has a website purporting to sell automobile parts, but also listing unrelated services (e. g., "Cyber Amor Suite, Fortifyi... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
[Commentator-2] based on ad revenue from web traffic or sponsors alone. " Despite Founder-1 's warning that Commentator-I and Commentator-2 would not be profitable to employ, on or about February 14, 2023, Persona-I informed Founder-I that "[w]e would love to move forward with [Commentator-I and Commentator-2]. " d. On... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
writing that Persona-1 was unsure that "Mr. Grigoriann... gave out any public interviews, but you could send [Commentator-1] our Linkedln page," with a hyperlink to a Linkedln page for Viewpoint Productions. Persona-1 also attached a receipt for another $8,000 money transfer from Czech Shell Entity-1 to Canadian Compan... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
The Fake "Eduard Grigoriann " Profile J. Bank-1 's affiliate in the United States has no record of an "Eduard Grigoriann " ever being employed by Bank-1. Nor, as set forth above, do Google searches for "[Bank-1] Eduard Grigoriann" yield any results for a person by that name. 13 | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
16. Other irregularities in Founder-1 's email correspondence further signaled that "Eduard Grigoriann" and his purported representatives, Persona-I through Persona-3, were all fake personas. For example: a. By on or about February 16, 2023, Persona-I had misspelled the surname of his purported boss as "Grigorian" (rat... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
a term used by liberals, but we're trying to create a conservative network. " Founder-I suggested that "[Commentator-I] and Eduard could simply speak together" to clarify the profile. 19. On or about June 2, 2023, "Eduard Grigoriann" circulated an email to Founder-I and to Commentator-1 's assistant, scheduling a Zoom ... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
transferable... license, during the applicable License Term, to display, transmit, and distribute the Licensed Content. " Founder-I and Founder-2 Negotiate The U. S. Company-I Contract with the "Russians" 21. In or about mid-2023, as Founder-I worked to recruit Commentator-I and. Commentator-2 to perform work on behalf... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
April 28, 2023, Founder-2 messaged Founder-I that "[t]hey [i. e., the investors] also have full rights to the IP," and "[s]o if we grow" the platform, "they can still technically take it away. " Founder-1 replied that the "french" clarified that "we own the channel, but they own the rights to the content," and "so in t... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
Grigoriann" nor Hungarian Shell Entity-1 nor Czech Shell Entity-1, but rather an entity based in the United Kingdom ("U. K. Shell Entity-1 ") that has no website. After forwarding the contract to Founder-2 and discussing it with Founder-2 on Discord, Founder-I signed the contract. 27. Despite describing U. S. Company-1... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
name ("k"). On approximately 38 occasions between in or about December 2023 and in or about January 2024, KALASHNIKOV's Discord account was accessed from a Moscow-based IP address that was also used to access KALASHNIKOV's personal Gmail account on approximately 10 occasions. 29. On or about June 21, 2023, Founder-2 jo... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
Investor Discord Channel, writing: "Hey @[Persona-I], just wanted to follow up and see if your finance department has any update on the transfers. " KALASHNIKOV and AF ANASYEVA Begin Operations at U. S. Company-I 31. As U. S. Company-I prepared to launch in the fall of 2023, consistent with Persona-1 's instruction to ... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
channel on the U. S. Company-I Discord Server, KALASHNIKOV requested raw footage from Commentator-4, and later shared an edited version of Commentator-4's first video for U. S. Company-I. b. KALASHNIKOV similarly participated in a Discord channel on the U. S. Company-I Discord Server for another commentator listed on U... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
"Victoria Pesti" Discord account, which, as set forth below, was another fake persona used by AF ANASYEV A at U. S. Company-I. b. AF AN AS YEV A ( as ''Helena Shudra") initially adopted a similar editorial role as KALASHNIKOV ; for example, in communications on the U. S. Company-I Discord Server, "Helena Shudra" solici... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
[Commentator-4] didn't share any raw videos, ·she only shared her mini doc and its promo. [Commentator-5] is good at sharing our content so far. " AFANASYEVA then asked: "[D]o you think it would be possible if [Producer-I] could start posting videos a bit earlier?" Founder-I responded that Founder-I would "talk to [Pro... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
team. " AFANASYEVA (as "Victoria Pesti") announced that "[f]rom now on our top priority should be establishing [U. S. Company-I] social media presence and we do ask you to start sharing [U. S. Company-I] posts through your own accounts daily. " 37. Second, with Founder-1 and Founder-2's backing, AFANASYEVA directed U. ... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
more. Producer-I privately messaged Founder-I, writing: "I don't know if you saw it, but they want me to post some footage from an attack in Moscow today. There's a watermark in the middle of the page that's blurred, which looks bad, and it's also pretty graphic. You can see people getting shot, albeit from far away. "... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
accounts. Founder-I thus gave AFANASYEVA and KALASHNIKOV unfettered access to serve RT messaging to U. S. Company-1 's audiences. U. S. Company-] Receives Nearly $10 Million From Foreign Shell Entities 39. Founder-I and Founder-2 profited from their unregistered services to RT: a. Starting in approximately August 2023,... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
alone," U. S. Company-1 's foreign wire transfers far exceeded its receipts of advertising revenue. Indeed, the approximately $9. 7 million that U. S. Company-I received from foreign wire transfers represented nearly 90% of all the deposits into the U. S. Company-I Bank Account from in or about October 2023 to in or ab... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
Grigoriann," U. K. Shell Entity-1 (U. S. Company-1 's purported contract counterparty), Persona-1, Persona-2, Persona-3, Viewpoint Productions, Hungarian Shell Entity-1, or Czech Shell Entity-1. 42. Contrary to U. S. Company-1 's invoices, which reflect fees for staff and commentators (as well as Founder-I and Founder-... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
of foreign principals without registering with the Attorney General, in violation of Title 22, United States Code, Sections 612 and 618. 46. It was a part and an object of the conspiracy that KOSTIANTYN KALASHNIKOV, and ELENA AFANASYEVA, a/k/a "Lena," the defendants, and others known and unknown, would and did knowingl... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
--------------■-from foreign shell entities in furtherance of the conspiracy, each of which was processed by a correspondent bank in the Southern District of New York. (Title 18, United States Code, Section 371. ) COUNT TWO (Conspiracy to Commit Money Laundering) The Grand Jury further charges: 48. The allegations cont... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
FORFEITURE ALLEGATIONS 51. As a result of committing the offense alleged in Count One of this Indictment, KOSTIANTYN KALASHNIKOV, a/k/a "Kostya," and ELENA AFANASYEVA, a/k/a "Lena," the defendants, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 981(a)(l)(C) and Title 28, United St... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p) and Title 28, United States Code, Section 2461 ( c ), to seek forfeiture of any other property of the defendants up to the value of the above forfeitable property. (Title 18, United States Code, Sections 981 and 982; Title 2... | u.s._v._kalashnikov_and_afanasyeva_indictment_0.pdf |
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