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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