Page:U.s. v. kalashnikov and afanasyeva indictment 0.pdf/1

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

1. 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").
2. 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