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-1 and Founder-2's commissions), the wire notes of many of U.S. Company-1's inbound wire transfers ascribe the payments to the purchase of electronics. For example, the wire note for Turkish Shell Entity-1's $318,800 wire payment to U.S. Company-1 on March 1, 2024 read: "BUYING GOODS-INV.013-IPHONE 15 PRO MAX 512GB."
43. To deliver funds into the U.S. Company-1 Bank Account, each of U.S. Company-1's 30 inbound international wire transfers—which totaled nearly $10 million, as set forth above—utilized a correspondent bank in Manhattan, New York.[1]
44. According to records of the FARA Unit, neither U.S. Company-1, nor Founder-1, nor Founder-2 has ever registered as a foreign agent with the Attorney General.
STATUTORY ALLEGATIONS
COUNT ONE
(Conspiracy to Violate the Foreign Agents Registration Act)
45. From at least in or about December 2022 through at least in or about September 2024, in the Southern District of New York, Russia, and elsewhere, KOSTIANTYN KALASHNIKOV, a/k/a "Kostya," and ELENA AFANASYEVA, a/k/a "Lena," the defendants, and others known and unknown, knowingly and intentionally did combine, conspire, confederate, and agree, together and with each other, to commit an offense against the United States, to wit, to knowingly and willfully act and cause U.S. Company-1, Founder-1, and Founder-2 to act as agents
- ↑ Foreign banks often use U.S. banks, in which the foreign bank maintains a "correspondent account," to facilitate international money transfers involving the United States or denominated in U.S. Dollars.
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