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 knowingly and willfully act and cause U.S. Company-1, Founder-1, and Founder-2 to act as agents of foreign principals without registering with the Attorney General, as required by law, in violation of Title 22, United States Code, Sections 612 and 618.
Overt Acts
47. In furtherance of the conspiracy and to effect the illegal object thereof, KOSTIANTYN KALASHNIKOV, a/k/a "Kostya," and ELENA AFANASYEVA, a/k/a "Lena," the defendants, and others known and unknown, committed the following overt acts, among others, in the Southern District of New York and elsewhere:
- In or about August 2023, KALASHNIKOV added AFANASYEVA to the U.S. Company-1 Discord Server.
- In or about 2024, AFANASYVEA circulated to U.S. Company-1 staff approximately 841 video clips, which were routinely posted onto U.S. Company-1's social media channels.
- In or about June 2024, Founder-1 authorized AFANASYEVA and KALASHNIKOV to post content directly on U.S. Company-1's platform.
- Between in or about October 2023 and in or about August 2024, members of the conspiracy caused U.S. Company-1 to receive approximately 30 international wire transfers
29
