- 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 contained in paragraphs 1 through 44 of this Indictment are incorporated as though fully set forth herein.
49. 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, willfully and knowingly combined, conspired, confederated, and agreed, together and with each other, to commit money laundering, in violation of Title 18, United States Code, Section 1956(a)(2)(A).
50. It was a part and an object of the conspiracy that KOSTIANTYN KALASHNIKOV, a/k/a "Kostya," and ELENA AFANASYEVA, a/k/a "Lena," the defendants, and others known and unknown, would and did transport, transmit, and transfer, and attempt to transport, transmit, and transfer, a monetary instrument and funds from a place in the United States to and through a place outside the United States and to a place in the United States from and through a place outside the United States, with the intent to promote the carrying on of specified unlawful activity, to wit, felony violations of the Foreign Agents Registration Act, in violation of Title 18, United States Code, Section 1956(a)(2)(A).
(Title 18, United States Code, Section 1956(h).)
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