materials transmitted within the United States with a conspicuous statement disclosing that the materials are distributed by the agent on behalf of the foreign principal.
RT'S COVERT OPERATIONS THROUGH U.S. COMPANY-1
Founder-1 Scouts Influencers for "Eduard Grigoriann"
14. In or about December 2022, Founder-1 began working with an individual operating under the fictitious name "Eduard Grigoriann," and three purported representatives of "Eduard Grigoriann" (Persona-1 and two additional purported representatives, "Persona-2" and "Persona-3") to launch a new YouTube channel, initially under the name "Viewpoint Productions." On or about January 10, 2023, Persona-2 told Founder-1 that Founder-1's "first task" was to "find a personality that could serve as the face of the channel," and that "[f]or the right candidate we're willing to pay around $1-2 million per year." On or about January 13, 2023, Persona-2 sent Founder-1 a proposed contract for Founder-1's "Influencer Talent Scouting" services, with Founder-1 listed as the "Agent" and a Hungarian entity ("Hungarian Shell Entity-1") listed as the "Client." Hungarian Shell Entity-1 has no publicly available website. In exchange for Founder-1's services, the proposed contract awarded Founder-1 $8,000 per month, plus a percentage of any deals that Founder-1 "close[d] with influencers." Over the next several months, while Founder-1 continued to negotiate Founder-1's contract, Founder-1 accepted interim payments and began to "scout" for influencers for the new YouTube channel for "Eduard Grigoriann."
15. Beginning in or about February 2023, Founder-1 solicited Commentator-1 and Commentator-2 to perform work on behalf of "Eduard Grigoriann." For example:
- On or about February 6, 2023, Persona-1 emailed Founder-1 a "shortlist of candidates" for the YouTube channel, including Commentator-1 and Commentator-2. In the same email, Persona-1 attached a receipt for an $8,000 money transfer from an entity in the Czech Republic ("Czech Shell Entity-1") to Founder-1's Canadian company, Canadian Company-1.
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