SEALED INDICTMENT UNITED STATES OF AMERICA LEV PARNAS, IGOR FRUMAN ...

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

-

-

-

X

SEALED INDICTMENT

UNITED STATES OF AMERICA

19 Cr .

- v.

-

LEV PARNAS,

IGOR FRUMAN

,

DAVID CORREIA, and

ANDREY KUKUSHKIN,

Defendants

-

.

X

The Grand

Jury

charges

:

INTRODUCTI ON

1.

Throug h

foreign

nationals

certain

expenditures

from

, a n d prohibits

name

another.

through

the

and

amounts

with

federal

is

to

foreign

their

(i)

financial

campaign

the

true

anyone

Election

contributions

elections

protect

making

Congress

Federal

of

e l ection

the

.

United

influence

committees,

sources

of

laws ,

contribut

in connection

elections

of

its

with

from

Congress

i ons ,

federal

requires

Commission

(the

expenditures

A purpose

States

, and to

federal

contributions

do n ations

, State

of these

electoral

further

regulators

to

i ons

public

"FEC")

and

in

t he

reporting

of the

made

,

, and local

mak i ng contribut

further

and

prohibits

in

sources

connection

laws , ta ken together

system

inform

, and

candidates

from

all

illega

candidates

the

,

l

,

publ i c of

for

federal

office

;

federal

and

(ii)

, State

any

, or local

2.

against

foreign

th e

regulators

,

laundering

limit

make

than

legal

in the

buy

were

were

funded

to

influence

money .

entering

"straw

true

requirements

; or

to

(ii)

by FROMAN

, which

allowed

2

,

federal

agreements,

the

names

donors

reported

rather

funds .

defendants

, joint

and made

ons

of

who purported

committees

conceal

were

defendants

the i r own names ,

candidates

cont ributi

candidates,

secret

IGOR FRUMAN, the

,

so that

campaigns

in

funnel

the us e of straw

of the

ex pen diture

to

The

.

accounts

in

federal

corporation

with

,

federal

office

contributors")

source

to

State

into

bank

the

a scheme

influence

contributions

of

and

candidates

funne l ed through

source

in

, and through

LEV PARNAS and

true

circumvent

governments

the

or

name of the

liability

reporting

'

through

~conduits"

contributions

the

i al

corporations

intentionally

limited

potent

t h e publ i c by

commi tt ,ees , and independent

were

federal

from

money

to

for

scheme

campaign

3.

additional

foreign

by engaging

candidates

foreign

known as

conspired

the

and

ed liability

(also

nationals

with

influence

could

t he

,

candidates

and

concealed

to

to

defendants

,

foreign

elections

defendants

foreign

money

campaigns

by

LEV PARNAS, IGOR FRUMAN

, DAVID CORREIA, and ANDREY

KUKUSHKIN, t he

laws

effort

that

that

in

the

fundraising

either

skirt

( i)

name of , a

PARNAS and

and

, made

the

FRUMAN

federa

l

in PARNAS' s name but

FRUMANto

exceed

limits

on

contributions

to candidates

contributed

.

conspiracy

by ,

make false

statements

or committees

The defendants

among

further

other

to

concealed

things,

the

to whom he had previously

making

this

and

aspect

causing

of the

others

to

FEC.

THE CAMPAIGN FINANCE LAWS

4.

amended ,

(the

the

The

Ti tle

52 ,

"Election

indirectly,

l imit

outcome

on the

the

amou n ts

residents

which

for

committee,

are

committees

multiple

Election

Act ,

Act,

the

To

States

to a federal

including

established

at

prevent

the

the

El ection

also

Act

candidate

, directly

donations

in

Additionally,

could

have

or lawful

and the

fundraising

t h e purpose

on

the

limits

permanent

candidate

's

committees,

of

fundraising

same time .

individuals

and to enable

on

Act establishes

citizens

for

nationals

or

person

joint

seq . ,

on

nationals

elections.

, t h e Election

United

committees

6.

the

election

even

foreign

one

et

as

influences

foreign

contributions

any

1971 ,

.

of

, or local

that

can contribute

authorized

any

, State

influence

that

influence

making

federal

of a federal

the

of

30101 ,

financial

office

Act prohibits

from

with

federal

Act

Section

cer:tain

for

Election

Campaign

Code ,

prohibits

To preve nt

, the

connection

to

States

of candidates

5.

or

Election

United

Act " ) ,

election

elections

Federal

detection

prohibits

3

from

circumventing

of attempts

a person

the

to circumvent

from

mating

a

political

any

contribution

federal

a straw

election

donor

funds

on

for

to

a

committee

from

straw

of the

name of

to

7.

States

the

with

fundraising

file

regular

in st i ll

public

corruption

and

requires

all

the

of the

al l see

the

the

FEC to

candidates

specific

of that

straw

abuses

of

corruption,

reports

political

contr i butions

candidates

and registered

and

about

in the

spending

the

United

of

joint

,

of

Election

process

it

amounts

involving

.

the

Act

Act

so that

enforcement

and

to

against

Election

receives

and law

committees

4

the

the

expenditures

political

amounts

of

that

the

source

committees

election

public,

information

candidates

and

appea r ance

entire

true

of

expenditure

the

federal

and prohibitions

requ i ring

sources

the

.

department

in

, the

the

committee

and

to

a donation

expenditure

confidence

the

as

campaign

pass

's

contributing

To deter

publish

donor

name of

with

funds

candidate

t h e limits

t he

receive.

by giving

a

federal

by

connection

committee

, and independent

of

in

prohibits

an agency

part

to

the

Act also

in

reports

they

in

to enforce

committees

contributions

and

than

an independent

Act ,

the

or

rather

jurisdiction

Election

of having

f und raising

FEC is

another

example,

joint

outcome

The

for

candidate

or

to

the

name of

purpose

The Election

another

influence

the

donor,

money .

the

, including,

federal

campaign

the

in

may

sources

federal

of

RELEVANT INDIVIDUALS AND ENTITIES

8.

United

LEV PARNAS,

States

citizen

9.

United

States

and

is

a businessman

and

defendant

, is

a businessman

and

in the

United

who was born

12.

citizen

Foreign

citizen

and

citizen

or lawful

National-1

who ,

permanent

at

,

defendant

who was born

businessman

a

in Belarus.

ANDREY KUKUSHKIN, the

States

is

in Ukraine.

who was born

citizen

,

defendant

DAVID CORREIA, the

11 .

businessman

who was born

citizen

States

and Uni ted

defendant

IGOR FRUMAN, the

10 .

United

the

, is

in Ukraine

is

a foreign

all

relevant

resident

States

.

a businessman

.

national

Russian

times ,

of t h e United

was

not

a

States.

THE STRAW DONOR SCHEME

13.

Beginning

IGOR FRUMAN

, the

events

independent

their

to

influence

or

federa

candidates

in

i cal

financial

interests

Ukrainian

government

,

political

20 18 ,

l elections

joint

the

circles

, sought

committees

purpose

and

to

of

gaining

no

political

interests

official

with

whom they

were

and

access

their

of

,

enhancing

significant

advance

the

5

fundraising

and mak i ng substantial

fundraising

with

LEV PARNAS and

po li tical

FRUMAN, who had

donations

and

March

attending

committees

PARNAS and

of polit

about

, began

with

expenditure

politicians.

history

defendants

in connection

contributions

in

at

to

prio r

personal

least

working.

one

In

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