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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