UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK SEALED ...
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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.
The Grand Jury charges:
INTRODUCTION
1.
foreign
Through
nationals
its
from
election
making
laws,
Congress
contributions,
donations,
certain expenditures in connection with federal.
elections,
name
of
prohibits
State,
and
and local
and prohibits anyone from making contributions in the
another.
Congress
further
through the Federal Election Commission
requires
public
(the "FEC")
reporting
of the sources
and amounts of contributions and expenditures made in connection
with federal elections.
is
to
protect
the
A purpose of these laws,
United
States
electoral
taken together,
system
from
illegal
foreign financial influence, and to further inform all candidates,
their campaign committees,
(i)
the true
sources
federal regulators,
of contributions
and the public of
to candidates
for
federal
office;
and
federal,
(ii)
State,
laws
LEV PARNAS,
the
against
foreign
defendants
campaigns,
laundering
buy
the
foreign
for
potential
from
to
known
make
as
legal
to
to
circumvent
public
money
by
"conduits"
campaign
a
influence
influence
entering
bank
and ANDREY
the
scheme
and State
candidates,
through
or
in
federal
to
office
with
governments.
the
limited liability corporations,
(also
nationals
DAVID CORREIA,
federal
candidates'
scheme
and
conspired
candidates
the
the
regulators,
foreign
influence by engaging
could
and
concealed
by
IGOR FRUMAN,
defendants,
foreign money to
the
effort
or local elections with foreign money.
2.
KUKUSHKIN,
any
so that
candidates,
The
defendants
campaigns,
into
secret
accounts
in
funnel
federal
agreements,
the
names
of
and through the use of straw donors
"straw
contributors")
contributions
in
their
who purported
own
names,
rather
than in the name of the true source of the funds.
3.
LEV
PARNAS
and
IGOR
additional contributions to federal
committees,
were
were
liability
the
the
candidates,
defendants,
joint
made
fundraising
and independent expenditure committees that either
intentionally
limited
FRUMAN,
true
funneled
through,
corporation
conceal
of
contributions
reporting requirements;
or
(ii)
were
which
funded by
source
to
and made
FRUMAN,
in
that
and
the
name
PARNAS
skirt
and
the
of,
(i)
a
FRUMAN
federal
were reported in PARNAS's name but
allowed
2
FRUMAN
to
exceed
limits
on
contributions to candidates or committees to whom he had previously
contributed.
The defendants further concealed this aspect of the
1 ' l!
oop^pidacy by,
among
other
things,
making
and
causing
others
to
1971,
as
l/'V
itteke. false statements to the FEC.
M'i ViV'Ivai r,
THE CAMPAIGN FINANCE LAWS
4.
amended.
(the
The
Title
"Election
52,
Federal
United
Act"),
elections,
or
To
States
prohibits
the election of candidates
5.
Election
prevent
from
the
making
certain
any
to
that
influence
Section
of
30101,
financial
influence
State,
the
Act
seq.,
et
influences
on
nationals
on
for federal office.
connection with federal,
limit
Code,
the Election Act prohibits
indirectly,
Campaign
outcome of a federal election,
of
foreign
foreign nationals,
contributions
or
donations
or local elections.
any
one
person
directly
in
Additionally,
could
have
on
the
the Election Act establishes limits
on the amounts that even United States citizens or lawful permanent
residents can contribute to a federal candidate and the candidate's
authorized
which
are
committee,
committees
including
established
joint
for
fundraising
the
purpose
of
committees,
fundraising
for multiple committees at the same time.
6.
To
prevent
individuals
from
circumventing
the
Election Act,
and to enable the detection of attempts to circumvent
the
Election Act
Act,
the
also
prohibits
3
a
person
from making
a
political
any
a
contribution
federal
election,
straw donor
funds
on
for
to
a
from the
straw donor,
of
including,
federal
committee
name
the name of
the purpose
campaign
of the money.
in
or
for
or
to
fundraising
rather than
in
example,
of having the
candidate
joint
another
a
connection with
by giving
funds
straw donor pass
candidate's
committee
as
in the name of the
a
to
the
federal
donation
true source
The Election Act also prohibits contributing in the
another
to
an
independent
to influence the outcome of that
7.
The
FEC
is
expenditure
committee
spending
federal campaign.
an agency and
department
of
the United
States with jurisdiction to enforce the limits and prohibitions of
the
Election
Act,
in
fundraising committees,
file
regular
contributions
and
instill
corruption
requires
FEC
the
requiring
candidates,
the
sources
and
To deter abuses
in
the
appearance
of
corruption,
to publish the
amounts
of the
confidence
all of the candidates,
all
of
they receive.
and
by
joint
and independent expenditure committees to
reports
public
the
part
election
reports
the entire public,
that
it
the
Election Act
process
the
of
against
Election
receives
Act
so that
and law enforcement may
see the specific information about the amounts and sources of
political
contributions
and
expenditures
candidates and registered political committees.
4
involving
federal
RELEVANT INDIVIDUALS AND ENTITIES
8.
LEV
PARNAS,
the
defendant,
is
a
businessman
and
a
businessman
and
United States citizen who was born in Ukraine.
9.
IGOR
FRUMAN,
the
defendant,
is
United States citizen who was born in Belarus.
10.
DAVID CORREIA,
the defendant,
is a businessman and
United States citizen who was born in the United States.
11.
ANDREY
KUKUSHKIN,
the
defendant,
is
a
businessman
and United States citizen who was born in Ukraine.
12.
citizen
and
Foreign
National-1
businessman
who,
at
is
a
all
foreign
relevant
national
times,
Russian
was
not
a
citizen or lawful permanent resident of the United States.
THE STRAW DONOR SCHEME
13.
IGOR FRUMAN,
Beginning
in
the defendants,
or
about
March
2018,
LEV
PARNAS
and
began attending political fundraising
events in connection with federal elections and making substantial
contributions
independent
their
candidates,
expenditure
influence
politicians.
history
to
in
financial
interests
Ukrainian
government
committees
political
PARNAS
of political
joint
and
and
the
with
who
sought
political
official
the
circles
FRUMAN,
donations,
fundraising
with
5
purpose
and
had
to
no
access
to
prior
their personal
of
were
and
enhancing
significant
advance
they
of
gaining
interests
whom
committees,
at
least
working.
one
In
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