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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