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- UNITED STATES OF AMERICA
- V.
- INTERNET RESEARCH AGENCY LLC
- A/K/A MEDIASINTEZ LLC A/K/A
- GLAVSET LLC A/K/A MIXINFO
- LLC A/K/A AZIMUT LLC A/K/A
- NOVINFO LLC,
- CONCORD MANAGEMENT AND
- CONSULTING LLC,
- CONCORD CATERING,
- YEVGENIY VIKTOROVICH
- PRIGOZHIN,
- MIKHAIL IVANOVICH BYSTROV,
- MIKHAIL LEONIDOVICH BURCHIK
- A/K/A MIKHAIL ABRAMOV,
- ALEKSANDRA YURYEVNA
- KRYLOVA,
- _
- ANNA VLADISLAVOVNA
- BOGACHEVA,
- SERGEY PAVLOVICH POLOZOV,
- MARIA ANATOLYEVNA BOVDA
- A/K/A MARIA ANATOLYEVNA
- BELYAEVA,
- ROBERT SERGEYEVICH BOVDA,
- DZHEYKHUN NASIMI OGLY
- ASLANOV A/K/A JAYHOON
- ASLANOV A/K/A JAY ASLANOV,
- VADIM VLADIMIROVICH
- PODKOPAEV,
- GLEB IGOREVICH VASILCHENKO,
- IRINA VIKTOROVNA KAVERZINA,
- and
- VLADIMIR VENKOV.
- Defendants.
- **********-К-**********************
- IN THE UNITED STATES DISTRICT COURT
- FOR THE DISTRICT OF COLUMBIA
- *
- *******
- CRIMINAL NO.
- (18 U.S.C. §§ 2, 371, 1349,1028А)
- INDICTMENT
- The Grand Jury for the District of Columbia charges:
- Intr
- 1.
- uction
- The United States ofAmerica, through its departments and agencies, regulates the activities
- of foreign individuals and entities in and affecting the United States in order to prevent, disclose,
- and counteract improper foreign influence on US. elections and on the US. political system. US.
- law bans foreign nationals from making certain expenditures or financial disbursements for the
- purpose of influencing federal elections. US. law also bars agents of any foreign entity from
- engaging in political activities within the United States without first registering with the Attorney
- General. And US. law requires certain foreign nationals seeking entry to the United States to
- obtain a visa by providing truthful and accurate information to the government. Various federal
- agencies, including the Federal Election Commission, the US. Department of Justice, and the US.
- Department of State, are charged with enforcing these laws.
- 2.
- Defendant INTERNET RESEARCH AGENCY LLC (“ORGANIZATION”) is a Russian
- organization engaged in operations to interfere with elections and political processes. Defendants
- MIKHAIL IVANOVICH BYSTROV, MIKHAIL LEONIDOVICH BURCHIK, ALEKSANDRA
- YURYEVNA KRYLOVA, ANNA VLADISLAVOVNA BOGACHEVA, SERGEY PAVLOVICH
- POLOZOV,
- MARIA ANATOLYEVNA BOVDA,
- ROBERT SERGEYEVICH
- BOVDA,
- DZHEYKHUN NASIMI OGLY ASLANOV, VADIM VLADIMIROVICH PODKOPAEV, GLEB
- IGOREVICH VASILCHENKO, IRINA VIKTOROVNA KAVERZINA, and VLADIMIR
- VENKOV worked in various capacities to carry out Defendant ORGANIZATION’S interference
- operations targeting the United States.
- From in or around 2014 to the present, Defendants
- knowingly and intentionally conspired with each other (and with persons known and unknown to
- the Grand Jury) to defraud the United States by impairing, obstructing, and defeating the lawful
- functions of the government through fraud and deceit for the purpose of interfering with the U.S.
- political and electoral processes, including the presidential election of 2016.
- 3.
- Beginning as early as 2014, Defendant ORGANIZATION began operations to interfere
- with the U.S. political system, including the 2016 U.S. presidential election.
- ORGANIZATION
- received
- funding
- for
- its
- operations
- from
- Defendant
- Defendant
- YEVGENIY
- VIKTOROVICH PRIGOZHIN and companies he controlled, including Defendants CONCORD
- MANAGEMENT AND CONSULTING LLC and CONCORD CATERING (collectively
- “CONCORD”). Defendants CONCORD and PRIGOZHIN spent significant funds to further the
- ORGANIZATION’S operations and to pay the remaining Defendants, along with other uncharged
- ORGANIZATION employees, salaries and bonuses for their work at the ORGANIZATION.
- 4.
- Defendants, posing as U.S. persons and creating false U.S. personas, operated social media
- pages and groups designed to attract U.S. audiences. These groups and pages, which addressed
- divisive U.S. political and social issues, falsely claimed to be controlled by U.S. activists when, in
- fact, they were controlled by Defendants. Defendants also used the stolen identities of real U.S.
- persons to post on ORGANIZATION—controlled social media accounts. Over time, these social
- media accounts became Defendants’ means to reach significant numbers of Americans for
- purposes of interfering with the U.S. political system, including the presidential election of 2016.
- 5.
- Certain Defendants traveled to the United States under false pretenses for the purpose of
- collecting intelligence to inform Defendants’ operations. Defendants also procured and used
- computer infrastructure, based partly in the United States, to hide the Russian origin of their
- activities and to avoid detection by U.S. regulators and law enforcement.
- 6.
- Defendant ORGANIZATION had a strategic goal to sow discord in the U.S. political
- system, including the 2016 U.S. presidential election. Defendants posted derogatory information
- about a number of candidates, and by early to mid-2016, Defendants’ operations included
- supporting the presidential campaign of then-candidate Donald J . Trump (“Trump Campaign”) and
- disparaging Hillary Clinton. Defendants made various expenditures to carry out those activities,
- including buying political advertisements on social media in the names of U.S. persons and
- entities. Defendants also staged political rallies inside the United States, and while posing as U.S.
- grassroots entities and U.S. persons, and without revealing their Russian identities and
- ORGANIZATION afiiliation, solicited and compensated real U.S. persons to promote or disparage
- candidates. Some Defendants, posing as U.S. persons and without revealing their Russian
- association, communicated with unwitting individuals associated with the Trump Campaign and
- with other political activists to seek to coordinate political activities.
- 7.
- In order to carry out their activities to interfere in U.S. political and electoral processes
- without detection of their Russian affiliation, Defendants conspired to obstruct the lawful functions
- of the United States government through fraud and deceit, including by making expenditures in
- connection with the 2016 U.S. presidential election without proper regulatory disclosure; failing
- to register as foreign agents carrying out political activities within the United States; and obtaining
- visas through false and fraudulent statements.
- О NT
- NE
- (Conspiracy to Defraud the United States)
- 8.
- Paragraphs 1 through 7 of this Indictment are re-alleged and incorporated by reference as if
- fully set forth herein.
- 9.
- From in or around 2014 to the present, in the District of Columbia and elsewhere,
- Defendants, together with others known and unknOWn to the Grand Jury, knowingly and
- intentionally conspired to defraud the United States by impairing, obstructing, and defeating the
- lawful functions of the Federal Election Commission, the US. Department of J ustice, and the US.
- Department of State in administering federal requirements for disclosure of foreign involvement
- in cettain domestic activities.
- Defendants
- 10.
- Defendant
- INTERNET
- RESEARCH
- AGENCY
- LLC
- (Агентство
- Интернет
- Исследований) is a Russian organization engaged in political and electoral interference
- operations. In ог around July 2013, the ORGANIZATION registered with the Russian government
- as a Russian corporate entity. Beginning in or around J une 2014, the ORGANIZATION obscured
- its conduct by operating through a number of Russian entities, including Internet Research LLC,
- MediaSintez LLC, GlavSet LLC, Mixlnfo LLC, Azimut LLC, and Novlnfo LLC. Starting in or
- around 2014, the ORGANIZATION occupied an office at 55 Savushkina Street in St. Petersburg,
- Russia.
- That location became one of the ORGANIZATION’S operational hubs from which
- Defendants and other co-conspirators carried out their activities to interfere in the US. political
- system, including the 2016 US. presidential election.
- a.
- The ORGANIZATION employed hundreds of individuals for its online operations,
- ranging from creators of fictitious personas to technical and administrative support.
- The ORGANIZATION’S annual budget totaled the equivalent of millions of US.
- dollars.
- b.
- The ORGANIZATION was headed by a management group and organized into
- departments, including: a graphics department; a data analysis department; a
- search—engine optimization (“SEO”) department; an information—technology (“IT”)
- department to maintain the digital infrastructure used in the ORGANIZATION’S
- operations; and a finance department to budget and allocate funding.
- The ORGANIZATION sought, in part, to conduct what it called “information
- warfare against the United States ofAmerica” through fictitious U.S. personas on
- social media platforms and other Internet-based media.
- By in or around April 2014, the ORGANIZATION formed a department that went
- by various names but was at times referred to as the “translator project.” This
- project focused on the US. population and conducted operations on social media
- platforms such as YouTube, Facebook, Instagram, and Twitter. By approximately
- July 2016, more than eighty ORGANIZATION employees were assigned to the
- translator project.
- By in or around May 2014, the ORGANIZATION’S strategy included interfering
- with the 2016 US. presidential election, with the stated goal of “spread[ing] distrust
- towards the candidates and the political system in general.”
- Defendants
- CONCORD
- MANAGEMENT AND
- CONSULTING
- LLC
- (Конкорд
- Менеджмент и Консалтинг) and CONCORD CATERING are related Russian entities with
- various Russian government contracts. CONCORD was the ORGANIZATION’S primary source
- of funding for its interference operations.
- CONCORD controlled funding, recommended
- personnel, and oversaw ORGANIZATION activities through reporting and interaction with
- ORGANIZATION management.
- CONCORD funded the ORGANIZATION as part of a larger CONCORD-funded
- interference operation that it referred to as “Projechakhta.” Project Lakhta had
- multiple components, some involving domestic audiences within the Russian
- Federation and others targeting foreign audiences in various countries, including
- the United States.
- By in or around September 2016, the ORGANIZATION’S monthly budget for
- Project Lakhta submitted to CONCORD exceeded 73 million Russian rubles (over
- 1,250,000 US. dollars), including approximately one million rubles in bonus
- payments.
- То conceal its involvement, CONCORD labeled the monies paid to the
- ORGANIZATION for Project Lakhta as payments related to software support and
- development.
- То further conceal the source of funds, CONCORD distributed
- monies to the ORGANIZATION through approximately fourteen bank accounts
- held in the names of CONCORD affiliates, including Glavnaya Liniya LLC,
- Merkuriy LLC, Obshchepit LLC, Potentsial LLC, RSP LLC, ASP LLC, MTTs
- LLC, Kompleksservis LLC, SPb Kulinariya LLC, Almira LLC, Pishchevik LLC,
- Galant LLC, Rayteks LLC, and Standart LLC.
- 12.
- Defendant
- YEVGENIY
- VIKTOROVICH
- PRIGOZHIN
- (Пригожин
- Евгений
- Викторович) is a Russian national who controlled CONCORD.
- a.
- PRIGOZHIN approved and supported the ORGANIZATION’S operations, and
- Defendants and their co-conspirators were aware of PRIGOZHIN’S role.
- For example, on or about May 29, 2016, Defendants and their co-conspirators,
- through an ORGANIZATION-controlled social media account, arranged for a real
- US person to stand in front of the White House in the District of Columbia under
- false pretenses to hold a sign that read “Happy 55th Birthday Dear Boss.”
- Defendants and their co-conspirators informed the real US. person that the sign
- was for someone who “is a leader here and our boss . . . our funder.” PRIGOZHIN’s
- Russian passport identifies his date of birth as June 1, 1961.
- 13.
- Defendant MIKHAIL IVANOVICH BYS’I‘ROV (Быстров Михаил Иванович) joined the
- ORGANIZATION by at least in or around February 2014.
- a.
- By approximately April 2014, BYSTROV was the general director, the
- ORGANIZATION’S highest-ranking position. BYSTROV subsequently served as
- the head of various other entities used by the ORGANIZATION to mask its
- activities, including, for example, Glavset LLC, where he was listed as that entity’s
- general director.
- b.
- In or around 2015 and 2016, BYSTROV frequently communicated with
- PRIGOZHIN about Project Lakhta’s overall operations, including through
- regularly scheduled in-person meetings.
- 14.
- Defendant MIKHAIL LEONIDOVICH BURCHIK (Бурчик Михаил Леонидович)
- А/К/А MIKHAIL ABRAMOV joined the ORGANIZATION by at least in or around October
- 2013.
- By approximately March 2014, BURCHIK was the executive director, the
- ORGANIZATION’S second-highest ranking position.
- Throughout the ORGANIZATION’S
- operations to interfere in the US political system, including the 2016 US. presidential election,
- BURCHIK was a manager involved in operational planning, infrastructure, and personnel. In or
- around 2016, BURCHIK also had in-person meetings with PRIGOZHIN.
- 15.
- Defendant ALEKSANDRA YURYEVNA KRYLOVA (Крылова Александра Юрьевна)
- worked for the ORGANIZATION from at least in or around September 2013 to at least in or around
- November 2014.
- By approximately April 2014, KRYLOVA served as director and was the
- ORGANIZATION’S third-highest ranking employee. In 2014, KRYLOVA traveled to the United
- States under false pretenses for the purpose of collecting intelligence to inform the
- ORGANIZATION’S operations.
- 16.
- Defendant SERGEY PAVLOVICH POLOZOV (Полозов Сергей Павлович) worked for
- the ORGANIZATION from at least in or around April 2014 to at least in or around October 2016.
- POLOZOV served as the manager of the IT department and oversaw the procurement of U.S.
- servers and other computer infrastructure that masked the ORGANIZATION’S Russian location
- when conducting operations within the United States.
- 17.
- Defendant ANNA VLADISLAVOVNA BOGACHEVA (Богачева Анна Владиславовна)
- worked for the ORGANIZATION from at least in or around April 2014 to at least in or around
- July 2014. BOGACHEVA served on the translator project and oversaw the project’s data analysis
- group. BOGACHEVA also traveled to the United States under false pretenses for the purpose of
- collecting intelligence to inform the ORGANIZATION’S operations.
- 18.
- Defendant MARIA ANATOLYEVNA BOVDA (Бовда Мария Анатольевна) А/К/А
- MARIA ANATOLYEVNA BELYAEVA (“M. BOVDA”) worked for the ORGANIZATION from
- at least in or around November 2013 to at least in or around October 2014. M. BOVDA served as
- the head of the translator project, among other positions.
- 19.
- Defendant ROBERT SERGEYEVICH BOVDA (Бонда Роберт Сергеевич) (“R.
- BOVDA”) worked for the ORGANIZATION from at least in or around November 2013 to at least
- in or around October 2014. R. BOVDA served as the deputy head of the translator project, among
- other positions. R. BOVDA attempted to travel to the United States under false pretenses for the
- purpose of collecting intelligence to inform the ORGANIZATION’S operations but could not
- obtain the necessary visa.
- 20.
- Defendant DZHEYKHUN NASIMI OGLY ASLANOV (Асланов Джейхун Насими
- Оглы) А/К/А JAYHOON ASLANOV A/K/A JAY AS LANOV joined the ORGANIZATION by at
- least in or around September 2014. ASLANOV served as head of the translator project and
- oversaw many of the operations targeting the 2016 U.S. presidential election. ASLANOV was
- also listed as the general director of Azimut LLC, an entity used to move funds from CONCORD
- to the ORGANIZATION.
- 21.
- Defendant
- VADIM
- VLADIMIROVICH
- PODKOPAEV
- (Подкопаев
- Вадим
- Владимирович) joined the ORGANIZATION by at least in ог around June 2014. PODKOPAEV
- served as an analyst on the translator project and was responsible for conducting U.S.-focused
- research and drafting social media content for the ORGANIZATION.
- 22.
- Defendant GLEB IGOREVICH VASILCHENKO (Васильченко Глеб Игоревич) worked
- for the ORGANIZATION from at least in or around August 2014 to at least in or around September
- 2016. VASILCHENKO was responsible for posting, monitoring, and updating the social media
- content of many ORGANIZATION-controlled accounts while posing as U.S. persons or U.S.
- grassroots organizations. VASILCHENKO later served as the head of two sub-groups focused оп
- operations to interfere in the U.S. political system, including the 2016 U.S. presidential election.
- 23.
- Defendant IRINA VIKTOROVNA KAVERZINA (Каверзина Ирина Викторовна) joined
- the ORGANIZATION by at least in or around October 2014.
- KAVERZINA served оп the
- translator project and operated multiple U.S. personas that she used to post, monitor, and update
- social media content for the ORGANIZATION.
- 24.
- Defendant VLADIMIR VENKOV (Венков Владимир) joined the ORGANIZATION by
- at least in or around March 2015. VENKOV served on the translator project and operated multiple
- 10
- U.S. personas, which he used to post, monitor, and update social media content for the
- ORGANIZATION.
- Federal Regulatory Agencies
- 25.
- The Federal Election Commission is a federal agency that administers the Federal Election
- Campaign Act (“FECA”). Among other things, FECA prohibits foreign nationals from making
- any contributions, expenditures, independent expenditures, or disbursements for electioneering
- communications. FECA also requires that individuals or entities who make certain independent
- expenditures in federal elections report those expenditures to the Federal Election Commission.
- The reporting requirements permit the Federal Election Commission to fulfill its statutory duties
- of providing the American public with accurate data about the financial activities of individuals
- and entities supporting federal candidates, and enforcing FЕСА’Ь` limits and prohibitions,
- including the ban on foreign expenditures.
- 26.
- The U.S. Department of Justice administers the Foreign Agent Registration Act (“FARA”).
- FARA establishes a registration, reporting, and disclosure regime for agents of foreign principals
- (which includes foreign non-government individuals and entities) so that the U.S. government and
- the people ofthe United States are informed of the source of information and the identity of persons
- attempting to influence U.S. public opinion, policy, and law. FARA requires, among other things,
- that persons subject to its requirements submit periodic registration statements containing truthful
- information about their activities and the income earned from them. Disclosure of the required
- information allows the federal government and the American people to evaluate the statements and
- activities of such persons in light of their function as foreign agents.
- 27.
- The U.S. Department of State is the federal agency responsible for the issuance of non-
- immigrant visas to foreign individuals who need a visa to enter the United States.
- 11
- Foreign
- individuals who are required to obtain a visa must, among other things, provide truthful
- information in response to questions on the visa application form, including information about
- their employment and the purpose of their visit to the United States.
- Obiect of the Conspiracy
- 28.
- The conspiracy had as its object impairing, obstructing, and defeating the lawful
- governmental functions of the United States by dishonest means in order to enable the Defendants
- to interfere with U.S. political and electoral processes, including the 2016 U.S. presidential
- election.
- Manner and Means of the Conspiracy
- Intelligence-Gathering to Inform U.S. Operations
- 29.
- Starting at least in or around 2014, Defendants and their co-conspirators began to track and
- study groups on U.S. social media sites dedicated to U.S. politics and social issues. In order to
- gauge the performance of various groups on social media sites, the ORGANIZATION tracked
- certain metrics like the group’s size, the frequency of content placed by the group, and the level of
- audience engagement with that content, such as the average number of comments or responses to
- a post.
- 30.
- Defendants and their co-conspirators also traveled, and attempted to travel, to the United
- States under false pretenses in order to collect intelligence for their interference operations.
- a.
- KRYLOVA and BOGACHEVA, together with other Defendants and co-
- conspirators, planned travel itineraries, purchased equipment (such as cameras,
- SIM cards, and drop phones), and discussed security measures (including
- “evacuation scenarios”) for Defendants who traveled to the United States.
- b.
- То enter the United States, KRYLOVA, BOGACHEVA, R. BOVDA, and another
- co-conspirator applied to the U.S. Department of State for visas to travel. During
- 12
- their application process, KRYLOVA, BOGACHEVA, R. BOVDA, and their co-
- conspirator falsely claimed they were traveling for personal reasons and did not
- fully disclose their place of employment to hide the fact that they worked for the
- ORGANIZATION.
- с.
- Оп1у KRYLOVA and BOGACHEVA received visas, and from approximately June
- 4, 2014 through June 26, 2014, KRYLOVA and BOGACHEVA traveled in and
- around the United States, including stops in Nevada, California, New Mexico,
- Colorado, Illinois, Michigan, Louisiana, Texas, and New York to gather
- intelligence. After the trip, KRYLOVA and BURCHIK exchanged an intelligence
- report regarding the trip.
- d.
- Another co-conspirator who worked for the ORGANIZATION traveled to Atlanta,
- Georgia from approximately November 26, 2014 through November 30, 2014.
- Following the trip, the co-conspirator provided POLOZOV a summary of his trip’s
- itinerary and expenses.
- 31.
- In order to collect additional intelligence, Defendants and their co-conspirators posed as
- US. persons and contacted US. political and social activists. For example, starting in ог around
- June 2016, Defendants and their co-conspirators, posing online as US. persons, communicated
- with a real US. person affiliated with a Texas-based grassroots organization. During the exchange,
- Defendants and their co-conspirators learned from the real US. person that they should focus their
- activities on “purple states like Colorado, Virginia & F lorida.” Afier that exchange, Defendants
- and their co-conspirators commonly referred to targeting “purple states” in directing their efforts.
- 13
- Use of LLS. Social Media Platforms
- 32.
- Defendants and their co-conspirators, through fraud and deceit, created hundreds of social
- media accounts and used them to develop certain fictitious U.S. personas into “leader[s] of public
- opinion” in the United States.
- 33.
- ORGANIZATION employees, referred to as “specialists,” were tasked to create social
- media accounts that appeared to be operated by US. persons. The specialists were divided into
- day-shift and night-shift hours and instructed to make posts in accordance with the appropriate
- U.S. time zone. The ORGANIZATION also circulated lists of US. holidays so that specialists
- could develop and post appropriate account activity. Specialists were instructed to write about
- topics germane to the United States such as US. foreign policy and US. economic issues.
- Specialists were directed to create “political intensity through supporting radical groups, users
- dissatisfied with [the] social and economic situation and oppositional social movements.”
- 34.
- Defendants and their co-conspirators also created thematic group pages on social media
- sites, particularly on the social media platforms Facebook and Instagram. ORGANIZATIONcontrolled pages addressed a range of issues, including: immigration (with group names including
- “Secured Borders”); the Black Lives Matter movement (with group names including
- “Blacktivist”); religion (with group names including “United Muslims of America” and “Army of
- Jesus”); and certain geographic regions within the United States (with group names including
- “South United” and “Heart of Texas”). By 2016, the size of many ORGANIZATION-controlled
- groups had grown to hundreds of thousands of online followers.
- 35.
- Starting at least in or around 2015, Defendants and their co—conspirators began to purchase
- advertisements on online social media sites to promote ORGANIZATION-controlled social media
- groups, spending thousands of US. dollars every month. These expenditures were included in the
- budgets the ORGANIZATION submitted to CONCORD.
- 14
- 36.
- Defendants and their co-conspirators also created and controlled numerous Twitter
- accounts designed to appear as if US. persons or groups controlled them.
- For example, the
- ORGANIZATION created and controlled the Twitter account “Tennessee GOP,” which used the
- handle @TEN_GOP. The @TEN_GOP account falsely claimed to be controlled by a US. state
- political party. Over time, the @TEN_GOP account attracted more than 100,000 online followers.
- 37.
- То measure the impact of their online social media operations, Defendants and their co-
- conspirators tracked the performance of content they posted over social media. They tracked the
- size of the online U.S. audiences reached through posts, different types of engagement with the
- posts (such as likes, comments, and reposts), changes in audience size, and other metrics.
- Defendants and their co-conspirators received and maintained metrics reports on certain group
- pages and individualized posts.
- 38.
- Defendants and their co-conspirators also regularly evaluated the content posted by
- specialists (sometimes referred to as “content analysis”) to ensure they appeared authentic—as if
- operated by US. persons. Specialists received feedback and directions to improve the quality of
- their posts. Defendants and their co-conspirators issued or received guidance on: ratios of text,
- graphics, and video to use in posts; the number of accounts to operate; and the role of each account
- (for example, differentiating a main account from which to post information and auxiliary accounts
- to promote a main account through links and reposts).
- Use of US. Comguter Infrastructure
- 39.
- То hide their Russian identities and ORGANIZATION affiliation, Defendants and their co-
- conspirators—particularly POLOZOV and the ORGANIZATION’S IT department—purchased
- space оп computer servers located inside the United States in order to set up virtual private
- networks (“VPNs”). Defendants and their co-conspirators connected from Russia to the U.S.-
- 15
- based infrastructure by way of these VPNs and conducted activity inside the United States—
- including accessing online social media accounts, opening new accounts, and communicating with
- real U.S. persons—while masking the Russian origin and control of the activity.
- 40.
- Defendants and their co-conspirators also registered and controlled hundreds of web-based
- email accounts hosted by U.S. email providers under false names so as to appear to be U.S. persons
- and groups. From these accounts, Defendants and their co-conspirators registered or linked to
- online social media accounts in order to monitor them; posed as U.S. persons when requesting
- assistance from real U.S. persons; contacted media outlets in order to promote activities inside the
- United States; and conducted other operations, such as those set forth below.
- Use of Stolen U.S. Identities
- 41.
- In or around 2016, Defendants and their co-conspirators also used, possessed, and
- transferred, without lawful authority, the social security numbers and dates of birth of real U.S.
- persons without those persons’ knowledge or consent.
- Using these means of identification,
- Defendants and their co-conspirators opened accounts at PayPal, a digital payment service
- provider; created false means of identification, including fake driver’s licenses; and posted on
- ORGANIZATION-controlled social media accounts using the identities of these U.S. victims.
- Defendants and their co-conspirators also obtained, and attempted to obtain, false identification
- documents to use as proof of identity in connection with maintaining accounts and purchasing
- advertisements on social media sites.
- Actions Targeting the 2016 U.S. Presidential Election
- 42.
- By approximately May 2014, Defendants and their co-conspirators discussed efforts to
- interfere in the 2016 U.S. presidential election. Defendants and their co-conspirators began to
- monitor U.S. social media accounts and other sources of information about the 2016 U.S.
- presidential election.
- 16
- 43.
- By 2016, Defendants and their co-conspirators used their fictitious online personas to
- interfere with the 2016 U.S. presidential election. They engaged in operations primarily intended
- to communicate derogatory information about Hillary Clinton, to denigrate other candidates such
- as Ted Cruz and Marco Rubio, and to support Bernie Sanders and then-candidate Donald Trump.
- a.
- On or about February 10, 2016, Defendants and their co-conspirators internally
- circulated
- an
- outline
- of themes
- for
- future
- content
- to
- be
- posted
- to
- ORGANIZATION—controlled social media accounts. Specialists were instructed to
- post content that focused on “politics in the USA” and to “use any opportunity to
- criticize Hillary and the rest (except Sanders and Trump—we support them).”
- b.
- On ог about September 14, 2016, іп ап internal review of an ORGANIZATION—
- created and controlled Facebook group called “Secured Borders,” the account
- specialist was criticized for having a “low number of posts dedicated to criticizing
- Hillary Clinton” and was told “it is imperative to intensify criticizing Hillary
- Clinton” in future posts.
- 44.
- used
- Certain ORGANIZATION-produced materials about the 2016 U.S. presidential election
- election—related
- hashtags,
- including:
- “#Trump2016,”
- “#IWontProtectHillary,” and “#Hillary4Prison.”
- “#TrumpTrain,”
- “#MAGA,”
- Defendants and their co-conspirators also
- established additional online social media accounts dedicated to the 2016 U.S. presidential
- election, including the Twitter account “March for Trump” and Facebook accounts “Clinton
- FRAUDation” and “Trumpsters United.”
- 45.
- Defendants and their co-conspirators also used false U.S. personas to communicate with
- unwitting members, volunteers, and supporters of the Trump Campaign involved in local
- community outreach, as well as grassroots groups that supported then—candidate Trump. These
- 17
- individuals and entities at times distributed the ORGANIZATION’S materials through their own
- accounts via retweets, reposts, and similar means.
- Defendants and their co-conspirators then
- monitored the propagation of content through such participants.
- 46.
- In or around the latter half of 2016, Defendants and their co-conspirators, through their
- ORGANIZATION-controlled personas, began to encourage U.S. minority groups not to vote in
- the 2016 US. presidential election or to vote for a third-party US. presidential candidate.
- a.
- On or about October 16, 2016, Defendants and their co-conspirators used the
- ORGANIZATION-controlled Instagram account “Woke Blacks” to post the
- following message: “[A] particular hype and hatred for Trump is misleading the
- people and forcing Blacks to vote Killary. We cannot resort to the lesser of two
- devils. Then we’d surely be better off without voting AT ALL.”
- b.
- On or about November 3, 2016, Defendants and their co-conspirators purchased an
- advertisement to promote a post on the ORGANIZATION-controlled Instagram
- account “Blacktivist” that read in part: “Choose peace and vote for Jill Stein. Trust
- me, it’s not a wasted vote.”
- c.
- By in or around early November 2016, Defendants and their co-conspirators used
- the ORGANIZATION-controlled “United Muslims of America” social media
- accounts to post anti-vote messages such as: “American Muslims [are] boycotting
- elections today, most of the American Muslim voters refuse to vote for Hillary
- Clinton because she wants to continue the war оп Muslims in the middle east and
- voted yes for invading Iraq.”
- 47.
- Starting in or around the summer of 20 1 6, Defendants and their co-conspirators also began
- to promote allegations of voter fraud by the Democratic Party through their fictitious U.S. personas
- 18
- and groups on social media. Defendants and their co-conspirators purchased advertisements on
- Facebook to further promote the allegations.
- a.
- On or about August 4, 2016, Defendants and their co-conspirators began purchasing
- advertisements that promoted a post on the ORGANIZATION-controlled Facebook
- account “Stop Al.” The post alleged that “Hillary Clinton has already committed
- voter fraud during the Democrat Iowa Caucus.”
- b.
- On or about August 11, 2016, Defendants and their co-conspirators posted that
- allegations of voter fraud were being investigated in North Carolina on the
- ORGANIZATION-controlled Twitter account @TEN_GOP.
- c.
- On or about November 2, 2016, Defendants and their co-conspirators used the same
- account to post allegations of “#VoterFraud by counting tens of thousands of
- ineligible mail in Hillary votes being reported in Broward County, Florida.”
- Political Advertisements
- 48.
- From at least April 2016 through November 2016, Defendants and their co-conspirators,
- while concealing their Russian identities and ORGANIZATION affiliation through false personas,
- began to produce, purchase, and post advertisements on U.S. social media and other online sites
- expressly advocating for the election of then-candidate Trump ог expressly opposing Clinton.
- Defendants and their co-conspirators did not report their expenditures to the Federal Election
- Commission, or register as foreign agents with the U.S. Department of Justice.
- 49.
- То рау for the political advertisements, Defendants and their co-conspirators established
- various Russian bank accounts and credit cards, often registered in the names of fictitious U.S.
- personas created and used by the ORGANIZATION on social media. Defendants and their coconspirators also paid for other political advertisements using PayPal accounts.
- 19
- 50.
- The political advertisements included the following:
- Ар p ruxilmltc
- I)utc
- Apnl 6’ 2016
- Excerpt 0fA:\(Ivcrtisomcnt
- “You know, a great number of black people support us saying that
- #HillaryClintonlsNotMyPresident”
- April 7, 2016
- “I say no to Hillary Clinton / I say no to manipulation"
- April 19, 2016
- “JOIN our #HillaryClintonForPrison20l6”
- May 10, 2016
- “Donald wants to defeat terrorism . . . Hillary wants to sponsor it”
- Мау 19, 2016
- “Vote Republican, vote Trump, and support the Second Amendment
- May 24, 2016
- “Hillary Clinton Doesn’t Deserve the Black Vote”
- June 7, 2016
- “Trump is our only hope for a better future!”
- June 30, 2016
- “#NeverHillary #HillaryForPrison #Hillary4Prison #HillaryForPrison2016
- #Trump2016 #Trump #Trump4President”
- July 20, 2016
- “Ohio Wants Hillary 4 Prison”
- August 4, 2016
- '”
- “Hillary Clinton has already committed voter fraud during the Democrat Iowa
- Caucus.”
- August 10, 2016 “We cannot trust Hillary to take care of our veterans!”
- “Among all the candidates Donald Trump is the one and only who can defend
- October 14’ 2016 the police from terrorists.”
- October 19, 2016 “Hillary is a Satan, and her crimes and lies had proved just how evil she is.”
- Staging U.S. Political Rallies in the United States
- 51.
- Starting in approximately June 2016, Defendants and their co-conspirators organized and
- coordinated political rallies in the United States. То conceal the fact that they were based in Russia,
- Defendants and their co-conspirators promoted these rallies while pretending to be US. grassroots
- activists who were located in the United States but unable to meet or participate in person.
- 20
- Defendants and their co-conspirators did not register as foreign agents with the U.S. Department
- of Justice.
- 52.
- In order to build attendance for the rallies, Defendants and their co-conspirators promoted
- the events through public posts on their false U.S. persona social media accounts. In addition,
- Defendants and their co-conspirators contacted administrators of large social media groups
- focused on U.S. politics and requested that they advertise the rallies.
- 53.
- In or around late June 2016, Defendants and their co-conspirators used the Facebook group
- “United Muslims ofAmerica” to promote a rally called “Support Hillary. Save American Muslims”
- held on July 9, 2016 in the District of Columbia. Defendants and their co-conspirators recruited a
- real U.S. person to hold a sign depicting Clinton and a quote attributed to her stating “I think Sharia
- Law will be a powerful new direction of freedom.” Within three weeks, on or about July 26, 2016,
- Defendants and their co-conspirators posted on the same Facebook page that Muslim voters were
- “between Hillary Clinton and a hard place.”
- 54.
- In or around June and July 2016, Defendants and their co-conspirators used the Facebook
- group “Being Patriotic,” the Twitter account @March_for_Trump, and other ORGANIZATION
- accounts to organize two political rallies in New York. The first rally was called “March for
- Trump” and held on June 25, 2016. The second rally was called “Down with Hillary” and held on
- July 23, 2016.
- a.
- In or around June through July 2016, Defendants and their co-conspirators
- purchased advertisements on Facebook to promote the “March for Trump” and
- “Down with Hillary” rallies.
- b.
- Defendants and their co-conspirators used false U.S. personas to send
- individualized messages to real U.S. persons to request that they participate in and
- 21
- help organize the rally. То assist their efforts, Defendants and their co-conspirators,
- through false U.S. personas, offered money to certain U.S. persons to cover rally
- expenses.
- On or about June 5, 2016, Defendants and their co-conspirators, while posing as a
- U.S. grassroots activist, used the account @March_for_Trump to contact a
- volunteer for the Trump Campaign in New York. The volunteer agreed to provide
- signs for the “March for Trump” rally.
- 55.
- In or around late July 2016, Defendants and their co-conspirators used the Facebook group
- “Being Patriotic,” the Twitter account @March_for_Trump, and other false U.S. personas to
- organize a series of coordinated rallies in Florida. The rallies were collectively referred to as
- “Florida Goes Trump” and held on August 20, 2016.
- a.
- In or around August 2016, Defendants and their co-conspirators used false U.S.
- personas to communicate with Trump Campaign staff involved in local community
- outreach about the “Florida Goes Trump” rallies.
- Defendants and their co-conspirators purchased advertisements on Facebook and
- Instagram to promote the “Florida Goes Trump” rallies.
- Defendants and their co-conspirators also used false U.S. personas to contact
- multiple grassroots groups supporting then-candidate Trump in an unofiicial
- capacity. Many of these groups agreed to participate in the “Florida Goes Trump”
- rallies and serve as local coordinators.
- Defendants and their co-conspirators also used false U.S. personas to ask real U.S.
- persons to participate in the “Florida Goes Trump” rallies. Defendants and their
- co-conspirators asked certain of these individuals to perform tasks at the rallies.
- 22
- For example, Defendants and their co-conspirators asked one U.S. person to build
- a cage on a flatbed truck and another U.S. person to wear a costume portraying
- Clinton in a prison uniform.
- Defendants and their co-conspirators paid these
- individuals to complete the requests.
- 56.
- Afier the rallies in Florida, Defendants and their co-conspirators used false U.S. personas
- to organize and coordinate U.S. political rallies supporting then-candidate Trump in New York and
- Pennsylvania.
- Defendants and their co-conspirators used the same techniques to build and
- promote these rallies as they had in Florida, including: buying Facebook advertisements; paying
- U.S. persons to participate in, or perform certain tasks at, the rallies; and communicating with real
- U.S. persons and grassroots organizations supporting then-candidate Trump.
- 57.
- After the election of Donald Trump in or around November 2016, Defendants and their со-
- conspirators used false U.S. personas to organize and coordinate U.S. political rallies in support of
- then president-elect Trump, while simultaneously using other false U.S. personas to organize and
- coordinate U.S. political rallies protesting the results of the 2016 U.S. presidential election. For
- example, in or around November 2016, Defendants and their co-conspirators organized a rally in
- New York through one ORGANIZATION-controlled group designed to “show your support for
- President-Elect Donald Trump” held on or about November 12, 2016.
- At the same time,
- Defendants and their co-eonspirators, through another ORGANIZATION-controlled group,
- organized a rally in New York called “Trump is NOT my President” held on ог about November
- 12, 2016. Similarly, Defendants and their co-conspirators organized a rally entitled “Charlotte
- Against Trump” in Charlotte, North Carolina, held on or about November 19, 2016.
- 23
- Destruction of EvideLce
- 58.
- In order to avoid detection and impede investigation by US. authorities of Defendants’
- operations, Defendants and their co-conspirators deleted and destroyed data, including emails,
- social media accounts, and other evidence of their activities.
- a.
- Beginning in or around June 2014, and continuing into June 2015, public reporting
- began to identify operations conducted by the ORGANIZATION in the United
- States. In response, Defendants and their co-conspirators deleted email accounts
- used to conduct their operations.
- Beginning in or around September 2017, US. social media companies, starting
- with Facebook, publicly reported that they had identified Russian expenditures on
- their platforms to fund political and social advertisements.
- Facebook’s initial
- disclosure of the Russian purchases occurred on or about September 6, 2017, and
- included a statement that Facebook had “shared [its] findings with US authorities
- investigating these issues.”
- Media repoxting on or about the same day as Facebook’s disclosure referred to
- Facebook working with investigators for the Special Counsel’s Office of the US.
- Department of Justice, which had been charged with investigating the Russian
- government’s efforts to interfere in the 2016 presidential election.
- Defendants and their co-conspirators thereafter destroyed evidence for the purpose
- of impeding the investigation. On or about September 13, 2017, KAVERZINA
- wrote in an email to a family member: “We had a slight crisis here at work: the
- FBI busted our activity (not a joke). So, I got preoccupied with covering tracks
- together with the colleagues.” KAVERZINA further wrote, “I created all these
- pictures and posts, and the Americans believed that it was written by their people.”
- 24
- Overt Acts
- 59.
- In furtherance of the Conspiracy and to effect its illegal object, Defendants and their co-
- conspirators committed the following overt acts in connection with the staging of U.S. political
- rallies, as well as those as set forth in paragraphs 1 through 7, 9 through 27, and 29 through 58,
- which are re-alleged and incorporated by reference as though fully set forth herein.
- 60.
- On or about June 1, 2016, Defendants and their co-conspirators created and purchased
- Facebook advertisements for their “March for Trump” rally.
- 61.
- On
- or
- about
- June
- 4,
- 2016,
- Defendants
- and
- their
- co-conspirators
- used
- allforusa@yahoo.com, the email address of a false U.S. persona, to send out press releases for the
- “March for Trump” rally to New York media outlets.
- 62.
- On or about June 23, 2016, Defendants and their co-conspirators used the Facebook
- account registered under a false U.S. persona “Matt Skiber” to contact a real U.S. person to serve
- as a recruiter for the “March for Trump” rally, offering to “give you money to print posters and get
- a megaphone.”
- 63.
- On or about June 24, 2016, Defendants and their co-conspirators purchased advertisements
- on Facebook to promote the “Support Hillary. Save American Muslims” rally.
- 64.
- On or about July 5, 2016, Defendants and their co-conspirators ordered posters for the
- “Support Hillary. Save American Muslims” rally, including the poster with the quote attributed to
- Clinton that read “I think Sharia Law will be a powerful new direction of freedom.”
- 65.
- On or about July 8, 2016, Defendants and their co-conspirators communicated with a real
- U.S. person about the posters they had ordered for the “Support Hillary. Save American Muslims”
- rally.
- 25
- 66.
- On or about July 12, 2016, Defendants and their co-conspirators created and purchased
- Facebook advertisements for the “Down With Hillary” rally in New York.
- 67.
- On or about July 23, 2016, Defendants and their co-conspirators used the email address of
- a false U.S. persona, joshmilton024@gmail.com, to send out press releases to over thirty media
- outlets promoting the “Down With Hillary” rally at Trump Tower in New York City.
- 68.
- On or about July 28, 2016, Defendants and their co—conspirators posted a series of tweets
- through the false U.S. persona account @March_for_Trump stating that “[w]e’re currently
- planning a series of rallies across the state of Florida” and seeking volunteers to assist.
- 69.
- On or about August 2, 2016, Defendants and their co-conspirators used the false U.S.
- persona “Matt Skiber” Facebook account to send a private message to a real Facebook account,
- “Florida for Trump,” set up to assist then-candidate Trump in the state of Florida. In the first
- message, Defendants and their co—con5pirators wrote:
- Hi there! I’m a member of Being Patriotic online community. Listen,
- we’ve got an idea. Florida is still a purple state and we need to paint
- it red. If we lose Florida, we lose America. We can’t let it happen,
- right? What about organizing a YUGE pro—Trump flash mob in
- every Florida town? We are currently reaching out to local activists
- and we’ve got the folks who are okay to be in charge of organizing
- their events almost everywhere in FL. However, we still need your
- support. What do you think about that? Are you in?
- 70.
- On or about August 2, 2016, and August 3, 2016, Defendants and their co-conspirators,
- through the use of a stolen identity of a real U.S. person, T.W., sent emails to certain grassroots
- groups located in Florida that stated in part:
- My name is [T.W.] and I represent a conservative patriot community
- named as “Being Patriotic.” . . . So we’re gonna organize a flash
- mob across Florida to support Mr. Trump. We clearly understand
- that the elections winner will be predestined by purple states. And
- we must win Florida. . . . We got a lot of volunteers in ~25 locations
- and it’s just the beginning. We’re currently choosing venues for each
- 26
- location and recruiting more activists. This is why we ask you to
- spread this info and participate in the flash mob.
- 71.
- On or about August 4, 2016, Defendants and their co-conspirators created and purchased
- Facebook advertisements for the “Florida Goes Trump” rally. The advertisements reached over
- 59,000 Facebook users in Florida, and over 8,300 Facebook users responded to the advertisements
- by clicking on it, which routed users to the ORGANIZATION’S “Being Patriotic” page.
- 72.
- Beginning on or about August 5, 2016, Defendants and their co-conspirators used the false
- U.S. persona @March_for_Trump Twitter account to recruit and later pay a real U.S. person to
- wear a costume portraying Clinton in a prison uniform at a rally in West Palm Beach.
- 73.
- Beginning on or about August 11, 2016, Defendants and their co-conspirators used the false
- U.S. persona “Matt Skiber” Facebook account to recruit a real U.S. person to acquire signs and a
- costume depicting Clinton in a prison uniform.
- 74.
- On or about August 15, 2016, Defendants and their co-conspirators received an email at
- one of their false U.S. persona accounts from a real U.S. person, a Florida—based political activist
- identified as the “Chair for the Trump Campaign” in a particular Florida county. The activist
- identified two additional sites in Florida for possible rallies. Defendants and their co-conspirators
- subsequently used their false U.S. persona accounts to communicate with the activist about
- logistics and an additional rally in Florida.
- 75.
- On or about August 16, 2016, Defendants and their co-conspirators used a false U.S.
- persona Instagram account connected to the ORGANIZATION—created group “Tea Party News”
- to purchase advertisements for the “Florida Goes Trump” rally.
- 76.
- On or about August 18, 2016, the real “Florida for Trump” Facebook account responded to
- the false U.S. persona “Matt Skiber” account with instructions to contact a member of the Trump
- Campaign (“Campaign Official 1”) involved in the campaign’s Florida operations and provided
- 27
- Campaign Official 1’s email address at the campaign domain donaldtrump.com.
- On
- approximately the same day, Defendants and their co-conspirators used the email address of a false
- U.S. persona, joshmilton024@gmail.com, to send an email to Campaign Official 1 at that
- donaldtrump.com email account, which read in part:
- Hello [Campaign Official 1], [w]e are organizing a state-wide event
- in Florida on August, 20 to support Mr. Trump. Let us introduce
- ourselves first. “Being Patriotic” is a grassroots conservative online
- movement trying to unite people offline. . . . [W]e gained a huge lot
- of followers and decided to somehow help Mr. Trump get elected.
- You know, simple yelling on the Internet is not enough. There should
- be real action. We organized rallies in New York before. Now we’re
- focusing on purple states such as Florida.
- The email also identified thirteen “confirmed locations” in Florida for the rallies and requested the
- campaign provide “assistance in each location.”
- 77.
- On or about August 18, 2016, Defendants and their co-conspirators sent money via
- interstate wire to another real U.S. person recruited by the ORGANIZATION, using one of their
- false U.S. personas, to build a cage large enough to hold an actress depicting Clinton in a prison
- uniform.
- 78.
- On or about August 19, 2016, a supponer of the Trump Campaign sent a message to the
- ORGANIZATION-controlled “March for Trump” Twitter account about a member of the Trump
- Campaign (“Campaign Official 2”) who was involved in the campaign’s Florida operations and
- provided Campaign Official 2’s email address at the domain donaldtrump.com. On or about the
- same
- day,
- Defendants
- and
- their
- co-conspirators
- used
- the
- false
- U.S.
- persona
- joshmilton024@gmail.com account to send an email to Campaign Oflicial 2 at that
- donaldtrump.com email account.
- 79.
- On or about August 19, 2016, the real “Florida for Trump” Facebook account sent another
- message to the false U.S. persona “Matt Skiber” account to contact a member of the Trump
- 28
- Campaign (“Campaign Ofiicial 3”) involved in the campaign’s Florida operations. On or about
- August 20, 2016, Defendants and their co-conspirators used the “Matt Skiber” Facebook account
- to contact Campaign Official 3.
- 80.
- On or about August 19, 2016, Defendants and their co-conspirators used the false U.S.
- persona “Matt Skiber” account to write to the real US. person affiliated with a Texas-based
- grassroots organization who previously had advised the false persona to focus on “purple states
- like Colorado, Virginia & Florida.” Defendants and their co-conspirators told that US. person,
- “We were thinking about your recommendation to focus on purple states and this is what we’re
- organizing in FL.” Defendants and their co—conspirators then sent a link to the Facebook event
- page for the Florida rallies and asked that person to send the information to Tea Party members in
- Florida. The real US. person stated that he/she would share among his/her own social media
- contacts, who would pass оп the information.
- 81.
- On or about August 24, 2016, Defendants and their co-conspirators updated an internal
- ORGANIZATION list of over 100 real U.S. persons contacted through ORGANIZATIONcontrolled false U.S. persona accounts and tracked to monitor recruitment efforts and requests.
- The list included contact information for the US. persons, a summary of their political views, and
- activities they had been asked to perform by Defendants and their co-conspirators.
- 82.
- On or about August 31, 2016, Defendants and their co-conspirators, using a US. persona,
- spoke by telephone with a real US. person afiiliated with a grassroots group in Florida. That
- individual requested assistance in organizing a rally in Miami, Florida. On or about September 9,
- 2016, Defendants and their co-conspirators sent the group an interstate wire to pay for materials
- needed for the Florida rally on or about September 11, 2016.
- 29
- 83.
- On or about August 31, 2016, Defendants and their co-conspirators created and purchased
- Facebook advertisements for a rally they organized and scheduled in New York for September 11,
- 2016.
- 84.
- On or about September 9, 2016, Defendants and their co-conspirators, through a false U.S.
- persona, contacted the real US. person who had impersonated Clinton at the West Palm Beach
- rally. Defendants and their co-conspirators sent that U.S. person money via interstate wire as an
- inducement to travel from Florida to New York and to dress in costume at another rally they
- organized.
- 85.
- On or about September 22, 2016, Defendants and their co-conspirators created and
- purchased Facebook advertisements for a series of rallies they organized in Pennsylvania called
- “Miners for Trump” and scheduled for October 2, 2016.
- Al] in violation of Title 18, United States Code, Section 371.
- COUNT TWO
- (Conspiracy to Commit Wire Fraud and Bank Fraud)
- 86.
- Paragraphs 1 through 7, 9 through 27, and 29 through 85 of this Indictment are re-alleged
- and incorporated by reference as if fully set forth herein.
- 87.
- From in or around 2016 through present, in the District of Columbia and elsewhere,
- Defendants INTERNET RESEARCH AGENCY LLC, DZHEYKHUN NASIMI OGLY
- ASLANOV, and GLEB IGOREVICH VASILCHENKO, together with others known and
- unknown to the Grand Jury, knowingly and intentionally conspired to commit certain offenses
- against the United States, to wit:
- a.
- to knowingly, having devised and intending to devise a scheme and artifice to
- defraud, and to obtain money and property by means of false and fraudulent
- 30
- pretenses, representations, and promises, transmit and cause to be transmitted, by
- means of wire communications in interstate and foreign commerce, writings, signs,
- signals, pictures, and sounds, for the purposes of executing such scheme and
- artifice, in violation of Title 18, United States Code, Section 1343; and
- b.
- to knowingly execute and attempt to execute a scheme and artifice to defraud a
- federally insured financial institution, and to obtain monies, funds, credits, assets,
- securities and other property from said financial institution by means of false and
- fraudulent pretenses, representations, and promises, all in violation of Title 18,
- United States Code, Section 1344.
- Object of the Conspiracv
- 88.
- The conspiracy had as its object the opening of accounts under false names at US. financial
- institutions and a digital payments company in order to receive and send money into and out of
- the United States to support the ORGANIZATION’S operations in the United States and for selfenrichment.
- Manner and Means of the Conspiracx
- 89.
- Beginning in at least 2016, Defendants and their co—conspirators used, without lawful
- authority, the social security numbers, home addresses, and birth dates of real U.S. persons without
- their knowledge or conéent. Using these means of stolen identification, Defendants and their coconspirators opened accounts at a federally insured US. financial institution (“Bank 1”), including
- the following accounts:
- 31
- АрргохіптЩ- Dale
- Account Name
- Means 01' Identification
- Social Security Number
- June 16’ 2016
- Date of Birth
- July 21, 2016
- А.К. _
- S°°i3113Ёж
- № 27’ 2°16
- “*
- ЗосіаЬЁЁЁЁЁЁіЁЁтьы
- August 2, 2016
- 90.
- Т'В'
- T.W.
- ЗОСіаЬЁЁЁЁЁЁіЁЁШЬЫ
- Defendants and their co-conspirators also used, without lawful authority, the social security
- numbers, home addresses, and birth dates of real U.S. persons to open accounts at PayPal, a digital
- payments company, including the following accounts:
- .-'\ppruxinmlc Date
- Initials of Identity
- . ,. .
- …
- Пис" Victim
- June 16, 2016
- Т.В.
- July 21, 2016
- AR.
- ЗОСіаЬЁЁЁЁіЁЁтЬСГ
- August 2, 2016
- T.W.
- S°°ia$fggggigfimber
- November 11, 2016
- J.W.
- Home Address
- January 18, 2017
- V.S.
- Social Security Number
- Meansol'lilcntificalion
- Social Security Number
- Date ofBirth
- Defendants and their co-conspirators also established other accounts at PayPal in the names of
- false and fictitious U.S. personas. Some personas used to register PayPal accounts were the same
- as the false U.S. personas used in connection with the ORGANIZATION’S social media accounts.
- 91.
- Defendants and their co-conspirators purchased credit card and bank account numbers from
- online sellers for the unlawful purpose of evading security measures at PayPal, which used account
- numbers to verify a user’s identity. Many of the bank account numbers purchased by Defendants
- 32
- and their co-conspirators were created using the stolen identities of real U.S. persons. Afier
- purchasing the accounts, Defendants and their co-conspirators submitted these bank account
- numbers to PayPal.
- 92.
- On or about the dates identified below, Defendants and their co-conspirators obtained and
- used the following fraudulent bank account numbers for the purpose of evading PayPal’s security
- measures:
- Apprminmlc Date
- (‘urd/Brank Account
- l’intmctal
- limail lisul lo Ащпігс
- Number
- Institution
- Account Number
- June 13, 2016
- xxxxxxxxx8902
- Bank 2
- wemakeweather@gmail.com
- June 16, 2016
- xxxxxx8731
- Bank 1
- allforusa@yahoo.com
- July 21, 2016
- xxxxxx2215
- Bank 3
- antwan_8@yahoo.com
- August 2, 2016
- хххххх5707
- Bank 1
- xtimwaltersx@gmail.com
- October 18, 2016
- ххххххххх5792
- Bank 4
- unitedvetsofamerica@gmail.com
- October 18, 2016
- xxxxxxxxx4743
- Bank 4
- patriototus@gmail.com
- November 11, 2016
- xxxxxxxxx2427
- Bank 4
- beautifullelly@gmai1.com
- November 11, 2016
- xxxxxxxxx7587
- Bank 5
- staceyredneck@gmail.com
- November 11, 2016
- хххххххх7590
- Bank 5
- ihatecrime1@gmail.com
- November 11, 2016
- xxxxxxxxl 780
- Bank 6
- staceyredneck@gmail.com
- November 11, 2016
- хххххххх1762
- Bank 6
- ihatecrimel@gmai1.com
- December 13, 2016
- xxxxxxxx6168
- Bank 6
- thetaylorbrooks@aol.com
- March 30, 2017
- xxxxxxxxx63 16
- Bank 3
- wokeaztec@outlook.com
- Bank 3
- _ \—Jvokeaztec@outlook.com
- March 30, 2017
- ;);хххх95— 12 7 @
- 33
- Additionally, and in order to maintain their accounts at PayPal and elsewhere, including
- 93.
- online cryptocurrency exchanges, Defendants and their co-conspirators purchased and obtained
- false identification documents, including fake U.S. driver’s licenses. Some false identification
- documents obtained by Defendants and their co-conspirators used the stolen identities of real U.S.
- persons, including U.S. persons T.W. and J.W.
- After opening the accounts at Bank 1 and PayPal, Defendants and their co—conspirators
- 94.
- used them to receive and send money for a variety of purposes, including to pay for certain
- ORGANIZATION expenses. Some PayPal accounts were used to purchase advertisements on
- Facebook promoting ORGANIZATION—controlled social media accounts. The accounts were also
- used to pay other ORGANIZATION-related expenses such as buttons, flags, and banners for
- rallies.
- 95.
- Defendants and their co-conspirators also used the accounts to receive money from real
- U.S. persons in exchange for posting promotions and advertisements оп the ORGANIZATIONcontrolled social media pages. Defendants and their co-conspirators typically charged certain U.S.
- merchants and U.S. social media sites between 25 and 50 U.S. dollars per post for promotional
- content on their popular false U.S. persona accounts, including Being Patriotic, Defend the 2nd,
- and Blacktivist.
- All in violation ofTitle 18, United States Code, Section 1349.
- COUNTS THREE THROUGH EIGHT
- (Aggravated Identity Theft)
- 96.
- Paragraphs 1 through 7, 9 through 27, and 29 through 85, and 89 through 95 of this
- Indictment are re-alleged and incorporated by reference as if fully set forth herein.
- 97.
- On or about the dates specified below, in the District of Columbia and elsewhere,
- 34
- Defendants INTERNET RESEARCH AGENCY LLC, DZHEYKHUN NASIMI OGLY
- ASLANOV, GLEB IGOREVICH VASILCHENKO, IRINA VIKTOROVNA KAVERZINA, and
- VLADIMIR VENKOV did knowingly transfer, possess, and use, without lawful authority, a
- means of identification of another person during and in relation to a felony violation enumerated
- in 18 U.S.C. § 1028A(c), to wit, wire fraud and bank fraud, knowing that the means of
- identification belonged to another real person:
- (‘uunt Approximate Date
- 3
- June 16, 2016
- 4
- 5
- “““““
- М… 20“
- .
- Initials of Identity
- . .. .
- …
- llu-lt V'Ictnn
- Means 01' Identification
- т_в_
- Зосіа№
- A-RТ-С-
- $°°іаЬЁЁЁЁЁЁіЁЁ№
- 5°°іаЬЁЁЁ`ЗЁЁіЁЁ№
- 6
- August 2, 2016
- T.W.
- SOCiagsafggrtftByiElum—bef
- 7
- January 18, 2017
- V.S.
- Social Security Number
- 8
- May 19, 2017
- 1w.
- ЪЁЁЗЁЁЁЗ
- All in violation of Title 18, United States Code, Sections 1028A(a)(1) and 2.
- FORFEITURE ALLEGATION
- 98.
- Pursuant to Federal Rule of Criminal Procedure 32.2, notice is hereby given to Defendants
- that the United States will seek forfeiture as part of any sentence in accordance with Title 18,
- United States Code, Sections 981(a)(l)(C) and 982(a)(2), and Title 28, United States Code, Section
- 2461(с), іп the event of Defendants’ convictions under Count Two of this Indictment. Upon
- conviction of the offense charged in Count Two, Defendants INTERNET RESEARCH AGENCY
- LLC, DZHEYKHUN NASIMI OGLY ASLANOV, and GLEB IGOREVICH VASILCHENKO
- 35
- shall forfeit to the United States any property, real or personal, which constitutes or is derived from
- proceeds traceable to the offense of conviction. Upon conviction of the offenses charged in Counts
- Three through Eight, Defendants INTERNET RESEARCH AGENCY LLC, DZHEYKHW
- NASIMI OGLY ASLANOV, GLEB IGOREVICH VASILCHENKO, IRINA VIKTOROVNA
- KAVERZINA, and VLADIMIR VENKOV shall forfeit to the United States any property, real ог
- personal, which constitutes or is derived from proceeds traceable to the offense(s) of conviction.
- Notice is further given that, upon conviction, the United States intends to seek a judgment against
- each Defendant for a sum of money representing the property described in this paragraph, as
- applicable to each Defendant (to be offset by the forfeiture of any specific property).
- Substitute Assets
- 99.
- If any of the property described above as being subject to forfeiture, as a result of any act or
- omission of any defendant --
- a.
- cannot be located upon the exercise of due diligence;
- b.
- has been transferred or sold to, or deposited with, a third party;
- c.
- has been placed beyond the jurisdiction of the court;
- d.
- has been substantially diminished in value; or
- e.
- has been commingled with other property that cannot be subdivided without
- difficulty;
- 36
- it is the intent of the United States of America, pursuant to Title 18, United States Code, Section
- 982(b) and Title 28, United States Code, Section 2461(0), incorporating Title 21, United States
- Code, Section 853, to seek forfeiture of any other property of said Defendant.
- (18 U.S.C. §§ 981(a)(1)(C) and 982; 28 U.S.C. § 2461(0))
- Robert s. Mueller, ш
- ’
- Special Counsel
- US. Department of Justice
- A TRUE BILL:
- Date: Februarylé2018
- 37
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