l –  The United States of America, 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 U.S. elections and on the U.S. political system. U.S. law bans foreign nationals from making certain expenditures or financial disbursements for the purpose of influencing federal elections. U.S. 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 U.S. 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 U.S. Department of Justice, and the U.S. Department of State, are charged with enforcing these laws.

2 – Defendant[s]… 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, …

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 name s 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 affiliation, 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.

COUNT ONE

(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 U.S. Department of Justice, and the U.S. Department of State in administering federal requirements for disclosure of foreign involvement in certain domestic activities.

Defendants

10 – Defendant INTERNET RESEARCH AGENCY LLC is a Russian organization engaged in political and electoral interference operations.

11 – Defendants CONCORD MANAGEMENT AND CONSULTING LLC 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.

    To conceal its involvement, CONCORD labeled the monies paid to the ORGANIZATION for Project Lakhta as payments related to software support and development.

To further conceal the source of funds, CONCORD distributed monies to the ORGANIZATION.

12 – Defendant YEVGENIY VIKTOROVICH PRIGOZHIN 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.

b.) For example, on or about May 29, 2016, Defendants and their co-conspirators, through an ORGANIZATION-controlled social media account, arranged for a real U.S. 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 U.S. person that the sign was for someone who “is a leader here and our boss … our funder.”

13 – Defendant MIKHAIL IVANOVICH BYSTROV joined the ORGANIZATION by at least in or around February 2014.

    By approximately April 2014, BYSTROV was the general director, the ORGANIZATION’s highest-ranking position…

14 – Defendant MIKHAIL LEONIDOVICH BURCHIK A/K/A MIKHAIL ABRAMOV joined the ORGANIZATION by at least in or around October 2013. … including the 2016 U.S. 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 worked for the ORGANIZATION from at least in or around September 2013 [and] 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 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 … served on the translator project and oversaw the project’s data analysis group.

18 – Defendant MARIA ANATOLYEVNA BOVDA … served as the head of the translator project, among other positions.

19 – Defendant ROBERT SERGEYEVICH BOYDA …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 … 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 joined the ORGANIZATION by at least in or 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 … 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. …

23 – Defendant IRINA VIKTOROVNA KAVERZINA … operated multiple U.S. personas that she used to post, monitor, and update social media content for the ORGANIZATION.

24 – Defendant VLADIMIR VENKOV … VENKOV served on the translator project and operated multiple U.S. personas….

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 FECA’s 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 of the 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 nonimmigrant visas to foreign individuals ….

Object 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….

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 ….

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…..

31 – …starting in or around June 2016, Defendants and their co-conspirators, posing online as U.S. persons, communicated with a real U.S. person affiliated with a Texas-based grassroots organization. During the exchange, Defendants and their co-conspirators learned from the real U.S. person that they should focus their activities on “purple states like Colorado, Virginia & Florida.” …

Use of U.S. 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 U.S. 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 U.S. holidays so that specialists could develop and post appropriate account activity. …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. ORGANIZATION controlled 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 …

36 – Defendants and their co-conspirators also created and controlled numerous Twitter accounts designed to appear as if U.S. 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 U.S. state political party. Over time, the @TEN _ GOP account attracted more than 100,000 online followers.

37 – To measure the impact of their online social media operations, Defendants and their coconspirators tracked the performance of content they posted over social media. …

38 – …Specialists received feedback and directions to improve the quality of their posts.

Use of U.S. Computer Infrastructure

39 – To hide their Russian identities and ORGANIZATION affiliation, Defendants and their coconspirators-particularly POLOZOV and the ORGANIZATION’s IT department-purchased space on computer servers located inside the United States in order to set up virtual private networks (“VPNs”)….

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. …

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….

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.

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 or about September 14, 2016, in an 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 – Certain ORGANIZATION-produced materials about the 2016 U.S. presidential election used election-related hashtags, including: “#Trump2016,” “#TrumpTrain,” “#MAGA,” “#IWontProtectHillary,” and “#Hillary4Prison.” 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.

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 U.S. presidential election or to vote for a third-party U.S. 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.”

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 on Muslims in the middle east and voted yes for invading Iraq.”

47 – Starting in or around the summer of 2016, Defendants and their co-conspirators also began to promote allegations of voter fraud by the Democratic Party t….

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 A.I.” The post alleged that “Hillary Clinton has already committed voter fraud during the Democrat Iowa Caucus.”…

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 did not report their expenditures to the Federal Election Commission, or register as foreign agents with the U.S. Department of Justice.

49 – To pay for the political advertisements, Defendants and their co-conspirators established various Russian bank accounts and credit cards… Defendants and their coconspirators also paid for other political advertisements using PayPal accounts.

50 – The political advertisements included the following:

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. To conceal the fact that they were based in Russia, Defendants and their co-conspirators promoted these rallies while pretending to be U.S. grassroots activists ….

52 – …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 – …. 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.

55 – In or around late July 2016, …b. Defendants and their co-conspirators purchased advertisements on Facebook and Instagram to promote the “Florida Goes Trump” rallies.

d)…. 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 – ….. 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…

57 –  …At the same time, Defendants and their co-conspirators, through another ORGANIZATION-controlled group, organized a rally in New York called “Trump is NOT my President” held on or 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.

Destruction of Evidence

58 – In order to avoid detection and impede investigation by U.S. 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 September 2017, U.S. social media companies, starting with Facebook, publicly reported that they had identified Russian expenditures on their platforms to fund political and social advertisements. … Media reporting on or about the same day as Facebook’s disclosure referred to Facebook working with investigators for the Special Counsel’s Office of the U.S. Department of Justice, which had been charged with investigating the Russian government’s efforts to interfere in the 2016 presidential election.

d.) …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.”

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, …

60 – On or about June 1, 20I6, 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

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-conspirator s purchased advertisements 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, …

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.

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” …to assist then-candidate Trump in the state of Florida. In the first message, Defendants and their co-conspirators 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, 20I6, , Defendants 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.” … We got a lot of volunteers in ~25 locations and it’s just the beginning. We’re currently choosing venues for each 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. reached over 59,000 Facebook users in Florida, and over 8,300 Facebook users responded to the advertisements by clicking on it….

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” ….

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 … involved in the campaign’s Florida operations and provided 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. “You know, simple yelling on the Internet is not enough. There should be real action”….

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 build a cage large enough to hold an actress depicting Clinton in a prison uniform.

78 – On or about August 19, 2016, … Defendants and their co-conspirators used the false U.S. persona joshmi1ton024@gmail.com account to send an email to Campaign Official 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 ….

80 – On or about August 19, 2016, … The real U.S. person stated that he/she would share among his/her own social media contacts, who would pass on 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 ORGANIZATION controlled false U.S. persona accounts ….

82 – On or about 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 …

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 U.S. 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.

All 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 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 Conspiracy

88 – The conspiracy had as its object the opening of accounts under false names at U.S. 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 self-enrichment.

Manner and Means of the Conspiracy

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 consent. Using these means of stolen identification, Defendants and their co-conspirators opened accounts at a federally insured U.S. financial institution

90 – Defendants … also used, without lawful authority, the social security numbers, home addresses, and birth dates of real U.S. persons to open accounts at PayPal….

91 – Defendants … 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.

92 – Defendants … obtained and used the following fraudulent bank account numbers for the purpose of evading PayPal’s security measures…

93 – Additionally, and in order to maintain their accounts at PayPal and elsewhere, including online cryptocurrency exchanges, Defendants and their co-conspirators purchased and obtained false identification documents, including fake U.S. driver’s licenses.

94 – … 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 … used the accounts to receive money from real U.S. persons in exchange for posting promotions and advertisements on the ORGANIZATION-controlled 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 of Title 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, Defendants … 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….

All in violation of Title 18, United States Code, Sections 1028A(a)(l) 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 98l(a)(l)(C) and 982(a)(2), and Title 28, United States Code, Section 2461(c), in 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 OGL Y ASLANOV, and GLEB JGOREVICH VASILCHENKO shall forfeit to the United States any property, real or personal, which constitutes or is derived from proceeds traceable to the offense 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;

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(c), incorporating Title 21, United States Code, Section 853, to seek forfeiture of any other property of said Defendant.

(18 U.S.C. §§ 981(a)( l)(C) and 982; 28 U.S.C. § 2461(c))

Robert S. Mueller

Special Counsel

U.S. Department of Justice

A TRUE BILL: Date: February 16 2018