Case Document 201 Filed 02/16/18 Page 1 of 28 FILED IN OPEN COURT, FEB 16 21113 THE UNITED stares DISTRICT COURT CLERK. us. DISTRICT counr FOR THE DISTRICI or COLUMBIA or: UNITED STATES OF AMERICA CRIMINAL NO. 17-201 v. (18 U.S.C. 2, 371, 982, 1001(a), 1956(h), and 3551 91m; 22 U.S.C. 612, 618(a)(1), and 618(a)(2); 28 U.S.C. 2461(c)) PAUL J. MANAFORT, JR, Defendant. UNDER SEAL SUPERSEDING INDICTMENT The Grand Jury for the District of Columbia charges: Introduction At all times relevant to this Superseding Indictment: 1. Defendant PAUL J. MANAFORT, JR. (MANAFORT) served for years as a political consultant and lobbyist. Between at least 2006 and 2015, MANAFORT, through companies he ran, acted as an unregistered agent of a foreign government and foreign political parties. Speci?cally, he represented the Government of Ukraine, the President of Ukraine (Victor Yanukovych, who was President from 2010 to 2014), the Party of Regions (a Ukrainian political party led by Yanukovych), and the Opposition Bloc (a successor to the Party of Regions after Yanukovych fled to Russia in 2014). 2. MANAFORT generated tens of millions of dollars in income as a result of his Ukraine work. From approximately 2006 through 2017, MANAFORT, along with others including Richard W. Gates (Gates), engaged in a scheme to hide the Ukraine income from United States Case Document 201 Filed 02/16/18 Page 2 of 28 authorities, while enjoying the use of the money. From approximately 2006 to 2015, when MANAFORT was generating tens of millions of dollars in income from his Ukraine activities, with the assistance of Gates, avoided paying taxes by disguising tens of millions of dollars in income as alleged ?loans? from nominee offshore corporate entities and by making millions of dollars in unreported payments from foreign accounts to bank accounts they controlled and United States vendors. MANAFORT also used the offshore accounts to purchase real estate in the United States, and ANAF ORT used the undisclosed income to make improvements to and re?nance his United States properties. 3. In furtherance of the scheme, MANAFORT, with the assistance of Gates, funneled millions of dollars in payments into numerous foreign nominee companies and bank accounts, opened by them and their accomplices in nominee names and in various foreign countries, including Cyprus, Saint Vincent the Grenadines (Grenadines), and the Seychelles. MANAFORT concealed the existence and ownership of the foreign companies and bank accounts, falsely and repeatedly reporting to his tax preparers and to the United States that he had no foreign bank accounts. 4. In furtherance of the scheme, MANAFORT, with the assistance of Gates, concealed from the United States his work as an agent of, and millions of dollars in payments from, Ukraine and its political parties and leaders. Because MANAFORT, among other things, participated in a campaign to lobby United States of?cials on behalf of the Government of Ukraine, the President of Ukraine, and the Party of Regions, he was required by law to report to the United States his work and fees. MANAFORT did not do so. Instead, when the Department of Justice sent inquiries to MANAFORT and Gates in 2016 about their activities, MANAFORT and Gates responded with a series of false and misleading statements. 5. In furtherance of the scheme, MANAFORT used his hidden overseas wealth to enjoy a 2 Case Document 201 Filed 02/16/18 Page 3 of 28 lavish lifestyle in the United States, without paying taxes on that income. without reporting the income to his tax preparer or the United States, spent millions of dollars on luxury goods and services for himself and his extended family through payments wired from offshore nominee accounts to United States vendors. MANAFORT also used these offshore accounts to purchase multimillion dollar properties in the United States and to improve substantially another property owned by his family. 6. In total, more than $75,000,000 ?owed through these offshore accounts. with the assistance of Gates, laundered more than $30,000,000, income that he concealed from the United States Department of the Treasury (Treasury), the Department of Justice, and others. Relevant Individuals And Entities 7. MANAFORT was a United States citizen. He resided in homes in Virginia, Florida, and Long Island, New York. 8. Gates was a United States citizen. He resided in Virginia. 9. In 2005, MANAFORT and another partner created Davis Manafort Partners, Inc. (DMP) to engage principally in political consulting. DMP had staff in the United States, Ukraine, and Russia. In 201], MANAFORT created DMP International, LLC (DMI) to engage in work for foreign clients, in particular political consulting, lobbying, and public relations for the Government of Ukraine, the Party of Regions, and members of the Party of Regions. DMI was a partnership solely owned by MANAFORT and his spouse. Gates worked for both DMP and DMI and served as right-hand man. 10. The Party of Regions was a pro-Russia political party in Ukraine. Beginning in approximately 2006, it retained MANAFORT, through DMP and then DMI, to advance its interests in Ukraine, the United States, and elsewhere, including the election of its Ukrainian slate 3 Case Document 201 Filed 02/16/18 Page 4 of 28 of candidates. In 2010, its candidate for President, Yanukovych, was elected President of Ukraine. In 2014, Yanukovych ?ed Ukraine for Russia in the wake of popular protests of widespread governmental corruption. Yanukovyeh, the Party of Regions, and the Government of Ukraine were MANAFORT, DMP, and DM1 clients. 11. The European Centre for a Modern Ukraine (the Centre) was created in or about 2012 in Belgium as a mouthpiece for Yanukovych and the Party of Regions. It reported to the Ukraine First Vice Prime Minister. The Centre was used by MANAFORT, Gates, and others in order to lobby and conduct a public relations campaign in the United States and Europe on behalf of the existing Ukraine regime. Yanukovych in 2014. The Centre effectively ceased to operate upon the downfall of 12. MANAFORT, with the assistance of Gates, owned or controlled the following entities, which were used in the scheme (the MANAFORT entities): Domestic Entities Entity Name Date Created g? August 2008 Virginia Daisy Manafort, LLC (PM) . WW March 2011 Florida Davis Manafort International LLC March 2007 Delaware (PM) March 2005 Virginia DMP (PM) . W--. -. 1 March 2011 Florida October 1999 Delaware Davis Manafort, Inc. (PM) 111.1111 -, November 1999 Virginia June 2011 Delaware DMI (PM) 1.. .. .. March 2012 Florida 4 . . WA Case Document 201 Filed 02/16/18 Page 5 of 28 Entity Name Global Sites LI (PM RG) lesaud investment Cetporation (PM) Jesand Investments Corporation (PM) John Hannah, LLC (PM) Lilred, LLC (PM) IOAV (PM) MC Brookiyn Holdings LLC (PM) MC Soho Hoidings, LLC (PM) LLC (also known as LC) (PM, RG) Date Created July 2008 April 2002 March 201 1 April 2006 2 March 201 1 December 201 1 April i992 A 1x10411412; 2012 January 2012 April 2012 July 2008 Cypriot Entities Incorporation Location Delaware Virginia Florida Virginia - Florida 2 Florida Delaware New York Florida New York Delawaie Entity Nan?? Date Created Incorporation Location Actinet Trading Limited (PM, RG) May 2009 Cyprus Black Sea View Limited (PM, RG) August 2007 Cyprus Bletilla Ventures Limited (PM, RG) October 2010 Cyprus Global Highway Limited (PM, RG) August 2007 Cyprus Leviathan Advisers Limited (PM RG) August 2007 Cyprus Advisers I imited (PM, RG) August 2007 Cyprus Luciele Consultants Limited (PM, RG) December 2008 Cyprus Marziola Holdings Limited (PM) March 2012 Cyprus 5 Case Document 201 Filed 02/16/18 Page 6 of 28 Entity Name Date Created Incorporation Location Olivenia Trading Limited (PM, RG) March 2012 Cyprus Peranova Holdings Limited (Peranova) (PM, RG) June 2007 Cyprus Serangon Holdings Limited (PM, RG) January 2008 Cyprus Yiakora Ventures Limited (PM) February 2008 Cyprus Other Foreign Entities Etignhlame - IWWMW m" Date Created Incorporation Location Global Endeavour Inc. (also known as Unknown Grenadines Global Endeavor Inc.) (PM) eunet Ltd. (PM) August 2011 Grenadines Pompolo Limited (PM, RG) April 2013 United Kingdom 13. The Internal Revenue Service (IRS) was a bureau in the Treasury responsible for administering the tax laws of the United States and collecting taxes owed to the Treasury. The Scheme 14. Between in or around 2006 and 2017, both dates being approximate and inclusive, in the District of Columbia and elsewhere, MANAFORT and others devised and intended to devise, and executed and attempted to execute, a scheme and arti?ce to defraud, and to obtain money and property by means of false and fraudulent pretenses, representations, and premises from the United States and others. As part of the scheme, MANAFORT repeatedly provided and caused to be provided false information to ?nancial bookkeepers, tax accountants, and legal counsel, among others. Case Document 201 Filed 02/16/18 Page 7 of 28 Wirimg, Money From 0111:1101?; The United States 15. in order to use the money in the offshore nominee accounts of the entities without paying taxes on it, MANAFORT caused millions of dollars in wire transfers from these accounts to be made for goods, services, and real estate. He did not transfers as income. 16. From 2008 to 2014, MANAFORT caused the following wires, totaling over $12,000,000, to be sent to the vendors listed below for personal items. MANAFORT did not pay taxes on this income, which was used to make the purchases. Payee Transaction Originating Account Country of Amount of Date Holder Origination Transaction Vendor A 6/10/2008 LOAV Advisers Limited Cprus $107,000 (Home 6/25/2008 LOAV Advisers Limited Cyprus $23,500 Improvement 7/7/2008 LOAV Advisers Limited Cyprus $20,000 Company in the 8/5/2008 Yiakora Ventures Limited Cyprus $59,000 Hamptonss New 9/2/2008 Yiakora Ventures Limited Cyprus $272,000 10/6/2008 Yiakora Ventures Limited Cyprus 3 109,000 10/24/2008 Yiakora Ventures Limited Cyprus $107,800 11/20/2008 Yiakora Ventures Limited Cyprus $77,400 12/22/2008 Yiakora Ventures Limited Cyprus $100,000 1/ 14/2009 Yiakora Ventures Limited Cyprus $9,250 1/29/2009 Yiakora Ventures Limited Cyprus $97,670 2/25/2009 Yiakora Ventures Limited Cyprus $108,100 4/16/2009 Yiakora Ventures Limited Cyprus $94,394 5/7/2009 Yiakora Ventures Limited Cyprus $54,000 5/12/2009 Yiakora Ventures Limited Cyprus $9,550 6/1/2009 Yiakora Ventures Limited Cyprus $86,650 6/18/2009 Yiakora Ventures Limited Cyprus $34,400 7/31/2009 Yiakora Ventures Limited Cyprus $106,000 8/28/2009 Yiakora Ventures Limited Cyprus $37,000 9/23/2009 Yiakora Ventures Limited Cyprus $203,500 10/26/2009 Yiakora Ventures Limited Cyprus $3 8,800 7 Case Document 201 Filed 02/16/18 Page 8 of 28 Payee Transaction Originating Account Country of Amount of Date Holder Origination Transaction 1 1/18/2009 Global Highway Limited Cyprus $130,906 3/8/2010 Global Highway Limited Cyprus $124,000 5/ 1 1/2010 Global Highway Limited Cyprus $25,000 7/8/2010 Global Highway Limited Cyprus $28,000 7/23/2010 Leviathan Advisers Limited Cyprus $26,500 8/12/2010 Leviathan Advisers Limited Cyprus $138,900 9/2/2010 Yiakera Ventures Limited Cyprus $31,500 10/6/2010 Global Highway Limited Cyprus $67,600 10/14/2010 Yiakora Ventures Limited Cyprus $107,600 10/18/2010 Leviathan Advisers Limited Cyprus $31,500 12/16/2010 Global Highway Limited Cyprus $46,160 2/7/2011 Global Highway Limited Cyprus $36,500 3/22/2011 Leviathan Advisers Limited Cyprus $26,800 4/4/2011 Leviathan Advisers Limited Cyprus $195,000 5/3/2011 Global Highway Limited Cyprus $95,000 5/16/2011 Leviathan Advisers Limited Cyprus $6,500 5/31/2011 Leviathan Advisers Limited Cyprus $70,000 6/27/201 1 Leviathan Advisers Limited Cyprus $39,900 7/27/2011 Leviathan Advisers Limited Cyprus $95,000 10/24/2011 Global Highway Limited Cyprus $22,000 10/25/2011 Global Highway Limited Cyprus $9,300 11/15/2011 Global Highway Limited Cyprus $74,000 11/23/2011 Global Highway Limited Cyprus $22,300 11/29/2011 Global Highway Limited Cyprus $6,100 12/12/201 1 Leviathan Advisers Limited Cyprus $17,800 1/ 17/2012 Global Highway Limited Cyprus $29,800 1/20/2012 Global Highway Limited Cyprus $42,600 2/9/2012 Global Highway Limited Cyprus $22,300 2/23/2012 Global Highway Limited Cyprus $75,000 2/28/2012 Global Highway Limited Cyprus $22,300 3/28/2012 Peranova Cyprus $37,500 4/18/2012 Lucicle Consultants Limited Cyprus $50,000 5/15/2012 Lucicle Consultants Limited Cyprus $79,000 6/5/2012 Lucicle Consultants Limited Cyprus $45,000 6/19/2012 Lucicle Consultants Limited Cyprus $11,860 7/9/2012 Lucicle Consultants Limited Cyprus $10,800 7/ 18/2012 Lucicle Consultants Limited Cyprus $88,000 8/7/2012 Lucicle Consultants Limited Cyprus $48,800 8 Case Document 201 Filed 02/16/18 Page 9 of 28 Payee Transaction Originating Account Country of Amount of Date Holder Origination Transaction 9/27/2012 Lucicle Consultants Limited Cyprus $100,000 I 1/20/2012 Luciole Consultants Limited Cyprus $298,000 12/20/2012 Luciole Consultants Limited Cyprus $55,000 1/29/2013 Lueiole Consultants Limited Cyprus $149,000 3/12/2013 Lucicle Consultants Limited Cyprus $375,000 8/29/2013 Global Endeavour lnc. Grenadines $200,000 1 1/13/2013 Global Endeavour Inc. Grenadines $75,000 1 1/26/2013 Global Endeavour Inc. Grenadines $80,000 12/6/2013 Global Endeavour Inc. Grenadines $130,000 12/12/2013 Global Endeavour Inc. Grenadines $90,000 4/22/2014 Global Endeavour Inc. Grenadines $56,293 8/18/2014 Global Endeavour Inc. Grenadines $34,660 Vendor A Total $5,434,793 Vendor 3/22/20] 1 Leviathan Advisers Limited Cyprus $12,000 (Home 3/28/2011 Leviathan Advisers Limited Cyprus $25,000 Automation, 4727/2011 Leviathan Advisers Limited Cyprus $12,000 Lighting, and 5/16/2011 Leviathan Advisers Limited Cyprus $25,000 HOW 11/15/2011 Globa] Highway Limited Cyprus $17,006 Entertainment 1 1/23/2011 Global Highway Limited Cyprus $11,000 $123331 1? 2/28/2012 Global Highway Limited Cyprus $6,200 10/31/2012 Lucicle Consultants Limited Cyprus $290,000 12/17/2012 Lucicle Consultants Limited Cyprus $160,600 1/15/2013 Lueicle Consultants Limited Cyprus $194,000 1/24/2013 Lucicle Consultants Limited Cyprus $6,300 2/12/2013 Lueicle Consultants Limited Cyprus $51,600 2/26/2013 Lucicle Consultants Limited Cyprus $260,000 7/15/2013 Pompolo Limited [?11?th $175,575 Kingdom 1 1/5/2013 Global Endeavour Inc. Grenadines $73,000 Vendor Total $1,319,281 Vendor 10/7/2008 Yiakora Ventures Limited Cyprus $15,750 (Antique Rug 3/17/2009 Yiakora Ventures Limited Cyprus $46,200 Store in 4/ 16/2009 Yiakora Ventures Limited Cyprus $7,400 Alexandria, 4/27/2009 Yiakora Ventures Limited Cyprus $65,000 Virginia) 5/7/2009 Yiakora Ventures Limited Cyprus $210,000 7/15/2009 Yiakora Ventures Limited Cyprus $200,000 3/31/2010 Yiakora Ventures Limited Cyprus $140,000 6/16/2010 Global Highway Limited Cyprus $250,000 9 Case Document 201 Filed 02/16/18 Page 10 of 28 Payee Transaction Originating Account Country of Amount of Date Holder Origination Transaction Vendor Total $934,350 Vendor (Related to 2/28/2012 Global Highway Limited Cyprus $100,000 Vendor C) Vendor Total $100,000 Vendor 1 1/7/2008 Yiakera Ventures Limited Cyprus $32,000 (Men?s Clothing 2/5/2009 Yiakera Ventures Limited Cyprus $22,750 Store in New 4/27/2009 Yiakera Ventures Limited Cyprus $13,500 York) 10/25/2009 Yiakora Ventures Limited Cyprus $32,500 3/30/2010 Yiakora Ventures Limited Cyprus $15,000 5/11/2010 Global Highway Limited Cyprus $39,000 6/28/2010 Leviathan Advisers Limited Cyprus $5,000 8/12/2010 Leviathan Advisers Limited Cyprus $32,500 11/17/2010 Global Highway Limited Cyprus $11,500 2/7/2011 Global Highway Limited Cyprus $24,000 3/22/2011 Leviathan Advisers Limited Cyprus $43,600 3/28/2011 Leviathan Advisers Limited Cyprus $12,000 4/27/2011 Leviathan Advisers Limited Cyprus $3,000 6/30/2011 Global Highway Limited Cyprus $24,500 9/26/2011 Leviathan Advisers Limited Cyprus $12,000 11/2/2011 Global Highway Limited Cyprus $26,700 12/12/2011 Leviathan Advisers Limited Cyprus $46,000 2/9/2012 Global Highway Limited Cyprus $2,800 2/28/2012 Global Highway Limited Cyprus $16,000 3/14/2012 Lucicle Consultants Limited Cyprus $8,000 4/18/2012 Lucicle Consultants Limited Cyprus $48,550 5/15/2012 Lucicle Consultants Limited Cyprus $7,000 6/19/2012 Luciele Consultants Limited Cyprus $21,600 8/7/2012 Lucicle Consultants Limited Cyprus $15,500 11/20/2012 Lucicle Consultants Limited Cyprus $10,900 12/20/2012 Lucicle Consultants Limited Cyprus $7,500 1/ 15/2013 Luoicle Consultants Limited Cyprus $3 7,000 2/12/2013 Luciele Consultants Limited Cyprus $7,000 2/26/2013 Lucicle Consultants Limited Cyprus $39,000 9/3/2013 Global Endeavour Inc. Grenadines $81,500 10/15/2013 Global Endeavour Inc. Grenadines $53,000 1 1/26/2013 Global Endeavour Inc. Grenadines $1 3,200 4/24/2014 Global Endeavour Inc. Grenadines $26,680 10 Case Document 201 Filed 02/16/18 Page 11 of 28 Payee 'l?ransaction Originating Account Country of Amount of Date Holder Origination Transaction 9/1 1/2014 Global [Endeavour Inc. Grenadines $58,435 Vendor Total $849,215 Vendor 4/27/2009 Yiakera Ventures Limited Cyprus $34,000 (Landscaper in 5/12/2009 Yiakera Ventures Limited Cyprus $45,700 the Hampton-9, 6/1/2009 Yiakera Ventures Limited Cyprus $21,500 New York) 6/18/2009 Yiakera Ventures Limited Cyprus $29,000 9/21/2009 Yiakora Ventures Limited Cyprus $21,800 5/11/2010 Global Highway Limited Cyprus $44,000 6/28/2010 Leviathan Advisers Limited Cyprus $50,000 7/23/2010 Leviathan Advisers Limited Cyprus $19,000 9/2/2010 Yiakera Ventures Limited Cyprus $21,000 10/6/2010 Global Highway Limited Cyprus $57,700 10/18/2010 Leviathan Advisers Limited Cyprus $26,000 12/ 16/201 0 Global Highway Limited Cyprus $20,000 3/22/2011 Leviathan Advisers Limited Cyprus $50,000 5/3/201 1 Global Highway Limited Cyprus $40,000 6/1/2011 Leviathan Advisers Limited Cyprus $44,000 7/27/201 1 Leviathan Advisers Limited Cyprus $27,000 8/16/2011 Leviathan Advisers Limited $13,450 9/19/2011 Leviathan Advisers Limited Cyprus $12,000 10/24/2011 Global Highway Limited Cyprus $42,000 11/2/2011 Global Highway Limited Cyprus $37,350 Vendor Total $655,500 Vendor 9/2/2010 Yiakora Ventures Limited Cyprus $165,000 (Antique Dealer 10/18/2010 Leviathan Advisers Limited Cyprus $165,000 in New York) 2/23/2012 Global Highway Limited Cyprus $190,600 3/14/2012 Lueiele Consultants Limited Cyprus $75,000 2/26/2013 Lueicle Consultants Limited Cyprus $28,310 Vendor Total $623,910 Vendor 6/25/2008 LOAV Advisers Limited Cyprus $52,000 (Clothing Store in 12/ 16/2008 Yiakera Ventures Limited Cyprus $49,000 H1115, 12/22/2008 Yiakera Ventures Limited Cyprus $10,260 California) 8/12/2009 Yiakera Ventures Limited Cyprus $76,400 5/11/2010 Global Highway Limited Cyprus $85,000 1 1/17/2010 Global Highway Limited Cyprus $128,280 5/31/2011 Leviathan Advisers Limited Cyprus $64,000 11/15/2011 Global Highway Limited Cyprus $48,000 12/ 17/2012 Lucicle Censultants Limited Cyprus $7,500 11 Case Document 201 Filed 02/16/18 Page 12 of 28 Payee Transaction Originating Account Country of Amount of Date Holder Origination Transaction Vendor Total $520,440 Vendor I (Investment 9/3/2013 Global Endeavour inc. Grenadines $500,000 Company) Vendor I Total $500,000 Vendor 1 1/15/2011 Globai Highway Limited Cyprus $8,000 (Contractor in 12/5/201 1 Leviathan Advisers Limited Cyprus $11,237 Florida) 12/21/201 1 Black Sea View Limited Cyprus $20,000 2/9/2012 Global Highway Limited Cyprus $51,000 5/17/2012 Luciclc Consultants Limited Cyprus $68,000 6/19/2012 Luciclc Consultants Limited Cyprus $60,000 7/18/2012 Lucicle Consultants Limited Cyprus $32,250 9/19/2012 Lucicle Consultants Limited Cyprus $112,000 11/30/2012 Lueicle Consultants Limited Cyprus $39,700 1/9/2013 Lucicle Consultants Limited Cyprus $25,600 2/28/2013 Lucicle Consultants Limited Cyprus $4,700 Vendor .1 Total $432,487 Vendor 12/5/2011 Leviathan Advisers Limited Cyprus $4,115 (Landscaper in 3/1/2012 Global Highway Limited Cyprus $50,000 the Hamptons, 6/6/2012 Lucicle Consultants Limited Cyprus $47,800 New York) 6/25/2012 Lucicle Consultants Limited Cyprus $17,900 6/27/2012 Luciolc Consultants Limited Cyprus $18,900 2/12/2013 Lucicle Consultants Limited Cyprus $3,300 7/15/2013 Pompolo Limited Exam $13,325 1 1/26/2013 Global Endeavour Inc. Grenadines $9,400 Vendor Total $164,740 Vendor 4/12/2012 Luoicle Consultants Limited Cyprus $83,525 (Payments 5/2/2012 Lucicle Consultants Limited Cyprus $12,525 Relating to Three Range Rovers) 6/29/2012 Lusicle Consultants Limited Cyprus $67,655 Vendor Total $163,705 Vendor 11/20/2012 Lucicle Consultants Limited Cyprus $45,000 (Contractor in 12/7/2012 Lucicle Consultants Limited Cyprus $21,000 Virginia) 12/17/2012 Lucicle Consultants Limited Cyprus $21,000 1/17/2013 Luciele Consultants Limited Cyprus $18,750 1/29/2013 Luciele Consultants Limited Cyprus $9,400 12 Case Document 201 Filed 02/16/18 Page 13 of 28 Payee Transaction Originating Account Country of Amount of Date Holder Origination Transaction 2/12/2013 Lucicle Consultants Limited Cyprus $10,500 Vendor Total $125,650 Vendor 1/29/2009 Yiakora Ventures Limited Cyprus $10,000 (Audio, Video, 3/17/2009 Yiakora Ventures Limited Cyprus $21,725 and Control 4/16/2009 Yiakora Ventures Limited Cyprus $24,650 System Home 12/2/2009 Global Highway Limited Cyprus $10,000 Integration and 3/8/2010 Global Highway Limited Cyprus $20,300 ?Milan"? 4/23/2010 Yiakora Ventures Limited Cyprus $3,500 Company in the 3:33)) tons, New 7/29/2010 Leviathan Advisers Limited Cyprus $17,650 Vendor Total $112,825 Vendor 0 $3223: 3:112) 10/5/2012 Lucicle Consultants Limited Cyprus $62,750 Vendor 0 Total $62,750 Vendor (Purchase of 12/30/2008 Yiakora Ventures Limited Cyprus $47,000 Range Rover) .. Vendor Total $47,000 Vendor 9/2/2010 Yiakora Ventures Limited Cyprus $10,000 (Property 10/6/2010 Global Highway Limited Cyprus $10,000 Management 10/18/2010 Leviathan Advisors Limited Cyprus $10,000 Company in 2/3/2011 Global Highway Limited Cyprus $13,500 South Carolina) 2/9/2012 Global Highway Limited Cyprus $2,500 Vendor Total $46,000 Vendor 2/9/2011 Global Highway Limited Cyprus $17,900 gilgingllery 1n 2/ 14/2013 Lucicle Consultants Limited Cyprus $14,000 Vendor Total $31,900 Vendor 9/26/20] 1 Leviathan Advisers Limited Cyprus $5,000 (Housekeeping in 9/19/2012 Lucicle Consultants Limited Cyprus $5,000 New York) . 1 0/ 9/201 3 Global Endeavour Inc. Grenadines $10,000 Vendor Total $20,000 13 Case Document 201 Filed 02/16/18 Page 14 of 28 17. In 2012, MANAFORT caused the following wires to be sent to the entities listed below to purchase the real estate also listed below. MANAFORT did not report the money used to make these purchases on his 2012 tax return, was}; easing? Purchased Payee Date Account Origin Amou::mw Howard Street DMP Condominium International 2/1/201 2 Peranova Cyprus 1 ,5 00,000 (New York) LLC WW I l? Actinet Trading Union Street Account of 11/29/2012 Limited Cyprus $1,800,000 3:333:33: [Real ?Iona; 253a; Attorneyl Limited 13 WW Arlington . House Real Esme 8/31/2012 timid" cmmkams Cyprus $1,900,000 . . . Trust Limited (Virginia) Total $6,400,000 18. MANAFORT also disguised, as purported ?loans,? more than $10 million from Cypriot entities, including the overseas MANAFORT entities, to domestic entities owned by MANAFORT. For example, a $1.5 million wire from Peranova to DMI that MANAFORT used to purchase real estate on Howard Street in Manhattan, New York, was recorded as a ?loan? from Peranova to DMI, rather than as income. The following loans were Shams designed to reduce fraudulently reported taxable income. Year Payer Ostensible Payee I Ostensible Country of Total Amount Wj?wLender? ?fBorrower? Origin of ?Loans? 2008 Yiakora Ventures Limited Jesand Investment Cyprus $8,120,000 . Corporation - 2008 Yiakora Ventures Limited DMP Cyprus $500,000 2009 Yiakora Ventures Limited DMP Cyprus $694,000 2009 Yiako?ra?Ventures Limited Daisy Manafort, LLC Cyprus $500,000 2012M intersrigramn PMIW -i Cyprus $mt?mQ9i9?0w 14 Case Document 201 Filed 02/16/18 Page 15 of 28 JIZQM 13? 0M1 .. sniff: can: t??ig??g 2015 ?l?clmar Investments Ltd. Cyprus $1,000,000 Total $13,214,000 Hiding Ukraine lobbying Work 19. It is illegal to act as an agent of a foreign principal engaged in certain United States in?uence activities without registering the af?liation. Speci?cally, a person who engages in lobbying or public relations work in the United States (hereafter collectively referred to as lobbying) for a foreign principal, such as the Government of Ukraine or the Party of Regions, is required to provide a detailed written registration statement to the United States Department of Justice. The ?ling, made under oath, must disclose the name of the foreign principal, the ?nancial payments to the lobbyist, and the measures undertaken for the foreign principal, among other information. A person required to make such a ?ling must further include in all lobbying material a ?conspicuous statemen that the materials are distributed on behalf of the foreign principal, among other things. The ?ling thus permits public awareness and evaluation of the activities of a lobbyist who acts as an agent of a foreign power or foreign political party in the United States. 20. In furtherance of the scheme, from 2006 until 2014, both dates being approximate and inclusive, MANAFORT, with the assistance of Gates and others, engaged in a multi?million dollar lobbying campaign in the United States at the direction of Yanukovych, the Party of Regions, and the Government of Ukraine. MANAFORT did so without registering and providing the disclosures required by law. 21. As one part of the scheme, in February 2012, MANAFORT, with the assistance of Gates, solicited two Washington, DC, firms (Company A and Company B) to lobby in the United States on behalf of Yanukovych, the Party of Regions, and the Govemment of Ukraine. For instance, 15 Case Document 201 Filed 02/16/18 Page 16 of 28 Gates wrote to Company A that it would be ?representing the Government of Ukraine in [Washington,] 22. MANAFORT repeatedly communicated in person and in writing with Yanukovych, and Gates passed on directions to Company A and Company B. For instance, MANAFORT wrote Yanukovyeh a memorandum dated April 8, 2012, in which be provided Yanukovych an update on the lobbying ?rms? activities ?since the inception of the project a few weeks ago. It is my intention to provide you with a weekly update moving forwar Toward the end of that ?rst year, in November 2012, Gates wrote to Company A and Company that the firms needed to prepare an assessment of their past and prospective lobbying efforts so the ?President? could be briefed by ?Paul? ?on what Ukraine has done well and what it can do better as we move into 2013.? 23. At the direction of MANAFORT and Gates, Company A and Company engaged in extensive lobbying. Among other things, they lobbied multiple Members of Congress and their staffs about Ukraine sanctions, the validity of Ukraine elections, and the propriety of Yanukovych?s imprisoning his presidential rival, Yulia Tymoshenko. In addition, with the assistance of Company A, MANAFORT directly lobbied a Member of Congress who had Ukraine within his subcommittee?s purview, and reported that lobbying effort to senior Government of Ukraine leadership. 24. To minimize public disclosure of their lobbying campaign and distance their work from the Government of Ukraine, MANAFORT, Gates, and others arranged for the Centre to be the nominal client of Company A and Company B, even though in fact the Centre was under the ultimate direction of the Government of Ukraine, Yanukovych, and the Party of Regions, and reported to the First Vice Prime Minister. For instance, MANAFORT and Gates selected Company A and Company B, and only thereafter did the Centre sign contracts with the lobbying firms without ever 16 Case Document 201 Filed 02/16/18 Page 17 of 28 meeting either company. Company A and Company were paid for their services not by their nominal client, the Centre, but solely through offshore accounts associated with the MANAFORT entities, namely Bletilla Ventures Limited (in Cyprus) and .leunet Ltd. and Global Endeavour Inc. (in Grenadines). In total, Company A and Company were paid more than $2 million from these accounts between 2012 and 2014. Indeed, various employees of Company A and Company viewed the Centre as a ?g leaf. As a Company A employee noted to another employee: Gates was lobbying for the Centre ?in name only. [Y]ou?ve gotta see through the nonsense of 25. Neither Company A nor Company registered as required with the United States Department of Justice. In order to avoid such registration, Gates provided the companies a false and misleading signed statement from the Centre, stating that it was not ?directly or indirectly supervised, directed, controlled, ?nanced, or subsidized in whole or in part by a government of a foreign country or a foreign political party.? In fact, the Centre took direction from Yanukovych and the Ukraine First Vice Prime Minister. 26. To conceal the scheme, MANAFORT and Gates developed a false and misleading cover story that would distance themselves and the Government of Ukraine, Yanukovych, and the Party of Regions from the Centre, Company A, and Company B. For instance, in the wake of extensive press reports on MANAFORT and his connections with Ukraine, on August 16, 2016, Gates conununicated false and misleading talking points to Company in writing, including: Q: ?Can you describe your initial contact with [Company and the lobbying goals he discussed with them?? A: ?We provided an introduction between the [Centre] and [Company B/Company in 2012. The [Centre] was seeking to retain representation in Washington, DC to support the mission of the A: ?Our and Gates?] task was to assist the [Centre to] ?nd 17 Case Document 201 Filed 02/16/18 Page 18 of 28 representation in Washington, but at no time did our ?rm or members provide any direct lobbying support.? 0 A: ?The structure of the arrangement between the [Centre] and [Company A Company was worked out by the two parties.? 0 Q: ?Can you say where the funding from for [sic] the [Centre] came from? (this amounted to well over a million dollars between 2012 and 2014).? A: ?This is a question better asked of the [Centre] who contracted with the two ?rms.? 0 Q: ?Can you describe the lobbying work Speci?cally undertaken by [Company on behalfof the Party of Regions/the [Centre]?? A: ?This is a question better asked to [Company and/or the [Centre] as the agreement was between the parties. Our ?rm did not play a role in the structure, nor were we registered lobbyists." Company through a principal replied to Gates the same day that ?there?s a lot of email traf?c that has you much more involved than this suggests[.] We will not disclose that but heaven knows what former employees of [Company or [Company might say.? 27. In September 2016, after numerous recent press reports concerning MANAFORT, the Department of Justice informed MANAFORT, Gates, and that it sought to determine whether they had acted as agents of a foreign principal under the Foreign Agents Registration Act (FARA), without registering. In November 2016 and February 2017, MANAFORT, Gates, and DM1 caused false and misleading letters to be submitted to the Department of Justice, which mirrored the false cover story set out above. The letters, both of which were approved by MANAFORT and Gates before they were submitted, represented, among other things, that: 0 ?efforts on behalf of the Party of Regions? ?did not include meetings or outreach within the l8 Case Document 201 Filed 02/16/18 Page 19 of 28 I MANAFORT and Gates did not ?recall meeting with or conducting outreach to US. government of?cials or US. media outlets on behalf of the [Centre], nor do they recall being party to. arranging, or facilitating any such communications. Rather, it is the recollection and understanding of Messrs. Gates and Manafort that such communications would have been facilitated and conducted by the [Centre?s] U.S. consultants, as directed by the [Centre]. . . MANAFORT and Gates had merely served as a means of introduction of Company A and Company to the Centre and provided the Centre with a list of ?potential U.S.-based consultants??including [Company and [Company the [Centre?s] reference and further consideration.? DMI ?does not retain communications beyond thirty days? and as a result of this policy, a ?search has returned no reSponsive documents.? The November 2016 letter attached a one-page, undated document that purported to be a DMI ?Email RetentiOn Policy.? In fact, MANAFORT and Gates had: selected Company A and Company engaged in weekly scheduled calls and frequent emails with Company A and Company to provide them directions as to speci?c lobbying steps that should be taken; sought and received detailed oral and written reports from these ?rms on the lobbying work they had performed; communicated with Yanukovych to brief him on their lobbying efforts; both congratulated and reprimanded Company A and Company on their lobbying work; communicated directly with United States of?cials in connection with this work; and paid the lobbying ?rms over $2 million from offshore accounts they controlled, among other things. In addition, court?authorized searches of MANAFORT and Gates? DMI email accounts in 2017 and a search of Virginia residence in July 19 Case Document 201 Filed 02/16/18 Page 20 of 28 2017 revealed numerous documents, including documents related to lobbying, which were more than thirty-days old at the time of the November 2016 letter to the Department of Justice. 29. As a second part of the lobbying scheme, in 2012, MANAFORT, with the assistance of Gates, on behalf of Yanukovych and the Government of Ukraine?s Ministry of Justice, retained a United States law firm to write a report on the trial of Tymoshenko, among other things. The treatment of "l'ymoshenko was condemned by the United States and was viewed as a major hurdle to normalization of relations with Ukraine. and Gates used one of their offshore accounts to funnel $4 million to pay for the report, a fact that was not disclosed in the report or to the public. They also retained a public relations ?rm (Company C) to create and implement a roll- out plan for the report. MANAFORT and Gates again secretly used one of their offshore accounts to pay Company C, funneling the equivalent of more than $1 million to pay for the work. MANAFORT, Gates, and their conspirators developed detailed written lobbying plans in connection with the dissemination of the law ?rm?s report, including outreach to United States politicians and press. MANAFORT reported on the law ?rm?s work and the lobbying plan to representatives of the Government of Ukraine, including President Yanukovych. For instance, a July 27, 2012, memorandum from MANAFORT noted: ?[t]his document will address the global rollout strategy for the [law ?rm's] legal report, and provide a detailed plan of The plans included lobbying in the United States. 30. As a third part of the lobbying scheme, in or about 2012, MANAFORT, with the assistance of Gates, on behalf of Yanukovych and the Party of Regions, secretly retained a group of former senior European politicians to take positions favorable to Ukraine, including by lobbying in the United States. Although the former politicians would appear to be providing their independent assessments of Government of Ukraine actions, in fact they were paid lobbyists for Ukraine. In 20 Case Document 201 Filed 02/16/18 Page 21 of 28 2012 and 2013, used at least four offshore accounts to wire more than 2 million euros to pay the group of former politicians. 31. explained in an memorandum created in or about June 2012 that the purpose of the effort would be to ?assemble a small group of high-level European highly in?uencial [sic] champions and politically credible friends who can act informally and without any visible relationship with the Government of Ukraine.? The group was managed by a former European Chancellor, Foreign Politician A, in coordination with MANAFORT. As explained by MANAFORT, a nongovernmental agency would be created to retain this group, but it would act ?at our quiet direction.? In or about 2013, Foreign Politician A and other former politicians from the group lobbied United States Members of Congress, of?cials in the Executive Branch, and their staffs in coordination with MANAFORT, Gates, Company A, and Company B. Hiding Foreign Bank Accounts And False 32. United States citizens who have authority over certain foreign bank or not the accounts are set up in the names of nominees who act for their principals?have reporting obligations to the United States. 33. United States citizens'are obligated to report information to the IRS regarding foreign bank accounts. For instance, in 2010, Schedule of IRS Form 1040 had a ?Yes? or ?No? box to record an answer to the question: ?At any time during [the calendar year], did you have an interest in or a signature or other authority over a financial account in a foreign country, such as a bank account, securities account, or other ?nancial account?? If the answer was ?Yes,? then the form required the taxpayer to enter the name of the foreign country in which the ?nancial account was located. 34. In each of tax ?lings for 2008 through 2014, MANAFORT, with the 21 Case Document 201 Filed 02/16/18 Page 22 of 28 assistance of Gates, represented falsely that he did not have authority over any foreign bank accounts. MANAFORT and Gates had repeatedly and falsely represented in writing to tax preparer that MANAFORT had no authority over foreign bank accounts, knowing that such false representations would result in false tax ?lings in name. For instance, on October 4, 2011, tax preparer asked MANAFORT in writing: ?At any time during 2010, did you [or your wife or children] have an interest in or a signature or other authority over a ?nancial account in a foreign country, such as a bank account, securities account or other ?nancial account?? On the same day, MANAFORT falsely responded MANAFORT responded the same way as recently as October 3, 2016, when tax preparer again emailed the question in connection with the preparation of tax returns: ?Foreign bank accounts etc?? MANAFORT responded on or about the same day: Statutory Allegations COUNT ONE (Conspiracy Against The United States) 35. Paragraphs 1 through 34 are incorporated here. 36. From in or about and between 2006 and. 2017, both dates being approximate and inclusive, in the District of Columbia and elsewhere, the defendant PAUL J. MANAFORT, JR., together with others, including Gates, knowingly and intentionally conspired to defraud the United States by impeding, impairing, obstructing, and defeating the lawful governmental functions of a government agency, namely the Department of Justice and the Treasury, and to commit offenses against the United States, to wit, the Violations of law charged in Counts Three, Four, and Five. 37. In furtherance of the conspiracy and to effect its illegal object, MANAFORT and his 22 Case Document 201 Filed 02/16/18 Page 23 of 28 conspirators committed the overt acts noted in Count Four and the overt acts, among others, in the District of Columbia and elsewhere, set forth in paragraphs 9, 16?18, 2 l~?31, and 34, which are incorporated herein. (18 use. 371) COUNT TWO (Conspiracy To Launder Money) 38. Paragraphs 1 through 34 are incorporated here. 39. in or around and between 2006 and 2016, both dates being approximate and inclusive, within the District of Columbia and elsewhere, the defendant PAUL J. MANAFORT, R., together with others, including Gates, did knowingly and intentionally conspire to: tranSport, transmit, and transfer monetary instruments and funds from places outside the United States to and through places in the United States and from places in the United States to and through places outside the United States, with the intent to promote the carrying on of Speci?ed unlawful activity, to wit: a felony violation of PARA, in violation of Title 22, United States Code, Sections 612 and 618 (the ?Speci?ed Unlawful Activity?), contrary to Title 18, United States Code, Section l956(a)(2)(A); and conduct financial transactions, affecting interstate and foreign commerce, knowing that the property involved in the ?nancial transactions would represent the proceeds of some form of unlawful activity, and the transactions in fact would involve the proceeds of the Speci?ed Unlawful Activity, knowing that such ?nancial transactions were designed in whole and in part to engage in conduct constituting a violation of sections 7201 and 7206 of the Internal Revenue Code of 1986, and (ii) to conceal and disguise the nature, location, source, ownership, and control of the proceeds of the Speci?ed Unlawful 23 Case Document 201 Filed 02/16/18 Page 24 of 28 Activity, contrary to Title 18, United States Code, Section 1956(a)(1)(A)(ii) and (18 U.S.C. l956(h)) COUNT THREE (Unregistered Agent or A Foreign Principal) 40. Paragraphs 1 through 34 are incorporated here. 41. From in or about and between 2008 and 2014, both dates being approximate and inclusive, within the District of Columbia and elsewhere, the defendant PAUL J. MANAFORT, JR., knowingly and willfully acted as an agent of a foreign principal, and caused and aided and abetted Companies A, B, and C, and others, including former senior foreign politicians, to act as agents of a foreign principal, to wit, the Government of Ukraine, the Party of Regions, and Yanukovych, without registering with the Attorney General as required by law. (22 use. 612 and 618(a)(1); 18 use. 2) COUNT FOUR (False and Misleading FARA Statements) 42. Paragraphs 1 through 34 are incorporated here. 43. On or about November 23, 2016, and February 10, 2017, within the District of Columbia and elsewhere, the defendant PAUL J. MANAFORT, JR., knowingly and willfully caused to be made a false statement of a material fact, and emitted a material fact necessary to make the statements therein not misleading, in a document ?led with and furnished to the Attorney General under the provisions of FARA, to wit, the underlined statements: a efforts on behalf of the Party of Regions and Opposition Bloc did not include meetings or outreach within the 24 Case Document 201 Filed 02/16/18 Page 25 of 28 - ?INleither nor Messrs. Manal?ort or Gates had any agreement with the Ltlid provide the; ?enlmj, at the request of members of the Party of Regions, with a list of potential ll.S.?based consultants? including [Company A and Company Bl?for reference and til on non 131191.95le trendy wW1 111. title and ?911] mun. 131 tents wists nemesis within the United States for which these entities registered under the Lobbying Disclosure Act.? 0 ?Although Gates recalls interacting, with [the Centrel?s consultants regarding efforts in the Ukraine and Europe, neither Gates nor Mr. Manafort recall meeting with or conducting outreach to LLS. government of?cials or .8. media outlets on behal l' of the the Centre], nor do they recall being: party to, arranging, or facilitating an such mmunications. Rather it is the recollection and understandin1 Messrs. Gates and such communications would have been facilitated and conducted by the ICentreJ?s U.S. consultants. as directed by the lCentrel, pursuant to the agreement reached between those parties (to which was not a part}: 0 ?[Al search has been conducted for correspondence containing additional to.ms??stationingtilted .in. ?issuers However, as a result of lDMl?sl Email Retention Policy, which does not retain conmtunieations beyond thirtv days. the search has retumed no responsive communications.? (22 use. 612 and 618(a)(2); 18 use. 2) 25 Case Document 201 Filed 02/16/18 Page 26 of 28 COUNT FIVE (False Statements) 44. Paragraphs 1 through 34 and paragraph 43 are incorporated here. 45. On or about November 23, 2016, and February 10, 2017, within the District of Columbia and elsewhere, in a matter within the jurisdiction of the executive branch of the Government of the United States, the defendant PAUL J. MANAFORT, JR., knowingly and willfully did cause another: to falsify, conceal, and cover up by a scheme and device a material fact; to make a materially false, ?ctitious, and fraudulent statement and representation; and to make and use a false writing and document knowing the same to contain a materially false, ?ctitious, and fraudulent statement, to wit, the statements in the November 23, 2016, and February 10, 2017, submissions to the Department of Justice quoted in paragraph 43. (18 use. 2 and 1001(a)) FORFEITURE ALLEGATION 46. Pursuant to Fed. R. Crim. P. 32.2, notice is hereby given to the defendant that the United States will seek forfeiture as part of any sentence in accordance with Title 18, United States Code, Sections 981(a)(1)(C) and 982(a)(1), and Title 28, United States Code, Section 2461(c), in the event of the defendant?s convictions. Upon conviction of the offense charged in Count Two, the defendant PAUL J. MANAFORT, JR., shall forfeit to the United States any property, real or personal, involved in such offense, and any property traceable to such property. Upon conviction of the offenses charged in Counts One, Three, and Four, the defendant PAUL J. MANAFORT, JR., shall forfeit to the United States any property, real or 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 the defendant for a sum of money 26 Case Document 201 Filed 02/16/18 Page 27 of 28 representing the property described in this paragraph (to be offset by the forfeiture of any speci?c property). 47. The grand jury ?nds probable cause to believe that the property subject to forfeiture by PAUL J. MANAFORT, JR., includes, but is not limited to, the following listed assets: a. The real property and premises commonly known as 377 Union Street, Brooklyn, 1 New York 11231 (Block 429, Lot 65), including all appurtenances, improvements, and attachments thereon, and any property traceable thereto; b. The real property and premises commonly known as 29 Howard Street, New York, New York 10013 (Block 209, Lot 1 104), including all appurtenances, improvements, and attachments thereon, and any property traceable thereto; c. The real property and premises commonly known as 1046 N. Edgewood Street, Arlington, Virginia 2220], including all appurtenances, improvements, and attachments thereon, and any property traceable thereto; d. The real property and premises commonly known as 174 Jobs Lane, Water Mill, New York 11976, including all appurtenances, improvements, and attachments thereon, and any property traceable thereto; e. Northwestem Mutual Universal Life Insurance Policy 18268327, and any property traceable thereto; f. All funds held in account-- at Charles A. Schwab Co. Inc., and any property traceable thereto; and g. All funds held in account number -0969 at The Federal Savings Bank, and any property traceable thereto. 27 Case Document 201 Filed 02/16/18 Page 28 of 28 Substitute Assets 48. If any of the preperty described above as being subject to forfeiture, as a result of any act or omission of the defendant a. cannot be located upon the exercise ofdue 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 c. has been with other property that cannot be subdivided without dif?culty; it is the intent of the United States of America, pursuant to Title 18, United States Code, Section 982(1)) 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. Robert S. Mueller, Special Counsel Department of Justice A TRUE BILL: 1'8 Date: February 16, 2018 28