Case 1:1$o-00260
lssioneclTo: Judge Amy Berman Jackson
DatJAssiqned: 8131 12018
Descnotion: INFORMATION (A)
Case Related: 17-cr-201 IABJ)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
CRIMINAT- NO.

18-

(ABO

Violation: 22 U.S.C. $$ 612 and
618(a)(1)

(Foreign Agents Registration Act)

W. SAMIIEL PATTEN,
Defendant.

CRIMINAL INFORMATION
The United States Attomey for the District of Columbia and the National Securify

Division ofthe U.S. Deparhnent ofJustice charge that:

1.

From in or around 2014 until in or around 2018, both dates being approximate and inclusive,

within the District of Columbia and elsewhere, the defendant W. SAMUEL PATTEN knowingly
and

willfully acted as ar agent of a foreigrr principal, to wit, the Opposition Bloc (a Ukrainian

political parfy) and its members, without registering with the Attomey General, whose office in
the Department of Justice is located in the District of Columbia, as required by law.

2.

Beginning in or around 2014 to the present, PATTEN worked with a Russian national

(Foreigner

A) on lobbying and political

(Company

A) in the United

Company

A,

consulting services. The two formed a company

States, and were 50-50 partners. Beginning

in or around 2015,

among other things, advised the Opposition Bloc and members

of that party,

ilcluding a prominent Ukraine oligarch (Foreigner B). Company A performed political consulting
services, which inv6lysd ry6fl1plthin Ukraine as well as lobbying in the United States. As part

Company

A's work, PATTEN travelled to

of

Lrkraine on numerous occasions, and met with

 Foreigners A and B, and other foreigners. For this work, Foreigrrer B caused payments to be made

to Company A through an offshore Cypriot account. From in or around the spring of 201 5 through

in or around 2017, Company A received over $1,000,000 for its work for ttre Opposition Bloc and
other llkraine consulting work, a portion of which was received as a result of conduct which
violated the Foreign Agents Registration Act.

3.

As part of his work for Company A, PATTEN violated the Foreign Agents Registration

Act

by contacting members of the United States legislative and executive branches as well as the
media. Such communications included efforts to set up meetings between Foreigners A and B
with Members of Congress and staff. PATTEN also drafted talking points for Foreigner B for his
meetings on Capitol

Hill

as

well

as

talking points for Congressional staffers to use to convince

other Congressional Members and staff to meet with Foreigner

B. The activity

was undertaken to

promote the interests of Foreigner B and the Opposition Bloc to inJluence United States policy. ln

addition, during this time period, PATTEN and Foreigner

A

assisted Foreigner

B in drafting

periodic articles (e.g. "op-eds") targeted at the United States press.

4.

Specifically, PATTEN in coordination with Foreigner A worked on setting up meetings in

Washinglon, D.C., from on or about January 19, 2015, through on or about Janvry 21,2015,
between Foreigner B and (a) Members of Congress and their staff

-

specifically, Senators on the

Foreign Relations Committee and Representatives on the House Committee on Foreign Affairs;
(b) the Executive Branch - including officials from the U.S. Departrnent of State; and (c) numerous
members of the United States media. PATTEN also drafted and provided staffers with points

of

discussion conceming Foreigner B and his message with respect to Llkraine. As anotler example,

in or around May 2016, PATTEN and Foreigner A wrote a letter for Foreigner B to use in lobbying
a

high-ranking member ofthe Department of State regarding recent developments on the llkrainian

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 Central Election Commission, and requested the official's engagement on the issue.

5.

PATTEN also drafted op-ed pieces on behalf of Foreiper B and then placed them with

United States media. For instance, in or around January 2017, PATTEN and Foreigner A drafted
an op-ed article on behalf of Foreigner B to address concems regarding flkraine's ability to work

effectively with the new United States administration. PATTEN then attempted to get the op-ed
article placed with various United States media outlets. In or around February 2017, PATTEN
succeeded in having the op-ed article published in a national United States media outlet. Prior to
the publication ofthe op-ed, PATTEN facilitated Foreigner B's signing the required United States

media outlet's license agreement.

6.

PATTEN knew at the time that he took all ofthe actions described above that the Foreign

Agents Registration Act required him to register in order to engage legally in such United States

activities for a foreign principal. PATTEN had previously filed under the Foreign Agents
Registration Act for another client. PATTEN and Foreigner A inquired of Foreigner B whether
Company A could fi1e under the Foreign Agents Registration Act; Foreigner B said

il

substance

that he did not want them to register now, but they could eventually do so at an unspecified future

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 date. As a result, PATTEN and Foreigner A never filed, timely or not, and continued to work for
and represent the Opposition Bloc and members of that party, including Foreigner B.

(Violation of the Foreign Agents Registration Act, pursuant to Title 22, Section 612 and
618(a)(1))

JESSIE

I'

Lru

United States Attomey

Bv:

Michael C. Dilorerzo
Assistant United States Attomey
Scott A. C1affee

Trial Attomey
U.S. Departrnent of Justice
National Security Division

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