Case 1:17-cr-00201-ABJ Document 419 Filed 09/14/18 Page 1 of 38

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA

v.
PAUL J. MANAFORT, JR.,
Defendant.

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CRIMINAL NO. 17-201-1 (ABJ)(S-5)
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Violations: 18 U.S.C. § 371
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*******

SUPERSEDING CRIMINAL INFORMATION
The Special Counsel informs the Court:
1.

PAUL J. MANAFORT, JR. (MANAFORT) served for years as a political consultant and

lobbyist. Between at least 2006 and 2015, MANAFORT conspired with Richard W. Gates (Gates),
Konstantin Kilimnik (Kilimnik), and others to act, and acted, as unregistered agents of a foreign
government and political party. Specifically, MANAFORT conspired to act and acted as an agent
of the Government of Ukraine, the Party of Regions (a Ukrainian political party whose leader
Victor Yanukovych was President from 2010 to 2014), President Yanukovych, and the Opposition
Bloc (a successor to the Party of Regions that formed in 2014 when Yanukovych fled to Russia).
MANAFORT generated more than 60 million dollars in income as a result of his Ukraine work.
In order to hide Ukraine payments from United States authorities, from approximately 2006
through at least 2016, MANAFORT, with the assistance of Gates and Kilimnik, laundered the
money through scores of United States and foreign corporations, partnerships, and bank accounts.
2.

In furtherance of the scheme, MANAFORT funneled millions of dollars in payments into
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 Case 1:17-cr-00201-ABJ Document 419 Filed 09/14/18 Page 2 of 38

foreign nominee companies and bank accounts, opened by him and his underlings in nominee
names and in various foreign countries, including Cyprus, Saint Vincent & the Grenadines
(Grenadines), and the United Kingdom. MANAFORT hid the existence 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.
3.

In furtherance of the scheme, MANAFORT 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 directed a campaign to lobby United States officials and the United States
media on behalf of the Government of Ukraine, the President of Ukraine, and Ukrainian political
parties, he was required by law to report to the United States his work and fees. MANAFORT did
not do so, either for himself or any of his companies. Instead, when the Department of Justice sent
inquiries to MANAFORT in 2016 about his activities, MANAFORT responded with a series of
false and misleading statements.
4.

In furtherance of the scheme, MANAFORT used his hidden overseas wealth to enjoy a

lavish lifestyle in the United States, without paying taxes on that income. MANAFORT, without
reporting the income to his bookkeeper or tax preparers or to 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 multi-million dollar properties in the United States. Manafort then borrowed
millions of dollars in loans using these properties as collateral, thereby obtaining cash in the United
States without reporting and paying taxes on the income. In order to increase the amount of money
he could access in the United States, Manafort defrauded the institutions that loaned money on
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 Case 1:17-cr-00201-ABJ Document 419 Filed 09/14/18 Page 3 of 38

these properties so that they would lend him more money at more favorable rates than he would
otherwise be able to obtain.
5.

Manafort laundered more than $30 million to buy property, goods, and services in the

United States, income that he concealed from the United States Treasury, the Department of
Justice, and others. MANAFORT cheated the United States out of over $15 million in taxes.
Relevant Individuals And Entities
6.

MANAFORT was a United States citizen. He resided in homes in Virginia, Florida, and

Long Island, New York.
7.

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 2011, 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 and Kilimnik worked for both DMP and
DMI and served as close confidants of MANAFORT.
8.

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, including the election of its slate of candidates. In 2010, its candidate for
President, Yanukovych, was elected President of Ukraine. In 2014, Yanukovych fled Ukraine for
Russia in the wake of popular protests of widespread governmental corruption. Yanukovych, the
Party of Regions, and the Government of Ukraine were Manafort, DMP, and DMI clients.
9.

The European Centre for a Modern Ukraine (the Centre) was created in or about 2012 in
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 Case Document 419 Filed 09/14/18 Page 4 of 38

Belgium as a mouthpiece for Yanukovych and the Party of Regions. The Centre was used by
MANAFORT and others in order to lobby and conduct a public relations campaign in the United
States and Eru?ope on behalf of the existing Ukraine regime. The Centre effectively ceased to
operate upon the downfall of Yanukovych in 2014.

10. MANAFORT owned or controlled the following entities, which were used in the scheme

 

 

 

 

 

 

 

 

 

 

 

(the MANAFORT entities):
Domestic Entities

Entity Name Date Created Incorporation Location

August 2008 Virginia
Daisy Manafort, LLC (PM)

March 2011 Florida
Davis Manafort International LLC March 2007 Delaware
(PM)

March 2005 Virginia
DMP (PM)

March 2011 Florida

October 1999 Delaware
Davis Manafort, Inc. (PM)

November 1999 Virginia

J1me 201 1 Delaware
DMI (PM)

March 2012 Florida
Global Sites LLC (PM) July 2008 Delaware
esand Investment Corporation (PM) April 2002 Virginia
esand Investments Corporation (PM) March 2011 Florida

April 2006 Virginia
John Hannah, LLC (PM)

March 2011 Florida

 

 

 

 

 

 

Case Document 419 Filed 09/14/18 Page 5 of 38

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entity Name Date Created Incorporation Location
Lih?ed, LLC (PM) December 2011 Florida
LOAV Ltd. (PM) April 1992 Delaware
MC Brooklyn Holdings, LLC (PM) November 2012 New York

January 2012 Florida
MC Soho Holdings, LLC (PM)

April 20 1 2 New York
LLC (also known as July 2008 Delaware
LLC) (PM)

Cypriot Entities

Entity Name Date Created Incorporation Location
Actinet Trading Limited May 2009 Cyprus
Black Sea View Limited August 2007 Cyprus
Bletilla Ventures Limited October 2010 Cyprus
avenari Investments Limited December 2007 Cyprus
Global Highway Limited August 2007 Cyprus
Leviathan Advisors Limited August 2007 Cyprus
LOAV Advisors Limited August 2007 Cyprus
Lucicle Consultants Limited December 2008 Cyprus
Marziola Holdings Limited March 2012 Cyprus
Olivenia Trading Limited March 2012 Cyprus
Peranova Holdings Limited June 2007 Cyprus

 

 

 

 

 

Case Document 419 Filed 09/14/18 Page 6 of 38

 

 

 

 

 

Entity Name Date Created Incorporation Location
Serangon Holdings Limited January 2008 Cyprus
Yiakora Ventures Limited February 2008 Cyprus

 

 

Other Foreign Entities

 

 

 

 

 

 

 

Entity Name Date Created Incorporation Location
Global Endeavour Inc. (also known as October 2012 Grenadines

Global Endeavor Inc.)

Jeimet Ltd. August 2011 Grenadines

Pompolo Limited April 2013 United Kingdom

 

 

11. The Internal Revenue Service (IRS) was a bureau in the United States Department of the
Treasruy responsible for administering the tax laws of the United States and collecting taxes owed
to the Treasury.
The Scheme

12. Between in or arormd 2006 and 2017, both dates being approximate and inclusive, in the
District of olrunbia 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 promises from the United
States, banks, and other fmancial institutions. As part of the scheme, MANAFORT repeatedly
provided false information to ?nancial bookkeepers, tax accountants, and legal cormsel, among

others.

Case Document 419 Filed 09/14/18 Page 7 of 38

Wiring Of Money From Offshore Accormts Into The United States

13. In order to use the money in the offshore nominee accounts of the MANAFORT entities

without paying taxes on it, MANAFORT caused millions of dollars in wire transfers ??om these

accormts to be made for goods, services, and real estate. He did not report these transfers as income

to DMP, DMI, or MANAFORT.

14. 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
Home 6/10/2008 LOAV Advisors Limited Cypfus $107,000
Improvement 6/25/2008 LOAV Advisors Limited Cyprus $23,500
IDC- 7/7/2008 LOAV Advisors Limited Cyprus $20,000
(Home 8/5/2008 Yiakora Ventiu?es Limited Cyprus $59,000
ImPfovem?m 9/2/2008 Yiakora Ventures Limited Cyprus $272,000
company 1? the 10/6/2008 Yiakora Ventures Limited Cyprus $109,000
Eggtons? New 10/24/2008 Yiakora Ventures Limited Cyprus $107,800
11/20/2008 Yiakora Ventru'es Limited Cyprus $77,400
12/22/2008 Yiakora Ventru'es Limited Cyprus $100,000
1/ 14/2009 Yiakora Ventru'es Limited Cyprus $9,250
1/29/2009 Yiakora Ventru'es Limited Cyprus $97,670
2/25/2009 Yiakora Ventru?es Limited Cyprus $108,100
4/ 16/2009 Yiakora Ventru'es Limited Cyprus $94,394
5/7/2009 Yiakora Ventru?es Limited Cyprus $54,000
5/12/2009 Yiakora Ventru?es Limited Cyprus $9,550
6/1/2009 Yiakora Ventru?es Limited Cyprus $86,650
6/ 18/2009 Yiakora Ventru?es Limited Cyprus $34,400
7/31/2009 Yiakora Ventures Limited Cyprus $106,000
8/28/2009 Yiakora Ventru?es Limited Cyprus $37,000
9/23/2009 Yiakora Ventures Limited Cyprus $203,500
10/26/2009 Yiakora Ventru?es Limited Cyprus $38,800
1 1/18/2009 Global Highway Limited Cyprus $130,906

 

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Case Document 419 Filed 09/14/18 Page 8 of 38

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Payee Transaction Originating Account Country of Amount of

Date Holder Origination Transaction
3/8/2010 Global Highway Limited ypr_us $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 Advisors Limited Cyprus $26,500
8/ 12/2010 Leviathan Advisors Limited Cyprus $138,900
9/2/2010 Yiakora 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 Advisors Limited Cyprus $3 1,500
12/16/2010 Global Highway Limited Cyprus $46,160
2/7/201 1 Global Highway Limited Cyprus $36,500
3/22/201 1 Leviathan Advisors Limited Cyprus $26,800
4/4/201 1 Leviathan Advisors Limited Cyprus $195,000
5/3/201 1 Global Highway Limited Cyprus $95,000
5/16/201 1 Leviathan Advisors Limited Cyprus $6,500
5/31/201 1 Leviathan Advisors Limited Cyprus $70,000
6/27/2011 Leviathan Advisors Limited Cyprus $39,900
7/27/2011 Leviathan Advisors Limited Cyprus $95,000
10/ 24/201 1 Global Highway Limited Cyprus $22,000
10/25/201 1 Global Highway Limited Cyprus $9,300
1 1/15/201 1 Global Highway Limited Cyprus $74,000
1 1/23/201 1 Global Highway Limited Cyprus $22,300
1 1/29/201 1 Global Highway Limited Cyprus $6,100
12/12/201 1 Leviathan Advisors 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 Per?anova Holdings Limited Cyprus $37,500
4/18/2012 ercicle Consultants Limited Cyprus $50,000
5/15/2012 ercicle Consultants Limited Cyprus $79,000
6/5/2012 ercicle Consultants Limited Cyprus $45,000
6/19/2012 ercicle Consultants Limited Cyprus $1 1,860
7/9/2012 ercicle Consultants Limited Cyprus 10,800
7/ 18/2012 ercicle Limited Cyprus $88,000

 

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Case Document 419 Filed 09/14/18 Page 9 of 38

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Payee Transaction Originating Account Country of Amount of

Date Holder Origination Transaction
8/7/2012 Lucicle Consultants Limited ypr_us $48,800
9/27/2012 Lucicle Consultants Limited Cyprus $100,000
11/20/2012 Lucicle Consultants Limited Cyprus $298,000
12/20/2012 Lucicle Consultants Limited Cyprus $55,000
1/29/2013 Lucicle Consultants Limited Cyprus $149,000
3/12/2013 Lucicle Consultants Limited Cyprus $375,000
8/29/2013 Global Endeavoru' Inc. Grenadines $200,000
1 1/13/2013 Global Endeavoru' Inc. Grenadines $75,000
1 1/26/2013 Global Endeavoru' Inc. Grenadines $80,000
12/6/2013 Global Endeavour Inc. Grenadines $130,000
12/12/2013 Global Endeavoru' Inc. Grenadines $90,000
4/22/2014 Global Endeavour Inc. Grenadines $56,293
8/ 18/2014 Global Endeavoru? Inc. Grenadines $34,660
Total $5,434,793
Big Picture 3/22/2011 Leviathan Advisors Limited Cyprus $12,000
3/28/2011 Leviathan Advisors Limited Cyprus $25,000
(Home 4/27/201 1 Leviathan Advisors Limited Cyprus $12,000
Automation, 5/ 1 6/201 1 Leviathan Advisors Limited Cyprus $25,000
ngh?mg and 11/15/2011 Global Highway Limited Cyprus $17,006
Eggiaimnem 11/23/201 1 Global Highway Limited Cyprus $11,000
Company in 2/28/2012 Global Highway Limited Cyprus $6,200
Florida) 10/3 1/2012 Lucrcle Consultants lelted Cyprus $290,000
12/1 7/2012 Lucicle Consultants Limited Cyprus 160,600
1/15/2013 Lucicle Consultants Limited Cyprus $194,000
1/24/2013 Lucicle Consultants Limited Cyprus $6,300
2/12/2013 Lucicle Consultants Limited Cyprus $5 1,600
2/26/2013 Lucicle Consultants Limited Cyprus $260,000
7/15/2013 Pompolo Limited Uimed $175,575

Kingdom

8/28/2013 Global Endeavoru' Inc. Grenadines 1 79,000
10/3 1/2013 Global Endeavoru' Inc. Grenadines $73,000
5/23/2014 Global Endeavoru' Inc. Grenadines $99,960
6/20/2014 Global Endeavour Inc. Grenadines $62,960
Total $1,661,201
Oriental 10/7/2008 Yiakora Ventru?es Limited Cyprus $15,750
Rug Gallery 3/17/2009 Yiakora Ventru'es Limited Cyprus $46,200

 

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Case Document 419 Filed 09/14/18 Page 10 of 38

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Payee Transaction Originating Account Country of Amount of
Date Holder Origination Transaction
(Antique Rug 4/ 16/2009 Yiakora Ventru?es Limited ypr_us $7,400
Store in 4/27/2009 Yiakora Ventru?es Limited Cyprus $65,000
Alexandria, 5/7/2009 Yiakora Ventures Limited Cyprus $210,000
Virginia) 7/ 1 5/2009 Yiakora Ventures Limited Cyprus $200,000
3/31/2010 Yiakora Ventures Limited Cyprus $140,000
6/16/2010 Global Highway Limited Cyprus $250,000
$934,350
Vendor 
(Related to .
Oriental Rug 2/28/2012 Global Highway Limited Cyprus $100,000
Gallery)
Vendor Total $100,000
Alan Couture 11/7/2008 Yiakora Ventru?es Limited Cyprus $32,000
(Men?s Clothing 2/5/2009 Yiakora Ventru?es Limited Cyprus $22,750
Store in New 4/27/2009 Yiakora Ventures Limited Cyprus $13,500
York) 10/26/2009 Yiakora Ventures Limited Cyprus $32,500
3/30/2010 Yiakora Ventures Limited Cyprus $15,000
5/1 1/2010 Global Highway Limited Cyprus $39,000
6/28/2010 Leviathan Advisors Limited Cyprus $5,000
8/ 12/2010 Leviathan Advisors Limited Cyprus $32,500
1 1/17/2010 Global Highway Limited Cyplus $1 1,500
2/7/201 1 Global Highway Limited Cyprus $24,000
3/22/2011 Leviathan Advisors Limited yplus $43,600
3/28/201 1 Leviathan Advisors Limited Cyprus $12,000
4/27/2011 Leviathan Advisors Limited Cyprus $3,000
6/ 30/201 1 Global Highway Limited Cyprus $24,500
9/26/201 1 Leviathan Advisors Limited Cyprus $12,000
11/2/201 1 Global Highway Limited Cyprus $26,700
12/12/201 1 Leviathan Advisors 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 Lucicle Consultants Limited Cyprus $2 1 ,600
8/7/2012 Lucicle Consultants Limited Cyprus 15,500

 

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Case Document 419 Filed 09/14/18 Page 11 of 38

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Payee Transaction Originating Account Country of Amount of
Date Holder Origination Transaction
1 1/20/2012 Lucicle Consultants Limited ypr_us $10,900
12/20/2012 Lucicle Consultants Limited Cyprus $7,500
1/15/2013 Lucicle Consultants Limited Cyprus $37,000
2/12/2013 Lucicle Consultants Limited Cyprus $7,000
2/26/2013 Lucicle Consultants Limited Cyprus $39,000
9/3/2013 Global Endeavoru' Inc. Grenadines $8 1 ,500
10/9/2013 Global Endeavoru' Inc. Grenadines $53,000
1 1/25/2013 Global Endeavoru' Inc. Grenadines $13,200
4/ 1 7/2014 Global Endeavoru' Inc. Grenadines $26,680
9/1 1/2014 Global Endeavoru? Inc. Grenadines $58,435
Total $849,215
Scott L. Wilson 4/27/2009 Yiakora Ventru?es Limited Cyprus $34,000
Landscaping 5/12/2009 Yiakora Ventru'es Limited Cyprus $45,700
(Landscaper in 6/ 1/2009 Yiakora Ventru?es Limited Cyprus $21,500
the Hamptons, 6/ 18/2009 Yiakora Ventru'es Limited Cyprus $29,000
New York) 9/21/2009 Yiakora Ventures Limited Cyprus $21,800
5/ 1 1/2010 Global Highway Limited Cyprus $44,000
6/28/2010 Leviathan Advisors Limited Cyprus $50,000
7/23/2010 Leviathan Advisors Limited Cyprus $19,000
9/2/2010 Yiakora Ventlu?es Limited Cyprus $21,000
10/6/2010 Global Highway Limited Cyprus $57,700
10/18/2010 Leviathan Advisors Limited Cyprus $26,000
12/16/2010 Global Highway Limited Cyprus $20,000
3/22/2011 Leviathan Advisors Limited Cyprus $50,000
5/3/201 1 Global Highway Limited Cyprus $40,000
6/1/2011 Leviathan Advisors Limited Cyprus $44,000
7/27/2011 Leviathan Advisors Limited Cyprus $27,000
8/16/201 1 Leviathan Advisors Limited Cyprus 13,450
9/19/201 1 Leviathan Advisors Limited Cyprus $12,000
10/ 24/201 1 Global Highway Limited Cyprus $42,000
1 1/2/201 1 Global Highway Limited Cyprus $37,350
Total $655,500
Vendor 9/2/2010 Yiakora Ventru?es Limited Cyprus $165,000
(Antique Dealer 10/18/2010 Leviathan Advisors Limited Cyprus 165,000
in New York) 2/28/2012 Global Highway Limited Cyprus $190,600
3/ 14/2012 Lucicle Consultants Limited Cyprus $75,000

 

 

 

 

 

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Case Document 419 Filed 09/14/18 Page 12 of 38

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Payee Transaction Originating Account Country of Amount of
Date Holder Origination Transaction
2/26/2013 Lucicle Consultants Limited yp1_us $28,310
Vendor Total $623,910
Fashion World, 6/25/2008 LOAV Advisors Limited yplus $52,000
Inc. d/b/a/ Bijan 12/16/2008 Yiakora Ventures Limited Cyplus $49,000
(Clothing Store in 12/22/2008 Yiakora Ventures Limited $10,260
Beverly Hills, 8/ 12/2009 Yiakora Ventures Limited yplus $76,400
Califomia) 5/ 1 1/2010 Global Highway Limited yplus $85,000
11/17/2010 Global Highway Limited Cyplus $128,280
5/31/201 1 Leviathan Advisors Limited yplus $64,000
1 1/15/201 1 Global Highway Limited $48,000
12/1 7/2012 Lucicle Consultants Limited yplus $7,500
Total $520,440
Aegis Holdings,
LLC .
(Investment 9/3/2013 Global Endeavom? Inc. Gl?enadmes $500,000
Company)
Total $500,000
Paul Sabatello 11/15/201 1 Global Highway Limited yplus $8,000
Construction 12/5/201 1 Leviathan Advisors Limited $11,237
(Contractor in 12/21/2011 Black Sea View Limited yplus $20,000
Florida) 2/9/2012 Global Highway Limited $51,000
5/17/2012 Lucicle Consultants Limited yplus $68,000
6/19/2012 Lucicle Consultants Limited yplus $60,000
7/18/2012 Lucicle Consultants Limited yplus $32,250
9/19/2012 Lucicle Consultants Limited yplus $1 12,000
11/30/2012 Lucicle Consultants Limited Cyplus $39,700
1/9/2013 Lucicle Consultants Limited Cyplus $25,600
2/28/2013 Lucicle Consultants Limited Cyplus $4,700
Total $432,487
New Leaf 12/5/2011 Leviathan Advisors Limited yplus $4,115
Landscape 3/1/2012 Global Highway Limited $50,000
Maintenance 6/6/2012 Lucicle Consultants Limited yplus $47,800
LLC 6/25/2012 Lucicle Consultants Limited yplus 17,900
6/27/2012 Lucicle Consultants Limited yplus 18,900
2/12/2013 Lucicle Consultants Limited yplus $3,300

 

 

 

 

 

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Case Document 419 Filed 09/14/18 Page 13 of 38

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Payee Transaction Originating Account Country of Amount of
Date Holder Origination Transaction
$33313)? 7/15/2013 Pompolo Limited E?gim $13,325
New York) 1 1/25/2013 Global Endeavoru' Inc. Grenadines $9,400
4/ 1 5/2014 Global Endeavoru' Inc. Grenadines $3 3 ,2 1 1
5/ 13/2014 Global Endeavoru' Inc. Grenadines $30,965
9/ 1 1/2014 Global Endeavoru' Inc. Grenadines $26,769
Total $255,685
Don Beyer 4/12/2012 Lucicle Consultants Limited Cyprus $83,525
Motors, Inc.
(Payments 5/2/2012 Lucicle Consultants Limited Cyprus $12,525
Relating to three
Range Rovers) 6/29/2012 Lucicle Consultants Limited Cyprus $67,655
Total $163,705
Federal Stone 11/20/2012 Lucicle Consultants Limited Cyprus $45,000
and Brick LLC 12/7/2012 Lucicle Consultants Limited Cyprus $21,000
(Contractor in 12/ 1 7/2012 Lucicle Consultants Limited Cyprus $2 1 ,000
Virginia) 1/1 7/2013 Lucicle Consultants Limited Cyprus 18,750
1/29/2013 Lucicle Consultants Limited Cyprus $9,400
2/12/2013 Lucicle Consultants Limited Cyprus $10,500
Total $125,650
Sensoryphile, 1/29/2009 Yiakora Ventures Limited Cyprus $10,000
Inc. 3/17/2009 Yiakora Ventures Limited Cyprus $21,725
(Audio, Video, 4/ 16/2009 Yiakora Ventures Limited Cyprus $24,650
and Control 12/2/2009 Global Highway Limited Cyprus $10,000
Home 3/8/2010 Global Highway Limited Cyprus $20,300
Integ1 'atron and 4/23/2010 Yiakora Ventru'es Limited Cyprus $8,500
Installation
Company in the
Hamptons, New 7/29/2010 Leviathan Advisors Limited Cyprus $17,650
York)
Total $112,825

 

 

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Case Document 419 Filed 09/14/18 Page 14 of 38

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Payee Transaction Originating Account Country of Amount of
Date Holder Origination Transaction
American
Service Center
Associates of . 
Alexiandria 10/5/2012 Luelcle Consultants lerted $62,750
(Plu?chase of
Mercedes Benz)
Total $62,750
Land Rover of
Palm Beach . 
(Plu?chase 0 12/30/2008 Ylakora Ventlu'es anted $47,000
Range Rover)
Total $47,000
Vendor 9/2/2010 Yiakora Ventlu?es Limited $10,000
(Property 10/6/2010 Global Highway Limited Cyprus 10,000
Management 10/18/2010 Leviathan Advisors Limited $10,000
Company in 2/8/201 1 Global Highway Limited $13,500
South Cm?OIina) 2/9/2012 Global Highway Limited Cyprus $2,500
Vendor Total $46,000
Vendor 2/9/201 1 Global Highway Limited $17,900
(Art Gallely in 
Florida) 2/ 14/2013 Luc1cle Consultants L1mited Cyprus $14,000
Vendor Total $31,900
Vendor 9/26/2011 Leviathan Advisors Limited Cyprus $5,000
(Housekeeping in 9/ 19/2012 Lucicle Consultants Limited $5,000
New York) 10/9/2013 Global Endeavoru? Inc. Grenadines 10,000
Vendor Total $20,000

 

15. 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 plu?chases on his 2012 tax retlu'n.

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Case Document 419 Filed 09/14/18 Page 15 of 38

 

 

 

 

 

 

 

 

 

 

 

 

Property Originating Country of
Purchased Payee Date Account Origin Amount
Howard Street DMP Pe ?anova Hol din 
Condominium International 2/ 1/2012 Lirlni ted Cyprus 1 ,500,000
(New York) LLC
11/20/2012 Lila?? COHS?lltams Cyprus $299,500
. Attorney erited
Umon Street A tOf A t' tT' d'
Brownstone, 11/29/2012 ?99 ?3 mg Cyprus $1,800,000
[Real Estate Limited
(New York) Attorne A t' d'
11/29/2012 me ?3 mg Cyprus $1,200,000
ermted
Arlington .
House Real Estate 8/31/2012 Lucrcle Consultants Cyprus $1,900,000
. . . Trust erited
(Vn?gmia)

 

16. MANAFORT also disguised, as pinported ?loans,? more than $13 million from Cypriot

entities, including the overseas MANAFORT entities, to domestic entities owned by

MANAFORT. For example, a $1.5 million wire from Peranova Holdings Limited (Peranova) to

DMI that MANAFORT used to pru?chase 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 Payor Ostensible Payee Ostensible Country of Total Amount
?Lender? ?Borrower? Origination of ?Loans?
2008 Yiakora Ventru?es Limited Jesand Investment Cyprus 120,000
orporatron
2008 Yiakora Ventru?es Limited DMP Cyprus $500,000
2009 Yiakora Ventru'es Limited DMP Cyprus $694,000
2009 Yiakora Ventru?es Limited Daisy Manafort, LLC Cyprus $500,000
2012 Peranova DMI yp1us $1,500,000
2014 Tehnar Investments Ltd. DMI Cyprus $900,000
20 1 5 Tehnar Investments Ltd. DMI Cyprus 1 ,000,000
Total $13,214,000

 

 

Case 1:17-cr-00201-ABJ Document 419 Filed 09/14/18 Page 16 of 38

MANAFORT’s Hiding Of Ukraine Lobbying And Public Relations Work
17.

MANAFORT knew it was illegal to lobby government officials and engage in public

relations activities (hereinafter collectively referred to as lobbying) in the United States on behalf
of a foreign government or political party, without registering with the United States Government
under the Foreign Agents Registration Act. MANAFORT knew he was lobbying in the United
States for the Government of Ukraine, President Viktor F. Yanukovych, the Party of Regions, and
the Opposition Bloc (the latter two being political parties in Ukraine), and thus he was supposed
to submit a written registration statement to the United States Department of Justice.
MANAFORT knew that the filing was required to disclose the name of the foreign country, all the
financial payments to the lobbyist, and the specific steps undertaken for the foreign country in the
United States, among other information.
18.

MANAFORT knew that Ukraine had a strong interest in the United States’ taking economic

and policy positions favorable to Ukraine, including not imposing sanctions on Ukraine.
MANAFORT also knew that the trial and treatment of President Yanukovych’s political rival,
former Prime Minister Yulia Tymoshenko, was strongly condemned by leading United States
executive and legislative branch officials, and was a major hurdle to improving United States and
Ukraine relations.
19.

From 2006 until 2015, MANAFORT led a multi-million dollar lobbying campaign in the

United States at the direction of the Government of Ukraine, President Yanukovych, the Party of
Regions, and the Opposition Bloc. MANAFORT intentionally did so without registering and
providing the disclosures required by law.
20.

As part of the lobbying scheme, MANAFORT hired numerous firms and people to assist in
16

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his lobbying campaign in the United States. He hired Companies A, B, C, D, and E, and Law Firm
A, among others, to participate in what he described to President Yanukovych in writing as a global
“Engage Ukraine” lobbying campaign that he devised and led. These companies and law firm
were paid the equivalent of over $11 million for their Ukraine work.
21.

MANAFORT viewed secrecy for himself and for the actions of his lobbyists as integral to

the effectiveness of the lobbying offensive he orchestrated for Ukraine. Filing under the Foreign
Agents Registration Act would have thwarted the secrecy MANAFORT sought in order to conduct
an effective campaign for Ukraine to influence both American leaders and the American public.
22.

MANAFORT took steps to avoid any of these firms and people disclosing their lobbying

efforts under the Foreign Agents Registration Act. As one example, even though MANAFORT
engaged Company E in 2007 to lobby in the United States for the Government of Ukraine,
MANAFORT tried to dissuade Company E from filing under the Foreign Agents Registration Act.
Only after MANAFORT ceased to use Company E in the fall of 2007 did Company E disclose its
work for Ukraine, in a belated filing under the Act in 2008.
23.

MANAFORT took other measures to keep the Ukraine lobbying as secret as possible. For

example, MANAFORT, in written communications on or about May 16, 2013, directed his
lobbyists (including Persons D1 and D2, who worked for Company D) to write and disseminate
within the United States news stories that alleged that Tymoshenko had paid for the murder of a
Ukrainian official. MANAFORT stated that it should be “push[ed]” “[w]ith no fingerprints.” “It
is very important we have no connection.” MANAFORT stated that “[m]y goal is to plant some
stink on Tymo.” Person D1 objected to the plan, but ultimately Persons D1 and D2 complied with
MANAFORT’s direction. The Foreign Agents Registration Act required MANAFORT to disclose
17

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such lobbying, as MANAFORT knew. He did not.
The Hapsburg Group and Company D
24.

As part of the lobbying scheme, starting in 2011, MANAFORT secretly retained Company

D and a group of four former European heads of state and senior officials (including a former
Austrian Chancellor, Italian Prime Minister, and Polish President) to lobby in the United States
and Europe on behalf of Ukraine. The former politicians, called the Hapsburg Group by
MANAFORT, appeared to be providing solely their independent assessments of Government of
Ukraine policies, when in fact they were paid by Ukraine. MANAFORT explained in an “EYES
ONLY” memorandum in or about June 2012 that his purpose was to “assemble a small group of
high-level European infuencial [sic] champions and politically credible friends who can act
informally and without any visible relationship with the Government of Ukraine.”
25.

Through MANAFORT, the Government of Ukraine retained an additional group of

lobbyists (Company D and Persons D1 and D2). In addition to lobbying itself, Company D secretly
served as intermediaries between the Hapsburg Group and MANAFORT and the Government of
Ukraine. In or about 2012 through 2013, MANAFORT directed more than the equivalent of
700,000 euros to be wired from at least three of his offshore accounts to the benefit of Company
D to pay secretly for its services.
26.

All four Hapsburg Group members, at the direction, and with the direct assistance, of

MANAFORT, advocated positions favorable to Ukraine in meetings with United States
lawmakers, interviews with United States journalists, and ghost written op-eds in American
publications. In or about 2012 through 2014, MANAFORT directed more than 2 million euros to
be wired from at least four of his offshore accounts to pay secretly the Hapsburg Group. To avoid
18

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European taxation, the contract with the Hapsburg Group falsely stated that none of its work would
take place in Europe.
27.

One of the Hapsburg Group members, a former Polish President, was also a representative

of the European Parliament with oversight responsibility for Ukraine. MANAFORT solicited that
official to provide MANAFORT inside information about the European Parliament’s views and
actions toward Ukraine and to take actions favorable to Ukraine. MANAFORT also used this
Hapsburg Group member’s current European Parliament position to Ukraine’s advantage in his
lobbying efforts in the United States. In the fall of 2012, the United States Senate was considering
and ultimately passed a resolution critical of President Yanukovych’s treatment of former Prime
Minister Tymoshenko. MANAFORT engaged in an all-out campaign to try to kill or delay the
passage of this resolution. Among the steps he took was having the Hapsburg Group members
reach out to United States Senators, as well as directing Companies A and B to have private
conversations with Senators to lobby them to place a “hold” on the resolution. MANAFORT told
his lobbyists to stress to the Senators that the former Polish President who was advocating against
the resolution was currently a designated representative of the President of the European
Parliament, to give extra clout to his supposedly independent judgment against the Senate
resolution. MANAFORT never revealed to the Senators or to the American public that any of
these lobbyists or Hapsburg Group members were paid by Ukraine.
28.

In another example, on May 16, 2013, another member of the Hapsburg Group lobbied in

the United States for Ukraine. The Hapsburg Group member accompanied his country’s prime
minister to the Oval Office and met with the President and Vice President of the United States, as
well as senior United States officials in the executive and legislative branches. In written
19

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communications sent to MANAFORT, Person D1 reported that the Hapsburg Group member
delivered the message of not letting “Russians Steal Ukraine from the West.” The Foreign Agents
Registration Act required MANAFORT to disclose such lobbying, as MANAFORT knew. He did
not.
Law Firm Report and Tymoshenko
29.

As another part of the lobbying scheme, in 2012, on behalf of President Yanukovych and

the Government of Ukraine’s Ministry of Justice, MANAFORT solicited a United States law firm
to write a report evaluating the trial of Yanukovych’s political opponent Yulia Tymoshenko.
MANAFORT caused Ukraine to hire the law firm so that its report could be used in the United
States and elsewhere to defend the Tymoshenko criminal trial and argue that President
Yanukovych and Ukraine had not engaged in selective prosecution.
30.

MANAFORT retained a public relations firm (Company C) to prepare a media roll-out plan

for the law firm report. MANAFORT used one of his offshore accounts to pay Company C the
equivalent of more than $1 million for its services.
31.

MANAFORT worked closely with Company C to develop a detailed written lobbying plan

in connection with what MANAFORT termed the “selling” of the report. This campaign included
getting the law firm’s report “seeded” to the press in the United States—that is, to leak the report
ahead of its official release to a prominent United States newspaper and then use that initial article
to influence reporting globally. As part of the roll-out plan, on the report’s issuance on December
13, 2012, MANAFORT arranged to have the law firm disseminate hard copies of the report to
numerous government officials, including senior United States executive and legislative branch
officials.
20

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32.

MANAFORT reported on the law firm’s work on the report and Company C’s lobbying

plan to President Yanukovych and other representatives of the Government of Ukraine. For
example, in a July 27, 2012 memorandum to President Yanukovych’s Chief of Staff, MANAFORT
reported on “the global rollout strategy for the [law firm’s] legal report, and provide[d] a detailed
plan of action[]” which included step-by-step lobbying outreach in the United States.
33.

MANAFORT directed lobbyists to tout the report as showing that President Yanukovych

had not selectively prosecuted Tymoshenko. But in November 2012 MANAFORT had been told
privately in writing by the law firm that the evidence of Tymoshenko’s criminal intent “is virtually
non-existent” and that it was unclear even among legal experts that Tymoshenko lacked power to
engage in the conduct central to the Ukraine criminal case. These facts, known by MANAFORT,
were not disclosed to the public.
34.

Manafort knew that the report also did not disclose that the law firm, in addition to being

retained to write the report, was retained to represent Ukraine itself, including in connection with
the Tymoshenko case and to provide training to the trial team prosecuting Tymoshenko.
35.

MANAFORT also knew that the Government of Ukraine did not want to disclose how much

the report cost. More than $4.6 million was paid to the law firm for its work. MANAFORT used
one of his offshore accounts to funnel $4 million to pay the law firm, a fact that MANAFORT did
not disclose to the public. Instead, the Government of Ukraine reported falsely that the report cost
just $12,000.
36.

MANAFORT and others knew that the actual cost of the report and the scope of the law

firm’s work would undermine the report’s being perceived as an independent assessment and thus
being an effective lobbying tool for MANAFORT to use to support the incarceration of President
21

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Yanukovych’s political opponent.
37.

In addition to the law firm report, MANAFORT took other steps on behalf of the

Government of Ukraine to tarnish Tymoshenko in the United States. In addition to disseminating
stories about her soliciting murder, noted above, in October 2012, MANAFORT orchestrated a
scheme to have, as he wrote in a contemporaneous communication, “[O]bama jews” put pressure
on the Administration to disavow Tymoshenko and support Yanukovych. MANAFORT sought
to undermine United States support for Tymoshenko by spreading stories in the United States that
a senior Cabinet official (who had been a prominent critic of Yanukovych’s treatment of
Tymoshenko) was supporting anti-Semitism because the official supported Tymoshenko, who in
turn had formed a political alliance with a Ukraine party that espoused anti-Semitic
views. MANAFORT coordinated privately with a senior Israeli government official to issue a
written statement publicizing this story. MANAFORT then, with secret advance knowledge of
that Israeli statement, worked to disseminate this story in the United States, writing to Person D1
“I have someone pushing it on the NY Post. Bada bing bada boom.” MANAFORT sought to have
the Administration understand that “the Jewish community will take this out on Obama on election
day if he does nothing.” MANAFORT then told his United States lobbyist to inform the
Administration that Ukraine had worked to prevent the Administration’s presidential opponent
from including damaging language in the Israeli statement, so as not to harm the Administration,
and thus further ingratiate Yanukovych with the Administration.
Company A and Company B
38.

As a third part of the lobbying scheme, in February 2012, MANAFORT solicited two

Washington, D.C. lobbying firms (Company A and Company B) to lobby in the United States on
22

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behalf of President Yanukovych, the Party of Regions and the Government of Ukraine. For
instance, in early 2012 at the inception of the relationship, Company B wrote in an email to its
team about a “potential representation for the Ukraine,” having been contacted “at the suggestion
of Paul Manafort who has been working on the current PM elections.”
39.

MANAFORT arranged to pay Companies A and B over $2 million from his offshore

accounts for their United States lobbying work for Ukraine.
40.

MANAFORT provided direction to Companies A and B in their lobbying efforts, including

providing support for numerous United States visits by numerous senior Ukrainian officials.
Companies A and B, at MANAFORT’s direction, engaged in extensive United States lobbying.
Among other things, they lobbied dozens of Members of Congress, their staff, and White House
and State Department officials about Ukraine sanctions, the validity of Ukraine elections, and the
propriety of President Yanukovych’s imprisoning Tymoshenko, his presidential rival.
41.

In addition, with the assistance of Company A, MANAFORT also personally lobbied in the

United States. He drafted and edited numerous ghost-written op-eds for publication in United
States newspapers. He also personally met in March 2013 in Washington, D.C., with a Member
of Congress who was on a subcommittee that had Ukraine within its purview. After the meeting,
MANAFORT prepared a report for President Yanukovych that the meeting “went well” and
reported a series of positive developments for Ukraine from the meeting.
42.

Indeed, MANAFORT repeatedly communicated in person and in writing with President

Yanukovych and his staff about the lobbying activities of Companies A and B and he tasked the
companies to prepare assessments of their work so he, in turn, could brief President Yanukovych.
For instance, MANAFORT wrote President Yanukovych a memorandum dated April 8, 2012, in
23

 Case 1:17-cr-00201-ABJ Document 419 Filed 09/14/18 Page 24 of 38

which he provided an update on the lobbying firms’ activities “since the inception of the project a
few weeks ago. It is my intention to provide you with a weekly update moving forward.” In
November 2012, Gates wrote to Companies A and B 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.” The resulting
memorandum from Companies A and B, with input from Gates, noted among other things that the
“client” had not been as successful as hoped given that it had an Embassy in Washington.
43.

To distance their United States lobbying work from the Government of Ukraine, and to

avoid having to register as agents of Ukraine under the Foreign Agents Registration Act,
MANAFORT with others arranged for Companies A and B to be engaged by a newly-formed
Brussels entity called the European Centre for the Modern Ukraine (the Centre), instead of directly
by the Government of Ukraine.
44.

MANAFORT described the Centre as “the Brussels NGO that we have formed” to

coordinate lobbying for Ukraine. The Centre was founded by a Ukraine Party of Regions member
and Ukraine First Vice-Prime Minister. The head of its Board was another member of the Party
of Regions, who became the Ukraine Foreign Minister.
45.

In spite of these ties to Ukraine, MANAFORT and others arranged for the Centre to

represent falsely that it was not “directly or indirectly supervised, directed, [or] controlled” in
whole or in major part by the Government of Ukraine or the Party of Regions. MANAFORT knew
that the false and misleading representations would lead Companies A and B not to register their
activities pursuant to the Foreign Agents Registration Act.
46.

Despite the Centre being the ostensible client of Companies A and B, MANAFORT knew
24

 Case 1:17-cr-00201-ABJ Document 419 Filed 09/14/18 Page 25 of 38

that the Centre did not direct or oversee their work.

The firms received direction from

MANAFORT and his subordinate Gates, on behalf of the Government of Ukraine.
47.

Various employees of Companies A and B understood that they were receiving direction

from MANAFORT and President Yanukovych, not the Centre, which was not even operational
when Companies A and B began lobbying for Ukraine. MANAFORT, Gates, and employees of
both Companies A and B referred to the client in ways that made clear they knew it was Ukraine,
for instance noting that the “client” had an Embassy in Washington D.C. The head of Company
B told his team to think the President of Ukraine “is the client.” As a Company A employee noted
to another company employee: the lobbying for the Centre was “in name only. [Y]ou’ve gotta see
through the nonsense of that[.]” “It’s like Alice in Wonderland.” An employee of Company B
described the Centre as a fig leaf, and the Centre’s written certification that it was not related to
the Party of Regions as “a fig leaf on a fig leaf,” referring to the Centre in an email as the “European
hot dog stand for a Modern Ukraine.”
Conspiring to Obstruct Justice: False and Misleading Submissions to the Department of Justice
48.

In September 2016, after numerous press reports concerning MANAFORT had appeared in

August, the Department of Justice National Security Division informed MANAFORT, Gates, and
DMI in writing that it sought to determine whether they had acted as agents of a foreign principal
under the Foreign Agents Registration Act, without registering. In November 2016 and February
2017, MANAFORT and Gates conspired to knowingly and intentionally cause false and
misleading letters to be submitted to the Department of Justice, through his unwitting legal
counsel. The letters, both of which were approved by MANAFORT before they were submitted
by his counsel, represented falsely, among other things, that:
25

 Case 1:17-cr-00201-ABJ Document 419 Filed 09/14/18 Page 26 of 38

a.

DMI’s “efforts on behalf of the Party of Regions” “did not include meetings or

outreach within the U.S.”;
b.

MANAFORT did not “recall meeting with or conducting outreach to U.S.

government officials or U.S. 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]. . . .”;
c.

MANAFORT had merely served as a means of introduction of Company A and

Company B to the Centre and provided the Centre with a list of “potential U.S.-based
consultants—including [Company A] and [Company B]—for the [Centre’s] reference and
further consideration”; and
d.

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.”
49.

In fact, MANAFORT had: selected Companies A and B; engaged in weekly scheduled calls

and frequent emails with Companies A and B to provide them directions as to specific lobbying
steps that should be taken; sought and received detailed oral and written reports from these firms
on the lobbying work they had performed; communicated with Yanukovych to brief him on their
lobbying efforts; both congratulated and reprimanded Companies A and B on their lobbying work;
communicated directly with United States officials in connection with this work; and paid the
26

 Case 1:17-cr-00201-ABJ Document 419 Filed 09/14/18 Page 27 of 38

lobbying firms over $2.5 million from offshore accounts he controlled, among other things.
50.

Although MANAFORT had represented to the Department of Justice in November 2016

and February 2017 that he had no relevant documents, in fact MANAFORT had numerous
incriminating documents in his possession, as he knew at the time. The Federal Bureau of
Investigation conducted a court-authorized search of MANAFORT’S home in Virginia in the
summer of 2017. The documents attached hereto as Government Exhibits 503, 504, 517, 532, 594,
604, 606, 616, 691, 692, 697, 706 and 708, among numerous others, were all documents that
MANAFORT had in his possession, custody or control (and were found in the search) and all predated the November 2016 letter.
Money Laundering Conspiracy
51.

In or around and between 2006 and 2016, MANAFORT, together with others,

did

knowingly and intentionally conspire (a) to conduct financial transactions, affecting interstate and
foreign commerce, which involved the proceeds of specified unlawful activity, to wit, felony
violations of FARA in violation of Title 22, United States Code, Sections 612 and 618, knowing
that the property involved in the financial transactions represented proceeds of some form of
unlawful activity, with intent to engage in conduct constituting a violation of sections 7201 and
7206 of the Internal Revenue Code of 1986; and (b) 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 specified unlawful activity, to wit: a felony violation of
FARA, in violation of Title 22, United States Code, Sections 612 and 618, contrary to Title 18,
United States Code, Section 1956(a)(1)(A)(ii) and (a)(2)(A).
27

 52.

Case Document 419 Filed 09/14/18 Page 28 of 38

MANAFORT caused the following transfers to be made, knowing that they were being

made to entities to carry on activities that were required to be timely reported under the Foreign

Agents Registration Act, but were not:

 

 

 

 

 

 

 

 

 

 

 

 

 

lPayee Date Payer Originating Country of. . . Amount
Bank Account Origin Destination (Bletilla Bank of Cyprus Cyprus US $270,000?)
Ventures Ltd. Account -0480 
10/10/2012 Bletilla Bank of Cyprus Cyprus US $90,000.00
Ventm'es Ltd. Account -0480
1 1/16/2012 Bletilla Bank of Cyprus Cyprus US $120,000.00
Ventru'es Ltd. Account -0480
11/20/2012 Bletilla Bank of Cyprus Cyprus US $182,968.07
Ventm'es Ltd. Account -0480
12/21/2012 Bletilla Bank of Cyprus Cyprus US $25,000.00
Ventru'es Ltd. Account -0480
i 3/ 15/2013 Bletilla Hellenic Bank Cyprus US $90,000.00
Ventm'es Ltd. Account -2501
2? 9/18/2013 Global Loyal Bank US $135,937.37
8 Endeavour Inc. Limited Account
-1840
10/31/2013 Jeunet Ltd. Loyal Bank US $167,689.40
Limited Account
-4978
3/28/2014 Jeunet Ltd. Loyal Bank US $135,639.65
Limited Account
-4978
4/3/2014 Jeunet Ltd. Loyal Bank US $82,979.93
Limited Account
-4978
Total Company A Transfers $1,300,214.42
5/30/2012 Bletilla Bank of Cyprus yplus US $130,00000
Ventm'es Ltd. Account -0480 
C: 8/ 2/ 20 1 2 Bletilla Bank of Cyprus Cyprus US $195,000.00
Ventru'es Ltd. Account -0480
10/10/2012 Bletilla Bank of Cyprus Cyprus US $130,000.00
8 Ventm'es Ltd. Account -0480
1 1/16/2012 Bletilla Bank of Cyprus Cyprus US $50,000.00
Ventru'es Ltd. Account -0480

 

 

 

 

 

 

 

 

 

 

 

 

28

Case Document 419 Filed 09/14/18 Page 29 of 38

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

lPayee Date Payer Originating Country of. . . Amount
Bank Account Origin Destination (U SD)
12/21/2012 Bletilla Bank of US $54,649.51
Ventlu'es Ltd. Accomlt -0480
3/15/2013 Bletilla Hellenic Bank Cyprus US $150,000.00
Ventures Ltd. Accomit -2501
9/3/2013 Jeunet Ltd. Loyal Bank US $175,857.51
Limited Account
-4978
10/31/2013 Jeunet Ltd. Loyal Bank US $195,857.51
Limited Account
-4978
3/12/2014 Jeunet Ltd. Loyal Bank US $26,891.78
Limited Account
-4978
3/21/2014 Jeunet Ltd. Loyal Bank US $138,026.00
Limited Account
?4978
4/ 1 5/2014 eunet Ltd. Loyal Bank US $4,728.81
Limited Account
-4978
4/25/2014 eunet Ltd. Loyal Bank US $4,739.23
Limited Account
-4978
Total Company Transfers $1,255,750.35
4/ 19/2012 Black Sea Bank of Cyprus US $2 000 000.00
3 View Limited Account ?74 2 i i
5/30/2012 Black Sea Bank of Cyprus US $1,000,000.00
View Limited Account -7412
7/13/2012 Black Sea Bank of Cyprus US $1,000,000.00
View Limited Accomit -7412
Total Law Firm A Transfers $4,000,000.00
TOTAL TRANSFERS $6,555,964.77

 

 

 

 

SVG refers to St. Vincent and the Grenadines.

Hiding Of Foreign Bank Accounts And False Tax Filings

53.

United States citizens who have authority over certain foreign bank acc01u1ts?whether or

not the accounts are set up in the names of nominees who act for their principals?have reporting

29

Case 1:17-cr-00201-ABJ Document 419 Filed 09/14/18 Page 30 of 38

obligations to the United States.
54.

First, the Bank Secrecy Act and its implementing regulations require United States citizens

to report to the United States Treasury any financial interest in, or signatory authority over, any
bank account or other financial account held in foreign countries, for every calendar year in which
the aggregate balance of all such foreign accounts exceeds $10,000 at any point during the year.
This is commonly known as a foreign bank account report or “FBAR.” The Bank Secrecy Act
requires these reports because they have a high degree of usefulness in criminal, tax, or regulatory
investigations or proceedings. The United States Treasury’s Financial Crimes Enforcement
Network (FinCEN) is the custodian for FBAR filings, and FinCEN provides access to its FBAR
database to law enforcement entities, including the Federal Bureau of Investigation. The reports
filed by individuals and businesses are used by law enforcement to identify, detect, and deter
money laundering that furthers criminal enterprise activity, tax evasion, and other unlawful
activities.
55.

Second, United States citizens also are obligated to report information to the IRS regarding

foreign bank accounts. For instance, in 2010 Form 1040, Schedule B 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 financial account?” If the answer was “Yes,” then the form
required the taxpayer to enter the name of the foreign country in which the financial account was
located.
56.

For each year in or about and between 2007 through at least 2014, MANAFORT had

authority over foreign accounts that required an FBAR report. Specifically, MANAFORT was
30

 Case 1:17-cr-00201-ABJ Document 419 Filed 09/14/18 Page 31 of 38

required to report to the United States Treasury each foreign bank account held by the foreign
MANAFORT entities noted above in paragraph 10.

No FBAR reports were made by

MANAFORT for these accounts.
57.

Furthermore, in each of MANAFORT’s tax filings for 2007 through 2014, Manafort

represented falsely that he did not have authority over any foreign bank accounts. MANAFORT
had repeatedly and falsely represented in writing to MANAFORT’s tax preparer that
MANAFORT had no authority over foreign bank accounts, knowing that such false
representations would result in false MANAFORT tax filings. For instance, on October 4, 2011,
MANAFORT’s 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 financial
account in a foreign country, such as a bank account, securities account or other financial
account?” On the same day, MANAFORT falsely responded “NO.” MANAFORT responded the
same way as recently as October 3, 2016, when MANAFORT’s tax preparer again emailed the
question in connection with the preparation of MANAFORT’s tax returns: “Foreign bank accounts
etc.?” MANAFORT responded on or about the same day: “NONE.”
MANAFORT’s Fraud To Increase Access To Offshore Money
58.

After MANAFORT used his offshore accounts to purchase real estate in the United States,

he took out mortgages on the properties thereby allowing MANAFORT to have the benefits of
liquid income without paying taxes on it. Further, MANAFORT defrauded the banks that loaned
him the money so that he could withdraw more money at a cheaper rate than he otherwise would
have been permitted.
59.

In 2012, MANAFORT, through a corporate vehicle called “MC Soho Holdings, LLC”
31

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owned by him and his family, bought a condominium on Howard Street in the Soho neighborhood
in Manhattan, New York. He paid approximately $2,850,000. All the money used to purchase
the condominium came from MANAFORT entities in Cyprus. MANAFORT used the property
from at least January 2015 through 2016 as an income-generating rental property, charging
thousands of dollars a week on Airbnb, among other places. In his tax returns, MANAFORT took
advantage of the beneficial tax consequences of owning this rental property.
60.

Also in 2012, MANAFORT -- through a corporate vehicle called “MC Brooklyn Holdings,

LLC” similarly owned by him and his family -- bought a brownstone on Union Street in the Carroll
Gardens section of Brooklyn, New York. He paid approximately $3,000,000 in cash for the
property. All of that money came from a MANAFORT entity in Cyprus.
COUNT ONE
Conspiracy Against The United States
61.

Paragraphs 1 through 60 are incorporated here.

62.

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 and Kilimnik, 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 Department of the
Treasury, and to commit offenses against the United States, to wit, (a) money laundering (in
violation of 18 U.S.C. § 1956); (b) tax fraud (in violation of 26 U.S.C. § 7206(1)); (c) failing to
file Foreign Bank Account Reports (in violation of 31 U.S.C. §§ 5312 and 5322(b)); (d) violating
the Foreign Agents Registration Act (in violation of 22 U.S.C. §§ 612, 618(a)(1), and 618(a)(2));
32

 Case 1:17-cr-00201-ABJ Document 419 Filed 09/14/18 Page 33 of 38

and (e) lying and misrepresenting to the Department of Justice (in violation of 18 U.S.C. § 1001(a)
and 22 U.S.C. §§ 612 and 618(a)(2)).
63.

In furtherance of the conspiracy and to effect its illegal object, MANAFORT, together with

others, committed the overt acts, in the District of Columbia and elsewhere, as set forth in the
paragraphs above, which are incorporated herein.
(18 U.S.C. §§ 371 and 3551 et seq.)

COUNT TWO
Conspiracy to Obstruct Justice (Witness Tampering)
64.

Paragraphs 1 through 60 are incorporated here.

65.

From in or about and between February 23, 2018 and April 2018, both dates being

approximate and inclusive, within the District of Columbia and elsewhere, the defendant PAUL J.
MANAFORT, JR., together with others, including Konstantin Kilimnik, knowingly and
intentionally conspired to corruptly persuade another person, to wit: Persons D1 and D2, with
intent to influence, delay and prevent the testimony of any person in an official proceeding, in
violation of 18 U.S.C. § 1512(b)(1).
66.

On February 22, 2018, MANAFORT was charged in the District of Columbia in a

Superseding Indictment that for the first time included allegations about the Hapsburg Group and
MANAFORT’s use of that group to lobby illegally in the United States in violation of the Foreign
Agent Registration Act. MANAFORT knew that the Act prescribed only United States lobbying.
Immediately after February 22, 2018, MANAFORT began reaching out directly and indirectly to
Persons D1 and D2 to induce them to say falsely that they did not work in the United States as part
33

 Case Document 419 Filed 09/14/18 Page 34 of 38

of the lobbying campaign, even though MANAFORT then and there well knew that they did lobby
in the United States.

67. MANAFORT committed the following overt acts directly and through his conspirators.

 

Date/Iime* Sender Receiver Event

 

 

 

 

contacted Person by phone mm1 a messaging application:

 

 

 

 

 

 

 

 

2/ 24/ 201 8; MANAFORT Person 1 Phone call (attempted): No dln?ation.
15 :5 1 (UTC)
2/24/2018; MAN AF ORT Person D1 Phone call: 1 min, 24 second call.
15 :5 1 (UTC)
2/24/2018; MAN AF ORT Person D1 Text: ?This is paul?
1 5 :5 3 (UTCORT Person D1 Phone call (attempted): No dm?ation.
1 8 :41 (UTC)
2/26/2018; MANAFORT Person D1 Text:
23:56 (UTC) 
elu'opean-leaders-mana fort-hapsblu?g-group-

2/2 6/201 8; MANAFORT Person D1 Text: ?We should talk. I have made clear that
23 :5 7 (UTC) they worked in Europe.?
2/ 2 7/201 8; MANAFORT Person 1 Phone call (attempted): No dln?ation.
1 1:03 (UTC)
2/ 2 7/ 201 8; MANAFORT Person 1 Phone call (attempted): No dln?ation.
1 1 :3 1 (UTC)

 

 

 

 

Kilimnik contacted Person D2 a messagi

ng application, sending four messages:

 

 

 

 

2/28/2018; Kilimnik Person D2 ?[Person hi! How are you? Hope you
01 :49 (CEST) are doing fine. 

2/28/2018; Kilimnik Person D2 ?My friend is ?ying to reach [Person 
01 :51 (C EST) to brief him on what's going on.?

2/28/2018; Kilimnik Person D2 ?If you have a chance to mention this to

01:51 (CEST)

 

 

[Person - would be great?

 

 

34

 

Case Document 419 Filed 09/14/18 Page 35 of 38

 

Date/Time*

Sender

Receiver

Event

 

2/28/2018;
01 :53 (CEST)

Kilinmik

 

Person D2

 

 

?Basically wants to give him a quick
summary that he says to everybody (which is
true) that our friends never lobbied in the
US, and the plupose of the program was 

 

Kilimnik contacted Person D2 us

ing a di?erent messaging application, sending ?ve messages:

 

 

 

 

 

2/28/2018; Kilimnik Person D2 ?Hey, how are you? This is 
06:01 (C EST)
2/28/2018; Kilimnik Person D2 ?Hope you are doing 
06:01 (C EST)
2/28/2018; Kilimnik Person D2 ?My ?'iend is tiying to reach [Person 
06:01 (CEST) to brief him on what's going on?
2/28/2018; Kilimnik Person D2 ?Basically wants to give him a quick
06:02 (C EST) smnmaiy that he says to everybody (which is
true) that om' friends never lobbied in the
US, and the pulpose of the program was 
2/28/2018; Kilimnik Person D2 ?If you have a chance to mention this to

06:03 (CEST)

 

 

 

[First Initial of Person D1 ?3 Name]. - it
would be great. It would be good to get them
connected to discuss in person. is his

 

 

 

 

friend.?
Kilimnik contacted Person D2 using two di?erent applications, sending three messages:

4/4/2018; Kilimnik Person D2 ?Hey. This is Konstantin. My friend asked

08:53 (CEST) me again to help connect him with [Person
Can you help??

4/4/2018; Kilimnik Person D2 ?Hey. My ??iend has asked me again if

08:54 (C EST) there is any way to help connect him through
[Person 
4/4/2018; Kilimnik Person D2 tried him on all munbers.?

08:54 (CEST)

 

Kilimnik contacted Person D1 using a messaging application:

 

 

4/4/2018;
13:00 (UTC)

Kilimnik

 

Person D1

 

 

?Hi. This is K. My friend is looking for
ways to connect to you to pass you several
messages. Can we arrange that.?

 

 

and CEST refer to Coordinated Universal Time and Central European Summer Time,
respectively.
35

Case 1:17-cr-00201-ABJ Document 419 Filed 09/14/18 Page 36 of 38

(18 U.S.C. §§ 371 and 3551 et seq.)
FORFEITURE ALLEGATIONS
68.

Upon conviction of the offense charged in Count One, 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, and any property, real or personal, which
constitutes or is derived from proceeds traceable to the offense, pursuant to Title 18, United States
Code, Sections 981(a)(1)(A), 981(a)(1)(C), and 982(a)(1), and Title 28, United States Code,
Section 2461(c). The United States will also seek a judgment against the defendant for a sum of
money representing the property described in this paragraph (to be offset by the forfeiture of any
specific property).
69.

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,

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, #4D, New

York, New York 10013 (Block 209, Lot 1104), including all appurtenances, improvements,
and attachments thereon, and any property traceable thereto;
c.

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;
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 Case 1:17-cr-00201-ABJ Document 419 Filed 09/14/18 Page 37 of 38

d.

All funds held in account number XXXXXX0969 at The Federal Savings Bank,

and any property traceable thereto;
e.

All funds seized from account number XXXXXX1388 at Capital One N.A., and

any property traceable thereto; and
f.

All funds seized from account number XXXXXX9952 at The Federal Savings

Bank, and any property traceable thereto;
g.

Northwestern Mutual Universal Life Insurance Policy 18268327, and any property

traceable thereto;
h.

All funds held in account number XXXX7988 at Charles A. Schwab & Co. Inc.,

and any property traceable thereto; and
i.

The real property and premises commonly known as 1046 N. Edgewood Street,

Arlington, Virginia 22201, including all appurtenances, improvements, and attachments
thereon, and any property traceable thereto.
Substitute Assets
70.

If any of the property 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 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;
37

 Case 1:17-cr-00201-ABJ Document 419 Filed 09/14/18 Page 38 of 38

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.

By:

Rs~£~Special Counsel
Department of Justice

38