UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

-

- -

X

UNITED STATES OF AMERICA

SEALED INDICTMENT
19 Cr.

- v. -

LEV PARNAS,
IGOR FRUMAN,
DAVID CORREIA, and
ANDREY KUKUSHKIN,

-

Defendants.
X

The Grand Jury charges:
INTRODUCTION
1.
foreign

Through

nationals

from

its

election

making

laws,

Congress

contributions,

prohibits

donations,

and

certain expenditures in connection with federal, State, and local
elections, and prohibits anyone from making contributions in the
name

of another.

Congress further requires public reporting

through the Federal Election Commission (the "FEC") of the sources
and amounts of contributions and expenditures made in connection
with federal elections.

A purpose of these laws, taken together,

is to protect the United States electoral system from illegal
foreign financial influence, and to further inform all candidates,
their campaign committees, federal regulators, and the public of
(i) the true sources of contributions to candidates for federal

 office;

and

(ii)

any effort by foreign nationals to influence

federal, State, or local elections with foreign money.
2.
KUKUSHKIN,

LEV PARNAS, IGOR FRUMAN, DAVID CORREIA, and ANDREY

the defendants,

conspired to circumvent the federal

laws against foreign influence by engaging in a scheme to funnel
foreign money to candidates for federal and State office so that
the defendants could buy potential influence with candidates,
campaigns,

and

concealed

the

regulators,

the

candidates'

scheme from

the

The

governments.
candidates,

defendants

campaigns,

federal

and the public by entering into secret agreements,

laundering foreign money through bank accounts in the names of
limited liability corporations, and through the use of straw donors
(also known as �conduits" or "straw contributors") who purported
to make legal campaign contributions in their own names, rather
than in the name of the true source of the funds.
3.

LEV PARNAS and IGOR FRUMAN,

the defendants, made

additional contributions to federal candidates, joint fundraising
committe
, es, and independent expenditure committees that either (i)
were intentionally funneled through, and made in the name of, a
limited liability corporation to conceal that PARNAS and FRUMAN
were

the true

source of

contributions

and skirt

the

federal

reporting requirements; or (ii) were reported in PARNAS's name but
were funded by FROMAN, which allowed FRUMAN to exceed limits on

2

 contributions to candidates or committees to whom he had previously
contributed.

The defendants further concealed this aspect of the

conspiracy by, among other things,

making and causing others to

make false statements to the FEC.
THE CAMPAIGN FINANCE LAWS
4.
amended,

The

Title 52,

Federal

Election

Campaign

United States Code,

(the "Election Act") ,

Act

of

Section 30101,

1971,

as

et seq.,

prohibits cer:tain financial influences on

the election of candidates for federal office.
5.

To prevent the influence of foreign nationals on

elections, the Election Act prohibits foreign nationals, directly
or indirectly,

from making any contributions or donations in

connection with federal, State, or local elections.

Additionally,

to limit the influence that any one person could have on the
outcome of a federal election, the Election Act establishes limits
on the amounts that even United States citizens or lawful permanent
residents can contribute to a federal candidate and the candidate's
authorized

committee,

including

joint

fundraising

committees,

which are committees established for the purpose of fundraising
for multiple committees at the same time.
6.

To

prevent

individuals

from

circumventing

the

Election Act, and to enable the detection of attempts to circumvent
the Act,

the Election Act also prohibits a person from mating a
3

 political contribution in the name of another in connection with
any federal election, including, for example, by giving funds to
a straw donor for the purpose of having the straw donor pass the
funds on to a federal

candidate or to a candidate's federal

campaign committee or joint fundraising committee as a donation
from the straw donor, rather than in the name of the true source
of the money.

The Election Act also prohibits contributing in the

name of another to an independent expenditure committee spending
to influence the outcome of that federal campaign.
7.

The FEC is an agency and department of the United

States with jurisdiction to enforce the limits and prohibitions of
the

Election

Act,

in

part

by

requiring

joint

candidates,

fundraising committees, and independent expenditure committees to
file

regular

reports

of

the

contributions they receive.

sources

and

amounts

of

the

To deter abuses of the Election Act

and instill public confidence in the election process against
corruption and the appearance of corruption,

the Election Act

requires the FEC to publish the reports that it receives so that
all of the candidates, the entire public, and law enforcement may
all see the specific information about the amounts and sources of
political

contributions

and

expenditures

involving

candidates and registered political committees.

4

federal

 RELEVANT INDIVIDUALS AND ENTITIES
8.

LEV PARNAS,

the defendant,

is a businessman and

United States citizen who was born in Ukraine.
9.

IGOR FRUMAN, the defendant,

is a businessman and

United States citizen who was born in Belarus.
10.

DAVID CORREIA, the defendant, is a businessman and

United States citizen who was born in the United States.
11.

ANDREY KUKUSHKIN, the defendant, is a businessman

and United States citizen who was born in Ukraine.
12.

Foreign National-1 is a foreign national Russian

citizen and businessman who,

at all relevant times,

was not a

citizen or lawful permanent resident of the United States.
THE STRAW DONOR SCHEME
13.

Beginning in or about March 2018, LEV PARNAS and

IGOR FRUMAN, the defendants, began attending political fundraising
events in connection with federal elections and making substantial
contributions to candidates,

joint fundraising committees,

and

independent expenditure committees with the purpose of enhancing
their

influence

politicians.

in

political

circles

PARNAS and FRUMAN,

and

gaining

access

to

who had no significant prior

history of political donations, sought to advance their personal
financial interests and the political interests of at least one
Ukrainian government official with whom they were working.
5

In

 order to conceal from third parties, including creditors, their
sources of funding and capital, PARNAS and FRUMAN created a limited
liability corporation, Global Energy Producers ("GEP"),

and then

intentionally caused certain large contributions to be reported in
the name of GEP instead of in their own names.
14.
access

Specifically,

in

to exclusive political

or

about

events and

May

2018,

to

obtain

gain influence with

politicians, LEV PARNAS and IGOR FRUMAN, the defendants, made a
$325,000 contribution

to an

independent

expenditure

committee

("Committee-1 11 ) and a $15,000 contribution to a second independent
expenditure committee ("Committee-2'').

Despite the fact that the

FEC forms for these contributions required PARNAS and FRUMAN to
disclose the true donor of the funds, they falsely reported that
the contributions came from GEP, a purported liquefied natural gas
("LNG") import-export business that was incorporated by FROMAN and
PARNAS around the time the contributions were made.
15.

In truth and in fact, the donations to Committee-1

and Committee-2 did not come from GEP funds.

Rather, the funds

came from a private lending transaction between FRUMAN and third
parties, and never passed through a GEP account.
and

FRUMAN

incorporated

GEP

at

and

around

the

Indeed, PARNAS
time

of

the

contributions to Committee-1 and Cammi ttee-2, and deliberately
made the contributions in GEP' s name, in order
6

to evade the

 reporting requirements under the Election Act and to conceal that
they were the true source of the contributions.
had

not

engaged

in

the

LNG business,

At that time, GEP

and had

no

income

or

significant assets.
16.

LEV

PARNAS

and

IGOR

FRUMAN,

the

defendants,

intentionally reported that the contributions came from GEP to
hide from creditors the fact that they had access to funding, and
to conceal from the public and the FEC their involvement in making
these contributions.

Indeed, when media reports about the GEP

contributions first surfaced, an individual working with PARNAS
remarked, "(t]his is what happens when you become visible ... the
buzzards descend," to which PARNAS responded,

"[t] hat's why we

need to stay under the radar ..."
17.

In addition to the contributions made and falsely

reported in the name of GEP, LEV PARNAS and IGOR FRUMAN,

the

defendants, caused illegal contributions to be made in PARNAS's
name that, in fact, were funded by FRUMAN, in order to evade
federal contribution limits.

Much as with the contributions

described above, these contributions were made for the purpose of
gaining influence with politicians so as to advance their own
personal

financial

interests

and

the

political

interests

of

Ukrainian government officials, including at least one Ukrainian
government official with whom they were workJng.

7

For example, in

 or about May and June 2018, PARNAS and FRUMAN committed to .r:aise
$20,000 or more for a then-sitting U.S. Congressman ("Congressman1"), who had also been the beneficiary of approximately $3 million
in

independent

election cycle.

expenditures

by

Comrnittee-1

during

the

2018

PARNAS and FRUMAN had met Congressman-1 at an

event sponsored by an independent expenditure committee to which
FRUMAN had recently made a substantial contribution. 1
2018 election cycle,

During the

Congressman-1 had been the beneficiary of

approximately $3 million in independent expenditures by Committee1.

At and around the same time PARNAS and FRUMAN committed to

raising

those

funds

for

Congressman-l r

PARNAS

met

with

Congressman-1 and sought Congressman-l's assistance in causing the
U.S. Government to remove or recall the then-U.S. Ambassador to
Ukraine

(the

"Ambassador") .

PARNAS's

efforts

to

remove

the

Ambassador were conducted, at least in part, at the request of one
or more Ukrainian government officials.
to

reach

their

contribution

commitment

Moreover, in an effort
to

Congressman-1

and

further their political goals, in or about June 2018, after FRUMAN
had already made a maximum $2,700 contribution to Congressman-1,

In fact; the contribution
and
contributions made at and around the
name of "Igor Furman" not IGOR FRUMAN,
effort to conceal the source of the
reporting requirements.
1

several other significant
same time - was made in the
the defendant, in a further
funds and to evade federal

 FRUMAN

paid

for

another

maximum

$2,700

contribution

to

Congressman-1 that was made and reported in PARNAS's name.
18.

Similarly, in or about June 2018, to fulfill a

financial commitment to gain access to an exclusive political
event, LEV PARNAS and IGOR FRUMAN, the defendants, made an $11,000
contribution in PARNAS' s name to a joint fundraising committee
("Committee-3") that was actually funded by FRUMAN.

As a result

of that contribution and a prior contribution FRUMAN had made to
A

Committee-3 in his own name, FRUMN made contributions in excess
of legal contribution limits.
19.

Moreover, and to further conceal the true source of

the funds used to make certain of the donations described above,
in

or

about

October

2018,

LEV

PARNAS

and

IGOR

FRUMAN,

the

defendants, submitted materially false sworn affidavits to the
FEC.

Specifically, and in response to a complaint filed with the

FEC regarding the $325,000 contribution to Committee-1 described
in paragraph 14, above, and the $2,700 donation to Congressman-1
made in the name of PARNAS, described in paragraph 17, above,
PARNAS and FRUMAN made the following false statements, in substance
and in part:
a.
1]

.

That "a $325,000 contribution to [Committee-

. was made with GEP funds for GEP purposes," when in truth

and in fact, the contribution was made with funds from a private
9

 lending transaction for the purposes described in paragraph 17,
above.
b.

That "GEP is a real business enterprise funded

with substantial bona fide capital investment; its major purpose
is energy trading, not political activity," when in truth and in
fact, GEP had no existing business, was not funded with bona fide
capital investment, and was not engaged in energy trading, as
described in paragraph 15, above.
c.

That a contribution made by PARNAS on or about

June 25, 2018 to [Congressman-1] "was made with a business credit
which [PARNAS] reimbursed," when in truth and in fact,

card

PARNAS did not reimburse FRUMAN or any other individual for that
contribution.
THE FOREIGN NATIONAL DONOR SCHEME
20.
PARNAS,

From in or about June 2018 through April 2019, LEV

IGOR FRUMAN, DAVID CORREIA, and ANDREY KUKUSHKIN,

defendants,

and

others

known

and

unknown,

conspired

to

the
make

political donations - funded by Foreign National-1 - to politicians
and candidates for federal and State office to gain influence with
candidates as to policies that would benefit a future business
venture.

Moreover,

and

to

conceal

the

true

source

of

the

contributions and donations funded by Foreign National-1, PARNAS,
FRUMAN,

CORREIA,

and

KUKOSHKIN

10

caused

the

contributions

and

 donations to be made in the defendants' names rather than in the
name of Foreign National-1.
21.

Beginning in or around July 2018, LEV PARNAS, IGOR

FRUMAN, DAVID CORREIA, and ANDREY KUKUSHKIN, the defendants, made
plans to form a recreational marijuana business that would be
funded by Foreign National-1 and required gaining access to retail
marijuana licenses in particular States,
"Business Venture").

including Nevada

In early September 2018,

PARNAS,

(the

FRUMAN,

CORREIA, KUKUSHKIN, and Foreign National-1 met in Las Vegas, Nevada
to discuss the Business Venture.

While in Las Vegas,

PARNAS,

FRUMAN, and KUKUSHKIN also attended a political fundraiser for a
State candidate in Nevada

("Candidate-1").

Shortly after that

meeting, PARNAS, FRUMAN, CORREIA, and KUKOSHKIN began to formalize
the

Business

Venture

lobbying efforts,
involvement

in

with

Foreign

National-1

and

fund

but took steps to hide Foreign National-1's

the

Business Venture,

including

any

contributions associated with the Business Venture,
KUKUSHKIN's

their

words,

"his

Russian

roots

and

political

due to,

current

in

political

paranoia about it."
22.
FRUMAN,

DAVID

To further the Business Venture, LEV PARNAS, IGOR
CORREIA,

and

ANDREY

KUKUSHKIN,

the

defendants,

planned to use Foreign National-1 as a source of funding for
donations and contributions to State and federal candidates and
11

 politicians in Nevada, New York r

and other States to facilitate
In or about September

acquisitions of retail marijuana licenses.

and October 2018, CORREIA drafted a table of political donations
and

contributions,

which

was

subsequently

defendants and Foreign National-1.

circulated

to

the

The table described a "multi­

state license strategy" to further the Business Venture.

The

table contemplated approximately between $1 and $2 million in
political contributions to federal and State political committees.
The table also included a "funding"
transfers.

schedule of two

$500,000

Foreign National-1 then arranged for two $500,000

wires on or about September 18, 2018 and October 16, 2018 to be
sent from overseas accounts to a U.S.
controlled

by

FRUMAN

and

another

corporate bank account

individual

(the

"FRUMAN

Account 11)
23.

LEV PARNAS, IGOR FRUMAN, DAVID CORREIA, and ANDREY

KUKUSHKIN, the defendants, then used those funds transferred by
Foreign National-1, in part, to attempt to gain influence and the
appearance of influence with politicians and candidates.

For

example,

and

on

or

about October

20,

2018,

PARNAS,

FRUMAN,

KUKUSHKIN attended a campaign rally for Candidate-1 in Nevada, at
which a different Nevada State candidate was present ("Candidate2"), and sent photographs of themselves posing with Candidate-2 to
Foreign National-1.

Following that event, on or about November
12

 1, 2018, a donation in the amount of $10,000 was made to Candidate2 in FRUMAN' s name, but it was funded with funds from Foreign
National-1.

On or about November 1, 2018, a donation in the amount
A

of $10,000 was made to Candidate-1 in FRUMN's name, but it was
funded with funds from Foreign National-1.
24.

Notwithstanding the purported purpose of Business

Venture-1 and the donations described above,

LEV PARNAS, IGOR

FRUMAN, DAVID CORREIA, and ANDREY KUKUSHKIN, the defendants, did
not timely apply for a recreational marijuana license in September
2018, the then-deadline for such applications in Nevada.

On or

about October 25, 2018, KUKUSHKIN told Foreign National-1, as well
as LEV PARNAS and IGOR FRUMAN, the defendants, that they were "2
months too late to the game unless we change the rules," and noted
that they needed a particular Nevada State official, the position
for which Candidate-1 was running, to "green light to implement
this."

As noted above, FRUMAN made a $10,000 donation, funded by

Foreign National-1, to Candidate-1 on or about November l, 2018.
On or about November 4,
for

additional

funding

2018, PARNAS asked KUKUSHKIN to arrange
from

Foreign

National-1

to

make

an

additional donation to Candidate-1, to wnich KUKUSHKIN responded
that the $1 million Foreign National-1 had already provided to GEP
was "in order to cover all the donations whatsoever.n

13

 25.

Moreover,

subsequent

communications

between

Foreign National-1, and ANDREY KUKUSHKIN, LEV PARNAS, IGOR FRUMAN,
and DAVID CORREIA, the defendants, confirm the defendants' use of
foreign funds - and, in particular, funds from Foreign National-1
- to make the donations described above.

For example, on or about

October 30, 2018, Foreign National-1 wrote to PARNAS, FRUMAN, and
KUKUSHKIN that he had "fulfilled all my obligations completely,"
including

"500

licenses

[in]

[for]
these

Nevada"

in order to
KUKUSHKIN

states."

"work on obtaining
similarly

noted

in

response that "Money transferred by [Foreign National-1] to [GEP]
was to support the very specific people & states (per [FRUMAN's]
table) in order to obtain green light for licensing.

I haven't

changed any rules of our engagement and was present at all the
scheduled meetings with officials in Nevada."

Although PARNAS,

FROMAN, CORREIA, and Foreign National-1 continued to meet into the
spring of 2019, the Business Venture did not come to fruition.
COUNT ONE
(Conspiracy)
26.

From in or about March 2018 through at least in or

about November 2018,

in the Southern District of New York and

elsewhere, LEV PARNAS and IGOR FRUMAN, the defendants, knowingly
conspired with each other and with others known and unknown to:
a. Knowingly

defraud

the

United

States

by

impairing, obstructing, and defeating the lawful functions of a
14

 department or agency of the United States;

to wit, the FEC' s

function to administer federal law concerning source and amount
restrictions in federal

elections,

including the prohibitions

applicable to straw donors.
b. Knowingly and willfully make contributions to
candidates for federal office, joint fundraising committees, and
independent expenditure committees in the names of other persons,
aggregating to $25,000 and more in a calendar year, in violation
of Title 52, United States Code, Section 30122 and 30109 (a) (1) (A).
27.
illegal

In furtherance of the conspiracy and to effect the

objects

thereof,

LEV

PARNAS

and

IGOR

FRUMAN,

the

defendants, and others known and unknown, committed the following
overt acts, among others, in the Southern District of New York and
elsewhere:
a. In or
making

a

$125,000

R

about March 2018, PANAS cornrni tted to

contribution

to

Committee-3

to

attend

a

fundraising event in the Southern District of New York.
b. In or about May 2018, FRUMAN, and others known
and unknown, obtained a private loan, the proceeds of which were
used to fund the contribution made in the name of GEP to Committee1,

c. In or about May 2018, FRUMAN and PARNAS, and
others known and unknown, transferred the proceeds of FRUMAN' s
15

 private loan through multiple bank accounts - none of which were
in the name of GEP - to conceal the true source of the funds before
they were paid to Committee-1.
d. In or about May 2018, PARNAS caused a $325,000
contribution to Committee-1 to be falsely reported in the name of
GEP.
e. In or about June 2018, PARNAS made an $11,000
contribution to Committee-3 using funds that belonged to FRUMAN
and another individual.
f. In or about June 2018, PARNAS used a business
credit card registered to a credit card account, with a registered
address in the Southern District of New York, belonging to FRUMAN
and

another

individual

in

order

to

make

a

maximum

$2,700

contribution to Congressman-l's reelection campaign.
(Title 18, United States Code, Section 371, and Title 52, United
States Code, Sections 30122 and 30109(d} (1) (A) & (D))
COUNT TWO
(False Statements to the FEC)
The Grand Jury further charges:
28.

The

Grand

Jury

incorporates

the

allegations

contained in paragraphs 1 through 19 of this Indictment as though
fully set forth herein.
29.
of New

York

In or about October 2018, in the Southern District
and

elsewhere,

LEV
16

PARNAS

and

IGOR

FRUMAN,

the

 defendants, willfully and knowingly. did make materially false,
fictitious, and fraudulent statements and representations in a
matter within the jurisdiction of the executive branch of the
Government of the United States, to wit, PARNAS and FRUMAN made
the materially false statements in their affidavits submitted to
the

FEC,

described

in

paragraph

contribution to [Committee-1)

19

above,

that

''a

$325,000

. was made with GEP funds for

GEE purposes;" that "GEP is a real business enterprise funded with
substantial bona fide capital investment;

its major purpose is

energy trading, not political activity"; and that a contribution
made

by PARNAS on or

about June 25,

2018 to Congressman-1' s

campaign for reelection "was made with a business credit card . .
which [PARNAS] reimbursed."
(Title 18, United States Code, Sections l00l(a) (2) and 2)
COUNT THREE
(Falsification of Records)
The Grand Jury further charges:
30.

The

Grand

Jury

incorporates

the

allegations

contained in paragraphs 1 through 19 of this Indictment as though
fully set forth herein.
31.
of

New

ln or about October 2018, in the Southern District

York and elsewhere,

LEV PARNAS

and

IGOR

FRUMAN,

the

defendants, willfully and knowingly did falsify and make a false
entry in a record and document with the intent to impede, obstruct,
17

 or influence the investigation or proper administration of a matter
within the jurisdiction of any department or agency of the United
States, and in relation to and in contemplation of any such matter,
to wit, PARNAS and FROMAN made the materially false statements in
affidavits submitted to the FEC, described in paragraph 19 above,
including that ''a $325,000 contribution to [Committee-1] . . . was
made with GEP funds for GEP purposes;" that "GEP is a real business
enterprise funded with substantial bona fide capital investment;
its major purpose is energy trading, not political activity"; and
that a contribution made by PARNAS on or about June 25, 2018 to
Congressman-l's campaign for reelection "was made with a business
which [PARNAS] reimbursed," with the intent to

credit card .
impede,

obstruct,

or

influence

the

investigation

and

proper

administration of a matter within the jurisdiction of the FEC.
(Title 18, United States Code, Sections 1519 and 2)
COUNT FOUR
(Conspiracy)
The Grand Jury further charges:
32.

The

Grand

Jury

incorporates

the

allegations

contained in paragraphs 1 through 12 and 20 through 25 of this
Indictment as though fully set forth herein.
33.
about

April

From in or about June 2018 through at least in or
2019,

elsewhere, LEV

in

the Southern

PARNAS, IGOR

District

of

New

FRUMAN, DAVID CORREIA,
18

York and

and ANDREY

 KUKUSHKIN, the defendants, and others known and unknown, knowingly
conspired with each other and with others known and unknown to:
a.

['(nowingly

defraud

the

United

States

by

impairing, obstructing, and defeating the lawful functions of a
department or agency of the United States;

to wit,

the

FEC's

function to administer federal law concerning source and amount
restrictions

in

federal

and

State

elections,

including

the

prohibitions applicable to foreign nationals and straw donors.
b.
donations

of

Knowingly and willfully make contributions and

money,

or

express

or

implied

promises

to

make

contributions or donations, directly and indirectly, by a foreign
national

in

connection

with

federal

and

State

elections,

aggregating to $25,000 and more in a calendar year, in violation
of Title 52, United States Code, Sections 30121 and 30109(a) (1) (A).
c.
candidates

for

Knowingly and willfully make contributions to

State

and

federal

office,

joint

fundraising

committees, and independent expenditure committees in the names of
other persons, aggregating to $25,000 and more in a calendar year,
in violation of Title 52, United States Code, Section 30122 and
30109 (a) (1) (A) (D).
34.

In furtherance of the conspiracy and to effect its

illegal object, LEV PARNAS, IGOR FRUMAN, DAVID CORREIA, and ANDREY
KUKUSHKIN, the defendants, and others known and unknown, committed
19

 the following overt acts, among others, in the Southern District
of New York and elsewhere�
a.

On

or

about

September

18,

2018,

Foreign

National-1 wired $500,000 from a foreign bank account, through the
Southern District of New York, to the defendants for purposes of
making political contributions and donations.
b.

On

or

about

October

16,

2018,

Foreign

National-1 wired $500,000 from a foreign bank account, through the
Southern District of New York, to the defendants for purposes of
making political contributions and donations.
c.

On or about November 1, 2018, the defendants

used funds wired by Foreign National-1 to make maximum donations
to two political candidates for State office in Nevada.
(Title 18, United States Code, Section 371, and Title 52,
United States Code, Sections 30121, 30122 and 30109(d) (1) (A))

United States Attorney

20

 UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
- v. LEV PARNAS,
IGOR FROMAN,
DAVID CORREIA, and
ANDREY KUKOSHKIN,
Defendants.
SEALED INDICTMENT
19 Cr.
Title 18, United States Code,
Sections 371, lOOl(a) (2), 1519, and
2 and Title 52, United States Code,
Sections 30121, 30122 and
30109 (d) (1) (A) & (D)).
GEOFFREY S. BERMAN
United States Attorney