The Grand Jury charges: INTRODUCTION

1. RT, formerly known as “Russia Today,” is a state-controlled media outlet funded and directed by the Government of Russia. After Russia invaded Ukraine in February 2022, RT was sanctioned, dropped by distributors, and ultimately forced to cease formal operations in the United States, Canada, the United Kingdom, and the European Union. In response, RT created, in the words of its editor-in-chief, an “entire empire of covert projects” designed to shape public opinion in “Western audiences.” One of RT‘s “covert projects,” as described herein, is its funding and direction of a Tennessee-based online content creation company (“TENETMEDIA “).
2. Over at least the past year, RT and its employees, including KOSTIANTYN KALASHNIKOV, a/k/a “Kostya,” and ELENA AFANASYEVA, a/ka “Lena,” the defendants, have deployed nearly $10 million, laundered through a network of foreign shell entities, to covertly fund and direct TENETMEDIA. TENETMEDIA publishes English-language videos on multiple social media channels, including TikTok, Instagram, X, and YouTube. Using multiple fake personas, AFANASYEVA edited, posted, and directed the posting by TENETMEDIA of hundreds of videos. Many of the videos published by TENETMEDIA contain commentary on events and issues in the United States, such as immigration, inflation, and other topics related to domestic and foreign policy. While the views expressed in the videos are not uniform, the subject matter and content of the videos are often consistent with the Government of Russia’s interest in amplifying U.S. domestic divisions in order to weaken U.S. opposition to core Government of Russia interests, such as its ongoing war in Ukraine.
3. Since publicly launching in or about November 2023, TENETMEDIA has posted nearly 2,000 videos that have garnered more than 16 million views on YouTube alone. TENETMEDIA never disclosed to its viewers that it was funded and directed by RT. Nor did TENETMEDIA or its two founders and principal executives (“Founder One (Lauren Chen)” and “Founder Two (Liam Donovan)“) register with the Attorney General as an agent of a foreign principal, as required by law.
4. KALASHNIKOV, AFANASYEVA, Chen, and Donovan also worked together to deceive two U.S. online commentators (“Dave Rubin” and “Tim Pool“), who respectively have over 2.4 million and 1.3 million YouTube subscribers. Chen and Donovan contracted with Dave Rubin and Tim Pool to produce videos, using Dave Rubin‘s and Tim Pool‘s own names and leveraging their existing audiences, for license and publication by TENETMEDIA . KALASHNIKOV, AFANASYEVA, Chen, and Donovan worked together to mask TENETMEDIA‘s true source of funding – ie., RT – by falsely portraying to Dave Rubin and Tim Pool that TENETMEDIA was sponsored by a private investor named “Eduard Grigoriann.” In truth and in fact, Grigoriann was a fictional persona. For example, during contract negotiations, Dave Rubin requested that Chen provide a profile or article on “Eduard Grigoriann.” In response, Chen sent Dave Rubin a one-page profile, provided to Chen by another fictional persona purporting to represent “Eduard Grigoriann,” falsely describing “Eduard Grigoriann” as an accomnplished finance professional” who had held various positions in Brussels and France at a multinational bank (““Bank-1”), including “Director of Private Banking [D]ivision and Wealth Management.” After receiving the fictitious profile, Dave Rubin agreed to work with TENETMEDIA and produced approximately 130 videos that were published on TENETMEDIA ‘s platform.

BACKGROUND ON RUSSIAN INFLUENCE OPERATIONS

BACKGROUND ON CERTAIN INDIVIDUALS AND ENTITIES

BACKGROUND ON THE FOREIGN AGENTS REGISTRATION ACT

RT’S COVERT OPERATIONS THROUGH TENETMEDIA

The Fake “Eduard Grigoriann'” Profile

Chen and Donovan Negotiate The U.S. Company-1 Contract with the “Russians”

Chen and Donovan Await Payment from Moscow

KALASHNIKOV and AFANASYEVA Begin Operations at TENETMEDIA

AFANASYEVA Steers TENETMEDIA Marketing and Messaging for RT

TENETMEDIA Receives Nearly $10 Million From Foreign Shell Entities

STATUTORY ALLEGATIONS COUNT ONE
(Conspiracy to Violate the Foreign Agents Registration Act)
Overt Acts

COUNT TWO
(Conspiracy to Commit Money Laundering)

FORFEITURE ALLEGATIONS