THE TENET MEDIA FRONT
Thank you for visiting our special presentation about the TENET MEDIA Campaign
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
V.
KOSTIANTYN KALASHNIKOV,
a/k/a Kostya,” and
ELENA AFANASYEVA,
ak/a “Lena,”
Defendants.
SEALED INDICTMENT
24 Cr. 24CRIM 519
LAUREN CHEN
TABLE OF CONTENTS
- Chen and Donovan are foreign nationals who reside in the United States. Chen and Donovan jointly control and operate TENETMEDIA , and they are the only authorized signatories for TENETMEDIA ‘s business checking account (the “TENETMEDIA Bank Account”), which is held at a bank in the United States. Before operating TENETMEDIA for RT, as set forth below, Chen and Donovan worked directly for RT and its affiliates, including as follows:a. From in or about March 2021 to in or about February 2022, Chen created videos, posted social media content, and wrote articles pursuant to a written contract between Chen‘s Canadian company (“CANADIAN TENET MEDIA “), and RT‘s parent organization, ANO TV-Novosti. This content generally consisted of English-language social commentary. RT directly published some of Chen‘s paid work, while Chen posted other of Chen‘s paid work on Chen‘s personal accounts (without attribution to RT). For example, Chen‘s invoices reflect that Chen billed ANO TV-Novosti for approximately 217 videos, of which approximately 209 were published on Chen‘s personal YouTube channels. Chen also wrote approximately 25 opinion articles that were published on RT‘s website, at least 19 of which Chen billed to ANO TV-Novosti. None of Chen‘s articles disclosed that Chen was paid by RT to write them.b. To create content for RT pursuant to Chen‘s written contract, Chen worked with Donovan and two individual producers (“Producer-1” and “Producer-2”), who later joined TENETMEDIA . RT invited Chen to appear on RT television programming, created a dedicated page on RT‘s website identifying Chen as a “Contributor” and featuring Chen‘s articles, and provided an official letter on RT letterhead designating Chen and Donovan as essential workers” during the COVID-19 pandemic. In private correspondence, however, Chen and Donovan recognized that truthfully disclosing their affiliation with RT made it more difficult for them to do business in the United States. For example, in a July 2021 email inviting a contact to apply for a job with RT, Chen wrote that “RT’s budget is gonna be larger” but acknowledged, “I know being Russian some folks in the US aren’t too hot on them lol.” As another example, in a private exchange on the messaging platform Discord in February 2022, Producer-1 told Donovan that “when I was asking people if they wanted to interview, many said yes until I said I was with RT so I switched to saying I was just working for [Chen],” Donovan replied: “Ha, not surprised.”c. In their private correspondence, while working directly for RT pursuant to Chen‘s written contract, Chen and Donovan regularly referred to their sponsor (i.e., RT) as the “Russians.” For example, on or about May 12, 2021, Donovan messaged Chen on Discord: *So we’re billing the Russians from the corporation, right?” On or about May 22, 2021, Chen messaged Donovan on Discord: “Also, the Russians paid. So we’re good to bill them for the second month I guess.” On or about June 2, 2021, Chen messaged Donovan on Discord: “also I say we bill the russians for the last month once we’re done the extra opeds,” referring to Chen‘s paid opinion articles for RT. And on or about Jarnuary 5, 2022, Donovan messaged an acquaintance on Discord about paid leave that “[t]he Russians” had offered to Chen.d. From in or about October 2021 to in or about May 2022, separate and apart from Chen‘s contract with RT‘s parent organization, ANO-TV Novosti, Donovan also worked directly for RT and with Ruptly GmbH, RT‘s German subsidiary. Donovan‘s paid work for RT included, among other things, preparing English-language text messages describing news events. During this time, Donovan and KALASHNIKOV appear to have had overlapping business contacts: On or about May 18, 2022, a Ruptly GmbH employee sent a Russian-language email to six recipients, including Donovan and KALASHNIKOV, requesting that they send their work email addresses to gain account access to Ruptly’s website.