THE TENET MEDIA FRONT
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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
BACKGROUND ON CERTAIN INDIVIDUALS AND ENTITIES
TABLE OF CONTENTS
BACKGROUND ON CERTAIN INDIVIDUALS AND ENTITIES
- KOSTIANTYN KALASHNIKOV, ak/a “Kostya,” the defendant, is a citizen of Russia and an employee of RT. KALASHNIKOV has identified himself as the “Deputy Chief of the Digital Media Projects Department” for RT, is a member of an internal RT email distribution list reserved for “leaders” at RT, and manages multiple RT covert distribution channels in the United States, including TENETMEDIA. As set forth below, Chen introduced KALASHNIKOV to TENETMEDIA employees and affiliates as a purported outside editor, and KALASHNIKOV edited TENETMEDIA content without disclosing that he was working for RT. KALASHNIKOV also participated in an internal TENETMEDIA messaging group comprised solely of KALASHNIKOV, Chen, Donovan, and an individual purporting to act as a representative of TENETMEDIA ‘s investor, “Eduard Grigoriann,” but who was, in fact, a fake persona (“PersonaOne“), as described below. In that messaging group, KALASHNIKOV monitored discussions of, among other things, TENETMEDIA ‘s funding, hiring, and contract negotiations with Dave Rubin and Tim Pool.
- ELENA AFANASYEVA, a/k/a Lena,” the defendant, is a citizen of Russia and an employee of RT. AFANASYEVA has identified herself on social media as “a producer at RT, dealing with overseas affairs and news.” As set forth below, KALASHNIKOV introduced AFANASYEVA to TENETMEDIA staff and contributors as a member of KALASHNIKOV’s editing team, and AFANASYEVA collected information from and gave direction to TENETMEDIA personnel on behalf of RT in that covert capacity. AFANASYEVA utilized multiple fake personas at TENETMEDIA , including “Helena Shudra” and “Victoria Pesti.”
- 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.
- TENETMEDIA is a United States corporation established under the laws of Tennessee. Chen has described TENETMEDIA as the U.S. subsidiary of Chen‘s Canadian company, CANADIAN TENET MEDIA ; as set forth above, from in or about March 2021 to in or about February 2022, Chen used CANADIAN TENET MEDIA to produce content for RT pursuant to a written contract. Chen incorporated TENETMEDIA on or about January 19, 2022, and applied with the Tennessee Department of State to transact business under its current operating name, which TENETMEDIA uses on its website and social media channels, on or about May 22, 2023. On its website, TENETMEDIA describes itself as a “network of heterodox commentators that focus on Western political and cultural issues” and identifies six commentators—including Dave Rubin and Tim Pool—as its “talent.” TENETMEDIA regularly posts videos featuring these commentators, as well as other videos that do not feature the commentators, across an array of social media channels, including YouTube, TikTok, X, Facebook, Instagram, and Rumble. To support the production and publication of its videos, TENETMEDIA employs three staff producers—Producer-1, Producer-2, and a third individual (“Producer-3“)—and a purported outside editing firm staffed by, among others, KALASHNIKOV and AFANASYEVA.