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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
COUNT TWO
TABLE OF CONTENTS
COUNT TWO
(Conspiracy to Commit Money Laundering)
The Grand Jury further charges:
- The allegations contained in paragraphs 1 through 44 of this Indictment are incorporated as though fully set forth herein.
- From at least in or about December 2022 through at least in or about September 2024, in the Southern District of New York, Russia, and elsewhere, KOSTIANTYN KALASHNIKOV, ak/a “Kostya,” and ELENA AFANASYEVA, ak/a “Lena,” the defendants, and others known and unknown, willfully and knowingly combined, conspired, confederated, and agreed, together and with each other, to commit money laundering, in violation of Title 18, United States Code, Section 1956(a)(2)(A).
- It was a part and an object of the conspiracy that KOSTIANTYN KALASHNIKOV, ak/a “Kostya,” and ELENA AFANASYEVA, a/k/a “Lena,” the defendants, and others known and unknown, would and did transport, transmit, and transfer, and attempt to transport, transmit, and transfer, a monctary instrument and funds from a place in the United States to and through a place outside the United States and to a place in the United States from and through a place outside the United States, with the intent to promote the carrying on of specified unlawful activity, to wit, felony violations of the Foreign Agents Registration Act, in violation of Title 18, United States Code, Section 1956(a)(2\A).
(Title 18, United States Code, Section 1956(h).)