TENETMEDIA Receives Nearly $10 Million From Foreign Shell Entities

39. Chen and Donovan profited from their unregistered services to RT:a. Starting in approximately August 2023, Chen and Donovan typically submitted two invoices each month to PersonaOne on the Investor Discord Channel: one invoice for TENETMEDIA ‘s expenses, such as its payments to its commentators, and another invoice for Chen and Donovan‘s own fees and commissions. Between in or about August 2023 and in or about June 2024, Chen and Donovan invoiced UKSHELLEntityOne more than $9.3 million for TENETMEDIA ‘s expenses, which they asked to be paid to the TENETMEDIA Bank Account. Chen and Donovan also invoiced UKSHELLEntityOne more than S760,000 for their own fees and commissions, some of which they asked to be paid to CANADIAN TENET MEDIA ‘s bank account in Canada, and some of which they asked to be paid to the TENETMEDIA Bank Account in the United States.b. After Chen and Donovan transmitted their monthly invoices to PersonaOne on the Investor Discord Channel, PersonaOne typically acknowledged receipt and confirmed payment. Between in or about October 2023 and in or about August 2024, the TENETMEDIA Bank Account received approximately 30 wire transfers from foreign entities totaling approximately $9.7 million. TENETMEDIA disbursed most of these funds to its contracted commentators, including approximately $8.7 million to the production companies of Dave Rubin, Tim Pool, and Benny Johnson alone. Consistent with Chen‘s February 8, 2023 warning to PersonaOne that “it would be very hard… to recoup the costs for the likes of [Dave Rubin] and Tim Pool] based on ad revenue from web traffic or sponsors alone,” TENETMEDIA‘s foreign wire transfers far exceeded its receipts of advertising revenue. Indeed, the approximately $9.7 million that TENETMEDIA received from foreign wire transfers represented nearly 90% of all the deposits into the TENETMEDIA Bank Account from in or about October 2023 to in or about August 2024.
40. TENETMEDIA received its 30 inbound wire transfers from seven foreign entities none of which were TENETMEDIA ‘s contract counterparty, UKSHELLEntityOne. Three of the remitting entities (TurkishShellEntityOne” through “ TurkishShellEntityThree“) listed identical addresses at an office building in Istanbul, Turkey. Three of the remitting entities (“UAEShellEntityOne,” “ UAEShellEntityTwo,” “ UAEShellEntityThree“) listed different addresses in Dubai and Ras Al-Khaimah, United Arab Emirates. And the last remitting entity (“MauritiusShellEntityOne“) listed an address in Mauritius. Of the seven foreign entities, only UAEShellEntityOne, UAEShellEntityTwo, and MauritiusShellEntityOne have websites.
41. Like the website of CzechShellEntityOne, the websites of UAEShellEntityOne, UAEShellEntityTwo, and MauritiusShellEntityOne reflect seemingly odd and inconsistent information. For example, MauritiusShellEntityOne appears to maintain two websites using nearly identical domain names; one claims to supply agricultural products, and the other purports to be a digital marketing agency. As another example, the website of UAEShellEntityOne states, in part: “Our company is always happy to create and implement new projects on the market. We are ready to provide a full range of services from creating a project to bringing it to the world’s top ratings.” And the website of UAEShellEntityTwo claims to provide a random array of services ranging from “construction projects,” to “[aļnalysis of investment attractiveness,” to “yacht consultancy,” as well as the sale of textile products, electronic goods, and jewelry. The websites of UAEShellEntityOne, UAEShellEntityTwo, and MauritiusShellEntityOne make no mention of “Eduard Grigoriann,” UAEShellEntityOne (TENETMEDIA ‘s purported contract counterparty), PersonaOne, PersonaTwo, PersonaThree, Viewpoint Productions, HungarianShellEntityOne, or CzechShellEntityOne.
42. Contrary to TENETMEDIA ‘s invoices, which reflect fees for staff and commentators (as well as Chen and Donovan‘s commissions), the wire notes of many of TENETMEDIA ‘s inbound wire transfers ascribe the payments to the purchase of electronics. For example, the wire note for Turkish Shell Entity-1’s $3 18,800 wire payment to TENETMEDIA on March 1, 2024 read: *BUYING GOODS-INV.013-IPHONE 15 PRO MAX 512GB.”
43. To deliver funds into the TENETMEDIA Bank Account, each of TENETMEDIA ‘s 30 inbound international wire transfers – which totaled nearly $10 million, as set forth above utilized a correspondent bank in Manhattan, New York.[iii]
44. According to records of the FARA Unit, neither TENETMEDIA , nor Chen, nor Donovan has ever registered as a foreign agent with the Attorney General.