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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
STATUTORY ALLEGATIONS: COUNT ONE
TABLE OF CONTENTS
STATUTORY ALLEGATIONS
COUNT ONE
(Conspiracy to Violate the Foreign Agents Registration Act)
- 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, a/k/a “Kostya,” and ELENA AFANASYEVA, ak/a Lena,” the defendants, and others known and unknown, knowingly and intentionally did combine, conspire, confederate, and agree, together and with each other, to commit an offense against the United States, to wit, to knowingly and willfully act and cause TENETMEDIA , Chen, and Donovan to act as agents of foreign principals without registering with the Attorney General, in violation of Title 22, United States Code, Sections 612 and 618.
- It was a part and an object of the conspiracy that KOSTIANTYN KALASHNIKOV, and ELENA AFANASYEVA, a/k/a “Lena,” the defendants, and others known and unknown, would and did knowingly and willfully act and cause TENETMEDIA , Chen, and Donovan to act as agents of foreign principals without registering with the Attorney General, as required by law, in violation of Title 22, United States Code, Sections 612 and 618.
Overt Acts
- In furtherance of the conspiracy and to effect the illegal object thereof, KOSTIANTYN KALASHNIKOV, akla “Kostya,” and ELENA AFANASYEVA, a/k/a Lena, the defendants, and others known and unknown, committed the following overt acts, among others, in the Southern District of New York and elsewhere:a. In or about August 2023, KALASHNIKOV added AFANASYEVA to the TENETMEDIA Discord Server.b. In or about 2024, AFANASYVEA circulated to TENETMEDIA staff approximately 841 video clips, which were routinely posted onto TENETMEDIA ‘s social media channels.c. In or about June 2024, Chen authorized AFANASYEVA and KALASHNIKOV to post content directly on TENETMEDIA ‘s platform.
d. Between in or about October 2023 and in or about August 2024, members of the conspiracy caused TENETMEDIA to receive approximately 30 international wire transfers from foreign shell entities in furtherance of the conspiracy, each of which was processed by a correspondent bank in the Southern District of New York.
(Title 18, United States Code, Section 371.)