Case 1:22-cr-00518-PKC Document 1 Filed 09/28/22 Page 1 of 31

ORIGINAL
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
- - - - - X

UNITED STATES OF AMERICA SEALED INDICTMENT

- v. - Sl 22 Cr .

OLEG VLADIMIROVICH DERIPASKA ,

a/k/a " Oleg Mukhamedshin , " ~
OLGA SHRIKI , C' , _'. -- ,.
NATALIA MIKHAYLOVNA BARDAKOVA , '-J -~
a/k/a "Natalya Mikhaylovna Bardakova , "
and
EKATERINA OLEGOVNA VORONINA ,
~
CRIM 518
a/k/a " Ekaterina Lobanova , "

Defendants.

- - - X

The Grand Jury charges :

Overview

1. On or about April 6, 2018, the United States

government imposed sanctions on Russian citizen OLEG VLADIMIROVICH

DERIPASKA , a/k/a " Oleg Mukhamedshin ," the defendant, and a company

he controlled called " Basic Element." Among other things , those

sanctions prohibited making any contribution or provision of

funds , goods , or services by , to , or for the benefit of any person

whose property and interests in property are blocked , and receiving

any contribution or provision of funds , goods , or services from

any such person . Yet for over four years afterwards , and in
I

violation of those sanctions , DERIPASKA continued to retain OLGA

SHRIKI and NATALIA MIKHAYLOVNA BARDAKOVA , a/k / a "Natalya

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Mikhaylovna Bardakova ," the defendants , to provide hundreds of

thousands of dollars worth of services for his benefit in the

United States . For example, in or about 2019 , SHRIKI facilitated

for DERIPASKA's benefit the sale of a music studio in California

for approximately $3 , 078 , 787 . Then, in or about 2020 , SHRIKI and

BARDAKOVA helped EKATERINA OLEGOVNA VORONINA , a/k/a "Ekaterina

Lobanova ," the defendant , travel from Russia to the United States,

so she could give birth to DERIPASKA's and VORONINA 's child in the

United States . SHRIKI orchestrated hundreds of thousands of

dollars worth of U. S . medical care, housing, childcare , and other

logistics to aid DERIPASKA ' s and VORONINA's efforts to have

VORONINA give birth in the United States, which resulted in the

child receiving U. S . citizenship. Later, in or about 2022 , at

DERIPASKA ' s further behest and for his further benefit , SHRIKI and

BARDAKOVA attempted to facilitate VORONINA ' s return to the United

States to give birth to DERIPASKA ' s and VORONINA ' s second child .

Additionally , between in or about 2018 and in or about 2020 ,

DERIPASKA routinely had SHRIKI and BARDAKOVA purchase various

products in the United States for DERIPASKA's personal use and as

gifts for others on his behalf . During the course of law

enforcement efforts to investigat e the scheme , SHRIKI destroyed

evidence , while BARDAKOVA and VORONINA made false statements to

U. S. government officers .

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The Defendants and Relevan t Entities

2. OLEG VLADIMIROVICH DERIPASKA , a/k / a " Oleg

Mukhamedshin ," the defendant, is a Russian national . At all times

relevant to this Indictment , DERIPASKA was the owner and

controller , directly or indirectly , of Basic Element Limited

("Basic Element " ) , a private investment and management company for

DERIPASKA ' s various business interests . As set forth in greater

detail below , on or about April 6, 2018 , the United States

Department of the Treasury ' s Office of Foreign Assets Control

(" OFAC " ) designated DERIPASKA as a Specially Designated National

(" SON " ) , i n connection with its finding that the actions of the

Government of the Russ i an Federation with respect to Ukraine

constitute an unusual and extraordinary threat to the national

secur i ty and foreign policy of the United States (the "OFAC

Sanctions " ) . I n so de si gnating DERIPASKA , OFAC explained that

DERIPASKA was sanctioned for having acted or purported to act for

or on beha l f of , direct l y or indirectly , a senior official of the

Government of the Russ i an Federation , as well as for operating in

the energy sector of the Russian Federation economy . On or about

the same date , OFAC a l so designated Basic Element . At all times

relevant to this In d i ctment , several properties original l y

purchased by DERIPASKA i n the United States , including properties

located at 2501 30th Street NW , Washington D.C .; 12 Gay Street ,

New York , New York ; and 11 East 64th Street , New York , New York

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(collectively, the "U.S. Properties ") , were maintained on his

behalf.

3. OLGA SHRIKI, the defendant, is a naturalized United

States citizen living in the United States. At all times relevant

to this Indictment, SHRIKI provided services to, and for the

benefit of, OLEG VLADIMIROVICH DERIPASKA, a/k/a "Oleg

Mukhamedshin," the defendant, including, for a period of time, as

an employee of DERIPASKA, or entities controlled by DERIPASKA.

Between in or about April 2018 and in or about 2021, despite

knowledge of the OFAC Sanctions imposed on DERIPASKA, SHRIKI

continued to provide services to, and for the benefit of, DERIPASKA

and received funds from entities controlled by DERIPASKA,

including in connection with facilitating the sale of one of

DERIPASKA' s holdings in the United States, gift deliveries on

behalf of DERIPASKA in the United States, and the birth of

DERIPASKA's first child in the United States.

4. NATALIA MIKHAYLOVNA BARDAKOVA, a/k/a "Natalya

Mikhaylovna Bardakova," the defendant, is a Russian national. At

all times relevant to this Indictment, BARDAKOVA worked for OLEG

VLADMIROVICH DERIPASKA, a/k/a "Oleg Mukhamedshin," the defendant,

or entities controlled by DERIPASKA, and otherwise provided

services to, and for the benefit of, DERIPASKA. Between in or

about April 2018 and in or about 2022, despite knowledge of the

OFAC Sanctions imposed on DERIPASKA, BARDAKOVA continued to

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provide services to and for the benefit of DERIPASKA , including in

connection with gift deliveries on behalf of DERIPASKA in the

United States, the birth of DERIPASKA's first child in the United

States, and the planned birth of DERIPASKA's second child in the

United States .

5. EKATERINA OLEGOVNA VORONINA, a/k/a "Ekaterina

Lobanova," the defendant, is a Russian national. Since in or about

2015 , VORONINA has been in an intimate relationship with OLEG

VLADIMIROVICH DERIPASKA, a/k/a "Oleg Mukhamedshin," the defendant.

Between in or about July 2020 and in or about December 2020,

VORONINA flew on a private jet funded by DERIPASKA to the United

States so that she could give birth in the United States to

DERIPASKA's child, who thereby became a U.S . citizen. In doing

so, VORONINA and DERIPASKA engaged OLGA SHRIKI and NATALIA

MIKHAYLOVNA BARDAKOVA , a/k/a "Natalya Mikhaylovna Bardakova," the

defendants , to undertake hundreds of thousands of dollars in

transactions in furtherance of the scheme and in violation of U.S.

sanctions. Later , in or about 2022, VORONINA and DERIPASKA agreed

to and did attempt to re-engage SHRIKI in connection with the

planned U. S. birth of their second child, but ultimately engaged

BARDAKOVA instead. In or about June 2022, VORONINA flew to the

United States on another private jet funded by DERIPASKA. Upon

arrival, VORONINA made multiple false statements to, and tried to

mislead , officers of the Department of Homeland Security, in an

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attempt to prevent the officers from learning DERIPASKA's name and

to conceal the roles of DERIPASKA, SHRIKI, and BARDAKOVA in

hundreds of thousands of dollars of illegal transactions in

violation of U.S. sanctions. VORONINA was refused entry to the

United States .

6. The U. S. Properties were purchased by OLEG

VLADMIROVICH DERIPASKA , a/k/a "Oleg Mukhamedshin , " the defendant,

between in or about 2005 and in or about 2008. Collectively worth

tens of millions of dollars , the U.S. properties were at all

relevant times managed by a company named Gracetown , Inc. Since

OFAC imposed sanctions on DERIPASKA on or about April 6, 2018 ,

individuals and/or entities controlled by DERIPASKA transmitted

millions of dollars to bank accounts held by Gracetown Inc . in

Manhattan for the upkeep of the U. S. Properties and for the benefit

of DERIPASKA . Gracetown Inc . used the funds to pay for various

expenses associated with the U. S . Properties , including staff

salaries , property taxes , and other services , and to maintain the

U. S . Properties .

The International Emergency Economic Powers Act and the Relevant

Sanctions Orders and Regulations

7. The International Emergency Ec:onomic Powers Act

("IEEPA") , codified at Title 50 , United States Code , Sections 1701-

1708 , confers upon the President authority to deal with unusual

and extraordinary threats to the national security and foreign

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policy of the United States. Section 1705 provides , in part, that

" [i] t shall be unlawful for a person to violate , attempt to

violate , conspire to violate , or cause a violation of any license,

order , regulation , or prohibition issued under this chapter. " 50

U. S.C . § 1705(a).

8. In 2014 , pursuant to his authorities under the

IEEPA , the President issued Executive Order 13660 , which declared

a national emergency with respect to the situation in Ukraine . To

address this national emergency , the President blocked all

property and interest in property that were then or thereafter

came within the United States or that were then or thereafter came

within the possession or control of any United States person , of

individuals determined by the Secretary of the Treasury to meet

one or more enumerated criteria . These criteria include , but are

not l imit ed to, i ndiv iduals determined to be responsible for or

complicit in , or who engage in , actions or po li cies that threaten

the peace, security, stability , sovereignty , or territorial

integrity of Ukraine ; or who materially assist , sponsor , or provide

financial , material , or technological support for, or goods or

services to , individuals or entities engaging in such activities.

Executive Order 13660 prohibits , among other things , the making of

any contribution or provision of funds , goods , or services by , to ,

or for the benefit of any person whose property and interests in

property are blocked , and the receipt of any contribution or

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provision of funds , goods , or services from any such person.

9. The national emergency declared in Executive Order

13660 with respect to the situation in Ukraine has remained in

continuous effect since 2014, and was most recently continued on

March 2 , 2021 .

10 . The President on multiple occasions expanded the

scope of the national emergency declared in Executive Order 13660 ,

including through : (1) Executive Order 13661 , issued on March 16 ,

2014 , which addresses the actions and policies of the Russian

Federation with respect to Ukraine , including the deployment of

Russian Federation military forces in the Crimea region of Ukraine;

and (2) Executive Order 13662 , issued on March 20, 2014, which

addresses the actions and policies of the Government of the Russian

Federat i on , including its purported annexation of Crimea and its

use of fo r ce in Ukraine . Executive Orders 13660 , 13661 , and 13662

are collectively referred to as the " Ukraine - Related Executive

Orders ." Additionally , Executive Order 14065 , issued on February

21 , 2022 , expanded the scope of the national emergency , finding

that the Russian Federation ' s purported recognition of the so -

called Donetsk People ' s Republic or Luhansk People ' s Republic

reg i ons of Ukraine contradicts Russia ' s commitments under the

Minsk Ag r eements and further threatens the peace , stability ,

sovereignty , and territorial integrity of Ukraine .

11 . The Ukraine-Related Executive Orders authorized the

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Secretary of the Treasury to take such actions , including the

promulgation of rules and regulations , and to employ all powers

granted to the President under the IEEPA , as may be necessary to

carry out the purposes of those orders . The Ukraine-Related

Executive Orders further authorized the Secretary of the Treasury

to redelegate any of the s e functions to other offices and agencies

of the Uni t ed States Government .

12 . To implement the Ukraine - Related Executive Orders ,

OFAC issued certain Ukraine-Related Sanctions Regulations . These

regulations incorporate by reference the definition of prohibited

tra n sact i ons set forth in the Ukraine - Re l ated Executive Orders .

See 31 C . F . R. § 589.201. The regulations also provide that ,the

names of persons designated directly by the Ukraine - Related

Executive Orders , or by OFAC pursuant to the Ukraine - Related

Executive Orders , whose property and interests are therefore

b l ocked , a r e publ i shed in the Federal Register and incorporated

into the SDN and Blocked Persons List (the " SDN List " ) , which is

published on OFAC ' s publ i c website . See 31 C . F . R . § 589.201 n.1 .

13 . According to the Ukraine - Related Sanctions

Regula t ions , a person whose property and interest in property is

b l ocke d pu r suant to the Ukraine - Related Executive Orders is

treated as having an interest in all property and interests in

propert y of any entity in which the person owns , directly or

indirect l y , a 50 percent or greater interest . See 31 C. F . R .

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§ 589.406 . Accordingly, such an entity is deemed a person whose

property and interests in property are blocked, regardless of

whether the name of the entity is incorporated into OFAC ' s SON

List . See 31 C.F.R. § 589.406.

lL On or about April 6, 2018, OFAC designated OLEG

VLADIMIROVICH DERIPASKA, a/k/a "Oleg Mukhamedshin," the defendant,

as an SON pursuant to the Ukraine - Related Exe cu ti ve Orders. In

particular , OFAC designated DERIPASKA pursuant to Executive Order

13661 for having acted or purported to act for or on behalf of ,

directly or indirectly, . a senior official of the Government of the

Russian Federation, as well as pursuant Executive Order 13662 for

operating in the energy sector of the Russian Federation economy .

On or about the same date , OFAC also designated Basic Element for

being owned or controlled by , directly or indirectly , DERIPASKA .

As OFAC explained, Basic Element is a private investment and

management company for DERIPASKA ' s var ious business interests .

SHRIKI and BARDAKOVA's Work for DERIPASKA Post-Sanctions

15 . Between in or about 2013 and in or about 2018 , OLGA

SHRIKI , the defendant , lived in the United States and worked for

Basic Element in its Manhattan office . Following OFAC ' s

des i gnation of OLEG VLADIMIROVICH DERIPASKA , a/k/a "Oleg

Mukhamedshin," the defendant , and Basic Element on or about April

6 , 2018 , SHRIKI helped to wind down the Manhattan off ice of Basic

Element, and continued to work for the benefit of DERIPASKA . On

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or about July 13 , 2018 , SHRIKI emailed herself a document entitled

" Olga Shriki Functional Responsibilities May 2018. docx," which

listed SHRIKI as a "Trusted contact for any assignments by OVD".

"OVD" are DERIPASKA ' s initials . The document also states that

SHRIKI ' s job responsibilities included "[s]earching for and

locating necessary items as requested by OVD or his team members" .

16 . In or about July 2018 , after OFAC designated OLEG

VLADIMIROVICH DERIPASKA , a/k/a " Oleg Mukhamedshin," the defendant ,

as an SDN , OLGA SHRIKI , the defendant , created a consulting

business named Global Consulting Services LLC ( "Global

Consulting " ) . Through Global Consulting , SHRIKI coordinated with

NATALIA MIKHAYLOVNA BARDAKOVA , a/k/a "Natalya Mikhaylovna

Bardakova ," the defendant , to continue providing services to and

for the bene f it of DERIPASKA and to continue receiving funds from

DERIPASKA or entit i es controlled by DERIPASKA .

17 . During the relevant period , OLGA SHRIKI , the

defendant , had knowledge of the OFAC sanctions imposed on OLEG

VLADIMIROVICH DERIPASKA , a/k/a " Oleg Mukhamedshin , " the defendant .

For example :

a. On or about April 6, 2018 , SHRIKI

received a text message with a link to the U. S . Treasury

Department ' s announcement of the imposition of sanctions on

DERIPASKA . SHRIKI replied , in part and substance , that the

sanctions were like l y to impact her work .

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b. On or about January 18 , 2020 , SHRIKI had

a conversation with an individual . SHRIKI made an audio recording

of the conversation , during which she explained to the individual ,

in part , that , "My clients are from [Moscow] but right now, because

of the sanctions I can ' t work with some of them. And that was a

very influential relationship So as a United States citizen

I can ' t work with somebody , it ' s against the law . . . It ' s United

States law . You can ' t work for people who are under United States

sanctions . So I don ' t. So if someone ' s on the blocked

list , you can ' t. " Despite this knowledge , and subsequent to this

conversation , SHRIKI received over a hundred thousand dollars to

provide services to and for the benefit of DERIPASKA.

18 . During the relevant period , NATALIA MIKHAYLOVNA

BARDAKOVA , a/k/a " Natalya Mikhaylovna Bardakova , " the defendant,

had knowledge of the sanctions imposed on DERIPASKA . For example :

a. On or about December 10 , 2018 , BARDAKOVA

acces se d a news article discussing efforts to " save Russian

oligarch Ol eg Deripaska ' s empire from the clutches of the US Office

of Foreign Assets Control ."

b. On or about September 1, 2020 , BARDAKOVA

accessed a document called " List of Sanctioned Companies " 1 that

included " EN+" , with the notation " Linked to Deripaska , Oleg

1 Documents and communications in Russian cited in this Indictment

have been translated into English as draft translations.

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Vladimirovich ", and " Agroholding Kuban ", with the notation "part

of group ' Basic Element ' of 0. Deripaska."

The Sanctions Violations

19 . From at least in or about 2019 through in or about

2022 , OLEG VLADIMIROVICH DERIPASKA , a/k/a "Oleg Mukhamedshin," the

defendant , employed OLGA SHRIKI and NATALIA MIKHAYLOVNA BARDAKOVA ,

a/k/a " Natalya Mikhaylovna Bardakova ," the defendants , to provide

funds , goods , and services to and for the benefit of DERIPASKA and

companies owned and controlled by DERIPASKA , and to receive funds ,

goods , and services from DERIPASKA. DERIPASKA continued to receive

funds , goods , and services from SHRIKI , assisted by BARDAKOVA , and

to prov i de funds , goods , and services to SHRIKI and other United

States persons by and through BARDAKOVA , after being designated as

an SON in or about April 2018 and in violation of the Ukraine -

Related Executive Orders and Ukraine - Related Sanctions

Regulations , unt i l at least June 2022 . In particular , DERIPASKA ,

the defendant , used SHRIKI ' s and BARDAKOVA ' s assistance to engage

in severa l endeavors in the United States in violation of the

Ukraine - Related Executive Orders and Ukraine - Related Sanctions

Regulations , including :

a. In or about December 2019 , SHRIKI

facilitated the sale of a music studio in Burbank , California (the

"Music Studio " ) for . the benefit of DERIPASKA , who owned and

controlled the Music Studio through a series of corporate entities .

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SHRIKI then attempted to expatriate the proceeds of the sale,

approximately $3 , 078 , 787 , from an account at Wells Fargo Bank,

held in the name of Ocean Studios LLC , to a bank account in Russia

belonging to a DERIPASKA-controlled entity.

b. Between in or about May 2018 and in or

about 2020 , BARDAKOVA instructed SHRIKI to purchase and send flower

and gift deliveries on behalf of DERIPASKA to DERIPASKA's social

contacts in the United States and Canada. The deliveries included,

among others, two Easter gift deliveries to a U.S. television host,

two flower deliveries to a then-former Canadian Parliament member ,

and two flower deliveries in 2020 to EKATERINA OLEGOVNA VORONINA,

a/k/a "Ekat erina Lobanova," the defendant , while she was in the

United States to give birth to DERIPASKA ' s child. The flower and

gift deliveries were often accompanied by notes that identified

DERIPASKA as the gifter , such as "Wishing you and your family a

beautiful Easter Holiday . Oleg D." or "Best Wishes On Your

Birthday . Oleg D."

c. In or about 2 02 0 , BARDAKOVA instructed

SHRIKI to purchase i terns in the United States for DERIPASKA' s

personal use , such as iPh ones and clothing . In or about December

2 02 0 , after VORONINA transported the purchased i terns back to

Russia , BARDAKOVA wrote to SHRIKI inquiring about the iPhones

SHRIKI had purchased for DERIPASKA, "I couldn't find the boss's

phones . Does [VORONINA] have them? " SHRIKI confirmed that

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VORONINA had packed them with her personal belongings .

Additionally , on or about December 9, 2020 , DERIPASKA and BARDAKOVA

transmitted between themselves an image of a man photographing

himself below the neck in a blue long - sleeved shirt. Approximately

24 minutes later , BARDAKOVA sent the same image to SHRIKI with the

message , " Olga , American Eagle wants a lot of units . " In a

separate message on another occasion , BARDAKOVA sent SHRIKI , who

was then living in the United States , an image of an American Eagle

branded t - shirt , writing " OV wants these t-shirts , 10 counts , size

XL . Could you find them and urgently send them? "

d. In or about 2020 , as the pandemic began

and people were worried about the state of hospital care in some

areas , DERIPASKA and VORONINA agreed that their child should be

born in the United States. DERIPASKA , by and through BARDAKOVA ,

SHRIKI , and other assoc i ates , organized and funded this endeavor ,

wh i ch entailed over $300 , 000 in transactions in the United States.

In or about March 2020 , DERIPASKA counseled VORONINA on obtaining

a U. S . visa , including by telling her to be " careful " ahead of an

interview by U. S . immigration authorities . VORONINA thereafter

applied for and obtained a U.S . visa for a purported ten - day

tourism visit without disclosing her intent to travel and stay in

the United States for approximately six months to give birth to

DERIPASKA ' s child .

e. Between in or about July 2020 and

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December 2020 , SHRIKI and BARDAKOVA , working at the direction and

for the benefit of DERIPASKA and VORONINA , facilitated

arrangements for VORONINA to give birth to DERIPASKA ' s child in

the United States. SHRIKI and BARDAKOVA coordinated with various

companies and individuals to provide , among other arrangements ,

(1) registration at the hospital where VORONINA gave birth , (2)

obstetrical care while VORONINA was in Los Angeles , California,

(3) rental of a two - story penthouse apartment in Beverly Hills,

California , where VORONINA stayed for approximately six months

(the " Beverly Hills Penthouse " ) , (4) childcare in the form of at

least five nannies and a housekeeper , (5) cord blood and placenta

preservation , and (6) VORONINA ' s arrival and departure from the

United States on a private jet .

f . DERIPASKA approved and provided funding

for these arrangements related to the birth in 2020 of his child

in the United St ates . As coordinated by BARDAKOVA on behalf of

DERIPASKA , SHR I KI received over $170 , 000 in payments to her Global

Cons u l t i n g bank account at a U. S . financial institution. SHRIKI

used some of these funds to pay for , or reimburse herself for the

payment of , r ent for the Beverly Hills Penthouse , medical

providers , nannies , transportation , and other expenses related to

DERIPASKA ' s child , for the benefit of DERIPASKA and VORONINA .

Using funds from her personal bank account in Russia , BARDAKOVA

separately caused thousands of dollars of payments to various

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service providers for the benefit of DERIPASKA and VORONINA in the

United States.

g. DERIPASKA obtained reports from

BARDAKOVA and VORONINA about SHRIKI's services to facilitate the

birth of his child. For example, on or about July 2 , 2020 , VORONINA

arrived in Los Angeles on a private jet approved by DERIPASKA and

sent DERIPASKA photos of the Beverly Hills Penthouse SHRIKI and

BARDAKOVA had rented for her to stay while in the United States.

The next day, on or about July 3 , 2020, VORONINA sent DERIPASKA a

message , stating , in part , "Now Olga and I are going to drive to

see where the clinic is and get a local telephone ." DERIPASKA

acknowledged the message. Later , on or about the same day, SHRIKI

sent an audio message to BARDAKOVA reporting on her assistance to

VORONINA , including the errands VORONINA had described to

DERIPASKA . On or about July 4 , 2020 , BARDAKOVA replied to SHRIKI

with an audio message stating, in part , "Listen, it ' s so cool that

you sorted out just about everything with her . That ' s just

excellent , really wonderful , really good. The dad is happy . I

told him that you are with her , that everything _is wonderful,

great , that you guys will have an appointment with a doctor there,

and he goes , ' Well , good , good . Yes. Keep me informed.'" SHRIKI

replied to BARDAKOVA's message , in part, "Go ahead and praise me

there ."

h. DERIPASKA ' s child was born in August

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2020 , in Los Angeles, California, obtaining U.S. citizenship by

birth. DERIPASKA arranged for SHRIKI , BARDAKOVA , and VORONINA to

obtain a U.S . passport and U.S . birth certificate for DERIPASKA's

child. On or about the date of the child 's birth, SHRIKI left an

audio message for BARDAKOVA, discussing that the child 's last name

on the birth certificate would be differentiated from the father's

last name by asking whether VORONINA had been "prepared" that "the

last name will be different?" SHRIKI also stated that VORONINA

had already ordered some custom-made i terns for the baby with

initials embroidered . As evidenced in SHRIKI's emails , SHRIKI had

in fact purchased personalized baby clothes and a picture frame to

be sent to the Beverly Hills Penthouse with inscriptions including

variations of the child ' s initials and name. Ultimately, on the

child ' s birth certificate , VORONINA omitted the name of the father ,

DERIPASKA , but spelled the child's last name using a variation of

DERIPASKA ' s surname with a couple of the letters changed and gave

the child a middle name that makes clear the father is DERIPASKA.

i. In or about 2022, DERIPASKA and VORONINA

decided to have VORONINA give birth to their second child in the

United States , the result of which would be that the second child

also would have United States citizenship . DERIPASKA once again

and in violation of U. S. sanctions authorized transactions related

to this endeavor , which included over $400,000 in expenses related

to a private charter flight for VORONINA and those accompanying

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her from Russia to the United States , a six- month pre - paid house

rental in Beverly Hills , and additional pre-paid medical and other

expenses .

j . On or about April 12 , 2022 , VORONINA

wrote to DERIPASKA inquiring whether she could tell another

DERIPASKA employee "to connect with Olga Shriki in connection with

our trip? " DERIPASKA replied to VORONINA , "Of course ." However ,

when VORONINA asked SHRIKI to organize everything as was done in

connection with the birth of DERIPASKA ' s first child, including

" doctor , clinic , apartment , everything maximally the same , " SHRIKI

expressed that she was busy with other ful l time work . Instead ,

SHRIKI advised BARDAKOVA on these tasks , sending BARDAKOVA the

addresses of the hospital used for VORONINA ' s first birth , the

apartment address , the name of the doctor , and advice on how to

use a rea l tor . BARDAKOVA then travelled to the United States and

coordinated the arrangements for VORONINA ' s planned stay ,

includ i ng a charter f li ght for VORONINA to fly into the United

States , a rented house in Beverly Hills , and potential appointments

with the same obstetrician , all for the benefit of DERIPASKA and

VORONINA .

k. On or about May 13 , 2022 , BARDAKOVA

t raveled to Los Ange l es t o tour houses potentially to rent for

VORONINA and for the benefit of DERIPASKA . On or about May 18 ,

2022 , VORONINA forwarded DERIPASKA a message from BARDAKOVA with

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a video of a potential rental. BARDAKOVA ' s message stated , in

part, "if OV agrees , then I would vote for this house as it meets

most of the requirements" . VORONINA noted to DERIPASKA , "Natali ya

found it, but very expensive, we will keep looking" . DERIPASKA

responded , "now will try to negotiate" , prompting a "thank you "

from VORONINA.

l. On or about May 20, BARDAKOVA sent

VORONINA a link for a house rental listing in Beverly Hills.

VORONINA sent the link to DERIPASKA, stating it was a better option

"but they are not moving on price and have two other families ready

to rent . How does it look to you?" DERIPASKA responded, "Will

inquire ." BARDAKOVA then finalized the agreement for the house

rental . On or about May 21, 2022 , VORONINA forwarded DERIPASKA a

message advising , in part , "Our application was selected and

confirmed . Now deciding questions of payment ". DERIPASKA

responded , "Hooray". BARDAKOVA then coordinated approximately

$229 , 000 in payments to intermediaries in Russia in order to have

a U.S . - based entity fund the cost of the Beverly Hills house

rental .

m. That same month, in or about May 2020 ,

DERIPASKA and BARDAKOVA arranged for VORONINA 's travel on a private

jet from Russia to Los Angeles so that she could arrive in the

United States in time to give birth to DERIPASKA ' s and VORONINA's

second child and for their benefit. On or about May 25 , 2022 ,

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BARDAKOVA sent a message to VORONINA, stating, in part , "The Chief

confirmed boarding for June 1. Let's decide on the outgoing flight

from Moscow . From Sheremetyevo (so as not to go far) at 10, 11,

12?" VORONINA selected the noon flight time and then asked, "Is

the 1st necessary? And what's the plan for the flight times and

connections" . BARDAKOVA replied , in part, "Oleg Vladimirovich so

instructed. Insisting on flight out . Planes very hard to confirm

now ." VORONINA forwarded BARDAKOVA' s message to DERIPASKA and

added, " We will fly when you tell us to". DERIPASKA replied,

"Looks like flight on the 1st will happen." On June 1, 2022, a

Cyprus aviation charter service paid a Swiss charter company

approximately 160 , 000 Euros for a private jet to ferry VORONINA ,

DERIPASKA ' s and VORONINA ' s first child , and a nanny from Istanbul

to Los Angeles . On or about June 1, 2022, VORONINA in fact traveled

to Los Angeles on the private jet .

SHRIKI's Deletion of Records and Obstruction of Justice

20. On or about September 23, 2020 , a federal grand

jury sitting in the Southern District of New York issued a subpoena

to OLGA SHRIKI , the defendant , seeking records pertaining to the

grand jury ' s investigation into OLEG VLADIMIROVICH DERIPASKA,

a/k/a "Oleg Mukhamedshin ," the defendant, and his real estate

holdings in the United States (the "Grand Jury Subpoena " ) . SHRIKI

failed to produce and deleted several categories of records

responsive to the Grand Jury Subpoena. For example, SHRIKI failed

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 Case 1:22-cr-00518-PKC Document 1 Filed 09/28/22 Page 22 of 31

to produce certain communications regarding facilitating the sale

of the Music Studio and making purchases for DERIPASKA . SHRIKI

also deleted records responsive to the Grand Jury Subpoena ,

including text messages between SHRIKI and NATALIA MIKHAYLOVNA

BARDAKOVA , a/k/a "Natalya Mikhaylovna Bardakova ," the defendant ,

coordinating the delivery of the Easter flowers and gifts to the

U.S . te l evision host , voice messages between SHRIKI and BARDAKOVA

discussing SHRIKI ' s assistance to EKATERINA OLEGOVNA VORONINA ,

a/k/a " Ekaterina Lobanova ," the defendant , and screenshots of bank

tra n sfers shared between SHRIKI and BARDAKOVA pertaining to

funding for Global Consulting to pay for VORONINA ' s expenses while

in the United States . On or about June 15 , 2021 , after an Assistant

United States Attorney notified SHRIKI ' s attorney that SHRIKI had

not produced all records required by the Grand J u ry Subpoena ,

SHRI KI conducted web searches on her phone for "if the client

withholds information about sanctions list ."

VORONINA's and BARDAKOVA's False Statements

21 . On or about June 2, 2022 , EKATERINA OLEGOVNA

VORONINA , a/k/a " Ekater i na Lobanova ," the defendant , arrived in

Los Angeles on a private jet with the first child she had with

OLEG VLADIMIROVICH DERIPASKA , a/k/a "Oleg Mukhamedshin , " the

defe n da nt. Upon arr i val , off ice rs from the U. S . Department of

Homeland Security i nterviewed VORONINA . During those interviews ,

VORONINA falsely stated that the name of the father of her child

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 Case 1:22-cr-00518-PKC Document 1 Filed 09/28/22 Page 23 of 31

and her then-unborn child was "Alec Deribasko." When subsequentl y

asked whether she knew "Oleg Deripaska," VORONINA stated that she

did know him and that he was a friend. Later , when shown a photo

of DERIPASKA, VORONINA stated that the individual depicted in the

photo looked like the father of her child. VORONINA also Btated,

in substance and in part , that she did not know where her child's

father lived or his occupation. In addition, VORONINA stated, in

substance and in part , that her parents had paid for her private

jet to arrive in the United States and that her parents had rented

her a house in Beverly Hills for her to stay while in the United

States.

22. On or about June 3, 2022 , Special Agents from the

Federal Bureau of Investigation met NATALIA MIKHAYLOVNA BARDAKOVA ,

a/k/a "Natalya Mikhaylovna Bardakova , " the defendant , at the Los

Angeles airport where she was waiting to pick up EKATERINA OLEGOVNA

VORONINA , a/k/a " Ekaterina Lobanova ," the defendant , after

VORONINA ' s arrival on the private jet BARDAKOVA had helped arrange .

The agents accompanied BARDAKOVA back to her hotel where they

interviewed her in the lobby . During the interview , BARDAKOVA

acknowledged , in substance and in part , that she had traveled to

the United States to facilitate arrangements for VORONINA to give

birth in the United States . But BARDAKOVA also made several

materially false statements . For example , BARDAKOVA falsely

stated , in substance and in part, that she had never communicated

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 Case 1:22-cr-00518-PKC Document 1 Filed 09/28/22 Page 24 of 31

with DERIPASKA directly . BARDAKOVA also falsely stated , in

substance and in part , that she did not assist VO RON INA with

VORONINA' s trip in 2020 to give birth to her first child with

DERIPASKA and , specifically , did not send any money from

BARDAKOVA ' s accounts for expenses associated with that trip.

BARDAKOVA also falsely stated , , in substance and in part , that she

had never visited DERIPASKA ' s property located at 12 Gay Street ,

New York , New York.

COUNT ONE
(Conspiracy to Violate the International Emergency Economic
Powers Act)

The Grand Jury further charges:

23 . The allegations set forth above in Paragraphs 1

through 22 are realleged and incorporated by reference as if set

fully forth herein.

24 . From at least in or about April 2018 through in or

about the present , in the Southern District of New York and

elsewhere , OLEG VLADIMIROVICH DERIPASKA , a/k/a "Oleg

Mukhamedshin ," OLGA SHRIKI , and NATALIA MIKHAYLOVNA BARDAKOVA ,

a/k/a "Natalya Mikhaylovna Bardakova," the defendants, and others

known and unknown , did combine , conspire , confederate, and agree

together and with each other to violate the IEEPA , in violation of

50 U.S . C . § 1705 , Executive Orders 13660 , 13661 , and 13662, and 31

C.F . R. § 589.201.

25 . It was a part and an object of the conspiracy that

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 Case 1:22-cr-00518-PKC Document 1 Filed 09/28/22 Page 25 of 31

OLEG VLADIMIROVICH DERIPASKA , a/k/a "Oleg Mukhamedshin , " OLGA

SHRIKI , and NATALIA MIKHAYLOVNA BARDAKOVA , a/k/a "Natalya

Mikhaylovna Bardakova ," the defendants , and others known and

unknown , would and did violate , attempt to violate , and cause a

violation of a license , order , regulation, and prohibition issued

under the IEEPA .

(Title 50 , United States Code , Section 1705 ; Executive Orders

13660 , 13661 , arid 13662 ; Title 31 , Code of Federal Regulations
§ 589 . 201.)

COUNT TWO
(Destruction of Records)

The Grand Jury further charges:

26. Th e allegations set forth above in Paragraphs 1

through 22 are real l eged and incorporated by reference as if set

fully forth herein.

27. From at least in or about 2020 through at least in

or about the present , i n the Southern District of New York and

elsewhere , OLGA SHRIKI , the defendant , knowingly altered ,

destroyed , mutilated , concealed , covered up , falsified , and made

a false entry in a record , document, and tangible object with the

intent to impede , obstruct , and influence a matter within the

juri sdiction of a department and agency of t he United States , and

in relation to and contemplat i on of s u ch matter , to wit , SHRIKI

de l eted portions of conversations and images related to her work

for OLEG VLADIMIROVICH DERIPASKA , a/k/a " Oleg Mukhamedshin ," after

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 Case 1:22-cr-00518-PKC Document 1 Filed 09/28/22 Page 26 of 31

being served with a Grand Jury Subpoena requiring the production

of such records .

(Title 18 , United States Code, Sections 1519 and 2.)

COUNT THREE
(False Statements}

The Grand Jury further charges:

28 . The allegations set forth above in Paragraphs 1

through 22 are realleged and incorporated by reference as if set

fully forth herein .

29. On or about June 2 , 2022 , in the Southern District

of New York and elsewhere , NATALIA MIKHAYLOVNA BARDAKOVA , a/k/a

" Natalya Mikhaylovna Bardakova ," the defendant , in a matter within

the jurisdiction of the executive branch of the Government of the

United States , knowingly and willfully made materially false ,

fictitious , and fraudulent statements and representations, to wit,

when interviewed by Special Agents from the Federal Bureau of

Investigation , BARDAKOVA falsely stated that (1) she never

communicated with OLEG VLADIMIROVICH DERIPASKA, a/k/a "Oleg

Mukhamedshin ," directly , (2) she had not assisted EKATERINA

OLEGOVNA VORONINA , a/k/a "Ekaterina Lobanova ," with VORONINA' s

trip in 2020 to give birth to her first child with DERIPASKA and,

specifically, did not send any money from BARDAKOVA's accounts for

expenses associated with that trip , and (3) she had never visited

any of DERIPASKA ' s properties in the United States , when in truth

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 Case 1:22-cr-00518-PKC Document 1 Filed 09/28/22 Page 27 of 31

and in fact, and as BARDAKOVA knew (1) BARDAKOVA regularly

communicated directly with DERIPASKA , (2) BARDAKOVA assisted

VORONINA with arrangements for VORONINA ' s 2020 trip to the United

States to give birth to DERIPASKA's child and paid for some of

VORONINA ' s expenses related to that trip from BARDAKOVA' s bank

account , and (3) BARDAKOVA had visited DERIPASKA ' s property

located at 12 Gay Street , New York , New York.

(Title 18 , United States Code , Section 1001 . )

COUNT FOUR
(False Statements)

The Grand Jury further charges:

30 . The allegations set forth above in Paragraphs 1

through 22 are realleged and incorporated by reference as if set

fully forth herein .

31 . On or about June 2 , 2022 , in the Southern District

of New York and elsewhere , EKATERINA OLEGOVNA VORONINA , a/k/a

" Ekaterina Lobanova ,n the defendant , in a matter within the

jurisdiction of the executive branch of the Government of the

United States , knowingly and willfully made materially false,

fictitious , and fraudulent statements and representations , to wit ,

when interviewed by officers from the U.S . Department of Homeland

Security , VORONINA falsely stated that her parents had rented her

housing accommodations during her intended stay in Los Angeles ,

California , when in truth and in fact , and as VORONINA knew , OLEG

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 Case 1:22-cr-00518-PKC Document 1 Filed 09/28/22 Page 28 of 31

VLADIMIROVICH DERIPASKA , a/k/a " Oleg Mukhamedshin, 11

and NATALIA

MIKHAYLOVNA BARDAKOVA, a/k/a "Natalya Mikhaylovna Bardakova , the

defendants , had rented , approved , and funded her housing.

(Title 18 , United States Code , Section 1001.)

FORFEITURE ALLEGATION

32 . As a result of committing the offense alleged in

Count One of this Indictment , OLEG VLADIMIROVICH DERIPASKA , a/k/a

" Oleg Mukhamedshin , 11

OLGA SHRIKI , and NATALIA MIKHAYLOVNA

BARDAKOVA , a/k/a " Natalya Mikhaylovna Bardakova , 11 the defendants ,

shall forfeit to the United States, pursuant to Title 18 , United

States Code , Sect i on 981 (a) (1) (C) , and Title 28 , United States

Code , Section 2461 , all property , real and personal , which

constitutes or is derived from proceeds traceable to the commission

of the offense alleged in Count One , including but not limited to

a sum of money in United States currency representing the amount

of proceeds traceable to the commission of said offense and the

following specific property :

a. Any and all monies and funds previously

on deposit at Wells Fargo Bank in account no. 2502560838, held in

the name of Ocean Studios LLC , and any and all funds traceable

thereto , including accrued interest ;

b. Th e real property located at 2501 30th

Street NW , Washington , D. C.;

c. The real property located at 12 Gay

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 Case 1:22-cr-00518-PKC Document 1 Filed 09/28/22 Page 29 of 31

Street , New York , New York ; and

d. The real property located at 11 East 64th

Street , New York , New York .

Substitute Asset Provision

33. If any of the property described above as being

subject to forfeiture , as a result of any act or omission of OLEG

VLADIMIROVICH DERIPASKA , a/k/a " Oleg Mukhamedshin , " OLGA SHRIKI ,

and NATALIA MIKHAYLOVNA BARDAKOVA , a/k/a " Natalya Mikhaylovna

Bardakova ," the defendants ,

a. cannot be located upon the exercise of due

diligence ;

b. has been transferred or sold to , or

deposited with , a third party ;

c. has been placed beyond the jurisdiction of

the cour t;

d. has been substantially diminished in value ;

or

e. has been commingled with other property

which cannot be divided without difficulty ;

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 Case 1:22-cr-00518-PKC Document 1 Filed 09/28/22 Page 30 of 31

it is the intent of the United States, pursuant to Title 21, United

States Code, Section 853(p); and Title 28, United States Code,

Section 2461 to seek forfeiture of any other property of the

defendants up to the value of the forfeitable property described

above.

(Title 18, United States Code, Sections 981;

Title 21, United States Code, Section 853;
Title 28, United States Code, Section 2461.)

k~i,DAMIAN WILLIAMS
United States Attorney
 Case 1:22-cr-00518-PKC Document 1 Filed 09/28/22 Page 31 of 31

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

-v. -

OLEG VLADIMIROVICH DERIPASKA, a/k/a "Oleg Mukhamedshin," OLGA

SHRIKI, NATALIA MIKHAYLOVNA BARDAKOVA, a/k/a "Natalya
Mikhaylovna Bardakova," and EKATERINA OLEGOVNA VORONINA, a/k/a
"Ekaterina Lobanova,"

Defendants .

SEALED INDICTMENT

Sl 22 Cr.

(50 U. S . C . § 1705; Executive Orders 13660 , 13661, and 13662; 31

C . F.R . § 589.201; 18 U. S.C . §§ 1001 , 1519, & 2.)

DAMIAN WILLIAMS
United States Attorney.