USA v. Teyf et al
Criminal

SECOND SUPERSEDING INDICTMENT as to Leonid Isaakovich Teyf (1) counts 1ss, 2ss-9ss, 11ss-13ss, 17ss-19ss, 21ss-24ss, 27ss, 28ss, 29ss, 30ss, 31ss, 33ss-35ss, 36ss, 40ss-41ss, Tatyana Anatolyevna Teyf (2) counts 1ss, 2ss, 5ss, 9ss-11ss, 13ss-26ss, 30ss, 37ss-40ss, Alexey Vladimirovich Timofeev (3) counts 1ss, 2ss, 12ss, 16ss, 21ss-23ss, 30ss, Olesya Yuryevna Timofeev (4) count 30s, Alexei Izrailevich Polyakov (5) counts 32s. The foreperson's signature has been redacted pursuant to the E-Government Act. The unredacted version of this document has been filed under seal. (Bullock, N.)

Eastern District of North Carolina, nced-5:2018-cr-00452-167684

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FILED IN OPEN oou~ ON QH.e- Lc1\ · Peter A. Moore, Jr., Clerk US District Court · Eastern District of NC UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISlON NO. 5:18-CR-00452-FL(3) UNITED STATES OF AMERICA).) v.)) SECOND, I LEONID ISAAKOVICH TEYF,) SUPERSEDING TATYANAANATOLYEVNA TEYF,) INDICTMENT a/k/a TATIANA TEYF,) ALEXEY VLADIMIROVICH TIMOFEEV,) OLESYA YURYEVNA TIMOFEEVA, ·) ALEXEI IZAILEVICH POLYAKOV, a/k/a) ALEXNORKA) The Grand Jury charges: INTRODUCTION J 1. LEONID ISAAKOVICH TEYF ("TEYF") was born in Belarus, which at the time was a Slavic Republic within the former Soviet Union. Prior to coming to the United States in 2010, he had been a resident of Russia. While in Russia, TEYF served as President of Fishing Group (FG) Delta:Plus (hereinafter "FGDP") for approximately five (5) years. Since arriving in the United States, TEYF has been the President of Delta Plus, LLC (hereinafter "Delta Plus"), the United States based subsidiary ofFGDP .. TEYF is a current legal resident of the United States. ' I 2. TATYANA ANATOLYEVNA TEYF (also known as Tatiana Teyf) ("TATYANA"), is the spouse of LEONID ISAAKOVICH TEYF. She is a citizen of Russia and currently a resident leg::,1.l alien of the United States. 3. ALEXEY VLADIMIROVIC.H TIMOFEEV ("TIMOFEEV'') is a Russian citizen. He has been in the United States since approximately October 28, 2014. 1 8 TIMOFEEV entered the United States pµrsuant to a B-2 Visa, and currently holds an F-2 visa, derivative to his spouse's F-1 student visa. 4. FGDP is a multinational company headquartered in Volodarskiy, Russia, and was organized on or,about April 8, 2002. It reportedly has over fifteen hundred (1,500) employees, eighty (80) fishirig vessels, and annual revenue in excess of $14 Million (USD) and is one of the largest fisheries and fish processing plants in the Volga region of Russia .. 5. Delta Plus is a .Limited Liability Company o~ganized in the State of North Carolina for the stated primary purpose of operating an urgent care clinic; and is an 80% owned subsidiary ofFGDP. 6. CTK Transportation Incorporated (hereinafter "CTK") was incorporated in the State of Illinois, on or about December 27, 2012. According to corporate registration documents, TIMOFEEV is the registered agent of CTK and TEYF is the President of CTK. 7. While Anatoli Serdyokov was Russia's Minister of Defense, Serdyokov granted the company, VOENTORG, a contract to provide the Russian military with goods and services (e.g., laundry,· food, and equipment). Voentorg, in turn, subcontracted with various other companies to provide these goods and service. 8. As relevant to this indictment, between 2010 and 2012, exact dates unknown, TEYF was Deputy Director of Voentorg. As such, TEYF arranged for subcontractors in Russia to fill the various goods and services required ofVoentorg's contract with the Russian Ministry .of Defense. TEYF and others devised a scheme 2 8 and artifice that pr10r to granting a subcontractor the work for Voentorg, the subcontractor had to agree that a certain percentage of the government funds which it would receive for completion of the work would be paid back to TEYF and others involved in that scheme and artifice. These kickbacks of government funds were paid in cash and amounted to more than $150,000,000 over an approximate two-year span. \ TEYF and others then directed some of the monies be paid to others involved in the scheme, and some of the monies were placed in various accounts over which TEYF · had control. Some of the monies belonging to TEYF were transferred to accounts outside of Russia, and ultimately into accounts located in the United States. 9. Since at least December 2010, TEYF, TATYANA, and others known and unknown to the grand jury have opened at least seventy (70) financial accounts at approximately four (4) domestic financial institutions, in the names of themselves and businesses under their control. TEYF and others received at least 294 wires for an approximate total of $39,500,000 into four (4) accounts held in TEYF's name and the names of co-conspirators at Bank of America, N.A ("BOA"). Foreign corporations and bank accounts in countries commonly known to be used for money laundering. are the source of 293 of the wires that total approximately $39,415,000. 10. Account XXXX XXXX 3905 ("BOA 3905") was opened on a date unknown at Bank of America, N.A. Between January 18, 2011 and March 2, 2013, BOA 3905 ' received $14,676,107 in wir~ transfers from accounts in Belize, the British Virgin Islands, Hong Kong, Panama, and Seychelles. Of the accounts from which these I funds originated, over $13,000,000 came from Cyprus, and the remainder from Hong 3. 8 Kong. TEYF is currently a signatory on this account. 11. On September 18, 2012, TEYF opened demand deposit account number XXXX XXXX 9409, (a/k/a LT Revocable Trust "BOA 9409") at Bank of America, N.A. in which TEYF and TATYANA were listed as individual owners and were the only authorized signers on the account. This account received $4,106,952 in wire transfers between January 2011 and December 2013, the majority of which originated in Cyprus. 12. On a date unknown, account XXXX XXXX 6014 ("BOA 6014") was opened at Bank of America, N.A. As of February 11, 2015, TATYANA was the authorized signer on the account. BOA 6014 received a total of $17,924,909 in wire transfers, over $15,000,000 originating in Cyprus, and approximately $2,000,000 in Hong Kong. 13. In October ·2012, account XXX XXXX 1736 was opened by TEYF and TATYANA in the name "New Market Way LLC." This account received $1,200,000 · in transfers from BOA 6014. 14. On a date unknown, account XXXX XXXX 3285 ("BOA 3285") was opened at Bank of America, N.A. Statements from January 2011 reflect the names of both TEYF and TATYANA; as of June 23, 2015, TEYF relinquished all interest in the account and TATYANA remained the sole signatory. Forty-four transfers were made from BOA 3905 into BOA 3285 for approximately $2,972,000. 15. On a date unknown, account XXXX XXXX 1991 ("BOA 1991") was opened at Bank of America, N.A. Statements from June 2011 reflect the names of 4 8 both TEYF and TATYANA on the account; in June 2015, TATYANA relinquished all interest in the account and TEYF became the sole signatory. Between August 11, 2011 and March 23, 2012, TEYF made thirteen transfers from BOA 3905 to BOA 1991 for a total of $10,807,000. 16. On June 22, 2016, TATYANA opened demand savings account number XXXX XXXX 9748 ("BOA 9748") at Bank of America, N.A. in which TATYANA was listed as sole owner and as the only authorized signer on the account. On the same day, $9,000,000 was transferred from BOA 6014 to BOA 9748: COUNT ONE 17. The grand jury realleges and incorporates by reference herein all of the allegations contained in paragi:aphs one (1) through sixteen (16) of the Introduction to the Indictment, and further alleges that: 18. Beginning on a date no later than on or about March· 2, 2011, and continuing through the present, in the Eastern District of North Carolina and elsewhere, the defendants, LEONID ISAAKOVICH TEYF, . TATYANA - ANATOLYEVNA TEYF (also known as TATIANA. TEYF), ALEXEY VLADIMIROVICH TIMOFEEV, and others known and unknown to the Grand Jury, knowingly combined, conspired and agreed among themselves to commit offenses against the United States in violation of Title 18, United States Code, Section 1957, to wit: by knowingly engaging and attempting to engage in monetary transactions by, through or to a financial institution, affecting interstate and foreign commerce, in criminally derived property of a value greater than $10,000, such property having 5 8 been derived from a specified unlawful activity, that is, theft of funds belonging to the government of Russia in the form of kickbacks, a crime in that country, in ' violation of Title 18, United States Code, Section 1957. 19. .All in violation of Title 18, United States Code, Section 1956(h). COUNTS TWO THROUGH TWENTY-SIX 20. The grarid jury realleges and incorporates by reference herein all of the allegations contained in paragraph~ one (1) through sixteen (16) of the Introduction \ to the Indictment, and further alleges that: 21. On or about the dates set forth below, in the Eastern District of North Carolina and elsewhere, the defendants, . LEONID ! ISAAKOVICH TEYF, TATYANA ANATOLYEVNA TEYF · (also known as TATIANA TEYF), ALEXEY VLADIMIROVICH TIMOFEEV, aiding arid abetting each other, did knowingly engage and attempt to engage in the following monetary transactions by through or \ to a financial institution, affecting interstate or foreign commerce, in criminally derived property of a value greater than $10,000, that is the deposit, withdrawal, t~ansfer, and exchange of U.S. currency,' funds, and monetary instruments, such property having been derived from a specified unlawful· activ!ty, that is, illegal kickback of funds belonging to the government of Russia. 6 8 \ MONETARY COUNT DEFENDANT(S} ON OR ABOUT DATE TRANSACTION LEONID ISAAKOVICH EYF, TATYANA ansfer of $260,000 from ATOLYEVNA TEYF ank of America Accoun 2 (also known as Tatiana August 11, 2017 XXXX 1736 to Ban eyf), and ALEXEY IMOFEEV written o EONID ISAAKOVICH 3 November 29, 2016 EYF LEONID ISAAKOVICH. 4 EYF November 29, 2016 LEONID ISAAKOVICH ransfer of $2,000,000 EYF and TATYANA om Bank of Americ 5 January 26, 2015 ATOLYEVNA TEYF ccount XXXX:XXXX 1991 o Bank ·of Americ ccount XXXX:XXXX 601 LEONID ISAAKOVICH 6 February 14, 2018 EYF Citizen's 7 8 .. MONETARY COUNT DEFENDANT(S) ON OR ABOUT DATE TRANSACTION ransfer of $5,035,000.00 from, Ban LEONID ISAAKOVICH of America Account 7 February 14, 2018 EYF 1991 to Accoun XXXX 1502 a ransfer of $5,03~,000.00 from Ban LEONID ISAAKOVICH 8 February 14, 2018 of America Account 1~11~~ EYF 1991 to Accoun XXXX 4 726 at PNC,";- LEONID ISAAKOVICH ayment of real estate EYF, TATYANA axes in the amount of 9 ATOLYEVNA TEYF October 12, 2016 $50,662.33 from Bank of · erica Account XXXX 3285 10 January 20, 2015 (also known as Tatiana eyf) ·:". •,,'. LEONID ISAAKOVICH urchase of a EYF and TATYANA check in the amount o ATOLYEVNA TEYF 11 April 23_, 2018 $1,087,804.34 using funds (also known as Tatiana om· Bank of Am.eric eyf) ccount XXXX XXXX 3905 ransfer of $30,000 from EYF and ALEXEY Bank of America Account 12 ADIMIROVICH,. May 10, 2018 XXXX 3905 to Ban IMOFEEV < <"; 8 8 MONETARY COUNT DEFENDANT(S) ON OR ABOUT DATE TRANSACTION. LEONID ISAAKOVICH ransfer of $100,000 from EYF and TATYANA ank of America Accoun ATOLYEVNA TEYF 13 February 3, 2016 IL"-""'""'"'-""' XXXX 6014 to Ban (also known as Tatiana eyf) ATYANA ATOLYEVNA TE 14 November 2, 2017 (also known· as Tatian eyf) ATYANA ATOLYEVNA TEYF 15 June 14, 2016 · ank of America Accoun XXXX3844 16 August 30, 2016 LEONID ISAAKOVICH EYF and TATYANA ATOLYEVNA TEYF 17 February 12, 2015 (also known as Tatiana eyf) LEONID ISAAKOVICH EYF and TATYANA ATOLYEVNA TEYF 18 November 6, 2015 (also known as Tatiana eyf) LEONID ISAAKOVICH ransfer of $9,000,000 EYF and TATYANA om Bank of America ATOLYEVNA TEYF cco:unt XXXX XXXX 19 May 29, 2014 (also known as Tatiana 6014 to Bank of America eyf) ccount XXXX XXXX 1991 9 8 MONETARY COUNT DEFENDANT(S) ON OR ABOUT DATE TRANSACTION ransfer of $9,000,000 om Bank' of America ATYANA ccount XXXX XXXX ATOLYEVNA TEYF 20 June 22,.2016 6014 to Bank of America (also known as Tatiana ccount XXXX XXXX eyf) . 9748 LEONID ISAAKOVICH ransfer of $132,000 from EYF, TATYANA Bank of America Account ATOLYEVNA TEYF '"'~~~-- XXXX 9409 to 21 Febrµary 19, 2015 ells Fargo Bank Account "TV"V V xxxx 1952 ransfer of $19,000 from Bank of America Account 22 November 4, 2014 XXXX 9409 to PNC LEONID ISAAKOVICH TEYF, TATYANA ransfer of $30,000 from ATOLYEVNA TEYF ank of America Account 23 (also known as Tatiana September 25, 2014 t"------ XXXX 9409 to PNC eyf) and ALEXEY · ank Account XXXX ADIMIROVIeH t'-~~~--5564 IMOFEEV LEONID ISAAKOVICH EYF and TATYANA 24 ATOLYEVNA TEYF September