USA v. Teyf et al
Criminal

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

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.)

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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 2, 2014 10 8 MONETARY COUNT DEFENDANT(S) ON OR ABOUT DATE TRANSACTION ransfer of $1,000,000 om Bank of America ATYANA ccount:XXXX:XXXX ATOLYEVNA TEYF 25 April 4, 2018 (also known as Tatiana Bank Account:XXXX eyf) 3951 ATYANA ATOLYEVNA TEYF 26 April 2, 2018 (also known as Tatiana eyf) 22. Each entry in the above table constituting a separate violation of Title 18, United States Code, Sections 1957 and 2. (. COUNT TWENTY-SEVEN 23. On or about May 23, 2018, in the Eastern District of North Carolina, the ' defendant, LEONID ISAAKOVICH TEYF, did, directly and indirectly, corruptly give, offer, and promise a thing of value to a public official, with intent to induce a public official to .do an act and omit to do an act in violation of his official duty, that is, by giving $10,000 to an employee of the United States Department of Homeland Security to cause an individual to be deported from the United States, in violation of Title 18, United States Code, Section 201(b)(l). COUNT TWENTY-EIGHT 24. On or about June 20, 2018, in the Eastern District of North Carolina and elsewhere, the defendant, LEONID ISAAKOVICH TEYF, did knowingly use or cause another to use a facility of interstate commerce, to wit, a cellular telephone, 11 8 with intent that the murder of A.G. be committed in violation of the laws of North Carolina as consideration for an agreement to pay things of pecuniary value, to wit: a sum of U.S. currency. 25. All in violation of Title 18, United States Code, Section 1958. COUNT TWENTY-NINE 26. On or about June 20, 2018, in the Eastern District of North Carolina, the defendant, LEONID ISAAKOVICH TEYF, aiding and abetting others known and unknown to the grand jury, knowingly possessed a firearm that had been shipped and transported in interstate commerce from which the manufacturer's;serial number had been removed, altered and obliterated. 27. All in violation of Title 18; United States Code, Sections 922(k), 924(a)(l)(B) and 2. COUNT THIRTY 28. From or about October 28, 2014, and continuing through in or around October ~8, 2018, in the Eastern District of North Carolina and elsewhere, the defendants, LEONID ISAAKOVICH TEYF, TATYANA ANATOLYEVNA TEYF (also \ known as Tatiana Teyf), ALEXSY VLADIMIROVICH TIMOFEEV, and OLESYA YURYEVNA TIMOFEEVA and others known and unknown to the Grand Jury conspired and aided and abetted one another to encourage and induce an alien to come to, enter, or reside in the United States, knowing and in reckless· disregard of \\ the fact that such coming to, entry, or residence is or will be in violation oflaw. 12 8 29. All in violation of Title 8 United States Code, Sections 1324(a)(l)(A)(iv), 1324(a)(l)(A)(v)(I), and 1324(a)(l)(A)(v)(II). Object of the Conspiracy 30. The object of the conspiracy was to encourage and induce an alien to reside in the United States knowing that it was illegal to engage in employment and aid and abet one another to encourage or induce an alien to come to, enter, or reside in the United States, knowing or in reckless disregard of the fact that such coming to, entry,. or residence is or will be in violation of law. Manner and Means of the Conspiracy. 31. The conspiracy was carried out by defendants LEONID ISAAKOVICH TEYF, TATYANA ANATOLYEVNA TEYF (also known as Tatiana Teyf), ALEXSY VLADIMIROVICH TIMOFEEV, and OLESYA YURYEVNA TIMOFEEVA, in the Eastern District of North Carolina and elsewhere by filing applications and supporting documents with United States Citizenship and Immigration Services (USCIS), and employment of aliens that were not authorized to be employed in the United States, knowing or in reckless disregard of that fact is or will .be in violation oflaw. Overt Acts 32. In furtherance of the conspiracy and to affect the illegal object thereof, the following overt acts, among others, were committed in the Eastern District of North Carolina and elsewhere: 13 8 33. On September 7, 2012, New Market Way, Limited Liability Company (LLC) was registered with the North Carolina Secretary of State, and currently has a filing status as dissolved. New Market Way LLC listed defendant TATIANA ANATOLYEVNA TEYF as registered agent and President of the company, with an address of:X:XXX.,__New Market Way, Raleigh, NC 27615. 34. On December 27, 2012, CTK Transportation Incorporated was registered in the State of Illinois, and currently has a filing status listed as active. CTK Transportation Incorporated listed defendant LEONID ISAAKOVICH TEYF as the President of the company, with an address of:X:XXX Glenwood Avenue, Raleigh, North Carolina 27603. 35. On August 25, 2014, Carolina Transportation Group Incorporated, was registered in the State of Illinois, and currently has a filing status listed as, dissolved as of January 12, 2018. Carolina Transportation Group listed A.S. as the Secretary, and defendant TATYANAANATOLYEVNA TEYF as the President of the company, with an address of:X:XXX West 47th Street, Chicago, Illinois 60638. 36. On or about October 28, 2014, defendants ALEXSY VLADIMIROVICH TIMOFEEV, and OLESYA YURYEVNA TIMOFEEVA entered the United States at New York, New York with nonimmigrant visitor visas (B-2 Visa) and were authorized to remain in the United States for a period not to exceed April 27, 2015. 37. On or about October 29, 2014 through November 29, 2014, defendants ALEXSYVLADIMIROVICH TIMOFEEV, and OLESYA YURYEVNA TIMOFEEVA 14 8 resided at the home of defendants LEONID ISAAKOVICH TETI', TATYANA ANATOLYEVNA TETI' at XXXX New Market Way, Raleigh, North Carolina. 38·. Sometime in or about November 29, 2014, defendants ALEXSY VLADIMIROVICH TIMOFEEV, and OLESYA YURYEVNA TIMOFEEVA moved to the Chicago, Illinoi~ area for providing bookkeeping and· auditing services ·for defendants LEONID ISAAKOVICH TETI' and TATYANA ANATOLYEVNA TETI' at CTK Transportation and Carolina Transportation respectively. 39. On or about February 28, 2015, defendant OLESYA YURYEVNA TIMOFEEVA applied to Computer Systems Institute (CSI) at the Lombard Campus, Lombard, Illinois as an F-1 student. 40. On March 25, 2015, defendant OLESYA YURYEVNA TIMOFEEVA was provided a letter from CSI stating that she met the entrance requirements for full- time enrollment in the Intermediate English as a Secpnd Language (ESL) program. As a result, CSI issued a Certificate of Eligibility for Nonimmigrant Student Status - For Academic and Language Students (Form I-20) in the name of TIMOFEEVA valid from ~eptember 28, 2015 to September 28, 2016. 41. On or about March 4, 2015, defendant TATYANA ANATOLYEVNA TETI' prepared an Affidavit of Support (Form I-134) in support of the filing of the Application to Change Nonimmigrant Status (Form I-539) filed by defendant OLESYA YURYEVNA TIMOFEEVA. I 42. As part of the I.:539 application, OLESYA YURYEVNA TIMOFEEVA claimed that neither she nor anyone else within the application had done anything 15 8 \ that violated the terms of the nonimmigrant status and explicitly claimed that neither she nor any other person included in this application had been employed in (the United States since last admitted or granted extension or change of status. She made these claims, when she knew that both she and her husband, ALEXSY VLADIMIROVICH TIMOFEEV, were unlawfully employed by LEONID ISAAKOVICH TEYF in violation of their nonimmigrant status. 43. On or about March 10, 2015, OLESYA YURYEVNA TIMOFEEVA filed two (2) Applications to Extend/Change Nonimmigrant Status (Form J.:.539) with USCIS requesting that her immigration status be changed from a nonimmigrant visitor for pleasure (B-2) to that of a noni.mmigrant student (F-1). Additionally, applications were filed for her husband, ALEXSY VLADIMIROVICH TIMOFEEV, and her.minor child for their status to be changed from nonimmigrant visitors for pleasure (B-2) to that ofnonimmigrant dependents (F-2'S) of an (F-1). These changes were granted on or about August 28, 2015. 44. On or about June 27, 2016, defendant OLESYA YURYEVNA TIMOFEEVA's school session ended, and on September 26, 2016 CSI granted her authorization to remain in the United States until March 27, 2017. At the time ofher application to apply for an extension of status, defendant TATYANA ANATOLYEVNA TEYF submitted an affidavit of support (Form I-134) on behalf of .. TIMOFEEVA indicating that TEYF has $136,829.00 in funding. At no time during this semester were OLESYA YURYEVNA TIMOFEEVA, or any of her dependents authorized to be employed in the United States. 16 8 45. On April 15, 2016, the United States Department of Education cut off federal student grants and loans to the Skokie, Illinois-based for-profit college chain Computer Systems Institute (CSI), citing detailed evidence of fraudulent conduct. 46. From on or about Deceniber 2014 through October 29, 2018, LEONID ISAAKOVICH TEYf continued to employ and provide monetary payments to ALEXSY VLADIMIROVICH TIMOFEEV in exchange for his auditor duties for Carolina Transportation Group, and CTK Trucking. located in Chicago, Illinois. 4 7. ALEXSY VLADIMIROVICH TIMOFEEV registered a vehicle in his name at the request of defendant LEONID ISAAKOVICH TEYF. 48. On or about April of 2015, defendant,· LEONID ISAAKOVICH TEYF directed ALEXSY VLADIMIROVICH TIMOFEEV to run the .finances of CTK Trucking on behalf of TEYF. 49. From on or about April of 2015 through October 29, 2018, LEONID ISAAKOVICH TEYF directed defendant ALEXSY VLADIMIROVICH TIMOFEEV to email daily financial .transactions concerning CTK Trucking to TEYF. 50. In or .about January of 2017, LEONID ISAAKOVICil TEYF directed ALEXSY VLADIMIROVICH TIMOFEEV to create TALV LLC as a company to register the semi-trucks in the state of Illinois. On or abo·ut January 18, 2017, defendant ALEXSY VLADIMIROVICH TIMOFEEV created TALV LLC with th~ Illinois, Secretary of State and listed himself as the manager. Thereafter defendant I ALEXSY VLADIMIROVICH TIMOFEEV registered approximately twenty semi- .trucks in his name in the state of Illinois. 17 8 51. On or 8:bout March 27, 2017, OLESYA YURYEVNA TIMOFEEVA's school session ended, and on May 1, 2017 CSI granted her authorization to remain in the United States until July 9, 2018. At the time of her application to apply for an extension of status, TATYANA ANATOLYEVNA TEYF submitted an affidavit of support (Form I-134) on behalf of TIMOFEEVA indicating that TEYF has $314, 724.00 in funding. The affidavit of support indicated that the source of the funds were with New Market Way LLC. At no time during this semester were!OLESYA YURYEVNA TIMOFEEVA, or her dependents authorized to be employed in the United States. -- 52. On or about July 9, 2018, 'OLESYA YURYEVNA TIMOFEEVA's school session ended, and on September 24 2018, CSI granted her authorizatipn to remain in the United States until December 16, 2018~ At the time of her application to apply- for an extension of status, TATYANA ANATOLYEVNA TEYF submitted an affidavit of support (Form I-134) on behalf of TIMOFEEVA indicating that TEYF has $313,373.00 in funding. At no time during this semester was OLESYA YURYEVNA TIMOFEEVA, nor her dependents authorized to be employed in the United States. 53. On or about September 24, 2018, OLESYA YURYEVNA TIMOFEEVA applied for and was authorized "curriculum practical training" (CPT) (8 C.F.R. 214.2(£)(10)) valid until September 15, 2019 .. At the time CSI approved the application for CPT, OLESYA YURYEVNA TIMOFEEVA stated that she would be employed at CKT (sic) Transportation Inc. At no time during this approved CPT were 18 8 the dependents ofOLESYA YURYEVNA TIMOFEEVA authorized to be employed in the United States. 54. From on or about May of 2015 through October 29, 2018, LEONID ISAAKOVICH TEYF paid ALEXEY VLADIMIROVICH TIMOFEEV $1600 per week from the account of CTK Trucking. 55. Since May of 2015 through October 29, 2018, ALEXSY · VLADIMIROVICH TIMOFEEV has ean:ied approximately $83,200 per year from LEONID ISAAKOVICH TEYF and CTK Trucking. 56. Since on or about May of 2015 through October 29,~.2018, OLESYA YURYEVNA TIMOFEEVA has been paid approximately $1100 per week from LEONID ISAAKOVICH TEYF and CTK Trucking and has earned approximately $57,200 per year from TEYF and CTK Trucking. 57. All in violation of Title 8, United States Code, Sections 1324(a)(l)(A)(iv), L 1324(a)(l)(A)(v)(I), and 13Q4(a)(l)(A)(v)(II). COUNT THIRTY-ONE 58. On or about August 10, 2018, within the Eastern District of North Carolina the defendant, LEONID ISAAKOVICH TEYF did knowingly use and possess an immigrant visa in the name of LEONID ISAAKOVICH TEYF, which the defendant knew to be procured by means of a false claim and statement, in that the defendant did falsely claik on an 1-140 application that he was entering the United States to be a multinational executive employee of Delta Plus, LLC, making $110,000 19 8 annually, and LEONID ISAAKOVICH- TEYF was in possession of and used the resulting visa at the Raleigh-Durham International Airport. 59. All in violation of Title 18, United States Code, Sections 1546(~). COUNT THIRTY-TWO 60. On or about October 10, 2016, in the Eastern District of North Carolina and else~here, the defendant, ALEXEI IZAILEVICH POLYAKOV, a/k/a ALEX NORKA, knowingly procured and attempted to procure, contrary to law, naturalization for himself, to wit: by willful misrepresentation and concealment of material facts on the Form N-400, application for naturalization, when he did fail to. assert under penalty of perjury that he had previously use the name "Alex Norka,;" when he failed to assert that he had been arrested on at least 10 occasions in addition to the five reported occasions; and when he reported that he had served six (6) days in jail prior to the application, when he knew he had spent more days in jail than that reported. 61. All in violation of Title 18; United States Code, Section 1425(a). COUNTS THIRTY-THREE THROUGH FORTY-ONE 62. The grand jury realleges and incorporates by reference herein all of the allegations contained in paragraphs one (1) through sixteen (16) of the Introduction to the Indictment, and further alleges that: 63. On or about the dates set forth below, in the Eastern District of North Carolina and elsewhere, the defendants, LEONID ISAAKOVICH TEYF and TATYANA ANATOLYEVNA TEYF (also known as Tatiana Teyf), did knowingly 20 8 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 dep'osit, withdrawal, transfer, and exchange of U.S. currency, funds, and monetary instruments, such property having been derived from a specified unlawful activity, that is, illegal kickback of funds belonging to the government·ofRussia. MONETARY COUNT DEFENDANT(S) ON OR ABOUT DATE TRANSACTION Official check from Bank o erica for $114,106.95 drawn on Account LEONID ISAA.KOVICH 33 February 3, 2014 6014 for EYF I urchase of a 'Mercedes enz 8550, with YIN DUG8CB9EA009828 LEONID ISAAKOVICH 34 June 4, 2018 EYF urchase of a Mercedes Benz 8560, with VI # WDDUG8DB8JA368001 Official check from PNC Bank for $163,000.00 drawn on Account LEONID ISAA.KOVICH 35 February 27, 2018 4726 for EYF urchase of a Mercedes J enz 863 AMG 4MA, VI # WDDUG8JBOJA394158 21 8 .MONETARY COUNT DEFENDANT(S) ON OR ABOUT DATE TRANSACTION ransfer of $2,600,000 om Bank of Americ LEONID ISAAKOVICH 36 1 September 22, 2015 ccount:XXXX XXXX 1991 EYF o ABA Gallery, Inc. for th purchase of artwork. ATYANA ATOLYEVNA TEYF (also known as Tatiana ransfer of $2,750,000 eyf) om Bank of Americ 37 September 25, 2018 ccount XXXX:XXXX 97 48 o Merrill Lynch Accoun ' -X0857. ATYANA ATOLYEVNA TEYF (also known as Tatiana Transfer of $750,000 from eyf) Merrill Lynch Accoun 38 November 28, 2018 -X0857 to Merril account XXX- ATYANA ATOLYEVNA TEYF (also known as Tatiana ransfer. of $250,000 from eyf) errill Lynch Accoun 39 November 5, 2018 -X0857 to Merril account XXX- 22 8 MONETARY· COUNT DEFENDANT(S) ON OR ABOUT DATE TRANSACTION LEONID ISAAKOVICH EYF and TATYANA urchase of 133 Harget ATOLYEVNA TEYF St, Raleigh, NC, wit (also known as Tatiana unds from Bank 40 Teyf) April 23, 2018 erica Accounts 6014 and 3905 EONID ISAAKOVICH TEYF urchase of 510 Glenwoo ve, Unit #503, Raleigh, 41 February 23, 2017 C, with funds from Ban 1'' of America Account 1991 64. Each entry in the above table constituting a separate violation of Title 18, United States Code, Section 1957. 23 8 FORFEITURE NOTICE Each named defendant is given notice that all of the defendant's interest in all property specified herein is subject to forfeiture. Upon conviction of one or more of the offense(s) set forth in Count(s) One through Twenty-Six and Counts Thirty-Three through Forty-One, the defendant .shall forfeit to the United States, pursuant to Title 18 United States Code, Section 982(a)(l), any property, real or personal, involved in such offense(s), or any property traceable to such property. Upon conviction, of one or more of the offense(s) set forth in Count(s) Twenty- Seven and Twenty-Eight, the defendant shall forfeit to the United States, pursuant to Title 18, United States Code, Section 981(a)(l)(C), as made applicable by Title 28, Umted States Code, Section 2461(c), any property, real or personal, which constitutes or is derived from proceeds traceable to the said violation(s). Upon conviction of the offense(s) set forth in Count Twenty-Nine, the· defendant shall forfeit to the United States, pursuant to Title 18, United States Code, Section 924(d), as made applicable by Title 28, United States Code, Section 246l(c), any and all firearms or ammunition involved in or used in a knowing commission of the said offense(s). The forfeitable property includes, but is not limited to, the following: (a) Real property having the physical addtess of 6510 New Market Way, Raleigh, North Carolina, including all appurtenances and improvements thereto, being legally described in deed book 017.100 page 24 8 01227 of the Wake County Registry, North Carolina; and any and all proceeds from the sale of said property. (b) Real property having the physical address of 7900 Hardwick Drive, Raleigh, North Carolina, including all appurtenances and improvements thereto, being legally described in deed book 017105 page· 00839 of the Wake County Registry, North Carolina; and any and all I proceeds from the sale of said property. (c) Real property having the physical address of 133 Hargett St., Raleigh, North Carolina, including all appurtenances and improvements thereto, being legally described in deed book 017105 page 928-31 of the Wake County Registry, North Carolina; and any and all proceeds from the sale of said property. · (d) Real property having the physical address of 510 Glenwood Ave., Unit #503, Raleigh, North Carolina, including all appurtenances and improvements thereto, being legally described in deed book 16702 page 01356 of the Wake County Registry; North Carolina; and any and all proceeds from the sale of said property. (e) A Ruger P94 .40 caliber pistol with obliterated serial number, marked "Sturm, Ruger & Co. Inc. Southport, CONN, U.S.A."; (f) 2014 Mercedes Benz S550V, with VIN # WDDUG8CB9EA008419; (g) 2014 Mercedes Benz S550, with VIN #WDDUG8CB9EA009828; (h) 2018 Mercedes Benz S560, with VIN# WDDUG8DB8JA368001; 25 8 (i) 2018 Mercedes Benz 863 AMG 4MA, with VIN # WDDUG8JBOJA394158; (j) Artwork purchase by LEONID I. TEYF, on or about August 14, 2015, from ABA Gallery, Inc. located at 7 East 17th Street, New York, New York 1003 for a total amount of $2,600,000; (k) All funds held'in Bank of America Account No. XXXX XXXX 3905; (1) All funds held in Bank of America Account No. XXXX XXXX 6014; · (m) All fun~s held in Bank of America Account No. XXXX XXXX 3844; (n) All funds held in Bank of America Account No. XXXX XXXX 9409; (o) All funds held in Bank of America Account No. XXXX XXXX 1314; (p) All funds held in Bank of America Account No. XXXX XXXX 1991; (q) All funds held in Bank of America Account No. XXXX XXXX 1736; (r) All funds held in Bank of America Account No. XXXX XXXX 97 48; (s) All funds held in Bank of America Account No. XXXX ~ 3285; (t) All funds held in Bank of America Account No. XXXX XXXX 0990; (u) All funds held in Bank of America Account No. XXXX XXXX 4981; (v) All funds held in Bank of America Account No. XXXX XXXX 1292; (w) All funds held. in Bank of America Account No. XXXX XXXX 3691; (x) All funds held in Bank of America Account No. IDCXXXXXX 1563; (y) All funds held in Bank of America Account No. XXXX XXXX 7892; (z) All funds held in Bank of America Account No. XXXX XXXX 4884; (aa) All funds held in Branch Bank and Trust Account No. XXXX ·:xxxx 26 8 1502; (bb) All funds held in Branch Bank and Trust Account No. XXXX XXXX 4394; (cc) All funds held in First Citizen's Ban~ Account No. XXXX XXXX 091,8; (dd) All funds held in First Citizen's Bank Account No. XXXX XXXX 0897; (ee) All funds held in First Citizen's Bank Account No. XXXX XXXX 3812; (ff) All funds held in First Citizen's Bank Account No. XXXX XXXX 3951; (gg) All funds held in PNC Bank Account No. XXXXXXXX 4742; (hh) All funds held in PNC Bank Account No. XXXX XXXX 4726; (ii) All funds held in PNC Bank Account No. XXXX XXXX 5564; (jj) All funds held in Wells Fargo Bank Account No. XXXX XXXX 1952; I (kk) All funds held in Merrill Lynch Account No. XXX-X0857; (ll) All funds held in Merrill Lynch Account No. XXX-Xl096; (mm) All funds held in Merrill Lynch Account No. XXX-X0890. If any of the above.;described forfeitable property, as a result of any act .or omission of a defendant -- (1) cannot be located upon the exercise of due diligence; (2) has been transferred or sold to, or deposited with, a third party; (3) has been placed beyond the jurisdiction of the court; (4) has been substantially diminished in value; or (5) has been commingled with other property which cannot be divided without difficulty; 27 8 it is the intent of the United States, pursuant to Title 21, United States Code; Section 853(p), to seek forfeiture of any other property of said defendant up to the value of the forfeitable property described above. A TRUE BILL· FOREPERSON ROBERT J. HIGDON, JR. United States Attorney · t(),v/:Jt91AA- .b. JASON M. KELLHOFER ffe&k- !---- / Assistant Uni~ed States Attorney BARBARA D. KOCHER Assistant United States Attorney 28 8