(Contributions in the Names of Others) The Grand Jury charges: Background 1. The Federal Election Campaign Act of 1971, as amended, Title Code, Section.431, et seq. (the "Election Act"), limits financial influence in the election of candidates for federal office, including the Officmaof United.States Senator, and provides for the public disclosure of the financing of federal election campaigns: a. The Election Act limits the amount and source of money that may be contributed to a federal candidate or that candidate' authorized campaign committee. b. The Election.Act prohibits any person from making any contribution in the name of another, including reimbursing a third person, before or after that third person' contribution, as inducement
to make that contribution.
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c. In 2012, the Election Act limited.both primary and
general election campaign.contributions to $2,500 for a total of $5,000
from any individual to any one candidate.
2. The Federal Election Commission is an agency and
department of the United States with jurisdiction to compile and
publicly report accurate information about the sources and amounts of
3. In or about August 2012, in the Southern District of New York and elsewhere, DINESH the defendant, willfully and knowingly made and Caused to be made contributions of money, aggregating more than $10,000 during the 2012 calendar year, in the names of others to the campaign of a candidate for the United States Senate, to wit, reimbursed others with whom he was associated and who he had directed to contribute a total of $20,000 to the campaign.
(Title 2, United States Code, Sections 44lf and 437g(d) (1) (D) and Title 18, United States Code, Section 2.)
(Causing False Statements) The Grand Jury further charges: 4. From in or about August 2012 through in or about
July 2013, in the Southern District of New York and elsewhere, in
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a matter within the jurisdiction of the executive branch of the Government of the United States, DINESH the defendant, willfully and knowingly caused the submission of materially false, fictitious, and fraudulent statements and representations, to wit, caused the submission by an unwitting authorized campaign committee of a candidate for the United States Senate to the FEC of reports that falsely reported the sources and amounts of contributions to the campaign by certain individuals.
(Title 18, United States Code, Sections lOO1(a)(2) and 2.)
PREET BHARARA United States Attorney
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA V- DINESH
(2 U.S.C. 441f and 437g(d) (1) 18 U.S.C. 1oo1(a) (2) and 2.)