Read the special counsel's indictment of Paul Manafort and Rick Gates

Special counsel Robert S. Mueller III filed new charges Thursday against Paul Manafort and his business partner Rick Gates, intensifying the legal pressure on them as they prepare for trial later this year. Special counsel Mueller files new charges in Manafort, Gates case

Case 1:17-cr-00201-ABJ Document 190 Filed 02/22/18 Page 1 of 4

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
v.
PAUL J. MANAFORT, JR., and
RICHARD W. GATES III,

Crim. No. 17-201 (ABJ)

Defendants.

STATUS REPORT
The United States of America, by and through Special Counsel Robert S. Mueller, III,
respectfully submits this status report to apprise the Court of a recent development related to this
matter.
1.

On Thursday, February 22, 2018, a grand jury sitting in the Eastern District of

Virginia, filed a 32-count indictment charging defendants Paul J. Manafort, Jr., and Richard W.
Gates III as follows:

Count
1

2

3

4

5

Charge
Subscribing to False United States Individual Income Tax
Returns (2010)
(26 U.S.C. ASS 7206(1); 18 U.S.C. ASS 2)
Subscribing to False United States Individual Income Tax
Returns (2011)
(26 U.S.C. ASS 7206(1); 18 U.S.C. ASS 2)
Subscribing to False United States Individual Income Tax
Returns (2012)
(26 U.S.C. ASS 7206(1); 18 U.S.C. ASS 2)
Subscribing to False United States Individual Income Tax
Returns (2013)
(26 U.S.C. ASS 7206(1); 18 U.S.C. ASS 2)
Subscribing to False United States Individual Income Tax
Returns (2014)
(26 U.S.C. ASS 7206(1); 18 U.S.C. ASS 2)

Defendant
Manafort

Manafort

Manafort

Manafort

Manafort

Case 1:17-cr-00201-ABJ Document 190 Filed 02/22/18 Page 2 of 4

Count
6

7

8

9

10

11

12

13

14

15

16

17

18

19

Charge
Assisting in the Preparation of False United States Individual
Income
(2010) (26 U.S.C. ASS 7206(2))
Assisting in the Preparation of False United States Individual
Income
(2011) (26 U.S.C. ASS 7206(2))
Assisting in the Preparation of False United States Individual
Income
(2012) (26 U.S.C. ASS 7206(2))
Assisting in the Preparation of False United States Individual
Income
(2013) (26 U.S.C. ASS 7206(2))
Assisting in the Preparation of False United States Individual
Income
(2014) (26 U.S.C. ASS 7206(2))
Failure To File Reports Of Foreign Bank And Financial Accounts
(2011)
(31 U.S.C. ASSASS 5314 and 5322(a); 18 U.S.C. ASS 2)
Failure To File Reports Of Foreign Bank And Financial Accounts
(2012)
(31 U.S.C. ASSASS 5314 and 5322(a); 18 U.S.C. ASS 2)
Failure To File Reports Of Foreign Bank And Financial Accounts
(2013)
(31 U.S.C. ASSASS 5314 and 5322(a); 18 U.S.C. ASS 2)
Failure To File Reports Of Foreign Bank And Financial Accounts
(2014)
(31 U.S.C. ASSASS 5314 and 5322(a); 18 U.S.C. ASS 2)
Subscribing to False United States Individual Income Tax
Returns
(2010)
(26 U.S.C. ASS 7206(1); 18 U.S.C. ASS 2)
Subscribing to False United States Individual Income Tax
Returns
(2011)
(26 U.S.C. ASS 7206(1); 18 U.S.C. ASS 2)
Subscribing to False United States Individual Income Tax
Returns
(2012)
(26 U.S.C. ASS 7206(1); 18 U.S.C. ASS 2)
Subscribing to False United States Individual Income Tax
Returns
(2013)
(26 U.S.C. ASS 7206(1); 18 U.S.C. ASS 2)
Subscribing to False United States Individual Income Tax
Returns
2

Defendant
Gates

Gates

Gates

Gates

Gates

Manafort

Manafort

Manafort

Manafort

Gates

Gates

Gates

Gates

Gates

Case 1:17-cr-00201-ABJ Document 190 Filed 02/22/18 Page 3 of 4

Count

20

21

22

23

24
25
26
27
28
29
30
31
32

2.

Charge
(2014)
(26 U.S.C. ASS 7206(1); 18 U.S.C. ASS 2)
Subscribing to a False Amended United States Individual Income
Tax Return (2013)
(26 U.S.C. ASS 7206(1); 18 U.S.C. ASS 2)
Failure To File Reports Of Foreign Bank And Financial Accounts
(2011)
(31 U.S.C. ASSASS 5314 and 5322(a); 18 U.S.C. ASS 2)
Failure To File Reports Of Foreign Bank And Financial Accounts
(2012)
(31 U.S.C. ASSASS 5314 and 5322(a); 18 U.S.C. ASS 2)
Failure To File Reports Of Foreign Bank And Financial Accounts
(2013)
(31 U.S.C. ASSASS 5314 and 5322(a); 18 U.S.C. ASS 2)
Bank Fraud Conspiracy (Lender B/$3.4 million loan)
(18 U.S.C. ASS 1349)
Bank Fraud (Lender B/$3.4 million loan)
(18 U.S.C. ASSASS 1344, 2)
Bank Fraud Conspiracy (Lender C / $1 million loan)
(18 U.S.C. ASS 1349)
Bank Fraud (Lender C / $1 million loan)
(18 U.S.C. ASS 1344, 2)
Bank Fraud Conspiracy (Lender B / $5.5 million loan)
(18 U.S.C. ASS 1349)
Bank Fraud Conspiracy (Lender D / $9.5 million loan
(18 U.S.C. ASS 1349)
Bank Fraud (Lender D / $9.5 million loan)
(18 U.S.C. ASSASS 1344, 2)
Bank Fraud Conspiracy (Lender D / $6.5 million loan)
(18 U.S.C. ASS 1349)
Bank Fraud (Lender D / $6.5 million loan)
(18 U.S.C. ASSASS 1344, 2)

Defendant

Gates

Gates

Gates

Gates

Manafort
Gates
Manafort
Gates
Manafort
Gates
Manafort
Gates
Manafort
Gates
Manafort
Gates
Manafort
Gates
Manafort
Gates
Manafort
Gates

A copy of the indictment returned in the Eastern District of Virginia is attached

(redacted to omit the signature of the foreperson).
3.

The Special Counselas Office proceeded before the Grand Jury in the Eastern

District of Virginia because, based on our current evidence, venue for these charges does not exist
in the District of Columbia. Prior to instituting this criminal action, the Special Counselas Office
met with defense counsel to go over the proof underlying the bank fraud charges (the tax charges
3

Case 1:17-cr-00201-ABJ Document 190 Filed 02/22/18 Page 4 of 4

were already the subject of charges before this Court) and to provide counsel an opportunity to
present any arguments as to why these charges should not be brought. The Special Counsel's
Office also alerted defense counsel for each defendant that the government was prepared to bring
all of the charges before a Grand Jury in the District of Columbia, if the defendants were willing
to waive venue (since otherwise we could not do so legally). If venue had been waived, the
defendants would have faced a single indictment in one district, and not two indictments in
adjacent districts.

One defendant elected, as is his right, not to waive venue. The Special

Counsel's Office accordingly has proceeded in the Eastern District of Virginia.
Respectfully submitted,
ROBERT S. MUELLER III

Dated: February 22, 2018

By:

~

Andrew Weissmann
Greg D. Andres (D.D.C. Bar No. 459221)
Kyle R. Freeny
U.S. Department of Justice
Special Counsel' s Office
950 Pennsylvania Avenue NW
Washington, DC 20530
Telephone: (202) 616-0800

Attorneys for the United States ofAmerica

4

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 1 of 37

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES OF AMERICA

v.

PAUL J. MANAFORT, JR.,
(Counts 1 through 5, 11 through 14, and
24 through 32)
and
RICHARD W. GATES III,
(Counts 6 through 10 and 15 through 32)
Defendants.

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CRIMINAL NO. 1:18 Cr. 83 (TSE)(S-1)
COUNTS 1a5: 26 U.S.C. ASS 7206(1); 18
U.S.C. ASSASS 2 and 3551 et seq.
Subscribing to False United States
Individual Income Tax Returns
COUNTS 6a10: 26 U.S.C. ASS 7206(2); 18
U.S.C. ASS 3551 et seq.
Assisting in the Preparation of False
United States Individual Income
COUNTS 11a14: 31 U.S.C. ASSASS 5314 and
5322(a); 18 U.S.C. ASSASS 2 and 3551 et seq.
Failure To File Reports Of Foreign Bank
And Financial Accounts
COUNTS 15a19: 26 U.S.C. ASS 7206(1);
18 U.S.C. ASSASS 2 and 3551 et seq.
Subscribing to False United States
Individual Income Tax Returns
COUNT 20: 26 U.S.C. ASS 7206(1); 18

U.S.C. ASSASS 2 and 3551 et seq.
Subscribing to a False Amended United
States Individual Income Tax Return
COUNTS 21a23: 31 U.S.C. ASSASS 5314 and
5322(a); 18 U.S.C. ASSASS 2 and 3551 et seq.
Failure To File Reports Of Foreign Bank
And Financial Accounts
COUNT 24: 18 U.S.C. ASSASS 1349 and 3551
et seq.
Bank Fraud Conspiracy
COUNT 25: 18 U.S.C. ASSASS 1344, 2, and
3551 et seq.
Bank Fraud

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 2 of 37

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*******

COUNT 26: 18 U.S.C. ASSASS 1349 and 3551
et seq.
Bank Fraud Conspiracy
COUNTS 27: 18 U.S.C. ASSASS 1344, 2, and
3551 et seq.
Bank Fraud
COUNT 28a29: 18 U.S.C. ASSASS 1349 and
3551 et seq.
Bank Fraud Conspiracy
COUNT 30: 18 U.S.C. ASSASS 1344, 2, and
3551 et seq.
Bank Fraud
COUNT 31: 18 U.S.C. ASSASS 1349 and 3551
et seq.
Bank Fraud Conspiracy
COUNT 32: 18 U.S.C. ASSASS 1344, 2, and
3551 et seq.
Bank Fraud
FORFEITURE NOTICE

SUPERSEDING INDICTMENT
February 2018 Term a At Alexandria, Virginia

THE GRAND JURY CHARGES THAT:
Introduction
At all times relevant to this Superseding Indictment:
1.

Defendants PAUL J. MANAFORT, JR. (MANAFORT) and RICHARD W. GATES III

(GATES) served for years as political consultants and lobbyists. Between at least 2006 and 2015,
2

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 3 of 37

MANAFORT and GATES acted as unregistered agents of a foreign government and foreign
political parties. Specifically, they represented the Government of Ukraine, the President of
Ukraine (Victor Yanukovych, who was President from 2010 to 2014), the Party of Regions (a
Ukrainian political party led by Yanukovych), and the Opposition Bloc (a successor to the Party
of Regions after Yanukovych fled to Russia).
2.

MANAFORT and GATES generated tens of millions of dollars in income as a result of their

Ukraine work. From approximately 2006 through the present, MANAFORT and GATES engaged
in a scheme to hide income from United States authorities, while enjoying the use of the money.
During the first part of the scheme between approximately 2006 and 2015, MANAFORT, with
GATESa assistance, failed to pay taxes on this income by disguising it as alleged aloansa from
nominee offshore corporate entities and by making millions of dollars in unreported payments
from foreign accounts to bank accounts they controlled and United States vendors. MANAFORT
also used the offshore accounts to purchase United States real estate, and MANAFORT and
GATES used the undisclosed income to make improvements to and refinance their United States
properties.
3.

In the second part of the scheme, between approximately 2015 and at least January 2017,

when the Ukraine income dwindled after Yanukovych fled to Russia, MANAFORT, with the
assistance of GATES, extracted money from MANAFORTas United States real estate by, among
other things, using those properties as collateral to obtain loans from multiple financial institutions.
MANAFORT and GATES fraudulently secured more than twenty million dollars in loans by
falsely inflating MANAFORTas and his companyas income and by failing to disclose existing debt
in order to qualify for the loans.
4.

In furtherance of the scheme, MANAFORT and GATES funneled millions of dollars in
3

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 4 of 37

payments into numerous foreign nominee companies and bank accounts, opened by them and their
accomplices in nominee names and in various foreign countries, including Cyprus, Saint Vincent
& the Grenadines (Grenadines), and the Seychelles. MANAFORT and GATES hid the existence
and ownership of the foreign companies and bank accounts, falsely and repeatedly reporting to
their tax preparers and to the United States that they had no foreign bank accounts.
5.

In furtherance of the scheme, MANAFORT used his hidden overseas wealth to enjoy a

lavish lifestyle in the United States, without paying taxes on that income. MANAFORT, without
reporting the income to his tax preparer or the United States, spent millions of dollars on luxury
goods and services for himself and his extended family through payments wired from offshore
nominee accounts to United States vendors. MANAFORT also used these offshore accounts to
purchase multi-million dollar properties in the United States and to improve substantially another
property owned by his family.
6.

In furtherance of the scheme, GATES used millions of dollars from these offshore accounts

to pay for his personal expenses, including his mortgage, childrenas tuition, and interior decorating
and refinancing of his Virginia residence.
7.

In total, more than $75,000,000 flowed through the offshore accounts. MANAFORT, with

the assistance of GATES, laundered more than $30,000,000, income that he concealed from the
United States Department of the Treasury (Treasury), the Department of Justice, and others.
GATES obtained more than $3,000,000 from the offshore accounts, income that he too concealed
from the Treasury, the Department of Justice, and others.

4

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 5 of 37

Relevant Individuals And Entities
8.

MANAFORT was a United States citizen. He resided in homes in Virginia, Florida, and

Long Island, New York.
9.

GATES was a United States citizen. He resided in Virginia.

10.

In 2005, MANAFORT and another partner created Davis Manafort Partners, Inc. (DMP) to

engage principally in political consulting. DMP had staff in the United States, Ukraine, and
Russia. In 2011, MANAFORT created DMP International, LLC (DMI) to engage in work for
foreign clients, in particular political consulting, lobbying, and public relations for the Government
of Ukraine, the Party of Regions, and members of the Party of Regions. DMI was a partnership
solely owned by MANAFORT and his spouse. GATES worked for both DMP and DMI and
served as MANAFORTas right-hand man.
11.

The Party of Regions was a pro-Russia political party in Ukraine.

Beginning in

approximately 2006, it retained MANAFORT, through DMP and then DMI, to advance its
interests in Ukraine, the United States, and elsewhere, including the election of its slate of
candidates. In 2010, its candidate for President, Yanukovych, was elected President of Ukraine.
In 2014, Yanukovych fled Ukraine for Russia in the wake of popular protests of widespread
governmental corruption. Yanukovych, the Party of Regions, and the Government of Ukraine
were MANAFORT, DMP, and DMI clients.
12.

MANAFORT and GATES owned or controlled the following entities, which were used in

the scheme (the MANAFORTaGATES entities):
Domestic Entities
Entity Name

Date Created

Incorporation Location

Bade LLC (RG)

January 2012

Delaware

5

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 6 of 37

Entity Name

Date Created

Incorporation Location

August 2008

Virginia

March 2011

Florida

March 2007

Delaware

March 2005

Virginia

March 2011

Florida

October 1999

Delaware

November 1999

Virginia

June 2011

Delaware

March 2012

Florida

Global Sites LLC (PM, RG)

July 2008

Delaware

Jemina LLC (RG)

July 2008

Delaware

Jesand Investment Corporation (PM)

April 2002

Virginia

Jesand Investments Corporation (PM)

March 2011

Florida

April 2006

Virginia

March 2011

Florida

Jupiter Holdings Management, LLC
(RG)

January 2011

Delaware

Lilred, LLC (PM)

December 2011

Florida

LOAV Ltd. (PM)

April 1992

Delaware

MC Brooklyn Holdings, LLC (PM)

November 2012

New York

January 2012

Florida

April 2012

New York

July 2008

Delaware

Daisy Manafort, LLC (PM)
Davis Manafort International LLC
(PM)
DMP (PM)

Davis Manafort, Inc. (PM)

DMI (PM)

John Hannah, LLC (PM)

MC Soho Holdings, LLC (PM)
Smythson LLC (also known as
Symthson LLC) (PM, RG)

6

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 7 of 37

Cypriot Entities
Entity Name

Date Created

Incorporation Location

Actinet Trading Limited (PM, RG)

May 2009

Cyprus

Black Sea View Limited (PM, RG)

August 2007

Cyprus

Bletilla Ventures Limited (PM, RG)

October 2010

Cyprus

Cavenari Investments Limited (RG)

December 2007

Cyprus

Global Highway Limited (PM, RG)

August 2007

Cyprus

Leviathan Advisors Limited (PM, RG) August 2007

Cyprus

LOAV Advisors Limited (PM, RG)

Cyprus

August 2007

Lucicle Consultants Limited (PM, RG) December 2008

Cyprus

Marziola Holdings Limited (PM)

March 2012

Cyprus

Olivenia Trading Limited (PM, RG)

March 2012

Cyprus

Peranova Holdings Limited (Peranova)
June 2007
(PM, RG)

Cyprus

Serangon Holdings Limited (PM, RG)

January 2008

Cyprus

Yiakora Ventures Limited (PM)

February 2008

Cyprus

Other Foreign Entities
Entity Name

Date Created

Incorporation Location

Global Endeavour Inc. (also known as
Global Endeavor Inc.) (PM)

Unknown

Grenadines

Jeunet Ltd. (PM)

August 2011

Grenadines

Pompolo Limited (PM, RG)

April 2013

United Kingdom

7

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 8 of 37

13.

The Internal Revenue Service (IRS) was a bureau in the Treasury responsible for

administering the tax laws of the United States and collecting taxes owed to the Treasury.
The Tax Scheme
MANAFORT And GATESa Wiring Money From Offshore Accounts Into The United States
14.

In order to use the money in the offshore nominee accounts of the MANAFORTaGATES

entities without paying taxes on it, MANAFORT and GATES caused millions of dollars in wire
transfers from these accounts to be made for goods, services, and real estate. They did not report
these transfers as income.
15.

From 2008 to 2014, MANAFORT caused the following wires, totaling over $12,000,000,

to be sent to the vendors listed below for personal items. MANAFORT did not pay taxes on this
income, which was used to make the purchases.
Payee
Vendor A
(Home
Improvement
Company in the
Hamptons, New
York)

Transaction
Date
6/10/2008
6/25/2008
7/7/2008
8/5/2008
9/2/2008
10/6/2008
10/24/2008
11/20/2008
12/22/2008
1/14/2009
1/29/2009
2/25/2009
4/16/2009
5/7/2009
5/12/2009
6/1/2009
6/18/2009
7/31/2009

Originating Account
Holder
LOAV Advisors Limited
LOAV Advisors Limited
LOAV Advisors Limited
Yiakora Ventures Limited
Yiakora Ventures Limited
Yiakora Ventures Limited
Yiakora Ventures Limited
Yiakora Ventures Limited
Yiakora Ventures Limited
Yiakora Ventures Limited
Yiakora Ventures Limited
Yiakora Ventures Limited
Yiakora Ventures Limited
Yiakora Ventures Limited
Yiakora Ventures Limited
Yiakora Ventures Limited
Yiakora Ventures Limited
Yiakora Ventures Limited
8

Country of
Origination
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus

Amount of
Transaction
$107,000
$23,500
$20,000
$59,000
$272,000
$109,000
$107,800
$77,400
$100,000
$9,250
$97,670
$108,100
$94,394
$54,000
$9,550
$86,650
$34,400
$106,000

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 9 of 37

Payee

Transaction
Date
8/28/2009
9/23/2009
10/26/2009
11/18/2009
3/8/2010
5/11/2010
7/8/2010
7/23/2010
8/12/2010
9/2/2010
10/6/2010
10/14/2010
10/18/2010
12/16/2010
2/7/2011
3/22/2011
4/4/2011
5/3/2011
5/16/2011
5/31/2011
6/27/2011
7/27/2011
10/24/2011
10/25/2011
11/15/2011
11/23/2011
11/29/2011
12/12/2011
1/17/2012
1/20/2012
2/9/2012
2/23/2012
2/28/2012
3/28/2012
4/18/2012
5/15/2012
6/5/2012
6/19/2012

Originating Account
Holder
Yiakora Ventures Limited
Yiakora Ventures Limited
Yiakora Ventures Limited
Global Highway Limited
Global Highway Limited
Global Highway Limited
Global Highway Limited
Leviathan Advisors Limited
Leviathan Advisors Limited
Yiakora Ventures Limited
Global Highway Limited
Yiakora Ventures Limited
Leviathan Advisors Limited
Global Highway Limited
Global Highway Limited
Leviathan Advisors Limited
Leviathan Advisors Limited
Global Highway Limited
Leviathan Advisors Limited
Leviathan Advisors Limited
Leviathan Advisors Limited
Leviathan Advisors Limited
Global Highway Limited
Global Highway Limited
Global Highway Limited
Global Highway Limited
Global Highway Limited
Leviathan Advisors Limited
Global Highway Limited
Global Highway Limited
Global Highway Limited
Global Highway Limited
Global Highway Limited
Peranova
Lucicle Consultants Limited
Lucicle Consultants Limited
Lucicle Consultants Limited
Lucicle Consultants Limited
9

Country of
Origination
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus

Amount of
Transaction
$37,000
$203,500
$38,800
$130,906
$124,000
$25,000
$28,000
$26,500
$138,900
$31,500
$67,600
$107,600
$31,500
$46,160
$36,500
$26,800
$195,000
$95,000
$6,500
$70,000
$39,900
$95,000
$22,000
$9,300
$74,000
$22,300
$6,100
$17,800
$29,800
$42,600
$22,300
$75,000
$22,300
$37,500
$50,000
$79,000
$45,000
$11,860

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 10 of 37

Payee

Vendor B
(Home
Automation,
Lighting and
Home
Entertainment
Company in
Florida)

Transaction
Date
7/9/2012
7/18/2012
8/7/2012
9/27/2012
11/20/2012
12/20/2012
1/29/2013
3/12/2013
8/29/2013
11/13/2013
11/26/2013
12/6/2013
12/12/2013
4/22/2014
8/18/2014
3/22/2011
3/28/2011
4/27/2011
5/16/2011
11/15/2011
11/23/2011
2/28/2012
10/31/2012
12/17/2012
1/15/2013
1/24/2013
2/12/2013
2/26/2013
7/15/2013
11/5/2013

Vendor C
(Antique Rug
Store in
Alexandria,
Virginia)

10/7/2008
3/17/2009
4/16/2009
4/27/2009
5/7/2009

Originating Account
Country of
Holder
Origination
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Global Endeavour Inc.
Grenadines
Global Endeavour Inc.
Grenadines
Global Endeavour Inc.
Grenadines
Global Endeavour Inc.
Grenadines
Grenadines
Global Endeavour Inc.
Global Endeavour Inc.
Grenadines
Grenadines
Global Endeavour Inc.
Vendor A Total
Leviathan Advisors Limited Cyprus
Leviathan Advisors Limited Cyprus
Leviathan Advisors Limited Cyprus
Leviathan Advisors Limited Cyprus
Global Highway Limited
Cyprus
Global Highway Limited
Cyprus
Global Highway Limited
Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
United
Pompolo Limited
Kingdom
Global Endeavour Inc.
Grenadines
Vendor B Total
Yiakora Ventures Limited
Cyprus
Yiakora Ventures Limited
Cyprus
Yiakora Ventures Limited
Cyprus
Yiakora Ventures Limited
Cyprus
Yiakora Ventures Limited
Cyprus
10

Amount of
Transaction
$10,800
$88,000
$48,800
$100,000
$298,000
$55,000
$149,000
$375,000
$200,000
$75,000
$80,000
$130,000
$90,000
$56,293
$34,660
$5,434,793
$12,000
$25,000
$12,000
$25,000
$17,006
$11,000
$6,200
$290,000
$160,600
$194,000
$6,300
$51,600
$260,000
$175,575
$73,000
$1,319,281
$15,750
$46,200
$7,400
$65,000
$210,000

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 11 of 37

Payee

Vendor D
(Related to
Vendor C)
Vendor E
(Menas Clothing
Store in New
York)

Transaction
Originating Account
Date
Holder
7/15/2009 Yiakora Ventures Limited
3/31/2010 Yiakora Ventures Limited
6/16/2010 Global Highway Limited

2/28/2012 Global Highway Limited

11/7/2008
2/5/2009
4/27/2009
10/26/2009
3/30/2010
5/11/2010
6/28/2010
8/12/2010
11/17/2010
2/7/2011
3/22/2011
3/28/2011
4/27/2011
6/30/2011
9/26/2011
11/2/2011
12/12/2011
2/9/2012
2/28/2012
3/14/2012
4/18/2012
5/15/2012
6/19/2012
8/7/2012
11/20/2012
12/20/2012
1/15/2013
2/12/2013
2/26/2013
9/3/2013

Country of
Origination
Cyprus
Cyprus
Cyprus
Vendor C Total
Cyprus

Vendor D Total
Yiakora Ventures Limited
Cyprus
Yiakora Ventures Limited
Cyprus
Yiakora Ventures Limited
Cyprus
Yiakora Ventures Limited
Cyprus
Yiakora Ventures Limited
Cyprus
Global Highway Limited
Cyprus
Leviathan Advisors Limited Cyprus
Leviathan Advisors Limited Cyprus
Global Highway Limited
Cyprus
Global Highway Limited
Cyprus
Leviathan Advisors Limited Cyprus
Leviathan Advisors Limited Cyprus
Leviathan Advisors Limited Cyprus
Global Highway Limited
Cyprus
Leviathan Advisors Limited Cyprus
Global Highway Limited
Cyprus
Leviathan Advisors Limited Cyprus
Global Highway Limited
Cyprus
Global Highway Limited
Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Global Endeavour Inc.
Grenadines
11

Amount of
Transaction
$200,000
$140,000
$250,000
$934,350
$100,000
$100,000
$32,000
$22,750
$13,500
$32,500
$15,000
$39,000
$5,000
$32,500
$11,500
$24,000
$43,600
$12,000
$3,000
$24,500
$12,000
$26,700
$46,000
$2,800
$16,000
$8,000
$48,550
$7,000
$21,600
$15,500
$10,900
$7,500
$37,000
$7,000
$39,000
$81,500

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 12 of 37

Payee

Transaction
Date
10/15/2013
11/26/2013
4/24/2014
9/11/2014

Vendor F
(Landscaper in
the Hamptons,
New York)

4/27/2009
5/12/2009
6/1/2009
6/18/2009
9/21/2009
5/11/2010
6/28/2010
7/23/2010
9/2/2010
10/6/2010
10/18/2010
12/16/2010
3/22/2011
5/3/2011
6/1/2011
7/27/2011
8/16/2011
9/19/2011
10/24/2011
11/2/2011

Vendor G
(Antique Dealer
in New York)

9/2/2010
10/18/2010
2/28/2012
3/14/2012
2/26/2013

Vendor H
(Clothing Store
in Beverly Hills,
California)

6/25/2008
12/16/2008
12/22/2008
8/12/2009
5/11/2010
11/17/2010

Originating Account
Holder
Global Endeavour Inc.
Global Endeavour Inc.
Global Endeavour Inc.
Global Endeavour Inc.

Country of
Origination
Grenadines
Grenadines
Grenadines
Grenadines
Vendor E Total
Yiakora Ventures Limited
Cyprus
Yiakora Ventures Limited
Cyprus
Yiakora Ventures Limited
Cyprus
Yiakora Ventures Limited
Cyprus
Yiakora Ventures Limited
Cyprus
Global Highway Limited
Cyprus
Leviathan Advisors Limited Cyprus
Leviathan Advisors Limited Cyprus
Yiakora Ventures Limited
Cyprus
Global Highway Limited
Cyprus
Leviathan Advisors Limited Cyprus
Global Highway Limited
Cyprus
Leviathan Advisors Limited Cyprus
Global Highway Limited
Cyprus
Leviathan Advisors Limited Cyprus
Leviathan Advisors Limited Cyprus
Leviathan Advisors Limited Cyprus
Leviathan Advisors Limited Cyprus
Global Highway Limited
Cyprus
Global Highway Limited
Cyprus
Vendor F Total
Yiakora Ventures Limited
Cyprus
Leviathan Advisors Limited Cyprus
Global Highway Limited
Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Vendor G Total
LOAV Advisors Limited
Cyprus
Yiakora Ventures Limited
Cyprus
Yiakora Ventures Limited
Cyprus
Yiakora Ventures Limited
Cyprus
Global Highway Limited
Cyprus
Global Highway Limited
Cyprus
12

Amount of
Transaction
$53,000
$13,200
$26,680
$58,435
$849,215
$34,000
$45,700
$21,500
$29,000
$21,800
$44,000
$50,000
$19,000
$21,000
$57,700
$26,000
$20,000
$50,000
$40,000
$44,000
$27,000
$13,450
$12,000
$42,000
$37,350
$655,500
$165,000
$165,000
$190,600
$75,000
$28,310
$623,910
$52,000
$49,000
$10,260
$76,400
$85,000
$128,280

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 13 of 37

Payee

Vendor I
(Investment
Company)

Transaction
Originating Account
Country of
Date
Holder
Origination
5/31/2011 Leviathan Advisors Limited Cyprus
11/15/2011 Global Highway Limited
Cyprus
12/17/2012 Lucicle Consultants Limited Cyprus
Vendor H Total
9/3/2013 Global Endeavour Inc.

Vendor J
(Contractor in
Florida)

11/15/2011
12/5/2011
12/21/2011
2/9/2012
5/17/2012
6/19/2012
7/18/2012
9/19/2012
11/30/2012
1/9/2013
2/28/2013

Vendor K
(Landscaper in
the Hamptons,
New York)

12/5/2011
3/1/2012
6/6/2012
6/25/2012
6/27/2012
2/12/2013
7/15/2013
11/26/2013

Vendor L
(Payments
Relating to Three
Range Rovers)
Vendor M

4/12/2012
5/2/2012

Grenadines

Vendor I Total
Global Highway Limited
Cyprus
Leviathan Advisors Limited Cyprus
Black Sea View Limited
Cyprus
Global Highway Limited
Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Vendor J Total
Leviathan Advisors Limited Cyprus
Global Highway Limited
Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
United
Pompolo Limited
Kingdom
Grenadines
Global Endeavour Inc.
Vendor K Total
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus

6/29/2012 Lucicle Consultants Limited Cyprus
Vendor L Total
11/20/2012 Lucicle Consultants Limited Cyprus
12/7/2012 Lucicle Consultants Limited Cyprus
13

Amount of
Transaction
$64,000
$48,000
$7,500
$520,440
$500,000
$500,000
$8,000
$11,237
$20,000
$51,000
$68,000
$60,000
$32,250
$112,000
$39,700
$25,600
$4,700
$432,487
$4,115
$50,000
$47,800
$17,900
$18,900
$3,300
$13,325
$9,400
$164,740
$83,525
$12,525
$67,655
$163,705
$45,000
$21,000

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 14 of 37

Payee
(Contractor in
Virginia)

Vendor N
(Audio, Video,
and Control
System Home
Integration and
Installation
Company in the
Hamptons, New
York)

Transaction
Date
12/17/2012
1/17/2013
1/29/2013
2/12/2013
1/29/2009
3/17/2009
4/16/2009
12/2/2009
3/8/2010
4/23/2010

Originating Account
Country of
Holder
Origination
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Lucicle Consultants Limited Cyprus
Vendor M Total
Yiakora Ventures Limited
Cyprus
Yiakora Ventures Limited
Cyprus
Yiakora Ventures Limited
Cyprus
Global Highway Limited
Cyprus
Global Highway Limited
Cyprus
Yiakora Ventures Limited
Cyprus

7/29/2010 Leviathan Advisors Limited

Cyprus

Vendor N Total
Vendor O
(Purchase of
Mercedes Benz)

10/5/2012 Lucicle Consultants Limited Cyprus
Vendor O Total

Vendor P
(Purchase of
Range Rover)
Vendor Q
(Property
Management
Company in
South Carolina)

12/30/2008 Yiakora Ventures Limited

9/2/2010
10/6/2010
10/18/2010
2/8/2011

Vendor P Total
Yiakora Ventures Limited
Cyprus
Global Highway Limited
Cyprus
Leviathan Advisors Limited Cyprus
Global Highway Limited
Cyprus

2/9/2012 Global Highway Limited
Vendor R
(Art Gallery in
Florida)
Vendor S

Cyprus

2/9/2011 Global Highway Limited

Cyprus
Vendor Q Total
Cyprus

Amount of
Transaction
$21,000
$18,750
$9,400
$10,500
$125,650
$10,000
$21,725
$24,650
$10,000
$20,300
$8,500
$17,650
$112,825
$62,750
$62,750
$47,000
$47,000
$10,000
$10,000
$10,000
$13,500
$2,500
$46,000
$17,900

2/14/2013 Lucicle Consultants Limited Cyprus

$14,000

Vendor R Total
9/26/2011 Leviathan Advisors Limited Cyprus
9/19/2012 Lucicle Consultants Limited Cyprus

$31,900
$5,000
$5,000

14

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 15 of 37

Transaction
Date

Payee
(Housekeeping
in New York)

16.

Originating Account
Holder

Country of
Origination

10/9/2013 Global Endeavour Inc.

Amount of
Transaction

Grenadines

$10,000

Vendor S Total

$20,000

In 2012, MANAFORT caused the following wires to be sent to the entities listed below to

purchase the real estate also listed below. MANAFORT did not report the money used to make
these purchases on his 2012 tax return.

Property
Purchased

Payee

Howard Street DMP
Condominium International
(New York)
LLC
Union Street
Brownstone,
(New York)

Attorney
Account Of
[Real Estate
Attorney]

Arlington
House
(Virginia)

Real Estate
Trust

Originating
Account

Date

2/1/2012 Peranova
Actinet Trading
Limited
Actinet Trading
11/29/2012
Limited
11/29/2012

8/31/2012

Lucicle Consultants
Limited

Country of
Origin

Amount

Cyprus

$1,500,000

Cyprus

$1,800,000

Cyprus

$1,200,000

Cyprus

$1,900,000

Total

17.

$6,400,000

MANAFORT and GATES also disguised, as purported aloans,a more than $10 million

transferred from Cypriot entities, including the overseas MANAFORTaGATES entities, to
domestic entities owned by MANAFORT. For example, a $1.5 million wire from Peranova to
DMI that MANAFORT used to purchase real estate on Howard Street in Manhattan, New York,
was recorded as a aloana from Peranova to DMI, rather than as income. The following loans were
shams designed to reduce fraudulently MANAFORTas reported taxable income.

15

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 16 of 37

Year

Payor / Ostensible
aLendera

2008

Yiakora Ventures Limited

2008
2009
2009
2012
2014
2015

Yiakora Ventures Limited
Yiakora Ventures Limited
Yiakora Ventures Limited
Peranova
Telmar Investments Ltd.
Telmar Investments Ltd.

18.

Payee / Ostensible
aBorrowera
Jesand Investment
Corporation
DMP
DMP
Daisy Manafort, LLC
DMI
DMI
DMI

Country of
Origin

Total Amount
of aLoansa

Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Total

$8,120,000
$500,000
$694,000
$500,000
$1,500,000
$900,000
$1,000,000
$13,214,000

From 2010 to 2014, GATES caused the following wires, totaling more than $3,000,000, to

be sent to entities and bank accounts of which he was a beneficial owner or he otherwise controlled.
GATES did not report this income on his tax returns.

Payee
Richard Gates
United Kingdom
Bank Account A
Richard Gates
United Kingdom
Bank Account B
Richard Gates
United States
Bank Account C
Jemina LLC
United States
Bank Account D
Richard Gates
United Kingdom
Bank Account B
Richard Gates
United Kingdom
Bank Account B

Transaction
Date
3/26/2010
4/20/2010
5/6/2010
9/7/2010

Originating Account
Holder
Serangon Holdings Limited
Serangon Holdings Limited
Serangon Holdings Limited
Serangon Holdings Limited

Country of
Origination
Cyprus
Cyprus
Cyprus
Cyprus

Amount of
Transaction
$85,000
$50,000
$150,000
$160,000

10/13/2010 Serangon Holdings Limited

Cyprus

$15,000

9/27/2010 Global Highway Limited

Cyprus

$50,000

2010 Tax Year Total

$510,000

9/9/2011 Peranova

Cyprus

$48,500

12/16/2011 Peranova

Cyprus

$100,435

1/9/2012
1/13/2012
2/29/2012
3/27/2012

2011 Tax Year Total
Global Highway Limited
Cyprus
Peranova
Cyprus
Global Highway Limited
Cyprus
Bletilla Ventures Limited
Cyprus
16

$148,935
$100,000
$100,435
$28,500
$18,745

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 17 of 37

Payee

Richard Gates
United Kingdom
Bank Account B

Transaction
Date
4/26/2012
5/30/2012
5/30/2012
6/27/2012
8/2/2012
8/30/2012
9/27/2012
10/31/2012
11/20/2012
11/30/2012
12/21/2012
12/28/2012
1/11/2013
1/22/2013
1/30/2013
2/22/2013
2/28/2013
3/1/2013
3/15/2013
4/15/2013
4/26/2013
5/17/2013
5/30/2013
6/13/2013
8/7/2013

Jemina LLC
United States
Bank Account D

9/6/2013
9/13/2013
7/8/2013
9/4/2013
10/22/2013
11/12/2013
12/20/2013

Jemina LLC
United States
Bank Account D

2/10/2014
4/29/2014
10/6/2014

Originating Account
Country of
Holder
Origination
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
Lucicle Consultants Limited Cyprus
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
2012 Tax Year Total
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
Bletilla Ventures Limited
Cyprus
Olivenia Trading Limited
Cyprus
Actinet Trading Limited
Cyprus
Lucicle Consultants Limited Cyprus
United
Pompolo Limited
Kingdom
Lucicle Consultants Limited Cyprus
Cypriot Agent
Cyprus
Marziola Holdings Limited Cyprus
Marziola Holdings Limited Cyprus
Cypriot Agent
Cyprus
Cypriot Agent
Cyprus
Cypriot Agent
Cyprus
2013 Tax Year Total
Cypriot Agent
Cyprus
Cypriot Agent
Cyprus
Global Endeavour Inc.
Grenadines
17

Amount of
Transaction
$26,455
$15,000
$14,650
$18,745
$28,745
$38,745
$32,345
$46,332
$48,547
$38,532
$47,836
$47,836
$651,448
$47,836
$34,783
$46,583
$46,233
$46,583
$42,433
$37,834
$59,735
$48,802
$57,798
$45,622
$76,343
$250,784
$68,500
$179,216
$72,500
$89,807
$119,844
$80,000
$90,000
$1,541,237
$60,044
$44,068
$65,000

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 18 of 37

Payee
Bade LLC
United States
Bank Account E

Transaction
Date

Originating Account
Holder

11/25/2014 Global Endeavour Inc.

Country of
Origination
Grenadines

2014 Tax Year Total

Amount of
Transaction
$120,000
$289,112

MANAFORT And GATESa Hiding Foreign Bank Accounts And False Filings
19.

United States citizens who have authority over certain foreign bank accountsawhether or

not the accounts are set up in the names of nominees who act for their principalsahave reporting
obligations to the United States.
20.

First, the Bank Secrecy Act and its implementing regulations require United States citizens

to report to the Treasury any financial interest in, or signatory authority over, any bank account or
other financial account held in foreign countries, for every calendar year in which the aggregate
balance of all such foreign accounts exceeds $10,000 at any point during the year. This is
commonly known as a foreign bank account report or aFBAR.a The Bank Secrecy Act requires
these reports because they have a high degree of usefulness in criminal, tax, or regulatory
investigations or proceedings. The Treasuryas Financial Crimes Enforcement Network (FinCEN)
is the custodian for FBAR filings, and FinCEN provides access to its FBAR database to law
enforcement entities, including the Federal Bureau of Investigation.

The reports filed by

individuals and businesses are used by law enforcement to identify, detect, and deter money
laundering that furthers criminal enterprise activity, tax evasion, and other unlawful activities.
21.

Second, United States citizens also are obligated to report information to the IRS regarding

foreign bank accounts. For instance, in 2010, Schedule B of IRS Form 1040 had a aYesa or aNoa
box to record an answer to the question: aAt any time during [the calendar year], did you have an
interest in or a signature or other authority over a financial account in a foreign country, such as a
18

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 19 of 37

bank account, securities account, or other financial account?a If the answer was aYes,a then the
form required the taxpayer to enter the name of the foreign country in which the financial account
was located.
22.

For each year in or about and between 2008 through at least 2014, MANAFORT had

authority over foreign accounts that required an FBAR filing. Specifically, MANAFORT was
required to report to the Treasury each foreign bank account held by the foreign MANAFORTa
GATES entities noted above in paragraph 12 that bears the initials PM. No FBAR filings were
made by MANAFORT for these accounts.
23.

For each year in or about and between 2010 through at least 2013, GATES had authority

over foreign accounts that required an FBAR filing. Specifically, GATES was required to report
to the United States Treasury each foreign bank account held by the foreign MANAFORTa
GATES entities noted above in paragraph 12 that bears the initials RG, as well as United Kingdom
Bank Accounts A and B noted in paragraph 18. No FBAR filings were made by GATES for these
accounts.
24.

Furthermore, in each of MANAFORTas tax filings for 2008 through 2014, MANAFORT,

with the assistance of GATES, represented falsely that he did not have authority over any foreign
bank accounts. MANAFORT and GATES had repeatedly and falsely represented in writing to
MANAFORTas tax preparer that MANAFORT had no authority over foreign bank accounts,
knowing that such false representations would result in false tax filings in MANAFORTas name.
For instance, on October 4, 2011, MANAFORTas tax preparer asked MANAFORT in writing: aAt
any time during 2010, did you [or your wife or children] have an interest in or a signature or other
authority over a financial account in a foreign country, such as a bank account, securities account
or other financial account?a

On the same day, MANAFORT falsely responded aNO.a
19

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 20 of 37

MANAFORT responded the same way as recently as October 3, 2016, when MANAFORTas tax
preparer again emailed the question in connection with the preparation of MANAFORTas tax
returns: aForeign bank accounts etc.?a MANAFORT responded on or about the same day:
aNONE.a
25.

In each of GATESa tax filings for 2010 through 2013, GATES represented falsely that he

did not have authority over any foreign bank accounts. GATES had repeatedly and falsely
represented to his tax preparers that he had no authority over foreign bank accounts, knowing that
such false representations would result in false tax filings. As recently as October 2017, in
preparation for his amended 2013 tax filing, GATES was asked by his tax preparer: aDid you have
any foreign assets/bank accounts during 2013 or 2014?a to which he responded ano.a
The Financial Institution Scheme
26.

Between in or around 2015 and the present, both dates being approximate and inclusive, in

the Eastern District of Virginia and elsewhere, MANAFORT, GATES, and others devised and
intended to devise, and executed and attempted to execute, a scheme and artifice to defraud, and
to obtain money and property, by means of false and fraudulent pretenses, representations, and
promises, from banks and other financial institutions. As part of the scheme, MANAFORT and
GATES repeatedly provided and caused to be provided false information to banks and other
lenders, among others.
MANAFORT And GATESa Fraud To Access Offshore Money
27.

When they were flush with Ukraine funds, MANAFORT, with the assistance of GATES,

used their offshore accounts to purchase and improve real estate in the United States. When the
income from Ukraine dwindled in 2014 and 2015, MANAFORT, with the assistance of GATES,
obtained millions of dollars in mortgages on the United States properties, thereby allowing
20

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 21 of 37

MANAFORT to have the benefits of liquid income without paying taxes on it. MANAFORT and
GATES defrauded the lenders in various ways, including by lying about MANAFORTas and
DMIas income, lying about their debt, and lying about MANAFORTas use of the property and the
loan proceeds. For example, MANAFORT and GATES submitted fabricated profit and loss
statements (P&Ls) that inflated income, and they caused others to provide doctored financial
documents.
A. The Loan From Lender A On The Union Street Property
28.

In 2012, MANAFORT, through a corporate vehicle called aMC Brooklyn Holdings, LLCa

owned by him and his family, bought a brownstone on Union Street in the Carroll Gardens section
of Brooklyn, New York. He paid approximately $3,000,000 in cash for the property. All of that
money came from a MANAFORTaGATES entity in Cyprus. After purchase of the property,
MANAFORT began renovations to transform it from a multi-family dwelling into a single-family
home. MANAFORT used proceeds of a 2015 loan obtained from a financial institution to make
the renovations. In order to obtain that loan, MANAFORT falsely represented to the bank that he
did not derive more than 50% of his income/wealth from a country outside the United States.
29.

In late 2015 through early 2016, MANAFORT sought to borrow cash against the Union

Street property from Lender A. Lender A provided greater loan amounts for aconstruction
loansaathat is, loans that required the loan funds to be used to pay solely for construction on the
property and thus increase the value of the property serving as the loanas collateral. The institution
would thus loan money against the expected completed value of the property, which in the case of
the Union Street property was estimated to be $8,000,000. In early 2016, MANAFORT was able
to obtain a loan of approximately $5,000,000, after promising Lender A that approximately
$1,400,000 of the loan would be used solely for construction on the Union Street property.
21

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 22 of 37

MANAFORT never intended to limit use of the proceeds to construction as required by the loan
contracts and never did. In December 2015, before the loan was made, MANAFORT wrote his
tax preparer, among others, that the aconstruction mortgage will allow me to pay back [another
Manafort apartment] mortgage in full. . . .a

Further, when the construction loan closed,

MANAFORT used hundreds of thousands of dollars for purposes unrelated to the construction of
the property.
B. The Loan From Lender B On The Howard Street Property
30.

In 2012, MANAFORT, through a corporate vehicle called aMC Soho Holdings, LLCa

owned by him and his family, bought a condominium on Howard Street in the Soho neighborhood
of Manhattan, New York. He paid approximately $2,850,000. All the money used to purchase
the condominium came from MANAFORTaGATES entities in Cyprus. MANAFORT used the
property from at least January 2015 through at least August 2017 as an income-generating rental
property, charging thousands of dollars a week on Airbnb, among other places. On his tax returns,
MANAFORT took advantage of the beneficial tax consequences of owning this rental property.
31.

In late 2015 through early 2016, MANAFORT applied for a mortgage on the Howard Street

condominium from Lender B for approximately $3.4 million. Because the bank would permit a
greater loan amount if the property were owner-occupied, MANAFORT falsely represented to the
lender and its agents that it was a secondary home used as such by his daughter and son-in-law
and was not held as a rental property. In an email on January 6, 2016, MANAFORT noted: a[i]n
order to have the maximum benefit, I am claiming Howard St. as a second home. Not an
investment property.a Later, on January 26, 2016, MANAFORT wrote to his son-in-law to advise
him that when the bank appraiser came to assess the condominium, his son-in-law should
a[r]emember, he believes that you and [MANAFORTas daughter] are living there.a
22

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32.

MANAFORT, with GATESa assistance, also made a series of false and fraudulent

representations to the bank in order to secure the millions of dollars in financing. For example,
MANAFORT falsely represented the amount of debt he had by failing to disclose on his loan
application the existence of the Lender A mortgage on his Union Street property. That liability
would have risked his qualifying for the loan. Through its own due diligence, Lender B found
evidence of the existing mortgage on the Union Street property. As a result, Lender B wrote to
MANAFORT and GATES that the aapplication has the following properties as being owned free
& clear . . . Union Street,a but a[b]ased on the insurance binders that we received last night, we
are showing that there are mortgages listed on these properties, can you please clarify[?]a
33.

To cover up the falsity of the loan application, GATES, on MANAFORTas behalf, caused

an insurance broker to provide Lender B false information, namely, an outdated insurance report
that did not list the Union Street loan. MANAFORT and GATES knew such a representation was
fraudulent. After GATES contacted the insurance broker and asked her to provide Lender B with
false information, he updated MANAFORT by email on February 24, 2016. MANAFORT replied
to GATES, on the same day: agood job on the insurance issues.a
34.

MANAFORT and GATES submitted additional false and fraudulent statements to Lender

B. For example, MANAFORT submitted 2014 DMI tax returns to support his 2016 loan
application to Lender B. Those tax returns included as a purported liability a $1.5 million loan
from Peranova. Peranova was a Cypriot entity controlled by MANAFORT and GATES. On or
about February 1, 2012, Peranova transferred $1.5 million to a DMI account in the United States,
denominating the transfer as a loan so that MANAFORT would not have to declare the money as
income. MANAFORT used the aloana to acquire the Howard Street property.
35.

When MANAFORT needed to obtain a loan from Lender B, the existence of the Peranova
23

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aloana undermined his creditworthiness. As a result of the listed Peranova liability, Lender B was
not willing to make the loan to MANAFORT. To circumvent this issue, MANAFORT and
GATES caused MANAFORTas tax accountant to send to Lender B back-dated documentation that
falsely stated that the $1.5 million Peranova loan had been forgiven in 2015, and falsely inflated
income for 2015 to mask MANAFORTas 2015 drop in income.
36.

In March 2016, Lender B approved the loan in the amount of approximately $3.4 million

(the $3.4 million loan).
C. The Loan From Lender C
37.

In approximately February 2016, MANAFORT applied for a business loan from Lender C.

MANAFORT made a series of false statements to Lender C. For example, MANAFORT
submitted a false statement of assets and liabilities that failed to disclosed the Lender A loan on
the Union Street property and misrepresented, among other things, the amount of the mortgage on
the Howard Street property.
38.

Further, in approximately March 2016, MANAFORT and GATES submitted a doctored

2015 DMI P&L that overstated DMIas 2015 income by more than $4 million. GATES asked
DMIas bookkeeper to send him a aWord Document version of the 2015 P&L for [DMI]a because
MANAFORT wanted GATES ato add the accrual revenue which we have not received in order to
send to [Lender C].a The bookkeeper said she could send a .pdf version of the P&L. GATES then
asked the bookkeeper to increase the DMI revenue, falsely claiming that: a[w]e have $2.4m in
accrued revenue that [MANAFORT] wants added to the [DMI] 2015 income. Can you make
adjustments on your end and then just send me a new scanned version[?]a The bookkeeper refused
since the accounting method DMI used did not permit recording income before it was actually
received.
24

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39.

Having failed to secure a falsified P&L from the bookkeeper, GATES falsified the P&L.

GATES wrote to MANAFORT and another conspirator, aI am editing Paulas 2015 P&L
statement.a GATES then sent the altered P&L to Lender C, which claimed approximately $4.45
million in net income, whereas the true P&L had less than $400,000 in net income.
D. The Loan From Lender B On The Union Street Property
40.

In March 2016, MANAFORT, with the assistance of GATES and others, applied for a $5.5

million loan from Lender B on the Union Street property.

As part of the loan process,

MANAFORT submitted a false statement of assets and liabilities that hid his prior loan from
Lender A on the Union Street property, among other liabilities. In addition, another conspirator
on MANAFORTas behalf submitted a falsified 2016 DMI P&L. The falsified 2016 DMI P&L
overstated DMIas income by more than $2 million, which was the amount that Lender B told
MANAFORT he needed to qualify for the loan. When the document was first submitted to Lender
B, a conspirator working at Lender B replied: aLooks Drad. Canat someone just do a clean excel
doc and pdf to me??a A subsequent version was submitted to the bank.
E. The Loans From Lender D On The Bridgehampton And Union Street Properties
41.

In 2016, MANAFORT sought a mortgage on property in Bridgehampton, New York from

a financial institution. In connection with his application, MANAFORT falsely represented to the
bank that DMI would be receiving $2.4 million in income later in the year for work on a
ademocratic development consulting project.a

To support this representation, GATES, on

MANAFORTas behalf, provided the bank with a fake invoice for $2.4 million, directed aTo Whom
It May Concern,a for a[s]ervices rendered per the consultancy agreement pertaining to the
parliamentary elections.a The bank, unwilling to rely on the invoice to support MANAFORTas
stated 2016 income, requested additional information. The bank was unable to obtain satisfactory
25

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support for the stated income, and the loan application was denied.
42.

MANAFORT applied to a second bank, Lender D. Between approximately July 2016 and

January 2017, MANAFORT, with the assistance of GATES, sought and secured approximately
$16,000,000 in two loans from Lender D. MANAFORT used the Bridgehampton property as
collateral for one loan, and the Union Street property for the other.
43.

MANAFORT and GATES made numerous false and fraudulent representations to secure

the loans. For example, MANAFORT provided the bank with doctored P&Ls for DMI for both
2015 and 2016, overstating its income by millions of dollars. The doctored 2015 DMI P&L
submitted to Lender D was the same false statement previously submitted to Lender C, which
overstated DMIas income by more than $4 million. The doctored 2016 DMI P&L was inflated by
MANAFORT by more than $3.5 million. To create the false 2016 P&L, on or about October 21,
2016, MANAFORT emailed GATES a .pdf version of the real 2016 DMI P&L, which showed a
loss of more than $600,000. GATES converted that .pdf into a aWorda document so that it could
be edited, which GATES sent back to MANAFORT. MANAFORT altered that aWorda document
by adding more than $3.5 million in income. He then sent this falsified P&L to GATES and asked
that the aWorda document be converted back to a .pdf, which GATES did and returned to
MANAFORT. MANAFORT then sent the falsified 2016 DMI P&L .pdf to Lender D.
44.

In addition, Lender D questioned MANAFORT about a $300,000 delinquency on his

American Express card, which was more than 90 days past due. The delinquency significantly
affected MANAFORTas credit rating score. MANAFORT falsely represented to Lender D that
he had lent his credit card to a friend, GATES, who had incurred the charges and had not
reimbursed him. MANAFORT supplied Lender D a letter from GATES that falsely stated that

26

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GATES had borrowed MANAFORTas credit card to make the purchases at issue and would pay
him back by a date certain.
Statutory Allegations
COUNTS ONE THROUGH FIVE
(Subscribing to False United States Individual Income
Tax Returns For 2010a2014 Tax Years)
45.

Paragraphs 1 through 44 are incorporated here.

46.

On or about the dates specified below, in the Eastern District of Virginia and elsewhere,

defendant PAUL J. MANAFORT, JR., willfully and knowingly did make and subscribe, and aid
and abet and cause to be made and subscribed, United States Individual Income Tax Returns,
Forms 1040 and Schedule B, for the tax years set forth below, which returns contained and were
verified by the written declaration of MANAFORT that they were made under penalties of perjury,
and which returns MANAFORT did not believe to be true and correct as to every material matter,
in that the returns (a) claimed that MANAFORT did not have a financial interest in and signature
and other authority over a financial account in a foreign country and (b) failed to report income,
whereas MANAFORT then and there well knew and believed that he had a financial interest in,
and signature and other authority over, bank accounts in a foreign country and had earned total
income in excess of the reported amounts noted below:

COUNT

TAX
YEAR

APPROX. FILING
DATE

1
2
3
4
5

2010
2011
2012
2013
2014

October 14, 2011
October 15, 2012
October 7, 2013
October 6, 2014
October 14, 2015

FOREIGN ACCOUNT
REPORTED
(Sch. B, Line 7a)
None
None
None
None
None

(26 U.S.C. ASS 7206(l); 18 U.S.C. ASSASS 2 and 3551 et seq.)
27

TOTAL INCOME
REPORTED
(Line 22)
$504,744
$3,071,409
$5,361,007
$1,910,928
$2,984,210

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 28 of 37

COUNTS SIX THROUGH TEN
(Assisting in the Preparation of
False United States Individual Income
Tax Returns For 2010a2014 Tax Years)
47.

Paragraphs 1 through 44 are incorporated here.

48.

On or about the dates specified below, in the Eastern District of Virginia and elsewhere,

defendant RICHARD W. GATES III willfully and knowingly did aid and assist in, and procure,
counsel, and advise the preparation and presentation to the Internal Revenue Service, of a United
States Individual Income Tax Return, Form 1040 and Schedule B, of PAUL J. MANAFORT, JR.,
for the tax years set forth below, which returns were false and fraudulent as to a material matter,
in that the returns (a) claimed that MANAFORT did not have a financial interest in, and signature
and other authority over, a financial account in a foreign country and (b) failed to report income,
whereas GATES then and there well knew and believed that MANAFORT had a financial interest
in, and signature and other authority over, bank accounts in a foreign country and had earned total
income in excess of the reported amounts noted below:
COUNT

TAX
YEAR

APPROX. FILING
DATE

6
7
8
9
10

2010
2011
2012
2013
2014

October 14, 2011
October 15, 2012
October 7, 2013
October 6, 2014
October 14, 2015

FOREIGN ACCOUNT
REPORTED
(Sch. B, Line 7a)
None
None
None
None
None

TOTAL INCOME
REPORTED
(Line 22)
$504,744
$3,071,409
$5,361,007
$1,910,928
$2,984,210

(26 U.S.C. ASS 7206(2); 18 U.S.C. ASS 3551 et seq.)
COUNTS ELEVEN THROUGH FOURTEEN
(Failure To File Reports Of Foreign Bank And Financial
Accounts For Calendar Years 2011a2014)
49.

Paragraphs 1 through 44 are incorporated here.

50.

On the filing due dates listed below, in the Eastern District of Virginia and elsewhere,
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defendant PAUL J. MANAFORT, JR., unlawfully, willfully, and knowingly did fail to file with
the Treasury an FBAR disclosing that he had a financial interest in, and signature and other
authority over, a bank, securities, and other financial account in a foreign country, which had an
aggregate value of more than $10,000 in a 12-month period, during the years listed below:
COUNT

YEAR

DUE DATE TO FILE FBAR

11
12
13
14

2011
2012
2013
2014

June 29, 2012
June 30, 2013
June 30, 2014
June 30, 2015

(31 U.S.C. ASSASS 5314 and 5322(a); 18 U.S.C. ASSASS 2 and 3551 et seq.)
COUNTS FIFTEEN THROUGH NINETEEN
(Subscribing to False United States Individual Income
Tax Returns For 2010a2014 Tax Years)
51.

Paragraphs 1 through 44 are incorporated here.

52.

On or about the dates specified below, in the Eastern District of Virginia and elsewhere,

defendant RICHARD W. GATES III willfully and knowingly did make and subscribe, and aid and
abet and cause to be made and subscribed, United States Individual Income Tax Returns, Forms
1040 and Schedule B, for the tax years set forth below, which returns contained and were verified
by the written declaration of defendant GATES that they were made under penalties of perjury,
and which returns defendant GATES did not believe to be true and correct as to every material
matter, in that the returns (a) claimed that GATES did not have a financial interest in, and signature
and other authority over, a financial account in a foreign country and (b) failed to report income,
whereas GATES then and there well knew and believed that he had a financial interest in, and
signature and other authority over, a financial account in a foreign country and had earned total
income in excess of the reported amounts noted below:
29

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COUNT

TAX
YEAR

APPROX. FILING
DATE

15
16
17
18
19

2010
2011
2012
2013
2014

July 26, 2011
October 11, 2012
October 15, 2013
October 15, 2014
October 14, 2015

FOREIGN ACCOUNT
REPORTED
(Sch. B, Line 7a)
None
None
None
None
None

TOTAL INCOME
REPORTED
(Line 22)
$194,257
$250,307
$365,646
$307,363
$292,892

(26 U.S.C. ASS 7206(l); 18 U.S.C. ASSASS 2 and 3551 et seq.)
COUNT TWENTY
(Subscribing to a False Amended United States Individual Income
Tax Return For 2013 Tax Year)
53.

Paragraphs 1 through 44 are incorporated here.

54.

On or about October 25, 2017, in the Eastern District of Virginia and elsewhere, defendant

RICHARD W. GATES III willfully and knowingly did make and subscribe, and aid and abet and
cause another to make and subscribe, a United States Individual Income Tax Return, Form 1040X,
for the 2013 tax year, which return contained and was verified by the written declaration of
defendant GATES that it was made under penalties of perjury, and which return defendant GATES
did not believe to be true and correct as to every material matter, in that the return failed to report
income, whereas GATES then and there well knew and believed that he had earned adjusted gross
income in excess of the reported amount on Line 1C, to wit: $292,055.
(26 U.S.C. ASS 7206(l); 18 U.S.C. ASSASS 2 and 3551 et seq.)
COUNTS TWENTY-ONE THROUGH TWENTY-THREE
(Failure To File Reports Of Foreign Bank And Financial
Accounts For Calendar Years 2011a2013)
55.

Paragraphs 1 through 44 are incorporated here.

56.

On the filing due dates listed below, in the Eastern District of Virginia and elsewhere,

defendant RICHARD W. GATES III unlawfully, willfully, and knowingly did fail to file with the
30

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Treasury an FBAR disclosing that he had a financial interest in, and signature authority over, a
bank, securities, and other financial account in a foreign country, which had an aggregate value of
more than $10,000 in a 12-month period, during the years listed below:

COUNT

YEAR

DUE DATE TO FILE FBAR

21

2011

June 29, 2012

22

2012

June 30, 2013

23

2013

June 30, 2014

(31 U.S.C. ASSASS 5314 and 5322(a); 18 U.S.C. ASSASS 2 and 3551 et seq.)
COUNT TWENTY-FOUR
(Bank Fraud Conspiracy / Lender B / $3.4 million loan)
57.

Paragraphs 1 through 44 are incorporated here.

58.

On or about and between December 2015 and March 2016, both dates being approximate

and inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J.
MANAFORT, JR., and RICHARD W. GATES III did knowingly and intentionally conspire to
execute a scheme and artifice to defraud one or more financial institutions, to wit: Lender B, the
deposits of which were insured by the Federal Deposit Insurance Corporation, and to obtain
moneys, funds, and credits owned by and under the custody and control of such financial institution
by means of materially false and fraudulent pretenses, representations, and promises, contrary to
Title 18, United States Code, Section 1344.
(18 U.S.C. ASSASS 1349 and 3551 et seq.)
COUNT TWENTY-FIVE
(Bank Fraud / Lender B / $3.4 million loan)
59.

Paragraphs 1 through 44 are incorporated here.

60.

On or about and between December 2015 and March 2016, both dates being approximate
31

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and inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J.
MANAFORT, JR., and RICHARD W. GATES III did knowingly and intentionally execute and
attempt to execute a scheme and artifice to defraud one or more financial institutions, to wit:
Lender B, the deposits of which were insured by the Federal Deposit Insurance Corporation, and
to obtain moneys, funds, and credits owned by and under the custody and control of such financial
institution by means of materially false and fraudulent pretenses, representations, and promises.
(18 U.S.C. ASSASS 1344, 2, and 3551 et seq.)
COUNT TWENTY-SIX
(Bank Fraud Conspiracy / Lender C / $1 million loan)
61.

Paragraphs 1 through 44 are incorporated here.

62.

On or about and between March 2016 and May 2016, both dates being approximate and

inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J. MANAFORT,
JR., and RICHARD W. GATES III did knowingly and intentionally conspire to execute a scheme
and artifice to defraud one or more financial institutions, to wit: Lender C, the deposits of which
were insured by the Federal Deposit Insurance Corporation, and to obtain moneys, funds, and
credits owned by and under the custody and control of such financial institution by means of
materially false and fraudulent pretenses, representations, and promises, contrary to Title 18,
United States Code, Section 1344.
(18 U.S.C. ASSASS 1349 and 3551 et seq.)
COUNT TWENTY-SEVEN
(Bank Fraud / Lender C / $1 million loan)
63.

Paragraphs 1 through 44 are incorporated here.

64.

On or about and between December 2015 and March 2016, both dates being approximate

and inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J.
32

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MANAFORT, JR., and RICHARD W. GATES III did knowingly and intentionally execute and
attempt to execute a scheme and artifice to defraud one or more financial institutions, to wit:
Lender C, the deposits of which were insured by the Federal Deposit Insurance Corporation, and
to obtain moneys, funds, and credits owned by and under the custody and control of such financial
institution by means of materially false and fraudulent pretenses, representations, and promises.
(18 U.S.C. ASSASS 1344, 2, and 3551 et seq.)
COUNT TWENTY-EIGHT
(Bank Fraud Conspiracy / Lender B / $5.5 million loan)
65.

Paragraphs 1 through 44 are incorporated here.

66.

On or about and between March 2016 and August 2016, both dates being approximate and

inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J. MANAFORT,
JR., and RICHARD W. GATES III did knowingly and intentionally conspire to execute a scheme
and artifice to defraud one or more financial institutions, to wit: Lender B, the deposits of which
were insured by the Federal Deposit Insurance Corporation, and to obtain moneys, funds, and
credits owned by and under the custody and control of such financial institution by means of
materially false and fraudulent pretenses, representations, and promises, contrary to Title 18,
United States Code, Section 1344.
(18 U.S.C. ASSASS 1349 and 3551 et seq.)
COUNT TWENTY-NINE
(Bank Fraud Conspiracy / Lender D / $9.5 million loan)
67.

Paragraphs 1 through 44 are incorporated here.

68.

On or about and between April 2016 and November 2016, both dates being approximate

and inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J.
MANAFORT, JR., and RICHARD W. GATES III did knowingly and intentionally conspire to
33

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execute a scheme and artifice to defraud one or more financial institutions, to wit: Lender D, the
deposits of which were insured by the Federal Deposit Insurance Corporation, and to obtain
moneys, funds, and credits owned by and under the custody and control of such financial institution
by means of materially false and fraudulent pretenses, representations, and promises, contrary to
Title 18, United States Code, Section 1344.
(18 U.S.C. ASSASS 1349 and 3551 et seq.)
COUNT THIRTY
(Bank Fraud / Lender D / $9.5 million loan)
69.

Paragraphs 1 through 44 are incorporated here.

70.

On or about and between April 2016 and November 2016, both dates being approximate

and inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J.
MANAFORT, JR., and RICHARD W. GATES III did knowingly and intentionally execute and
attempt to execute a scheme and artifice to defraud one or more financial institutions, to wit:
Lender D, the deposits of which were insured by the Federal Deposit Insurance Corporation, and
to obtain moneys, funds, and credits owned by and under the custody and control of such financial
institution by means of materially false and fraudulent pretenses, representations, and promises.
(18 U.S.C. ASS 1344, 2, and 3551 et seq.)
COUNT THIRTY-ONE
(Bank Fraud Conspiracy / Lender D / $6.5 million loan)
71.

Paragraphs 1 through 44 are incorporated here.

72.

On or about and between April 2016 and January 2017, both dates being approximate and

inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J. MANAFORT,
JR., and RICHARD W. GATES III did knowingly and intentionally conspire to execute a scheme
and artifice to defraud one or more financial institutions, to wit: Lender D, the deposits of which
34

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were insured by the Federal Deposit Insurance Corporation, and to obtain moneys, funds, and
credits owned by and under the custody and control of such financial institution by means of
materially false and fraudulent pretenses, representations, and promises, contrary to Title 18,
United States Code, Section 1344.
(18 U.S.C. ASSASS 1349 and 3551 et seq.)
COUNT THIRTY-TWO
(Bank Fraud / Lender D / $6.5 million loan)
73.

Paragraphs 1 through 44 are incorporated here.

74.

On or about and between April 2016 and January 2017, both dates being approximate and

inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J. MANAFORT,
JR., and RICHARD W. GATES III did knowingly and intentionally execute and attempt to execute
a scheme and artifice to defraud one or more financial institutions, to wit: Lender D, the deposits
of which were insured by the Federal Deposit Insurance Corporation, and to obtain moneys, funds,
and credits owned by and under the custody and control of such financial institution by means of
materially false and fraudulent pretenses, representations, and promises.
(18 U.S.C. ASSASS 1344, 2, and 3551 et seq.)
FORFEITURE NOTICE
75.

Pursuant to Fed. R. Crim. P. 32.2, notice is hereby given to the defendants that the United

States will seek forfeiture as part of any sentence in accordance with Title 18, United States Code,
Section 982(a)(2), in the event of the defendantsa convictions under Counts Twenty-Four through
Thirty-Two of this Superseding Indictment. Upon conviction of the offenses charged in Counts
Twenty-Four through Thirty-Two, defendants PAUL J. MANAFORT, JR., and RICHARD W.
GATES III shall forfeit to the United States any property constituting, or derived from, proceeds
35

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obtained, directly or indirectly, as a result of such violation(s). Notice is further given that, upon
conviction, the United States intends to seek a judgment against each defendant for a sum of money
representing the property described in this paragraph, as applicable to each defendant (to be offset
by the forfeiture of any specific property).
76.

The grand jury finds probable cause to believe that the property subject to forfeiture by

PAUL J. MANAFORT, JR., includes, but is not limited to, the following listed assets:
a. All funds held in account number XXXXXX0969 at Lender D, and any property
traceable thereto.
Substitute Assets
77.

If any of the property described above as being subject to forfeiture, as a result of any act or

omission of any defendant
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 court;

d.

has been substantially diminished in value; or

e.

has been commingled with other property that cannot be subdivided without
difficulty;

it is the intent of the United States of America, pursuant to Title 18, United States Code, Section
982(b) and Title 28, United States Code, Section 2461(c), incorporating Title 21, United States
Code, Section 853, to seek forfeiture of any other property of said defendant.
(18 U.S.C. ASS 982)

36

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Robert S. M Her, III
Special Counsel
Department of Justice

A TRUE BILL:

Foreperson
Date: February 22, 2018

37