statements related herein are related in substance and in part only. Finally, certain items related herein were translated by FBI linguists from Russian to English.
BACKGROUND
Title 18, U.S. Code, sections 371 (Conspiracy) and 951 (Agents of Foreign Governments)
3. Title 18 of the United States Code, section 371 (Conspiracy to Commit Offense or to Defraud United States), makes it a criminal offense for any person(s) to conspire together with one or more others either to commit an offense against the United States or to defraud the United States. or any agency thereof, in any manner or for any purpose.
4. Title 18 of the United States Code, section 951 (Agents of Foreign Governments), makes it a criminal offense for any person, other than a diplomatic or consular official or attaché, to act in the United States as an agent of a foreign government without prior notification to the Attorney General, as required by law. For purposes of this law, the term "agent of a foreign government" includes an individual who agrees to operate within the United States subject to the direction or control of a foreign government or official.
Relevant Persons and Definitions
5. Defendant BUTINA is a Russian citizen who entered the United States in August 2016 on an F-1 Student Visa. Before and after her arrival in the United States, BUTINA served as Special Assistant to the RUSSIAN OFFICIAL. Conspiring together, BUTINA and the RUSSIAN OFFICIAL took various overt acts in furtherance of the conspiracy and to effect the illegal purpose thereof.
6. The RUSSIAN OFFICIAL is a Russian citizen and a high-level official in the Russian government. The RUSSIAN OFFICIAL was previously a member of the legislature of the Russian Federation and later became a top official at the Russian Central Bank. The RUSSIAN OFFICIAL directed BUTINA's activities in furtherance of the conspiracy.
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