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SLUSH FUND COMPANIES
1. LT Enterprises Limited (“LT”)
LT is a company organized under the laws of the Bahamas and is controlled, directly or indirectly, by Blavatnick, Vekselberg, Spitz and Kuzmichev.
The Predicate Acts
LT, by and through its officers, directors, and above controlling persons, committed specific predicate acts of racketeering in furtherance of the Illegal Scheme. These included:
· - Mail and Wire Fraud: LT, by and through its officers and directors was managed and controlled through the use of mail and wires, including telephone calls made from the United States to Russia and other places, to bribe Russian government officials in order to effect the Illegal Scheme;
· - Wire Fraud: LT wired funds through banks in the United States in order to bribe Russian government officials as part of the Illegal Scheme;
· - Money Laundering: LT engaged in money laundering of the proceeds of the sale of petroleum from Chernogorneft, NNG, Kondpetroleum, and Yugraneft in furtherance of specified unlawful activity (i.e. bribery, extortion, mail and wire fraud, illegal transactions in monetary instruments, and Travel Act violations);
· - Illegal Transactions in Monetary Instruments: LT received “criminally derived property” from the sale of oil of NNG, Kondpetroleum, Chernogorneft, and Yugraneft through banks in the United States;
· - Travel Act Violations: The above controlling persons of LT traveled from the United States to Russia and back in aid of the racketeering of the Illegal Scheme;
· - Bribery: Upon information and belief LT, by and through its officers and directors and controlling persons, facilitated, controlled, directed and intentionally aided the bribery of Russian government officials in order to effect the Illegal Scheme in violation of N.Y.C.L.S. Penal §20 and §180.03.
Violation of 1961(a)
LT, through a pattern of racketeering, received income as a result of the Corrupt 1997 TNK Privatization and Corrupt 1999 TNK Privatization, the Corrupt NNG Takeover and Bankruptcy, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, and the Massive Tax Fraud which was effected through bribery, mail and wire fraud, economic extortion, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act. A part of such income or its proceeds were used, directly or indirectly, to acquire an interest in Yugraneft and to operate Yugraneft through the Illegal Takeover.
Violation of 1961(c)
LT, through its above controlling persons, conducted and participated in the conduct of the Access/Alfa/Astons Enterprise (association in fact) through a pattern of racketeering activity including bribery, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act in regard to the Corrupt 1997 TNK Privatization, the Corrupt 1999 TNK Privatization, the Corrupt NNG Takeover and Bankruptcy, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, the Massive Tax Fraud and the Illegal Takeover of Yugraneft.
Violation of 1961(d)
LT conspired with other defendants, and with others, to undertake and consummate the Illegal Scheme.
2. Sandwell Enterprises Limited (“Sandwell”)
Sandwell is a company organized under the laws of the Isle of Man and is controlled, directly or indirectly, by Blavatnik, Vekselberg, Spitz and Kuzmichev.
Sandwell, by and through it officers, directors, and above controlling persons, committed specific predicate acts of racketeering in furtherance of the Illegal Scheme. These included:
· - Mail and Wire Fraud: Sandwell, by and through its officers and directors was managed and controlled through the use of mail and wires, including telephone calls made from the United States to Russia and other places, to bribe Russian government officials in order to effect the Illegal Scheme;
· - Wire Fraud: Sandwell wired funds through banks in the United States in order to bribe Russian government officials as part of the Illegal Scheme;
· - Money Laundering: Sandwell engaged in money laundering of the proceeds of the sale of petroleum from Chernogorneft, NNG, Kondpetroleum, and Yugraneft in furtherance of specified unlawful activity (i.e. bribery, extortion, mail and wire fraud, illegal transactions in monetary instruments, and Travel Act violations);
· - Illegal Transactions in Monetary Instruments: Sandwell received “criminally derived property” from the sale of oil of NNG, Kondpetroleum, Chernogorneft, and Yugraneft through banks in the United States;
· - Travel Act Violations: The above controlling persons of Sandwell traveled from the United States to Russia in aid of the racketeering of the Illegal Scheme;
· - Bribery: Upon information and belief Sandwell, by and through its officers and directors and controlling persons, facilitated, controlled, directed and intentionally aided the bribery of Russian government officials in order to effect the Illegal Scheme in violation of N.Y.C.L.S. Penal §20 and §180.03.
Violation of 1961(a)
Sandwell, through a pattern of racketeering, received income as a result of the Corrupt 1997 TNK Privatization and Corrupt 1999 TNK Privatization, the Corrupt NNG Takeover and Bankruptcy, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, the Massive Tax Fraud which was effected through bribery, mail and wire fraud, economic extortion, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act. A part of such income or its proceeds were used, directly or indirectly, to acquire an interest in Yugraneft and to operate Yugraneft through the Illegal Takeover.
Violation of 1961(c)
Sandwell, through its above controlling persons, conducted and participated in the conduct of the Access/Alfa/Astons Enterprise (association in fact) through a pattern of racketeering activity including bribery, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act in regard to the Corrupt 1997 TNK Privatization, the Corrupt 1999 TNK Privatization, the Corrupt NNG Takeover and Bankruptcy, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, the Massive Tax Fraud and the Illegal Takeover of Yugraneft.
Violation of 1961(d)
Sandwell, through its above controlling persons, conspired with other defendants, to undertake and consummate the Illegal Scheme.
3. Eastmount Properties Limited (“Eastmount”)
Eastmount is a company organized under the laws of the Isle of Man and is controlled, directly or indirectly, by Blavatnick, Vekselberg, Spitz and Kuzmichev.
Eastmount, by and through its officers, directors, or above controlling persons, committed specific predicate acts of racketeering in furtherance of the Illegal Scheme. These included:
· - Mail and Wire Fraud: Eastmount, by and through its officers and directors was managed and controlled through the use of mail and wires, including telephone calls made from the United States to Russia and other places, to bribe Russian government officials in order to effect the Illegal Scheme;
· - Wire Fraud: Eastmount wired funds through banks in the United States in order to bribe Russian government officials as part of the Illegal Scheme;
· - Money Laundering: Eastmount engaged in money laundering of the proceeds of the sale of petroleum from Chernogorneft, NNG, Kondpetroleum, and Yugraneft in furtherance of specified unlawful activity (i.e. bribery, extortion, mail and wire fraud, illegal transactions in monetary instruments, and Travel Act violations);
· - Illegal Transactions in Monetary Instruments: Eastmount received “criminally derived property” from the sale of oil of NNG, Kondpetroleum, Chernogorneft, and Yugraneft through banks in the United States;
· - Travel Act Violations: The above controlling persons of Eastmount traveled from the United States to England and Russia in aid of the racketeering of the Illegal Scheme;
· - Bribery: Upon information and belief Eastmount, by and through its officers and directors and controlling persons, facilitated, controlled, directed and intentionally aided the bribery of Russian government officials in order to effect the Illegal Scheme in violation of N.Y.C.L.S. Penal §20 and §180.03.
Violation of 1961(a)
Eastmount, through the above controlling persons, through a pattern of racketeering, received income as a result of the Corrupt 1997 TNK Privatization and Corrupt 1999 TNK Privatization, the Corrupt NNG Takeover and Bankruptcy, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, the Massive Tax Fraud which was effected through bribery, mail and wire fraud, economic extortion, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act. A part of such income or its proceeds were used, directly or indirectly, to acquire an interest in Yugraneft and to operate Yugraneft through the Illegal Takeover.
Violation of 1961(c)
Eastmount, conducted and participated in the conduct of the Access/Alfa/Astons Enterprise (association in fact) through a pattern of racketeering activity including bribery, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act in regard to the Corrupt 1997 TNK Privatization, the Corrupt 1999 TNK Privatization, the Corrupt NNG Takeover and Bankruptcy, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, the Massive Tax Fraud and the Illegal Takeover of Yugraneft.
Violation of 1961(d)
Eastmount, through the above controlling persons, conspired with other defendants to undertake and consummate the Illegal Scheme.
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