ASTONS

1. Astons Corporate Management (“Astons”)
Astons is a company organized under the laws of the Isle of Man with its principal place of business in the Isle of Man.
Astons operated and controlled the organization and operation of a number of slush fund companies in the Isle of Man on behalf of Access/Renova and Alfa, including Defendants Sandwell and Eastmount, as well as dozens of other related companies, including Banstead Enterprises Limited, Fairfax Services Limited, Inverforth Properties Limited, Lamport Limited, Redhill Properties Limited, Ringford, Wasdale Limited, and Watford Limited.
Astons created many of these companies for employees of Access/Renova and/or Crown so that they could open bank accounts at the National Westminster Bank located on the Isle of Man in order to receive secret salary and bonus payments which were concealed from taxing authorities in the United States, UK, and Russia. Astons, through its officers and directors such as G. Caine, also sent invoices and statements of account for millions of dollars of fabricated services to Crown.
Based on its involvement in creating and operating the Slush Fund Companies and their bank accounts, Astons knowingly participated in the Illegal Scheme by directly effecting various illegal activities, including money laundering and tax fraud, so that Access/Renova and the Alfa Group could effect the Illegal Scheme.

The Predicate Acts

• Mail and Wire Fraud: Astons, 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 the Isle of Man and other places, to bribe Russian government officials in order to effect the Illegal Scheme;
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• Wire Fraud: Astons wired funds through banks in the United States in order to bribe Russian government officials as part of the Illegal Scheme;
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• Money Laundering: Astons 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);
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• Illegal Transactions in Monetary Instruments: Astons laundered “criminally derived property” from the sale of oil of NNG, Kondpetroleum, Chernogorneft, and Yugraneft through banks in the United States;
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• Travel Act Violations: Upon information and belief, Caine and Cubbons traveled from the United States to the Isle of Man and back in aid of the racketeering of the Illegal Scheme;
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• Bribery: Upon information and belief Astons, by and through its officers and directors, 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(c)

Violation of 1961(d)