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Access/Renova
1. Access Industries, Inc. (“Access”)
Access was incorporated in the State of New York on April 3, 1986 and continues to operate in the State of New York with its principal place of business at 730 5th Avenue, 20th Floor, New York, NY 10019. Access is controlled by its CEO and President, Defendant Leonard Blavatnik (“Blavatnik”) who owns 100% of its capital stock. Blavatnik emigrated from the Soviet Union in 1978 is a U.S. citizen residing principally in New York and serves as a director of TNK. Access is a controlling shareholder of TNK through a series of companies.
Access, through Blavatnick, in concert and conspiracy with Renova, through Viktor Vekselburg, and the Alfa Group, through its officers, directors, and members, directed, managed, and effected 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, and the Illegal Takeover of Yugraneft (overall, the “Illegal Scheme”), as detailed herein and in the Complaint.
The Predicate Acts
Access, through Blavatnik and, upon information and belief, other Access officers and directors, and through its control of TNK and other companies, committed specific predicate acts of racketeering in furtherance of the Illegal Scheme. These included:
· - Mail and Wire Fraud: Access through Blavatnik, and, upon information and belief, other officers and directors, was managed, directed, and controlled and managed, directed, and controlled various other companies, such as TNK, 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: Access, through Blavatnik, and, upon information and belief, other officers and directors, managed, directed, and controlled the “Slush Fund Companies,” such as Eastmount, LT and Sandwell, which wired funds through banks in the United States to bribe Russian government officials as part of the Illegal Scheme;
· - Money Laundering: Access, through Blavatnik, and, upon information and belief, other officers and directors, was managed, directed, and controlled and managed, directed, and controlled the Slush Fund Companies which 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: Access, through Blavatnick, and, upon information and belief, other officers and directors, was managed, directed, and controlled and managed, directed, and controlled of the wiring of proceeds constituting “criminally derived property” from the sale of oil of NNG, Kondpetroleum, Chernogorneft, and Yugraneft through banks in the United States;
· - Travel Act Violations: Access, through Blavatnik, and, upon information and belief, other officers and directors, repeatedly traveled from this District to Russia and back in aid of racketeering (i.e. bribery, mail and wire fraud, extortion, money laundering, and illegal transactions in monetary instruments) of the Illegal Scheme.
· - Bribery: Upon information and belief, Access, through Blavatnik, 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)
Access, through the pattern of racketeering which included bribery, mail and wire fraud, economic extortion, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act, received income, directly or indirectly, 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, and the Illegal Takeover of Yugraneft. Such income included shares in TNK obtained through the Corrupt 1997 TNK Privatization and the 1999 Corrupt TNK Privatization, assets of NNG, Kondpetroleum, and Chernogorneft obtained through the Corrupt the Corrupt NNG Takeover and Bankruptcy and the Kondpetroleum, and Chernogorneft Bankruptcies, and funds obtained through each of these schemes. Such income also included shares in Yugraneft which were obtained through the Corrupt Chernogorneft Bankruptcy.
A part of such income or its proceeds, and specifically including the shares of Yugraneft, were used, directly or indirectly, to acquire an interest in Yugraneft and to operate Yugraneft through the Illegal Takeover.
Violation of 1961(b)
Access, acquired and maintained, directly and/or indirectly, an interest and control of Yugraneft. Access acquired such an interest when TNK, directly or indirectly, acquired an interest in Chernogorneft through the Corrupt Chernogorneft Bankruptcy and then used Chernogorneft’s interest in Yugraneft to takeover Yugraneft through physical force and corrupted court proceedings.
Violation of 1961(c)
Access, through Blavatnik, and, upon information and belief, other officers and directors, conducted and participated in the conduct of the Access/Alfa/Astons Enterprise (association in fact), the Crown Enterprise, the TNK Enterprise, the Slush Fund Enterprise, the NNG Enterprise, the Kondepetroleum Enterprise, the Chernogorneft Enterprise, and the Yugraneft Enterprise 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)
Access conspired with other defendants, and with others, to undertake and consummate the Illegal Scheme.
2. Leonard Blavatnik (“Blavatnik”)
Blavatnik is the CEO and President of Access and owns 100% of its capital stock. Blavatnik emigrated from the Soviet Union in 1978 is a U.S. citizen residing principally in New York and serves as a director of TNK. Blavatnik exercises control over TNK through a series of companies he controls, as set forth in the chart attached hereto as Exhibit A.
Blavatnik through Access, in concert and conspiracy with Renova, through Vekselberg, and the Alfa Group, through its officers, directors, and members, directed, managed, and effected 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, and the Illegal Takeover of Yugraneft (overall, the “Illegal Scheme”), as detailed herein and in the Complaint.
The Predicate Acts
Blavatnik individually and through Access and, and through his control of TNK and other companies, committed specific predicate acts of racketeering in furtherance of the Illegal Scheme. These included:
· - Mail and Wire Fraud: Blavatnik managed, directed, and controlled Access and various other companies, such as TNK, 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: Blavatnik managed, directed, and controlled the “Slush Fund Companies,” such as Eastmount, LT and Sandwell, which wired funds through banks in the United States in order to bribe Russian government officials as part of the Illegal Scheme;
· - Money Laundering: Blavatnik managed, directed, and controlled the Slush Fund Companies which 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: Blavatnik managed, directed, and controlled of the wiring of proceeds constituting “criminally derived property” from the sale of oil of NNG, Kondpetroleum, Chernogorneft, and Yugraneft through banks in the United States;
· - Travel Act Violations: Blavatnik repeatedly traveled from this District to Russia and back in aid of the racketeering of the Illegal Scheme.
· - Bribery: Upon information and belief, Blavatnik, 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)
Blavatnik, 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. Such income included shares in TNK obtained through the Corrupt 1997 and 1999 Privatizations, assets of NNG, Kondpetroleum, and Chernogorneft obtained through the Corrupt NNG Takeover and Bankruptcy and the Corrupt Kondpetroleum, and Chernogorneft Bankruptcies, and funds obtained through each of these Scheme. Such income also included shares in Yugraneft which were obtained through the Corrupt Chernogorneft Bankruptcy.
A part of such income or its proceeds, and specifically the shares of Yugraneft, were used, directly or indirectly, to acquire an interest in Yugraneft and to operate Yugraneft through the Illegal Takeover.
Violation of 1961(b)
Blavatnik, through a pattern of racketeering which included bribery, extortion, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act acquired and maintained, directly or indirectly, an interest and control of Yugraneft.
Violation of 1961(c)
Blavatnik, conducted and participated in the conduct of the Access/Alfa/Astons Enterprise (association in fact), the Access/Renova Enterprise, the Crown Enterprise, the TNK Enterprise, the Slush Fund Enterprise, the NNG, the Kondpetroleum Enterprise, the Chernogorneft Enterprises, and the Yugraneft Enterprise 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)
Blavatnik conspired with other defendants to undertake and consummate the Illegal Scheme.
3. Renova, Inc. (“Renova”)
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Renova was incorporated in the State of New York on November 8, 1994 with its principal place of business in New York, NY and is a controlling shareholder of TNK through a series of companies, as set forth in the chart attached hereto as Exhibit A. Renova is controlled by Defendant Victor Vekselberg (“Vekselberg”) the CEO.. Vekselberg, with an address of 111 West 67th Street, New York, NY 10017, is on the board of directors of TNK (deputy chief executive).
Renova, through Vekselberg, in concert and conspiracy with Access, through Blavatnik, and the Alfa Group, through its officers, directors, and members, directed, managed, and effected 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, and the Illegal Takeover of Yugraneft (overall, the “Illegal Scheme”), as detailed herein and in the Complaint.
The Predicate Acts
Renova, through Vekselberg and, upon information and belief, other Renova officers and directors, and through its control of TNK and other companies, committed specific predicate acts of racketeering in furtherance of the Illegal Scheme. These included:
· - Mail and Wire Fraud: Renova, through Vekselberg, and, upon information and belief, other Renova offices and directors, was managed, directed, and controlled and managed, directed, and controlled other companies, such as TNK, 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: Renova, through Vekselberg, and, upon information and belief, other Renova officers and directors, managed, directed, and controlled the “Slush Fund Companies,” such as LT and Sandwell, which wired funds through banks in the United States to bribe Russian government officials as part of the Illegal Scheme;
· - Money Laundering: Renova, through Vekselberg and, upon information and belief, other Renova officers and directors, was managed, directed, and controlled and managed, directed, and controlled the Slush Fund Companies which 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: Renova, through Vekselberg and, upon information and belief, other Renova officers and directors, was managed, directed, and controlled and managed, directed, and controlled of the wiring of proceeds constituting “criminally derived property” from the sale of oil of NNG, Kondpetroleum, Chernogorneft, and Yugraneft through banks in the United States;
· - Travel Act Violations: Renova, through Vekselberg and, upon information and belief, other Renova officers and directors, repeatedly traveled from this District to Russia and back in aid of the racketeering of the Illegal Scheme.
· - Bribery: Upon information and belief, Renova, through Vekselberg, 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)
Renova, through the pattern of racketeering which included bribery, mail and wire fraud, economic extortion, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act, received income, directly or indirectly, 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, and the Illegal Takeover of Yugraneft. Such income included shares in TNK obtained through the Corrupt 1997 TNK Privatization and the 1999 Corrupt TNK Privatization, assets of NNG, Kondpetroleum, and Chernogorneft obtained through the Corrupt NNG Takeover and Bankruptcy and the Corrupt Kondpetroleum, and Chernogorneft Bankruptcies, and funds obtained through each of these schemes. Such income also included shares in Yugraneft which were obtained through the Corrupt Chernogorneft Bankruptcy
A part of such income or its proceeds, and specifically including the shares of Yugraneft, were used, directly or indirectly, to acquire an interest in Yugraneft and to operate Yugraneft through the Illegal Takeover.
Violation of 1961(b)
Renova, through a pattern of racketeering which included bribery, extortion, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act, acquired and maintained, directly or indirectly, an interest and control of Yugraneft within the meaning of 18 U.S.C. § 1961(1)(B) and 1961(5) in violation of 18 U.S.C. §1962(b). Renova acquired such an interest when TNK, directly or indirectly, acquired an interest in Chernogorneft through the Corrupt Chernogorneft Bankruptcy and then used Chernogorneft’s interest in Yugraneft to takeover Yugraneft through physical force and corrupted court proceedings.
Violation of 1961(c)
Renova, through Vekselberg, and, upon information and belief, other officers and directors, conducted and participated in the conduct of the Access/Alfa/Astons Enterprise (association in fact), the Crown Enterprise, the TNK Enterprise, the Slush Fund Enterprise, the NNG Enterprise, the Kondpetroleum Enterprise, the Chernogorneft Enterprise, and the Yugraneft Enterprise 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)
Renova, through Vekselberg, conspired with other defendants to undertake and consummate the Illegal Scheme.
4. Victor Vekselberg (“Vekselberg”)
Vekselberg, the CEO of Renova, is a permanent resident of the United States with an address of 111 West 67th Street, New York, NY 10017. Vekselberg, is on the board of directors of TNK (deputy chief executive) and exercises control over TNK through a series of companies he controls.
Vekselberg through Renova, in concert and conspiracy with Access, through Blavatnik, and the Alfa Group, through its officers, directors, and members, directed, managed, and effected 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, and the Illegal Takeover of Yugraneft (overall, the “Illegal Scheme”), as detailed herein and in the Complaint.
The Predicate Acts
Vekselberg, individually and through Renova and, and through his control of TNK and other companies, committed specific predicate acts of racketeering in furtherance of the Illegal Scheme. These included:
· - Mail and Wire Fraud: Vekselberg managed, directed, and controlled Renova and various other companies, such as TNK, 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: Vekselberg managed, directed, and controlled the “Slush Fund Companies,” such as Eastmount, LT and Sandwell, which wired funds through banks in the United States to bribe Russian government officials as part of the Illegal Scheme;
· - Money Laundering: Vekselberg managed, directed, and controlled the Slush Fund Companies which 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: Vekselberg managed, directed, and controlled of the wiring of proceeds constituting “criminally derived property” from the sale of oil of NNG, Kondpetroleum, Chernogorneft, and Yugraneft through banks in the United States;
· - Travel Act Violations: Vekselberg repeatedly traveled from this District to Russia and back in aid of the racketeering of the Illegal Scheme.
· - Bribery: Upon information and belief, Vekselberg 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)
Vekselberg, 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. Such income included shares in TNK obtained through the Corrupt 1997 TNK Privatization and the 1999 Corrupt TNK Privatization, assets of NNG, Kondpetroleum, and Chernogorneft obtained through the Corrupt NNG Takeover and Bankruptcy and the Corrupt Kondpetroleum, and Chernogorneft Bankruptcies, and funds obtained through each of these schemes. Such income also included shares in Yugraneft which were obtained through the Corrupt Chernogorneft Bankruptcy
A part of such income or its proceeds, and specifically including the shares of Yugraneft, were used, directly or indirectly, to acquire an interest in Yugraneft and to operate Yugraneft through the Illegal Takeover.
Violation of 1961(b)
Vekselberg, through a pattern of racketeering which included bribery, extortion, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act acquired and maintained, directly or indirectly, an interest and control of Yugraneft.
Violation of 1961(c)
Vekselberg, conducted and participated in the conduct of the Access/Alfa/Astons Enterprise (association in fact), the Access/Renova Enterprise, the Crown Enterprise, the TNK Enterprise, the Slush Fund Enterprise, the NNG, the Kondpetroleum Enterprise, the Chernogorneft Enterprise and the Yugraneft Enterprise 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)
Vekselberg conspired with other defendants, to undertake and consummate the Illegal Scheme.
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