1. This case concerns the arbitrary prosecutions, arrests, and detentions of former Ukrainian Prime Minister Yulia Tymoshenko and other political opposition members in violation of international law, which have been carried out by or with the assistance of Defendants, representing a collection of private and public figures that stand to benefit politically and/or financially by eliminating Ukraine’s political opposition.
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7. From 2004 to early 2009, Defendant RosUkrEnergo AG (“RUE”) received substantial profits for serving as a middleman in natural gas dealings between Naftogaz, a Ukrainian state-owned gas company, and Gazprom, a Russian company. Ukrainian billionaire Defendant Dmytro Firtash a/k/a Dmitry Firtash (“Firtash”), who largely controls RUE, was able to secure profits from the Russia-Ukraine gas deals due to his close relationship with, and payment of illegal kickbacks to, Ukrainian government officials, including then Naftogaz Chairman Yuriy Boyko and Deputy Chairman Ihor Voronin, both of whom were nominated to RUE’s Coordination Committee after securing RUE’s initial brokerage contract.
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35. (…) Manafort played a key role in the defendants’ conspiracy and racketeering enterprise by assisting Firtash to become a major “investor” and silent partner in defendants CMZ Ventures (sometimes referred to as “ZMC Investors”), Group DF and their affiliated companies, through which Firtash and his associates were able to money launder a large portion of the funds that Firtash, Group DF and RUE were skimming from numerous Gazpron/Naftogaz natural gas transactions, as well as the windfall payments and profits worth approximately $3.5 billion that they received as a result of the corrupt transactions and breaches of fiduciary duties that resulted in the Stockholm Arbitration award, as described below in greater detail. These monies were then laundered through various New York based bank accounts under the guise of otherwise legitimate real estate and other investment activities in New York and elsewhere in the United States, and the contracts, agreements, meetings, discussions and electronic communications (e.g., computer, email and fax transmissions) relating to said money laundering and investment activities were primarily conducted through defendants’ offices located at 1501 Broadway, 25th floor.
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83. RUE is owned by Russian state-owned energy company, Gazprom (owning a 50% share of RUE), Firtash (owning a 45% share of RUE through holding company Centragas), and Ukrainian businessman and Firtash associate Ivan Fursin (owning a 5% share of RUE also through holding company Centragas, which is almost wholly owned by Firtash through Group DF).
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100. Firtash, Mogilevich, and their affiliated companies used three U.S. companies in particular—CMZ Ventures LLC, Kallista Investments LLC, and the Dynamic Fund (which were sometimes referred to collectively as “The Dynamic Group)—to launder money in the United States and abroad under the guise of investing in legitimate business ventures.
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136. As of June 2011, Nadra Bank had approximately $500 million on deposit in New York bank accounts at JP Morgan Chase (Acct No. 762804508), BNY Mellon (formerly Bank of New York) (Acct. No. 8900341629); and Standard Chartered Bank (Acct No. 3582021684001).
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