Defendants' operations included supporting the presidential campaign of then-candidate Donald J. Trump ("Trump Campaign") and disparaging Hillary Clinton. Defendants made various expenditures to carry out those activities, including buying political advertisements on social media in the names of U.S. persons and entities. Defendants also staged political rallies inside the United States, and while posing as U.S. grassroots entities and U.S. persons, and without revealing their Russian identities and ORGANIZATION affiliation, solicited and compensated real U.S. persons to promote or disparage candidates. Some Defendants, posing as U.S. persons and without revealing their Russian association, communicated with unwitting individuals associated with the Trump Campaign and with other political activists to seek to coordinate political activities.
In order to carry out their activities to interfere in U.S. political and electoral processes without detection of their Russian affiliation, Defendants conspired to obstruct the lawful functions of the United States government through fraud and deceit, including by making expenditures in connection with the 2016 U.S. presidential election without proper regulatory disclosure; failing to register as foreign agents carrying out political activities within the United States; and obtaining visas through false and fraudulent statements.
Defendants and their co-conspirators used their fictitious online personas to interfere with the 2016 U.S. presidential election. They engaged in operations primarily intended to communicate derogatory information about Hillary Clinton, to denigrate other candidates such as Ted Cruz and Marco Rubio, and to support Bernie Sanders and then-candidate Donald Trump.
On or about February 10, 2016, Defendants and their co-conspirators internally circulated an outline of themes for future content to be posted to ORGANIZATION-controlled social media accounts. Specialists were instructed to post content that focused on "politics in the USA" and to "use any opportunity to criticize Hillary and the rest (except Sanders and Trump--we support them)."
From at least April 2016 through November 2016, Defendants and their co-conspirators, while concealing their Russian identities and ORGANIZATION affiliation through false personas, began to produce, purchase, and post advertisements on U.S. social media and other online sites expressly advocating for the election of then-candidate Trump or expressly opposing Clinton. Defendants and their co-conspirators did not report their expenditures to the Federal Election Commission, or register as foreign agents with the U.S. Department of Justice. The political advertisements included the following:
April 6, 2016 "You know, a great number of black people support us saying that
April 7, 2016 "I say no to Hillary Clinton / I say no to manipulation"
April 19, 2016 "JOIN our
May 10, 2016 "Donald wants to defeat terrorism ... Hillary wants to sponsor it"
May 19, 2016 "Vote Republican, vote Trump, and support the Second Amendment!"
May 24, 2016 "Hillary Clinton Doesn't Deserve the Black Vote"
June 7, 2016 "Trump is our only hope for a better future!"
June 30, 2016 "#Never Hillary #Hillary F orPrison #Hillary4 Prison #HillaryForPrison2016 #Trump #Trump4President"
July 20, 2016 "Ohio Wants Hillary 4 Prison"
August 4, 2016 "Hillary Clinton has already committed voter fraud during the Democrat Iowa Caucus."
August 10, 2016 "We cannot trust Hillary to take care of our veterans!"
October 14, 2016 "Among all the candidates Donald Trump is the one and only who can defend the police from terrorists."
October 19, 2016 "Hillary is a Satan, and her crimes and lies had proved just how evil she is."
To pay for the political advertisements, Defendants and their co-conspirators established various Russian bank accounts and credit cards, often registered in the names of fictitious U.S. personas created and used by the ORGANIZATION on social media. Defendants and their coconspirators also paid for other political advertisements using PayPal accounts.
Beginning in at least 2016, Defendants and their co-conspirators used, without lawful authority, the social security numbers, home addresses, and birth dates ofreal U.S. persons without their knowledge or consent. Using these means of stolen identification, Defendants and their coconspirators opened accounts at a federally insured U.S. financial institution ("Bank I")
Defendants and their co-conspirators purchased credit card and bank account numbers from online sellers for the unlawful purpose of evading security measures at PayPal, which used account numbers to verify a user's identity. Many of the bank account numbers purchased by Defendants and their co-conspirators were created using the stolen identities of real U.S. persons. After purchasing the accounts, Defendants and their co-conspirators submitted these bank account numbers to PayPal.
On or about August 18, 2016, the real "Florida for Trump" Facebook account responded to the false U.S. persona "Matt Skiber" account with instructions to contact a member of the Trump Campaign ("Campaign Official l ") involved in the campaign's Florida operations and provided Campaign Official 1's email address at the campaign domain donaldtrump.com.On approximately the same day, Defendants and their co-conspirators used the email address of a false U.S. persona, email@example.com
, to send an email to Campaign Official 1 at that donaldtrump.com email account, which read in part:
"Hello [Campaign Official l], [w]e are organizing a state-wide event in Florida on August, 20 to support Mr. Trump. Let us introduce ourselves first. "Being Patriotic" is a grassroots conservative online movement trying to unite people offline. . . . [W]e gained a huge lot of followers and decided to somehow help Mr. Trump get elected. You know, simple yelling on the Internet is not enough. There should be real action. We organized rallies in New York before. Now we're focusing on purple states such as Florida." The email also identified thirteen "confirmed locations" in Florida for the rallies and requested the campaign provide "assistance in each location."
On or about August 24, 2016, Defendants and their co-conspirators updated an internal ORGANIZATION list of over 100 real U.S. persons contacted through ORGANIZATIONcontrolled false U.S. persona accounts and tracked to monitor recruitment efforts and requests. The list included contact information for the U.S. persons, a summary of their political views, and activities they had been asked to perform by Defendants and their co-conspirators