In anticipation of today's summit between US President Donald Trump and Russia leader Vladimir Putin, "Special" Counsel Robert Mueller and the US Department of "Justice" handed down 22 in absentia indictments to Russian nationals. Despite Mueller's activist fanfiction writing, Trump and Putin did indeed meet in Helsinki and announced plans for greater cooperation in a joint press conference following their summit.

The full text of Robert Muller's court approved fanfiction is below:

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
V.
VIKTOR BORISOVICH NETYKSHO,
BORIS ALEKSEYEVICH ANTONOV,
DMITRIY SERGEYEVICH BADIN,
IVAN SERGEYEVICH YERMAKOV,
ALEKSEY VIKTOROVICH
LUKASHEV,
SERGEY ALEKSANDROVICH
MORGACHEV,
NIKOLAY YURYEVICH KOZACHEK,
PAVEL VYACHESLAVOVICH
YERSHOV,
ARTEM ANDREYEVICH
MALYSHEV,
ALEKSANDR VLADIMIROVICH
OSADCHUK,
ALEKSEY ALEKSANDROVICH
POTEMKJN, and
ANATOLIY SERGEYEVICH
KOVALEV,
Defendants. *
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CRIMINAL NO.
(18 U.S.C‘ §§ 2, 371,1030,1028A, 1956,
and 3551 et seq.)
RECEIVED
JUL 13 2018
Clark, U.S. District & Bankruptcy
Courts for the District of Columbia
INDICTMENT
The Grand Jury for the District of Columbia charges:
COUNT ONE
(Conspiracy to Commit an Offense Against the United States)
1. In or around 2016, the Russian Federation (“Russia”) operated a military intelligence
agency called the Main Intelligence Directorate of the General Staff (“GRU”). The GRU had
multiple units, including. Units 26165 and 74455, engaged in cyber operations that involved the
staged releases of documents stolen through computer intrusions. These units conducted largescale
cyber operations to interfere with the 2016 US. presidential election.
2. Defendants VIKTOR BORISOVICH NETYKSHO, BORIS ALEKSEYEVICH
ANTONOV, DMITRIY SERGEYEVICH BADlN, IVAN SERGEYEVICH YERMAKOV,
ALEKSEY VIKTOROVICH LUKASHEV, SERGEY ALEKSANDROVICH MORGACHEV,
NIKOLAY YURYEVICH KOZACHEK, PAVEL VYACHESLAVOVICH YERSHOV, ARTEM
ANDREYEVICH MALYSHEV, ALEKSANDR VLADIMIROVICH OSADCHUK, and
ALEKSEY ALEKSANDROVICH POTEMKIN were GRU officers who knowingly and
intentionally conspired with each other, and with persons known and unknown to the Grand Jury
(collectively the “Conspirators”), to gain unauthorized access (to “hack”) into the computers of
U.S. persons and entities involved in the 2016 U.S. presidential election, steal documents from
those computers, and stage releases of the stolen documents to interfere with the 2016 U.S.
presidential election.
3. Starting in at least March 2016, the Conspirators used a variety of means to hack the email
accounts of volunteers and employees of the U.S. presidential campaign of Hillary Clinton (the
“Clinton Campaign”), including the email account ofthe Clinton Campaign’s chairman.
4. By in or around April 2016, the Conspirators also hacked into the computer networks of
the Democratic Congressional Campaign Committee (“DCCC”) and the Democratic National
Committee (“DNC”). The Conspirators covertly monitored the computers of dozens of DCCC
and DNC employees, implanted hundreds of files containing malicious computer code
(“malware”), and stole emails and other documents from the DCCC and DNC.
5. By in or around April 2016, the Conspirators began to plan the release of materials stolen
from the Clinton Campaign, DCCC, and DNC.
6. Beginning in or around June 2016, the Conspirators staged and released tens of thousands
of the stolen emails and documents. They did so using fictitious online personas, including
“DCLeaks” and “Guccifer 2.0.”
7. The Conspirators also used the Guccifer 2.0 persona to release additional stolen documents
through a website maintained by an organization (“Organization 1”), that had previously posted
documents stolen from U.S. persons, entities, and the U.S. government. The Conspirators
continued their U.S. election-interference operations through in or around November 2016.
8. To hide their connections to Russia and the Russian government, the Conspirators used
false identities and made false statements about their identities. To further avoid detection, the
Conspirators used a network ofcomputers located across the world, including in the United States,
and paid for this infrastructure using cryptocurrency.
Defendants
9. Defendant VIKTOR BORISOVICH NETYKSHO (HeTanmo BHKTOp Bopnconnq) was
the Russian military oflicer in command of Unit 26165, located at 20 Komsomolskiy Prospekt,
Moscow, Russia. Unit 26165 had primary responsibility for hacking the DCCC and DNC, as well
as the email accounts of individuals affiliated with the Clinton Campaign.
10. Defendant BORIS ALEKSEYEVICH ANTONOV (AHTOHOB Bopnc AneKceeBm) was a
Maj or in the Russian military assigned to Unit 26165. ANTONOV oversaw a department within
Unit 26165 dedicated to targeting military, political, governmental, and non-governmental
organizations with spearphishing emails and other computer intrusion activity. ANTONOV held
the title “Head ofDepartment.” In or around 2016, ANTONOV supervised other co-conspirators
who targeted the DCCC, DNC, and individuals affiliated with the Clinton Campaign.
11. Defendant DMITRIY SERGEYEVICH BADIN (EalIPIH IanTpnfi Cepreenmi) was a
Russian military officer assigned to Unit 26165 who held the title “Assistant Head ofDepartment.”
In or around 2016, BADIN, along withANTONOV, supervised other (re-conspirators who targeted
the DCCC, DNC, and individuals affiliated with the Clinton Campaign.
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12. Defendant IVAN SERGEYEVICH YERMAKOV (EpMaKOB I/IBaH Cepreeana) was a
Russian military officer assigned to ANTONOV’s department within Unit 26165. Since in or
around 2010, YERMAKOV used various online personas, including “Kate S. Milton,” “James
McMorgans,” and “Karen W. Millen,” to conduct hacking operations on behalf ofUnit 26165. In
or around March 2016, YERMAKOV participated in hacking at least two email accounts from
which campaign-related documents were released through DCLeaks. In or around May 2016,
YERMAKOV also participated in hacking the DNC email server and stealing DNC emails that
were later released through Organization 1.
l3. Defendant ALEKSEY VIKTOROVICH LUKASHEV (nyameB Aneiccefi Bmcropomm)
was a Senior Lieutenant in the Russian military assigned to ANTONOV’s department within Unit
26165. LUKASHEV used various online personas, including “Den Katenberg” and “Yuliana
Martynova.” In or around 2016, LUKASHEV sent spearphishing emails to members of the
Clinton Campaign and affiliated individuals, including the chairman of the Clinton Campaign.
14. Defendant SERGEY ALEKSANDROVICH MORGACHEV (MopI‘aueB Cepreiz’l
AneKcaI-mponmr) was a Lieutenant Colonel in the Russian military assigned to Unit 26165.
MORGACHEV oversaw a department within Unit 26165 dedicated to developing and managing
malware, including a hacking tool used by the GRU known as “X-Agent.” During the hacking of
the DCCC and DNC networks, MORGACHEV supervised the co-conspirators who developed and
monitored the X-Agent malware implanted on those computers.
15. Defendant NIKOLAY YURYEVICH KOZACHEK (KO3a‘IeK HnKonai/‘I IOpLeBHq) was a
Lieutenant Captain in the Russian military assigned to MORGACHEV’S department within Unit
26165. KOZACHEK used a variety of monikers, including “kazak” and “blablabla1234565.”
KOZACHEK developed, customized, and monitored X-Agent malware used to hack the DCCC
and DNC networks beginning in or around April 2016.
16. Defendant PAVEL VYACHESLAVOVICH YERSHOV (Epmoa Haaen BaqecnaBOBI/Iq)
was a Russian military officer assigned to MORGACHEV’S department within Unit 26165. In or
around 2016, YERSHOV assisted KOZACHEK and other co-conspirators in testing and
customizing X-Agent malware before actual deployment and use.
17. Defendant ARTEM ANDREYEVICH MALYSHEV (MaJILIIIIeB ApTeM AmpeeBI/I‘I) was
a Second Lieutenant in the Russian military assigned to MORGACHEV’s department within Unit
26165. MALYSHEV used a variety ofmonikers, including “djangomagicdev” and “realblatr.” In
or around 2016, MALYSHEV monitored X-Agent malware implanted on the DCCC and DNC
networks.
18. Defendant ALEKSANDR VLADIMJROVICH OSADCHUK (Ocanqu AJICKCaH/Ip
Bnanmvmpomq) was a Colonel in the Russian military and the commanding officer ofUnit 74455 .
Unit 74455 was located at 22 Kirova Street, Khimki, Moscow, a building referred to Within the
GRU as the “Tower.” Unit 74455 assisted in the release ofstolen documents through the DCLeaks
and Guccifer 2.0 personas, the promotion of those releases, and the publication of anti-Clinton
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content on social media accounts operated by the GRU.
19. Defendant ALEKSEY ALEKSANDROVICH POTEMKIN (HoreMKnH Aneiccefi
AneKcaanoanq) was an officer in the Russian military assigned to Unit 74455. POTEMKIN was
a supervisor in a department within Unit 74455 responsible for the administration of computer
infrastructure used in cyber operations. Infrastructure and social media accounts administered by
POTEMKIN’S department were used, among other things, to assist in the release of stolen
documents through the DCLeaks and Guccifer 2.0 personas.
Object of the Conspiracy
20. The object of the conspiracy was to hack into the computers of US. persons and entities
involved in the 2016 US. presidential election, steal documents from those computers, and stage
releases ofthe stolen documents to interfere with the 2016 US. presidential election.
Manner and Means of the Conspiracv
Spearphishing Operations
21. ANTONOV, BADIN, YERMAKOV, LUKASHEV, and their co-conspirators targeted
Victims using a technique known as spearphishing to steal victims’ passwords or otherwise gain
access to their computers. Beginning by at least March 2016, the Conspirators targeted over 300
individuals affiliated with the Clinton Campaign, DCCC, and DNC.
a. For example, on or about March 19, 2016, LUKASHEV and his co-conspirators
created and sent a spearphishing email to the chairman of the Clinton Campaign.
LUKASHEV used the account “john356g ”
at an online service that abbreviated
lengthy website addresses (referred to as a “URL-shortening service”).
LUKASHEV used the account to mask a link contained in the spearphishing email,
which directed the recipient to a GRU-created website. LUKASHEV altered the
appearance of the sender email address in order to make it look like the email was
a security notification from Google (a technique known as “spoofing”), instructing
the user to change his password by clicking the embedded link. Those instructions
were followed. On or about March 21, 2016, LUKASHEV, YERMAKOV, and
their co-conspirators stole the contents of the chairman’s email account, which
consisted of over 50,000 emails.
b. Starting on or about March 19, 2016, LUKASHEV and his co-conspirators sent
spearphishing emails to the personal accounts of other individuals affiliated with
the Clinton Campaign, including its campaign manager and a senior foreign policy
advisor. On or about March 25, 2016, LUKASHEV used the same john356gh
account to mask additional links included in spearphishing emails sent to numerous
individuals affiliated with the Clinton Campaign, including Victims 1 and 2.
LUKASHEV sent these emails from the Russia-based email account
hi.mymail@yandex.com that he spoofed to appear to be from Google.
c. On or about March 28, 2016, YERMAKOV researched the names ofVictims 1 and
2 and their association with Clinton on various social media sites. Through their
spearphishing operations, LUKASHEV, YERMAKOV, and their co-conspirators
successfully stole email credentials and thousands of emails from numerous
individuals affiliated with the Clinton Campaign. Many of these stolen emails,
including those from Victims l and 2, were later released by the Conspirators
through DCLeaks.
d. On or about April 6, 2016, the Conspirators created an email account in the name
(with a one-letter deviation from the actual spelling) of a known member of the
Clinton Campaign. The Conspirators then used that account to send spearphishing
emails to the work accounts of more than thirty different Clinton Campaign
employees. In the spearphishing emails, LUKASHEV and his co-conspirators
embedded a link purporting to direct the recipient to a document titled “hillaryclinton—favorable-rating.xlsx.”
In fact, this link directed the recipients’ computers
to a GRU—created website.
22. The Conspirators spearphished individuals affiliated with the Clinton Campaign
throughout the summer of 2016. For example, on or about July 27, 2016, the Conspirators
attempted after hours to spearphish for the first time email accounts at a domain hosted by a thirdparty
provider and used by Clinton’s personal office. At or around the same time, they also
targeted seventy-six email addresses at the domain for the Clinton Campaign.
Hacking into the DCCC Network
23. Beginning in or around March 2016, the Conspirators, in addition to their spearphishing ,
efforts, researched the DCCC and DNC computer networks to identify technical specifications and
vulnerabilities.
For example, beginning on or about March 15, 2016, YERMAKOV ran a technical
query for the DNC’s internet protocol configurations to identify connected devices.
On or about the same day, YERMAKOV searched for open-source information
about the DNC network, the Democratic Party, and Hillary Clinton.
On or about April 7, 2016, YERMAKOV ran a technical query for the DCCC’s
internet protocol configurations to identify connected devices.
24. By in or around April 2016, within days ofYERMAKOV’s searches regarding the DCCC,
the Conspirators hacked into the DCCC computer network. Once they gained access, they
installed and managed different types of malware to explore the DCCC network and steal data.
a. On or about April 12, 2016, the Conspirators used the stolen credentials of a DCCC
Employee (“DCCC Employee 1”) to access the DCCC network. DCCC
Employee 1 had received a spearphishing email from the Conspirators on or about
April 6, 2016, and entered her password after clicking on the link.
Between in or aroundApril 2016 and June 2016, the Conspirators installed multiple
versions oftheir X-Agent malware on at least ten DCCC computers, which allowed
them to monitor individual employees’ computer activity, steal passwords, and
maintain access to the DCCC network.
c. X—Agent malware implanted on the DCCC network transmitted information from
the victims’ computers to a GRU-leased server located in Arizona. The
Conspirators referred to this server as their “AMS” panel. KOZACHEK,
MALYSHEV, and their co-conspirators logged into the AMS panel to use
X—Agent’s keylog and screenshot functions in the course of monitoring and
surveilling activity on the DCCC computers. The keylog function allowed the
Conspirators to capture keystrokes entered by DCCC employees. The screenshot
function allowed the Conspirators to take pictures of the DCCC employees’
computer screens.
,
d. For example, on or about April 14, 2016, the Conspirators repeatedly activated
X-Agent’s keylog and screenshot functions to surveil DCCC Employee 1’s
computer activity over the course ofeight hours. During that time, the Conspirators
captured DCCC Employee 1’s communications with co-workers and the passwords
she entered while working on fundraising and voter outreach projects. Similarly,
on or about April 22, 2016, the Conspirators activated X-Agent’s keylog and
screenshot fimctions to capture the discussions of another DCCC Employee
(“DCCC Employee 2”) about the DCCC’s finances, as well as her individual
banking information and other personal topics.
25. On or aboutApril 19, 2016, KOZACHEK, YERSHOV, and their co—conspirators remotely
configured an overseas computer to relay communications between X-Agent malware and the
AMS panel and then tested X-Agent’s ability to connect to this computer. The Conspirators
referred to this computer as a “middle server.” The middle server acted as a proxy to obscure the
connection between malware at the DCCC and the Conspirators’ AMS panel. On or aboutApril
20, 2016, the Conspirators directed X-Agent malware on the DCCC computers to connect to this
middle server and receive directions from the Conspirators.
Hacking into the DNC Network
26. On or about April 18, 2016, the Conspirators hacked into the DNC’s computers through
their access to the DCCC network. The Conspirators then installed and managed different types
of malware (as they did in the DCCC network) to explore the DNC network and steal documents.
a.
0
On or about April 18, 2016, the Conspirators activated X-Agent’s keylog and
screenshot functions to steal credentials of a DCCC employee who was authorized
to access the DNC network. The Conspirators hacked into the DNC network from
the DCCC network using stolen credentials. By in or around June 2016, they
gained access to approximately thirty—three DNC computers.
b. In or around April 2016, the Conspirators installed X-Agent malware on the DNC
network, including the same versions installed on the DCCC network.
MALYSHEV and his co-conspirators monitored the X-Agent malware from the
AMS panel and captured data from the victim computers. The AMS panel collected
thousands of keylog and screenshot results from the DCCC and DNC computers,
such as a screenshot and keystroke capture of DCCC Employee 2 Viewing the
DCCC’s online banking information.
Theft of DCCC and DNC Documents
27. The Conspirators searched for and identified computers within the DCCC and DNC
networks that stored information related to the 2016 US. presidential election. For example, on
or about April 15, 2016, the Conspirators searched one hacked DCCC computer for terms that
included “hillary,” “cruz,” and “trump.” The Conspirators also copied select DCCC folders,
including “Benghazi Investigations.” The Conspirators targeted computers containing information
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such as opposition research and field operation plans for the 2016 elections.
28. To enable them to steal a large number of documents at once without detection, the
Conspirators used a publicly available tool to gather and compress multiple documents on the
DCCC and DNC networks. The Conspirators then used other GRU malware, known as
“X—Tunnel,” to move the stolen documents outside the DCCC and DNC networks through
encrypted channels.
a. For example, on or about April 22, 2016, the Conspirators compressed gigabytes
of data from DNC computers, including opposition research. The Conspirators
later moved the compressed DNC data using X-Tunnel to a GRU-leased computer
located in Illinois.
b. On or about April 28, 2016, the Conspirators connected to and tested the same
computer located in Illinois. Later that day, the Conspirators used X-Tunnel to
connect to that computer to steal additional documents from the DCCC network.
29. Between on or about May 25, 2016 and June 1, 2016, the Conspirators hacked the DNC
Microsoft Exchange Server and stole thousands of emails from the work accounts of DNC
employees. During that time, YERMAKOV researched PowerShell commands related to
accessing and managing the Microsoft Exchange Server.
30. On or about May 30, 2016, MALYSHEV accessed the AMS panel in order to upgrade
custom AMS software on the server. That day, the AMS panel received updates from
approximately thirteen different X—Agent malware implants on DCCC and DNC computers.
31. During the hacking ofthe DCCC and DNC networks, the Conspirators covered their tracks
by intentionally deleting logs and computer files. For example, on or about May 13, 2016, the
Conspirators cleared the event logs from a DNC computer. On or about June 20, 2016, the
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Conspirators deleted logs from the AMS panel that documented their activities on the panel,
including the login history.
Efforts to Remain on the DCCC and DNC Networks
32. Despite the Conspirators’ efl'orts to hide their activity, beginning in or around May 2016,
both the DCCC and DNC became aware that they had been hacked and hired a security company
(“Company 1”) to identify the extent of the intrusions. By in or around June 2016, Company 1
took steps to exclude intruders from the networks. Despite these efforts, a Linux-based version of
X-Agent, programmed to communicate with the GRU-registered domain linukal.net, remained
on the DNC network until in or around October 2016.
33. In response to Company 1’s efforts, the Conspirators took countermeasures to maintain
access to the DCCC and DNC networks.
a. On or about May 31, 2016, YERMAKOV searched for open-source information
about Company 1 and its reporting on X-Agent and X-Tunnel. On or about June
1, 2016, the Conspirators attempted to delete traces oftheir presence on the DCCC
network using the computer program CCleaner.
On or about June 14, 2016, the Conspirators registered the domain actblues.com,
which mimicked the domain of a political fundraising platform that included a
DCCC donations page. Shortly thereafter, the Conspirators used stolen DCCC
credentials to modify the DCCC website and redirect visitors to the actblues.com
domain.
On or about June 20, 2016, after Company 1 had disabled X-Agent on the DCCC
network, the Conspirators spent over seven hours unsuccessfully trying to connect
to X-Agent. The Conspirators also tried to access the DCCC network using
previously stolen credentials.
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34. In or around September 2016, the Conspirators also successfully gained access to DNC
computers hosted on a third-party cloud-computing service. These computers contained test
applications related to the DNC’s analytics. After conducting reconnaissance, the Conspirators
gathered data by creating backups, or “snapshots,” of the DNC’s cloud-based systems using the
cloud provider’s own technology The Conspirators then moved the snapshots to cloud-based
accounts they had registered with the same service, thereby stealing the data from the DNC.
Stolen Documents Released through DCLeaks
35. More than a month before the release of any documents, the Conspirators constructed the
online persona DCLeaks to release and publicize stolen election-related documents. On or about
April 19, 2016, after attempting to register the domain electionleaks.com, the Conspirators
registered the domain dcleaks.com through a service that anonymized the registrant. The funds
used to pay for the dcleaks.com domain originated fiom an account at an online cryptocurrency
service that the Conspirators also used to fund the lease of a Virtual private server registered with
the operational email account dirbinsaabol@mail.com. The dirbinsaabol email account was also
used to'register the john356gh URL-shortening account used by LUKASHEV to spearphish the
Clinton Campaign chairman and other campaign-related individuals.
36. On or about June 8, 2016, the Conspirators launched the public website dcleaks.com, which
they used to release stolen emails. Before it shutdown in or around March 2017, the site received
over one million page Views. The Conspirators falsely claimed on the site that DCLeaks was
started by a group of “American hacktivists,” when in fact it was started by the Conspirators.
37. Starting in or around June 2016 and continuing through the 2016 US. presidential election,
the Conspirators used DCLeaks to release emails stolen from individuals affiliated with the Clinton
Campaign. The Conspirators also released documents they had stolen in other spearphishing
operations, including those they had conducted in 2015 that collected emails from individuals
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affiliated with the Republican Party.
38. On or about June 8, 2016, and at approximately the same time that the dcleaks.com website
was launched, the Conspirators created a DCLeaks Facebook page using a preexisting social media
account under the fictitious name “Alice Donovan.” In addition to the DCLeaks Facebook page,
the Conspirators used other social media accounts in the names offictitious U.S. persons such as
“Jason Scott” and “Richard Gingrey” to promote the DCLeaks website. The Conspirators accessed
these accounts from computers managed by POTEMKJN and his co—conspirators.
39. On or about June 8, 2016, the Conspirators created the Twitter account @dcleaks_. The
Conspirators operated the @dcleaks_ Twitter account from the same computer used for other
efforts to interfere with the 2016 US. presidential election. For example, the Conspirators used
the same computer to operate the Twitter account @BaltimoreIsWhr, through which they
encouraged U.S. audiences to “[i]oin our flash mob” opposing Clinton and to post images with the
hashtag #BlacksAgainstHillary.
Stolen Documents Released through Guccifer 2.0
40. On or about June 14, 2016, the DNC~—through Company lupublicly announced that it
had been hacked by Russian government actors. In response, the Conspirators created the online
persona Guccifer 2,0 and falsely claimed to be a lone Romanian hacker to undermine the
allegations ofRussian responsibility for the intrusion.
41. On or about June 15, 2016, the Conspirators logged into a Moscow—based server used and
managed by Unit 74455 and, between 4:19 PM and 4:56 PM Moscow Standard Time, searched
for certain words and phrases, including:
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“some hundreds of sheets”
dcleaks
illuminati
mnpoxo naseernmfi nepenon
[widely known translation]
“worldwide known”
“think twice about”
“company’s competence”
42. Later that day, at 7:02 PM Moscow Standard Time, the online persona Guccifer 2.0
published its first post on a blog site created through WordPress. Titled “DNC’s sewers hacked
by a lone hacker,” the post used numerous English words and phrases that the Conspirators had
searched for earlier that day (bolded below):
Worldwide known cyber security company [Company 1] announced that
the Democratic National Committee (DNC) servers had been hacked by
“sophisticated” hacker groups.
I’m very pleased the company appreciated my skills so highly») [. .
.]
Here are just a few does from many thousands I extracted when hacking
into DNC’s network. [. .
.]
Some hundred sheets! This’s a serious case, isn’t it? [. .
.]
I guess [Company 1] customers should think twice about company’s
competence.
F[***] the Illuminati and their conspiracies!!!!!!!!! F[***]
[Companyl]!!!!!!!!!
43. Between in or around June 2016 and October 2016, the Conspirators used Guccifer 2.0 to
release documents through WordPress that they had stolen from the DCCC and DNC. The
Conspirators, posing as Guccifer 2.0, also shared stolen documents with certain individuals.
a. On or about August 15, 2016, the Conspirators, posing as Guccifer 2.0, received a
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request for stolen documents from a candidate for the US. Congress. The
Conspirators responded using the Guccifer 2.0 persona and sent the candidate
stolen documents related to the candidate’s opponent.
b. On or about August 22, 2016, the Conspirators, posing as Guccifer 2.0, transferred
approximately 2.5 gigabytes ofdata stolen from the DCCC to a
then-registered state
lobbyist and online source ofpolitical news. The stolen data included donor records
and personal identifying information for more than 2,000 Democratic donors.
c. On or about August 22, 2016, the Conspirators, posing as Guccifer 2.0, sent a
reporter stolen documents pertaining to the Black Lives Matter movement. The
reporter responded by discussing when to release the documents and offering to
write an article about their release.
44. The Conspirators, posing as Guccifer 2.0, also communicated with US. persons about the
release of stolen documents. On or about August 15, 2016, the Conspirators, posing as Guccifer
2.0, wrote to a person who was in regular contactwith senior members ofthe presidential campaign
of Donald J. Trump, “thank u for writing back . . . do u find anyt[h]ing interesting in the docs i
posted?” On or about August 17, 2016, the Conspirators added, “please tell me if i can help u
anyhow . . . itwould be a great pleasure to me.” On or about September 9, 2016, the Conspirators,
again posing as Guccifer 2.0, referred to a stolen DCCC document posted online and asked the
person, “what do u think of the info on the turnout model for the democrats entire presidential
campaign.” The person responded, “[p]retty standard.”
45. The Conspirators conducted operations as Guccifer 2.0 and DCLeaks using overlapping
computer infrastructure and financing.
a. For example, between on or about March 14, 2016 and April 28, 2016, the
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Conspirators used the same pool of bitcoin funds to purchase a virtual private
network (“VPN”) account and to lease a server in Malaysia. In or around June
2016, the Conspirators used the Malaysian server to host the dcleaks.com website.
On or about July 6, 2016, the Conspirators used the VPN to log into the
@Guccifer_2 Twitter account. The Conspirators opened that VPN account from
the same server that was also used to register malicious domains for the hacking of
the DCCC and DNC networks.
b. On or about June 27, 2016, the Conspirators, posing as Guccifer 2.0, contacted a
U.S. reporter with an offer to provide stolen emails from “Hillary Clinton’s staff.”
The Conspirators then sent the reporter the password to access a nonpublic,
password-protected portion of dcleaks.com containing emails stolen from Victim l
by LUKASHEV, YERMAKOV, and their co-conspirators in or around March
201 6.
i
46. On or about January 12, 2017, the Conspirators published a statement on the Guccifer 2.0
WordPress blog, falsely claiming that the intrusions and release of stolen documents had “totally
no relation to the Russian government.”
Use of Organization 1
47. In order to expand their interference in the 2016 U.S. presidential election, the Conspirators
transferred many of the documents they stole from the DNC and the chairman of the Clinton
Campaign to Organization 1. The Conspirators, posing as Guccifer 2.0, discussed the release of
the stolen documents and the timing ofthose releases with Organization 1 to heighten their impact
on the 2016 U.S. presidential election.
a. On or about June 22, 2016, Organization 1 sent a private message to Guccifer 2.0
to “[s]end any new material [stolen from the DNC] here for us to review and it will
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have a much higher impact than what you are doing.” On or about July 6, 2016,
Organization 1 added, “if you have anything hillary related we want it in the next
tvveo [sic] days prefable [sic] because the DNC [Democratic National Convention]
is approaching and she will solidify bernie supporters behind her after.” The
Conspirators responded, “ck . . . i see.” Organization 1 explained, “we think trump
has only a 25% chance of winning against hillary . . . so conflict between bemie
and hillary is interesting.”
b. After failed attempts to transfer the stolen documents starting in late June 2016, on
or about July 14, 2016, the Conspirators, posing as Guccifer 2.0, sent
Organization 1 an email with an attachment titled “wk dnc linkl.txt.gpg.” The
Conspirators explained to Organization 1 that the encrypted file contained
instructions on how to access an online archive of stolen DNC documents. On or
about July 18, 2016, Organization 1 confirmed it had “the 1Gb or so archive” and
would make a release of the stolen documents “this week.”
48. On or about July 22, 2016, Organization 1 released over 20,000 emails and other
documents stolen from the DNC network by the Conspirators. This release occurred
approximately three days before the start ofthe Democratic National Convention. Organization 1
did not disclose Guccifer 2.0’s role in providing them. The latest-in—time email released through
Organization 1 was dated on or about May 25, 2016, approximately the same day the Conspirators
hacked the DNC Microsoft Exchange Server.
49. On or about October 7, 2016, Organization 1 released the first set of emails from the
chairman ofthe Clinton Campaign that had been stolen by LUKASHEV and his co-conspirators.
Between on or about October 7, 2016 and November 7, 2016, Organization 1
released
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approximately thirty—three tranches of documents that had been stolen from the chairman of the
Clinton Campaign. In total, over 50,000 stolen documents were released.
Statutory Allegations
50. Paragraphs 1 through 49 ofthis Indictment are re—alleged and incorporated by reference as
if fully set forth herein.
51. From at least in or around March 2016 through November 2016, in the District ofColumbia
and elsewhere, Defendants NETYKSHO, ANTONOV, BADlN, YERMAKOV, LUKASHEV,
MORGACHEV, KOZACHEK, YERSHOV, MALYSHEV, OSADCHUK, and POTEMKJN,
together with others known and unknown to the Grand Jury, knowingly and intentionally conspired
to commit offenses against the United States, namely:
a. To knowingly access a computer without authorization and exceed authorized
access to a computer, and to obtain thereby information from a protected computer,
where the value of the information obtained exceeded $5,000, in violation ofTitle
18, United States Code, Sections 1030(a)(2)(C) and 1030(c)(2)(B); and
b. To knowingly cause the transmission of a program, information, code, and
command, and as a result of such conduct, to intentionally cause damage without
authorization to a protected computer, and where the offense did cause and, if
completed, would have caused, loss aggregating $5,000 in Value to at least one
person during a one~year period from a related course of conduct affecting a
protected computer, and damage affecting at least ten protected computers during
a one-year period, in violation of Title 18, United States Code, Sections
1030(a)(5)(A) and 1030(c)(4)(B).
52. In furtherance of the Conspiracy and to effect its illegal objects, the Conspirators
committed the overt acts set forth in paragraphs 1 through 19, 21 through 49, 55, and 57 through
19
64, which are re-alleged and incorporated by reference as iffully set forth herein.
53. In furtherance of the Conspiracy, and as set forth in paragraphs 1 through 19, 21 through
49, 55, and 57 through 64, the Conspirators knowingly falsely registered a domain name and
knowingly used that domain name in the course of committing an offense, namely, the
Conspirators registered domains, including dcleaks.com and actblues.com, with false names and
addresses, and used those domains in the course ofcommitting the felony offense charged in Count
One.
All in violation ofTitle 18, United States Code, Sections 371 and 3559(g)(1).
COUNTS TWO THROUGH NINE
(Aggravated Identity Theft)
54. Paragraphs 1 through 19, 21 through 49, and 57 through 64 ofthis Indictment are re-alleged
and incorporated by reference as iffully set forth herein.
55. On or about the dates specified below, in the District of Columbia and elsewhere,
Defendants VlKTOR BORISOVICH NETYKSHO, BORIS ALEKSEYEVICH ANTONOV,
DMITRIY SERGEYEVICH BADlN, IVAN SERGEYEVICH YERMAKOV, ALEKSEY
VIKTOROVICH LUKASHEV, SERGEY ALEKSANDROVICH MORGACHEV, NIKOLAY
YURYEVICH KOZACHEK, PAVEL VYACHESLAVOVICH YERSHOV, ARTEM
ANDREYEV'ICH MALYSHEV, ALEKSANDR VLADIMIROVICH OSADCHUK, and
ALEKSEY ALEKSANDROVICH POTEMKIN did knowingly transfer, possess, and use, without
lawful authority, a means of identification of another person during and in relation to a
felony
violation enumerated in Title 18, United States Code, Section 1028A(c), namely, computer fraud
in Violation of Title 18, United States Code, Sections 1030(a)(2)(C) and 1030(c)(2)(B), knowing
that the means of identification belonged to another real person:
20
proximate Date
'
Victim ,
2 March 21, 2016 Victim 3
Usemame andPasswmd for
personal emall account
3 March 25, 2016 Victim 1
Usemame and Passwmd for
personal emall account
. . . Username and password for
4 April 12, 2016 V1ctnn 4
DCCC computer network
. . . Username and password for
5 Apr11 15, 2016 Vlctirn 5
DCCC computer network
. . . Username and password for
6 April 18, 2016 Victim 6
DCCC computer network
. . Username and password for
.
7 May 10’ 2016 Victlm 7
DNC computer network
8 June 2, 2016 Victim 2
Username and password for
personal emall account
9 July 6, 2016 Victim 8
Username and password for
, personal email account
All in violation ofTitle 18, United States Code, Sections 1028A(a)(1) and 2.
‘ COUNT TEN
(Conspiracy to Launder Money)
56. Paragraphs 1 through 19, 21 through 49, and 55 are re—alleged and incorporated by reference
as iffully set forth herein.
V
57. To facilitate the purchase ofinfrastructure used in their hacking activity—including hacking
into the computers ofU.S. persons and entities involved in the 2016 U.S. presidential election and
releasing the stolen documents—the Defendants conspired to launder the equivalent of more than
$95,000 through a Web of transactions structured to capitalize on the perceived anonymity of
cryptocurrencies such as bitcoin.
58. Although the Conspirators caused transactions to be conducted in a variety of currencies,
including U.S. dollars, they principally used bitcoin when purchasing servers, registering domains,
and otherwise making payments in furtherance ofhacking activity. Many ofthese payments were
21
processed by companies located in the United States that provided payment processing services to
hosting companies, domain registrars, and other Vendors both international and domestic. The use
of bitcoin allowed the Conspirators to avoid direct relationships with traditional financial
institutions, allowing them to evade greater scrutiny oftheir identities and sources of funds.
59. All bitcoin transactions are added to a public ledger called the Blockchain, but the
Blockchain identifies the parties to each transaction only by alpha~numeric identifiers known as
bitcoin addresses. To further avoid creating a centralized paper trail of all oftheir purchases, the
Conspirators purchased infrastructure using hundreds of different email accounts, in some cases
using a new account for each purchase. The Conspirators used fictitious names and addresses in
order to obscure their identities and their links to Russia and the Russian government. For
example, the dcleaks.com domain was registered and paid for using the fictitious name “Carrie
Feehan” and an address in New York. In some cases, as part of the payment process, the
Conspirators provided vendors with nonsensical addresses such as “usa Denver AZ,”'“gfhgh
ghfhgfh fdgfdg WA,” and “1 2 dwd District of Columbia.”
60. The Conspirators used several dedicated email accounts to track basic bitcoin transaction
information and to facilitate bitcoin payments to vendors. One of these dedicated accounts,
registered with the usemame “gfadel47,” received hundreds of bitcoin payment requests from
approximately 100 different email accounts. For example, on or about February 1, 2016, the
gfadel47 account received the instruction to “[p]lease send exactly 0.026043 bitcoin to” a certain
thirty-four character bitcoin address. Shortly thereafter, a transaction matching those exact
instructions was added to the Blockchain.
61. On occasion, the Conspirators facilitated bitcoin payments using the same computers that
they used to conduct their hacking activity, including to create and send test spearphishing emails.
22
Additionally, one of these dedicated accounts was used by the Conspirators in or around 2015 to
renew the registration of a domain (linuxkrnlnet) encoded in certain X-Agent malware installed
on the DNC network.
I
62. The Conspirators funded the purchase of computer infrastructure for their hacking activity
in part by “mining” bitcoin. Individuals and entities can mine bitcoin by allowing their computing
power to be used to verify and record payments on the bitcoin public ledger, a service for which
they are rewarded with freshly-minted bitcoin. The pool of bitcoin generated from the GRU’s
mining activity was used, for example, to pay a Romanian company to register the domain
dcleaks.com through a payment processing company located in the United States.
63. In addition to mining bitcoin, the Conspirators acquired bitcoin through a variety of means
designed to obscure the origin ofthe funds. This included purchasing bitcoin through peer-to-peer
exchanges, moving funds through other digital currencies, and using pre-paid cards. They also
enlisted the assistance of one or more third—party exchangers who facilitated layered transactions
through digital currency exchange platforms providing heightened anonymity.
64. The Conspirators used the same funding structure—and in some cases, the very same pool
of fundsito purchase key accounts, servers, and domains used in their election—related hacking
activity.
a. The bitcoin mining operation that funded the registration payment for dcleaks.com
also sent newly-minted bitcoin to a bitcoin address controlled by “Daniel Farell,”
the persona that was used to renew the domain linuxkrnlnet. The bitcoin mining
operation also funded, through the same bitcoin address, the purchase of servers
and domains used in the GRU’s spearphishing operations, including accountsqooqle.com
and account—gooogle.com.
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b. On or about March 14, 2016, using funds in a bitcoin address, the Conspirators
purchased a VPN account, which they later used to log into the @Guccifer_2
Twitter account. The remaining funds from that bitcoin address were then used on
or about April 28, 2016, to lease a Malaysian server that hosted the dcleaks.com
website.
0. The Conspirators used a different set of fictitious names (including “Ward
DeClaur” and “Mike Long”) to send bitcoin to a US. company in order to lease a
server used to administer X-Tunnel malware implanted on the DCCC and DNC
networks, and to lease two servers used to hack the DNC’s cloud network.
Statutogx Allegations
65. From at least in or around 2015 through 2016, within the District of Columbia and
elsewhere, Defendants VIKTOR BORISOVICH NETYKSHO, BORIS ALEKSEYEVICH
ANTONOV, DMITRIY SERGEYEVICH BADlN, IVAN SERGEYEVICH YERMAKOV,
ALEKSEY VIKTOROVICH LUKASHEV, SERGEY ALEKSANDROVICH MORGACHEV,
NIKOLAY YURYEVICH KOZACHEK, PAVEL VYACHESLAVOVICH YERSHOV, ARTEM
ANDREYEVICH MALYSHEV, ALEKSANDR VLADIMIROVICH OSADCHUK, and
ALEKSEY ALEKSANDROVICH POTEMKIN, together with others, known and unknown to the
Grand Jury, did knowingly and intentionally conspire to transport, transmit, and transfer monetary
instruments and funds to a place in the United States from and through a place outside the United
States and from a place in the United States to and through a place outside the United States, with
the intent to promote the carrying on of specified unlawful activity, namely, a violation of Title
18, United States Code, Section 1030, contrary to Title 18, United States Code, Section
l956(a)(2)(A).
All in Violation ofTitle 18, United States Code, Section 1956(h).
24
COUNT ELEVEN
(Conspiracy to Commit an Offense Against the United States)
66. Paragraphs 1 through 8 of this Indictment are re-alleged and incorporated by reference as
iffully set forth herein.
Defendants
67. Paragraph 18 of this Indictment relating to ALEKSANDR VLADIMIROVICH
OSADCHUK is re—alleged and incorporated by reference as iffully set forth herein.
68. Defendant ANATOLIY SERGEYEVICH KOVALEV (KonaneB AHaronnfi CepreeBnq)
was an officer in the Russian military assigned to Unit 74455 who worked in the GRU’s 22 Kirova
Street building (the Tower).
69. Defendants OSADCHUK and KOVALEV were GRU officers who knowingly and
intentionally conspired with each other and with persons, known and unknown to the Grand Jury,
to hack into the computers of U.S. persons and entities responsible for the administration of 2016
U.S. elections, such as state boards of elections, secretaries of state, and U.S. companies that
supplied software and other technology related to the administration ofU.S. elections.
Object of the Conspiracy
70. The object of the conspiracy was to hack into protected computers of persons and entities
charged with the administration ofthe 2016 U.S. elections in order to access those computers and
steal voter data and other information stored on those computers.
Manner and Means of the Conspiracv
71. In or around June 2016, KOVALEV and his co—conspirators researched domains used by
U.S. state boards of elections, secretaries of state, and other election-related entities for website
vulnerabilities. KOVALEV and his co-conspirators also searched for state political party email
addresses, including filtered queries for email addresses listed on state Republican Party websites.
25
72. In or around July 2016, KOVALEV and his co-conspirators hacked the website of a state
board of elections (“SBOE 1”) and stole information related to approximately 500,000 voters,
including names, addresses, partial social security numbers, dates of birth, and driver’s license
numbers.
73. In or around August 2016, KOVALEV and his co-conspirators hacked into the computers
of a US. vendor (“Vendor 1”) that supplied software used to verify voter registration information
for the 2016 US. elections. KOVALEV and his co-conspirators used some of the same
infrastructure to hack into Vendor 1 that they had used to hack into SBOE 1.
74. In or around August 2016, the Federal Bureau of Investigation issued an alert about the
hacking of SBOE 1 and identified some ofthe infrastructure that was used to conduct the hacking.
In response, KOVALEV deleted his search history. KOVALEV and his co-conspirators also
deleted records from accounts used in their operations targeting state boards of elections and
similar election—related entities.
75. In or around October 2016, KOVALEV and his co-conspirators further targeted state and
county offices responsible for administering the 2016 US. elections. For example, on or about
October 28, 2016, KOVALEV and his co-conspirators visited the websites of certain counties in
‘
Georgia, Iowa, and Florida to identify vulnerabilities.
76. In or around November 2016 and prior to the 2016 US. presidential election, KOVALEV
and his co-conspirators used an email account designed to look like a Vendor 1 email address to
send over 100 spearphishing emails to organizations and personnel involved in administering
elections in numerous Florida counties. The spearphishing emails contained malware that the
Conspirators embedded into Word documents bearing Vendor 1’s logo.
Statutory Allegations
77. Between in or around June 2016 and November 2016, in the District of Columbia and
26
elsewhere, Defendants OSADCHUK and KOVALEV, together with others known and unknown
to the Grand Jury, knowingly and intentionally conspired to commit offenses against the United
States, namely:
a. To knowingly access a computer Without authorization and exceed authorized
access to a computer, and to obtain thereby information from a protected computer,
where the value of the information obtained exceeded $5,000, in violation of Title
18, United States Code, Sections 1030(a)(2)(C) and 1030(c)(2)(B); and
b. To knowingly cause the transmission of a program, information, code, and
command, and as a result of such conduct, to intentionally cause damage without
authorization to a protected computer, and where the offense did cause and, if
completed, would have caused, loss aggregating $5,000 in value to at least one
person during a one-year period from a related course of conduct affecting a
protected computer, and damage affecting at least ten protected computers during
a one-year period, in violation of Title 18, United States Code, Sections
1030(a)(5)(A) and 1030(c)(4)(B).
78. In furtherance of the Conspiracy and to effect its illegal objects, OSADCHUK,
KOVALEV, and their co—conspirators committed the overt acts set forth in paragraphs 67 through
69 and 71 through 76, which are re-alleged and incorporated by reference as if fully set forth
herein.
All in Violation ofTitle 18, United States Code, Section 371.
FORFEITURE ALLEGATION
79. Pursuant to Federal Rule of Criminal Procedure 32.2, notice is hereby given to Defendants
that the United States will seek forfeiture as part of any sentence in the event of Defendants’
convictions under Counts One, Ten, and Eleven of this Indictment. Pursuant to Title 18, United
27
States Code, Sections 982(a)(2) and 1030(i), upon conviction of the offenses charged in Counts
One and Eleven, Defendants NETYKSHO, ANTONOV, BADIN, YERMAKOV, LUKASHEV,
MORGACHEV, KOZACHEK, YERSHOV, MALYSHEV, OSADCHUK, POTEMKIN, and
KOVALEV shall forfeit to the United States any property, real or personal, which constitutes or
is derived from proceeds obtained directly or indirectly as a result of such violation, and any
personal property that was used or intended to be used‘to commit or to facilitate the commission
of such offense. Pursuant to Title 18, United States Code, Section 982(a)(1), upon conviction of
the offense charged in Count Ten, Defendants NETYKSHO, ANTONOV, BADlN,
YERMAKOV, LUKASHEV, MORGACHEV, KOZACHEK, YERSHOV, MALYSHEV,
OSADCHUK, and POTEMKIN shall forfeit to the United States any property, real or personal,
involved in such offense, and any property traceable to such property. Notice is further given that,
upon conviction, the United States intends to seek a judgment against each Defendant for a sum
of money representing the property described in this paragraph, as applicable to each Defendant
(to be offset by the forfeiture of any specific property).
Substitute Assets
80. Ifany ofthe property described above as being subject to forfeiture, as a result of any act or
omission of any Defendant —
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction ofthe court;
d. has been substantially diminished in value; or
c. has been commingled with other property that cannot be subdivided without
difficulty;
it is the intent of the United States ofAmerica, pursuant to Title 18, United States Code, Section
28
982(b) and Title 28, United States Code, Section 2461(0), incorporating Title 21, United States
Code, Section 853, to seek forfeiture of any other property of said Defendant.
Pursuant to 18 U.S.C. §§ 982 and 1030(i); 28 U.S.C. §2461(c).
Mia/r v:
Robert S. ueller, 111
Special Counsel
US. Department of Justice '
A TRUE BILL:
Foreperson
Date: July 13, 2018
29