Order to conduct searches and arrests in the FBK case

INVESTIGATIVE COMMITTEE OF THE RUSSIAN FEDERATION (IC OF RUSSIA) 2 Tekhnichesky Lane, Moscow, Russia 105005 03.09.2019 No. 11902450048000049 Re: To the Head of the Investigative Directorate of the Investigative Committee of the Russian Federation

INSTRUCTION

for the performance of certain investigative actions

The Main Directorate for the Investigation of Particularly Important Cases of the Investigative Committee of the Russian Federation is investigating criminal case No. 11902450048000049, initiated on 03.08.2019 on the fact of laundering funds obtained by criminal means, that is, on the grounds of an offense under Clause “b,” Part 4, Article 174 of the Criminal Code of the Russian Federation.

The investigation has established that, during the period from 01.01.2016 to 31.12.2018, a number of individuals who were employees of the non-profit organization “Anti-Corruption Foundation” (ACF, a Russian anti-corruption NGO), Taxpayer ID No. 7709471429 (hereinafter “ACF”), received cash funds totaling more than 75 million rubles from unidentified third parties and deposited those funds via ATMs in Moscow into their accounts opened with Sberbank PJSC and Alfa-Bank JSC.

These funds were subsequently credited to ACF’s accounts and used to finance its activities.

According to the information obtained, employees of “Navalny’s Headquarters” (regional political campaign offices associated with Alexei Navalny), located within the jurisdiction of the investigative directorate under your authority, may be involved in the laundering of funds acquired by criminal means.

The headquarters premises, as well as the residences of its employees, may contain items, documents, and electronic storage media relevant to the criminal case, as well as funds obtained by criminal means; therefore, it is necessary to locate and seize them and to question the persons whose premises are searched.

In addition, it is necessary in this case to freeze the funds of persons of interest to the investigation.

On the basis of the foregoing, and guided by Articles 38 and 152 of the Criminal Procedure Code of the Russian Federation,

I REQUEST:

that you instruct your subordinate officers to carry out the following investigative and other procedural actions.

1) Conduct searches at the addresses specified in the attached orders, with the participation of a specialist, as well as officers of the Main Directorate of the Ministry of Internal Affairs of Russia Investigative Committee of the Russian benennum

for the relevant constituent entity of the Russian Federation (issuing them a separate instruction for support and participation in the course of the investigative actions being carried out).

During the searches, the following shall be seized:

- large sums of money in the possession of the persons being searched, whether carried on their person or located at their place of residence or work, other valuables obtained by criminal means, items withdrawn from civil circulation, and bank cards;

contracts, correspondence, as well as any possible materials and equipment (technical devices, sound-recording equipment, printed materials, etc.) relating to participation in, campaigning for, and holding events not approved by local self-government authorities;

- documents and electronic storage media containing information on the activities of, and transfer of funds involving, the following individuals and organizations:

Leonid Mikhailovich Volkov, Anna Mikhailovna Chekhovich, Ruslan Tabrizovich Shaveddinov, Roman Viktorovich Rubanov, Vyacheslav Ilyich Gimadi, Evgeny Mikhailovich Zamyatin, Alexander Evgenyevich Pomazuyev, Anna Sergeyevna Biryukova, Vlada Andreyevna Ankina, Razmik Karenovich Simonyan, Alexander Nikolayevich Khomenko, Nikolay Vladimirovich Khomenko, Vladlen Kornelevich Los, Ildar Shamilievich Zakirov.

DMSTR Group LLC, DMSTR LLC, Stroy Engineering LLC, Business Services Center LLC, Fifth Season Media Support Foundation, Anti-Corruption Foundation NPO, EFSOL Financial Consulting LLC, Knopka LLC, sole proprietor Alexei Anatolyevich Navalny, Foundation for the Organization and Coordination of the Protection of Citizens’ Rights NPO, “A.A. Navalny Headquarters.”

In addition, any information relating to activities involving cryptocurrencies, bitcoins, and Yandex and QIWI wallets shall be seized.

2) If items, documents, and valuables are seized, inspect them, including electronic storage media, under conditions excluding any alteration of the information, with the possibility of recovering deleted data; if necessary, copy the information onto storage media.

The seized funds shall be examined for authenticity with a specialist, attached as physical evidence, and placed for safekeeping in the deposit account of the investigative directorate (with supporting documents to be provided to the initiator of this instruction).

3) In banks and banking institutions, impose freezes in accordance with the attached orders.

4) Question as witnesses the persons whose premises are searched, as well as persons who possess information about the organization of the headquarters’ work, its financing, and expenditure of funds, establishing the following circumstances:

Where is he (she) registered and where does he (she) actually reside, and what telephone numbers, messaging apps, social media accounts, and email addresses does he (she) and his (her) relatives use?

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Who are his (her) relatives, and what property is owned by him (her) and his (her) relatives (real estate, vehicles)?

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During what period and from which educational institutions did he (she) graduate, during what period did he (she) work, in which organizations and positions, and what was the amount of income received? In which banks and other credit institutions does he (she) have accounts, deposits, or loans? When and for what purpose were these accounts and deposits opened, and the loans taken out? How, in what amount, and from what funds are the loans repaid? Does he (she) have Yandex.Money or QIWI wallets? If so, for what purposes are they used, and what is the volume of funds passing through them? Does he (she) use bank accounts or Yandex.Money or QIWI wallets opened in the names of other persons or organizations?

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Does he (she) possess cryptocurrency (bitcoins)? If so, in what amount, in which wallets, how and with what funds was it acquired, how was it converted into cash, and where were these transactions carried out?

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Since what period, in what position, and in what organization has he (she) worked? What were his (her) job duties, and what work functions did he (she) actually perform? How is the headquarters’ work organized, who manages its activities, and with whom is the headquarters’ activity coordinated (full name, contact details)?

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From whom are funds received to finance the headquarters’ activities, in what form (cash or non-cash) were they received, how were their receipt and expenditure recorded, in what form, to whom, and how is reporting on their expenditure submitted, and with what supporting documents? Is he (she) acquainted with Alexei Anatolyevich Navalny? If so, where, when, and under what circumstances did they meet, what is the nature of their relationship, and how do they communicate? What is known about A.A. Navalny’s line of activity and his participation in the financial and business activities of the Anti-Corruption Foundation NPO?

- Who were the founders and managers, including the de facto head, of the Anti-Corruption Foundation NPO, what is the nature of this organization’s activities, how is it financed, and how are its funds spent?

- How and by whom was the decision made to open (establish) an “A.A. Navalny Headquarters” in the region? What is “A.A. Navalny Headquarters,” what is its official organizational form, what is the nature of its activities, how many employees does it have, and what are their functional duties? Where is “A.A. Navalny Headquarters” located, on the basis of what documents does it occupy those premises, by whom and for what amount were lease agreements concluded or the premises acquired as property? Who pays the rent for the occupied premises, in what manner, and in what amount? From what funds and in what manner was equipment (furniture, office equipment, and computers) acquired for the headquarters’ activities? - How, in what amount, and from what funds is monetary remuneration (salary) paid to headquarters employees, and how and in what documents is this recorded? Who allocates the funds for these payments? Is he (she) acquainted with Leonid Mikhailovich Volkov? If so, where, when, and under what circumstances did they meet, what is the nature of their relationship, and how do they communicate? What is known about L.M. Volkov’s line of activity and his participation in the financial and business activities of the Anti-Corruption Foundation NPO? - Is he (she) familiar with the following organizations and sole proprietors: sole proprietor Alexei Anatolyevich Navalny, sole proprietor Leonid Mikhailovich Volkov, Stroy Engineering LLC, DMSTR LLC, DMSTR GROUP LLC, Country of Tides LLC, Media-Live LLC, Leviathan-Media LLC, Business Services Center LLC, Knopka LLC, Alliance of Doctors Interregional Trade Union of Healthcare Workers, Foundation for the Organization and Coordination of the Protection of Citizens’ Rights NPO, Consumer Protection Society “Kontrol” Interregional Public Consumer Organization, Fifth Season Media Support Foundation? If so, what is the nature of the activities of these organizations and sole proprietors? Who are the founders, managers, and employees of these organizations, where are they located, and how are they financed? - Is he (she) acquainted with the following persons: Natalya Vladimirovna Volkova (Gredina), Roman Viktorovich Rubanov, Ruslan Tabrizovich Shaveddinov, Anna Mikhailovna Chekhovich, Alexander Evgenyevich Pomazuyev, Vyacheslav Ilyich Gimadi, Evgeny Mikhailovich Zamyatin, Vladlen Kornelevich Los, Alexander Nikolayevich Khomenko, Vlada Andreyevna Anikina, Nikolay Vladimirovich Khomenko, Svetlana Sergeyevna Potasheva (Bridun), Alexei Anatolyevich Navalny? If so, where, when, and under what circumstances did he (she) meet them, what is the nature of the relationship, and are (were) they employees of the Anti-Corruption Foundation NPO and the Foundation

for the Organization and Coordination of the Protection of Citizens’ Rights NPO, and what duties do (did) they perform?

This list of questions is not exhaustive or final and may be adjusted during the questioning.

The progress and results of the investigation of this criminal case are under the personal supervision of the leadership of the Investigative Committee of the Russian Federation; accordingly, I request that you personally supervise the execution of this instruction.

During the searches, do not prepare or provide copies of procedural decisions or other materials from the criminal case to requesting persons where their delivery is not expressly provided for by the Criminal Procedure Code of the Russian Federation.

In accordance with Article 161 of the Criminal Procedure Code of the Russian Federation, obtain non-disclosure undertakings regarding the preliminary investigation data from the persons being questioned and their lawyers, the persons whose premises are searched, their representatives, and the attesting witnesses.

Prepare records of investigative actions in typed form; if it is impossible to use technical means to prepare such records, then together with the handwritten record, send a certified typed copy.

When forwarding seized items and documents to the initiator, prepare an inventory enabling their identification.

Prevent any persons from becoming acquainted with this instruction, except for the employees of the investigative directorate tasked with its execution.

Also prevent any dissemination of this instruction in the mass media and on the Internet.

For matters relating to the execution of this instruction and its results, contact:

Lyubov Pavlovna Yudakova, Investigator for Particularly Important Cases of the Main Directorate for the Investigation of Particularly Important Cases of the Investigative Committee of the Russian Federation, (495) 966-96-85, 8-985-770-80-32.

Roman Alexandrovich Vidyukov, Investigator for Particularly Important Cases of the Main Investigative Directorate of the Investigative Committee of the Russian Federation, (495) 986-77-67, 8-916-009-13-68.

The orders authorizing the searches and permitting the seizure of property will be delivered by hand by officers of the Economic Security and Anti-Corruption Directorate of the regional departments of the Ministry of Internal Affairs.

Senior Investigator for Particularly Important Cases under the Chairman of the Investigative Committee of the Russian Federation Major General of Justice F.R. Gabdulin