Robert S. Mueller III

“ If venue had been waived, the defendants would have faced a single indictment in one district, and not two indictments in adjacent districts. One defendant elected, as is his right, not to waive venue. The Special Counsel's Office accordingly has proceeded in the Eastern District of Virginia. ”

“ On the filing due dates listed below, in the Eastern District of Virginia and elsewhere, defendant RICHARD W. GATES III unlawfully, willfully, and knowingly did fail to file with the Treasury an FBAR disclosing that he had a financial interest in, and signature authority over, a bank, securities, and other financial account in a foreign country, which had an aggregate value of more than $10,000 in a 12-month period, during the years listed below:
(31 U.S.C. §§ 5314 and 5322 (a) ; 18 U.S.C. §§ 2 and 3551 et seq.) ”

“ From 2010 to 2014, GATES caused the following wires, totaling more than $3,000,000, to be sent to entities and bank accounts of which he was a beneficial owner or he otherwise controlled. GATES did not report this income on his tax returns.
MANAFORT And GATES’ Hiding Foreign Bank Accounts And False Filings
19. United States citizens who have authority over certain foreign bank accounts—whether or not the accounts are set up in the names of nominees who act for their principals—have reporting obligations to the United States. ”

“ Lender C, the deposits of which were insured by the Federal Deposit Insurance Corporation, and to obtain moneys, funds, and credits owned by and under the custody and control of such financial institution by means of materially false and fraudulent pretenses, representations, and promises, contrary to Title 18, United States Code, Section 1344. ”

“ The Special Counsel's Office also alerted defense counsel for each defendant that the government was prepared to bring all of the charges before a Grand Jury in the District of Columbia, if the defendants were willing to waive venue (since otherwise we could not do so legally) . ”

“ MANAFORT applied to a second bank, Lender D. Between approximately July 2016 and January 2017, MANAFORT, with the assistance of GATES, sought and secured approximately $16,000,000 in two loans from Lender D. MANAFORT used the Bridgehampton property as collateral for one loan, and the Union Street property for the other.
43. MANAFORT and GATES made numerous false and fraudulent representations to secure the loans. For example, MANAFORT provided the bank with doctored P&Ls for DMI for both 2015 and 2016, overstating its income by millions of dollars. ”

“ Vendor A Total Leviathan Advisors Limited Cyprus Leviathan Advisors Limited Cyprus Leviathan Advisors Limited Cyprus Leviathan Advisors Limited Cyprus Global Highway Limited Cyprus Global Highway Limited Cyprus Global Highway Limited Cyprus Lucicle Consultants Limited Cyprus Lucicle Consultants Limited Cyprus Lucicle Consultants Limited Cyprus Lucicle Consultants Limited Cyprus Lucicle Consultants Limited Cyprus Lucicle Consultants Limited Cyprus United Pompolo Limited Kingdom Global Endeavour Inc. ”