2024-10-09 DOJ SDNY pdf 51,200 chars

United States v. Arthur Petrov; Zhanna Soldatenkova; and Ruslan Almetov, Southern District of New York (Oct. 9, 2024)

raw: Us V Petrov Et Al 24 Cr 583 Akh Indictment

Us V Petrov Et Al 24 Cr 583 Akh Indictment (S.D.N.Y. Oct. 9, 2024)

Caption: United States v. Arthur Petrov, et al.

Exhibit of Two Russian Nationals Charged For Their Participation In An Illicit Procurement Network That Exported To Russia Sensitive U.S.-Sourced Microelectronics With Military Applications In Violation Of U.S. Export Controls

Source PDF JSON

summary

paragraph

The scheme involved the use of shell companies and deceptive means to conceal the true destination of the electronics, which were then shipped to Electrocom, a Russia-based supplier of electronics to the Russian military. The defendants are accused of violating the Export Control Reform Act and conspiring to defraud the United States, and are facing charges of conspiracy to violate the Export Control Reform Act, conspiracy to defraud the United States, and conspiracy to smuggle goods from the United States. The alleged violations have significant implications for national security and foreign policy, and the defendants could face severe penalties, including fines and imprisonment.

narrative

Three individuals, including two Russian nationals and a German-Russian national, have been charged with violating U.S. export controls by fraudulently procuring micro-electronics from U.S. distributors and shipping them to Russia. The scheme involved the use of shell companies and deceptive means to conceal the true destination of the electronics, which were then shipped to Electrocom, a Russia-based supplier of electronics to the Russian military. The defendants are accused of violating the Export Control Reform Act and conspiring to defraud the United States, and are facing charges of conspiracy to violate the Export Control Reform Act, conspiracy to defraud the United States, and conspiracy to smuggle goods from the United States. The alleged violations have significant implications for national security and foreign policy, and the defendants could face severe penalties, including fines and imprisonment. The defendants used shell companies and deceptive means to conceal that the electronics components were destined for Russia. The technology that the defendants procured in contravention of export controls during the course of the conspiracy has significant military applications, and include various types of electronics components that have been recovered in Russian military hardware on the battlefield in Ukraine, such as Russian guided missiles, drones, and electronic warfare and communications devices. During the course of the scheme, ARTHUR PETROV, ZHANNA SOLDATENKOVA, and RUSLAN ALMETOV, the defendants, procured from U.S. distributors and shipped to Russia more than $225,000 worth of controlled electronics components with military applications. None of the defendants, or the entities they used to perpetrate their scheme, ever applied for an export license from the DOC.

Enriched metadata

Scheme: fcpa (100%)
Court: Southern District of New York

Classified fcpa(confidence 100%). No EDGAR filing fingerprint (criminal/DOJ-side scheme). detection rule →

Extracted insights

Dollar amounts 2

$225K $225,000 $100K–$1M
$10K $10,000 $10K–$100K

Entities 8

person Arthur Petrov ×2
company Astrafteros Technokosmos LTD
company astrafteros technokosmos ltd shell company
company Electrocom VPK
company Juzhoi Electroni
person Ruslan Almetov
company Ultra Trade Service LLC
person Zhanna Soldatenkov

Triples 5

Arthur Petrov procured micro‑electronics from U.S. distributors
Arthur Petrov used Astrafteros Technokosmos LTD shell company
Defendants shipped controlled items to Ultra Trade Service LLC in Latvia
Defendants shipped controlled items to Juzhoi Electroni LLC in Tajikistan
Electrocom supplied critical electronics components to the Russian military

PDF

Us V Petrov Et Al 24 Cr 583 Akh Indictment · Source

Text layers

Extracted body text (51,200c)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
------------------------------------ X

UNITED STATES OF AMERICA

- V. -

ARTHUR PETROV,
ZHANNASOLDATENKOVA, and
RUSLAN ALMETOV,

Defendants.

------------------------------------ X

The Grand Jury charges:

INDICTMENT

24 Cr.

2 4CRIM 58 3

INTRODUCTION

1. The charges in this Indictment arise out of a sophisticated international scheme to

violate and evade U.S. export controls against Russia that began before and continued after

Russia' s February 2022 invasion of Ukraine. The defendants, ARTHUR PETROV, a German

Russian national, and ZHANNA SOLDATENKOV A and RUSLAN ALMETOV, who are

Russian nationals operating an illicit procurement network in Russia and elsewhere overseas,

fraudulently procured from U.S. distributors large quantities of micro-electronics subject to U.S.

export controls on behalf of LLC Electrocom VPK ("Electrocom"), a Russia-based supplier of

critical electronics components for manufacturers supplying weaponry and other equipment to the

Russian military. To carry out the scheme, the defendants used shell companies and other

deceptive means to conceal that the electronics components were destined for Russia. The

technology that the defendants procured in contravention of export controls during the course of

the conspiracy has significant military applications, and include various types of electronics

components that have been recovered in Russian military hardware on the battlefield in Ukraine,

such as Russian guided missiles, drones, and electronic warfare and communications devices.

2. To perpetrate the scheme, ARTHUR PETROV, the defendant, first acquired the

controlled micro-electronics from U.S.-based electronics exporters using a Cyprus-based shell

company, Astrafteros Technokosmos LTD ("Astrafteros"). PETROV procured these sensitive

electronics components by falsely representing to the U.S. exporters that Astrafteros was

purchasing the items for fire security systems, among other commercial uses, and that the ultimate

end-users and destinations of the electronics were companies in Cyprus, Latvia, or Tajikistan -

when in fact the components were destined for Electrocom in Russia, which supplies

manufacturers for the Russian military. The micro-electronics that PETROV procured as part of

the conspiracy included, among other things, microcontrollers and integrated circuits that are on

the Commerce Control List ("CCL") maintained by the U.S. Department of Commerce ("DOC")

and cannot lawfully be exported or reexported to Russia without a license from the DOC. Invoices

provided to PETROV by the U.S. distributors expressly noted that these microcontrollers and

integrated circuits are subject to U.S. export controls. As noted, these types of micro-electronics

have been recovered in Russian military equipment on the battlefield in Ukraine.

3. To evade these controls, ARTHUR PETROV, ZHANNA SOLDATENKOV A, and

RUSLAN ALMETOV, the defendants, worked together to transship the controlled items using

pass-through entities in third countries. In particular, after fraudulently procuring the electronics

components from the U.S . distributors, PETROV shipped the controlled items to a pass-through

shipping company in Latvia used by SOLDATENKOV A, Ultra Trade Service LLC ("Ultra Trade

Service"), or to a pass-through shipping company in Tajikistan operated by ALMETOV, LLC

Juzhoi Electroni ("Juzhoi"). SOLDATENKOV A and ALMETOV then caused the items to be

shipped, sometimes through yet another third country, such as Lithuania, to the ultimate

destination: Electrocom in Saint Petersburg, Russia. At all times relevant to this Indictment, the

defendants concealed from the U.S. distributors that they were procuring the controlled electronics

components on behalf ofElectrocom- a key supplier for the Russian military industrial complex,

as set forth herein - and that the items were destined not for Cyprus, Latvia, or Tajikistan, but

rather for Russia.

4. During the course of the scheme, ARTHUR PETROV, ZHANNA

SOLDATENKOVA, and RUSLAN ALMETOV, the defendants, procured from U.S. distributors

and shipped to Russia more than $225,000 worth of controlled electronics components with

military applications. None of the defendants, or the entities they used to perpetrate their scheme,

ever applied for an export license from the DOC.

The Defendants and Relevant Entities

5. Electrocom is a Russia-based supplier of electronics to the Russian military,

founded by RUSLAN ALMETOV, the defendant, and two other Russian nationals. At all times

relevant to this Indictment, ALMETOV was an executive at Electrocom, and ARTHUR PETROV

and ZHANNA SOLDATENKOV A, the defendants, were employees at Electrocom. On behalf of

Electrocom, PETROV, SOLD A TENKOV A, ALMETOV, operated and used pass-through entities

-Astrafteros (in Cyprus), Ultra Trade Service (in Latvia), and Juzhoi (in Tajikistan), respectively

- to procure electronics from U.S.-based companies by misrepresenting the true destination and

end-use of the electronics, and then causing those goods and technology to be shipped to

Electrocom in Russia, in violation of U.S. export controls. The company's official name - LLC

Electrocom VPK - reflects its principal purpose as a supplier of components used by the Russian

military: "VPK" is commonly used as an acronym in Russian for "Military Industrial Complex."

Consistent with its corporate name, Electrocom supplies dual-use electronics - that is, electronics

with both civilian and military applications - to Russian military suppliers, including multiple

companies that have been sanctioned by the U.S. Government. For example, in a draft letter dated

March 10, 2023, which SOLDATENKOVA received from an associate, and was addressed from

Electrocom to TRY-Engineering - a U.S.-sanctioned Russian company affiliated with Tactical

Missiles Corporation JSC, a U.S .-sanctioned Russian defense conglomerate that produces airborne

weapons and weapon systems for Russia's navy 1
- ALMETOV, the signatory to the letter

identified as Electrocom's "General Director," described Electrocom as "specializ[ing]" in "the

supply" and import to Russia of "hard-to-reach" and "high-tech electric components produced in

the United States, Europe and Asia for domestic enterprises of both the civil sector and the military

industrial complex."

6. ARTHUR PETROV, the defendant, who principally resided in Cyprus and Russia,

among other locations, operated Astrafteros, a shell company registered in Cyprus, to procure from

U.S. distributors micro-electronics for transshipment to Russia. PETROV worked for Electrocom

and used Astrafteros as a front company, working together with ZHANNA SOLDATENKOVA

1 On or about March 24, 2022, the U.S. Department of the Treasury's Office of Foreign Assets
Control ("OF AC") designated Tactical Missiles Corporation JSC as a Specially Designated
National ("SDN") for "operating or having operated in the defense and related materiel sector of
the Russian Federation economy and for being owned or controlled by, or having acted or
purported to act for or on behalf of, directly or indirectly, the Government of the Russian
Federation," and OFAC designated TRY-Engineering (also known as TRY Auto Limited Liability
Company) as an SDN for "being owned or controlled by, or having acted or purported to act for
or on behalf of, directly or indirectly, [Tactical Missiles Corporation JSC]." On or about April 1,
2022, the DOC added "Tactical Missile Corporation, TRY Engineering" to the DOC's Entity List
- which identifies entities for which there is reasonable cause to believe the entities have been
involved, are involved, or pose a significant risk of being or becoming involved in activities
contrary to the national security or foreign policy interests of the United States - "for acquiring
and attempting to acquire items subject to the [DOC's Export Administration Regulations] in
support of Russia's military."

and RUSLAN ALMETOV, to procure from U.S. distributors hundreds of thousands of dollars'

worth of controlled goods that they then transshipped to Electrocom in Russia. Based on a review

of email communications, PETROV represented that he was "Head of Purchasings" for

Astrafteros. PETROV's public online profile stated that he stopped working for Electrocom in

February 2022 - and described his role there as "Purchaser" and "Head [o]f Purchasing

Department" in Russia" - yet his email signature blocks and the content of his email

correspondence made clear that he was still working for Electrocom but doing so under the

Astrafteros name. For example, even after he began operating as the "Head of Purchasings" for

Astrafteros, PETROV sometimes even used an email address expressly associating him with

Electrocom.

7. ZHANNA SOLDATENKOVA, the defendant, who resides in Russia, at all times

relevant to this Indictment, worked for Electrocom and transshipped U.S.-sourced electronics to

Electrocom in Russia through Ultra Trade Service, a Latvian third-party distributor.

SOLDATENKOVA used Ultra Trade Service as a pass-through for U.S.-sourced parts procured

for Electrocom by ARTHUR PETROV, the defendant, through Astrafteros in Cyprus. During the

course of the scheme, the website for Ultra Trade Service stated that the company supplies

"electronic components" and provides "supply and service in Russia."

8. RUSLAN ALMETOV, the defendant, who resides in Russia, is the co-founder and

has served as General Director of Electrocom. As part of the illicit procurement network with

ARTHUR PETROV and ZHANNA SOLDATENKOVA, the defendants, ALMETOV operated

Juzhoi, a shell company registered and based in Tajikistan, to transship U.S.-sourced electronics

procured by PETROV and Astrafteros in Cyprus, to Electrocom in Russia, a critical supplier for

the Russian military.

Background on Russia's Use of U.S.-Sourced Electronics in Ukraine

9. Russia is highly dependent on Western-sourced micro-electronics components for

its military's hardware, including components manufactured or sold in the United States. Russia

relies on third-party transshipment hubs and clandestine procurement networks, such as the

network operated by ARTHUR PETROV, ZHANNA SOLDATENKOVA, and RUSLAN

ALMETOV, the defendants, to secure access to such U.S.-sourced electronics.

10. Russia's weapons systems and military platforms - including rocket systems,

drones, ballistic missiles, tactical radios, and electronic warfare devices - contain a range of

predominantly Western-sourced components and micro-electronics that are critical to their

functions. Russia's war effort in Ukraine is particularly dependent on components sourced from

the United States. An array of U.S.-sourced components have been found in Russian military

hardware recovered in Ukraine since Russia's February 2022 invasion. As set forth below, many

of these components are subject to export controls in the United States. Categories of electronics

components found in Russian military hardware in Ukraine include, among other things, the types

of microcontrollers and integrated circuits that ARTHUR PETROV, ZHANNA

SOLDATENKOVA, and RUSLAN ALMETOV, the defendants, have fraudulently procured from

U.S. distributors and illicitly shipped to Electrocom in Russia.

Background on Applicable Export Regulations

11. On August 13, 2018, the then-President signed into law the National Defense

Authorization Act of 2019, which included the Export Control Reform Act ("ECRA"). See 50

U.S.C. § 4801 et seq. ECRA provides permanent statutory authority for the Export Administration

Regulations ("EAR"), Title 15, Code of Federal Regulations, Sections 730-774.

12. ECRA provides that "the national security and foreign policy of the United States

require that the export, reexport, and in-country transfer of items, and specified activities of United

States persons, wherever located, be controlled." 50 U.S.C. § 4811. To that end, ECRA grants

the President the authority to "(1) control the export, reexport, and in-country transfer of items

subject to the jurisdiction of the United States, whether by United States persons or foreign

persons; and (2) the activities of United States persons, wherever located, relating to" specific

categories of items and information. 50 U.S.C. § 4812. ECRA grants to the Secretary of

Commerce the authority to establish the applicable regulatory framework. 50 U.S.C. § 4813.

13. ECRA authorizes the DOC to review and control the export from the United States

of certain items, including goods, software, and technologies. The EAR outline the regulatory

framework as provided by ECRA. In particular, the EAR restrict the export of items that could

contribute to the military potential of other nations or that could be detrimental to U.S. foreign

policy or national security. The EAR impose licensing and other requirements for items subject

to the EAR to be lawfully exported from the United States or lawfully reexported from one foreign

destination to another.

14. Through the EAR, the DOC's Bureau oflndustry and Security ("BIS") reviews and

controls the export from the United States to foreign countries of certain items. In particular, the

BIS has placed restrictions on the export and reexport of items that the BIS has determined could

make a significant contribution to the military potential or nuclear proliferation of other nations or

that could be detrimental to the foreign policy or national security of the United States. Under the

EAR, such restrictions depend on several factors, including the technical characteristics of the

item, the destination country, the end-user, and the end-use.

15. The most sensitive items subject to EAR controls are identified on the Commerce

Control List, or CCL, set forth in Title 15, Code of Federal Regulations, Part 774, Supplement

Number 1. Items listed on the CCL are categorized by Export Control Classification Number

("ECCN"), each of which have export control requirements depending on destination, end-use,

and end-user. As of April 8, 2022, license requirements for export to Russia were expanded to

cover all items on the CCL. See 87 Fed. Reg. 122l6 (Mar. 3, 2022); 87 Fed. Reg. 22130 (Apr. 14,

2022); 15 C.F.R. § 746.8.

16. As detailed below, ARTHUR PETROV, ZHANNA SOLDATENKOVA, and

RUSLAN ALMETOV, the defendants, procured items controlled on the CCL, for which an export

license from the DOC is required for the export, or reexport, to Russia of these goods. None of

the defendants - nor their affiliated entities - applied for, or received, a license from the DOC

to ship controlled items to Russia.

17. Under ECRA, it is a crime to willfully violate, attempt to violate, conspire to

violate, or cause a violation of any regulation, order, license, or authorization issued pursuant to

the statute, including the EAR. See 50 U.S.C. § 4819(a)(l).

The Scheme

18. As described above, ARTHUR PETROV, ZHANNA SOLDATENKOVA, and

RUSLAN ALMETOV, the defendants, perpetrated a scheme to evade and violate U.S. export

controls by procuring and shipping controlled electronics with military applications to Russia.

PETROV negotiated the purchase and export of the electronics with U.S.-based suppliers. To

procure the technology, PETROV misrepresented that the goods would be shipped to Cyprus,

Latvia, or Tajikistan - which were in fact the locations of pass-through shipping companies

operated and used by PETROV and his co-conspirators to transship the components to Electrocom

in Russia. In particular, SOLD A TENKOV A used Ultra Trade Service in Latvia, and ALMETOV

used Juzhoi in Tajikistan, to ship to Russia the sensitive U.S.-sourced components initially

procured by PETROV. As an essential part of the scheme, the defendants concealed from the

U.S. exporters that the goods were destined for Russia at all times relevant to this Indictment.

19. Set forth below are three examples of exports of controlled technology that

ARTHUR PETROV, ZHANNA SOLDATENKOVA, and RUSLAN ALMETOV, the defendants,

executed as part of this scheme ("Export #1," "Export #2," and "Export #3").

Export #1

20. In or about April 2022, approximately six weeks after Russia's invasion of Ukraine,

ARTHUR PETROV, the defendant, began communicating with a U.S.-based electronics

distributor ("U.S. Distributor-I"), to purchase an array of micro-electronics, including electronics

subject to DOC export controls, as set forth below.

21. In his initial correspondence with U.S. Distributor- I in or about April 2022,

ARTHUR PETROV, the defendant, misrepresented that Astrafteros in Cyprus was the end-user of

the items, falsely claiming that Astrafteros is a "fabless manufacturer (fire security systems

sphere)," when in fact PETROV operated Astrafteros as a pass-through freight-forwarder, on

behalf of Electrocom and in coordination with ZHANNA SOLDATENKOV A and RUSLAN

ALMETOV, the defendants.2

22. The electronics that ARTHUR PETROV, the defendant, procured as part of the

scheme from U.S. Distributor-I in Export #1 included microcontrollers that are controlled on the

2 The defendants communicated primarily in Russian. Descriptions of those communications in
this Indictment reflect draft English translations. Throughout this Indictment, all communications
are described in substance and in part, and quoted text appears as in the original messages,
including any typographical and grammatical errors, except where-alterations are indicated.

CCL for Anti-Terrorism reasons under ECCN 3A991.a.2, such that a license from the DOC was

required for the export or reexport to Russia of this item at all times relevant to this Indictment.

23. On or about July 14, 2022, following the above-referenced misrepresentations by

ARTHUR PETROV, the defendant, about the nature of Astrafteros and the destination of the

electronics he was seeking to purchase, U.S. Distributor-I sold PETROV and Astrafteros

approximately 15 16-bit flash microcontrollers, controlled under ECCN 3A991.a.2, and shipped

the microcontrollers on or about July 16, 2022 from the United States to PETROV at an address

in Cyprus, where PETROV operated the shell company Astrafteros. On the invoice for the order

provided to PETROV, U.S. Distributor- I expressly noted that the 15 microcontrollers are

controlled under ECCN 3A991.a.2 and stated that the export of the microcontrollers is controlled

by the U.S. Government, authorized "only to the country of ultimate destination for use by the

ultimate consignee or end-user(s) herein identified," and that the items are prohibited from being

"resold, transferred, or otherwise disposed of, to any other country or to any person other than the

authorized ultimate consignee or end-user(s)."

24. On or about July 20, 2022, ARTHUR PETROV, the defendant, received the 15

controlled microcontrollers in Cyprus. On or about July 27, 2022, ZHANNA SOLDATENKOVA,

the defendant, emailed PETROV requesting a status update on the microcontrollers. On or about

July 28, 2022, PETROV informed SOLD A TENKOV A via email that he would send her the

microcontrollers imminently, along with other micro-electronics procured from U.S. Distributor-

25. On or about July 29, 2022, ZHANNA SOLDATENKOVA, the defendant, sent a

contract, which included the 15 controlled microcontrollers, to an employee of a Russia-based

logistics company, IBMLogistics, who was responsible for coordinating the transportation of the

goods to Russia. ARTHUR PETROV and ZHANNA SOLDATENKOVA, the defendants, used

IBMLogistics to transship sensitive, controlled electronics components - after PETROV

procured the goods from U.S. distributors and the goods were shipped to PETROV and Astrafteros

in Cyprus - to Electrocom in Russia. The contract explicitly stated that the buyer of the goods

was Electrocom, and the resulting invoice from IBMLogistics stated that the goods would be

shipped to Saint Petersburg, Russia.

26. On or about September 20, 2022, ZHANNA SOLDATENKOV A, the defendant,

emailed a contract to an employee of a Russian Radio Frequency Identification ("RFID")

company, Unimax LLC ("Unimax"), reflecting the sale by Electrocom to Unimax of

approximately 185 microcontrollers of the same make and model as the 15 microcontrollers that

U.S. Distributor-I exported to PETROV and Astrafteros. The contract indicated that Electrocom

was shipping the microcontrollers to Unimax's Moscow address. Russia is reliant on Western

imports for its RFID chips, which have significant military applications, including for use in

tagging military assets for tracking purposes.

27. A DOC license was not applied for, or obtained, in connection with the export of

the 15 controlled microcontrollers in Export # 1.

Export #2

28. In or about July 2022, ARTHUR PETROV, the defendant, began purchasing DOC-

controlled electronics from another U.S.-based distributor ("U.S. Distributor-2"). On or about July

27, 2022, in order to procure the sensitive controlled goods, PETROV misrepresented the nature

of Astrafteros's business to a U.S. Distributor-2 employee in an email, stating that the function of

Astrafteros is "design and production" - when in fact, as described above, PETROV operated

Astrafteros as a pass-through freight-forwarder, on behalf of Electrocom and in coordination with

ZHANNA SOLDATENKOVA and RUSLAN ALMETOV, the defendants, to obtain electronics

for Electrocom.

29. Export #2 included integrated circuits that were controlled on the CCL under ECCN

3A991.b.l.a for Anti-Terrorism reasons, such that a license from the DOC was required for the

export or reexport to Russia of this item at all relevant times to this Indictment.

30. On or about August 18, 2022, U.S. Distributor-2 shipped an array of dual-use

electronics to Astrafteros 's address in Cyprus. In the shipping, billing, and end-use records and

correspondence, ARTHUR PETROV, the defendant, falsely represented to U.S. Distributor-2 that

the "ultimate consignee" of the controlled items was Ultra Trade Service - that is, the Latvian

third-party distributor used by ZHANNA SOLDATENKOV A, the defendant, to perpetrate the

scheme on behalf of Electrocom. The invoice that U.S. Distributor-2 provided to PETROV for

Export #2 noted the ECCN numbers under which the goods were controlled and explicitly stated

that "re-export[ation]" or further "ship[ment] to another destination" was prohibited under U.S.

export controls.

31. On or about August 22, 2022, ARTHUR PETROV, the defendant, emailed

ZHANNA SOLDATENKOV A, the defendant, informing her that Export #2 would be sent the

following day. PETROV also emailed SOLD A TENKOV A a shipping label and an invoice for

Export #2, reflecting the controlled micro-electronics that had been shipped by U.S. Distributor-2

to Astrafteros in Cyprus.

32. On or about August 31 , 2022, ZHANNA SOLD A TENKOV A, the defendant,

emailed an employee of IBMLogistics, providing IBMLogistics with the weights for each of the

items ordered, including the export-controlled integrated circuits. On or about September 2, 2022,

SOLDA TENKOV A sent a contract for the order to IBMLogistics. The contract set forth that the

buyer of the goods was Electrocom, and the resulting invoice from IBMLogistics stated that the

goods would be shipped to Saint Petersburg, Russia.

33. A DOC license was not applied for, or obtained, in connection with the export of

the integrated circuits in Export #2.

Export #3

34. On or about July 15, 2022, ARTHUR PETROV, the defendant, ordered from U.S.

Distributor-I , via email, 90 microcontrollers - specifically, 16-bit flash digital signal processors

and controllers - based on his same April 2022 misrepresentation to U.S. Distributor-I that

Astrafteros was the end-user of the goods purchased from U.S. Distributor-I and that Cyprus was

the final destination.

35. The microcontrollers procured in Export #3 are controlled on the CCL under ECCN

3A991.a.2 for Anti-Terrorism reasons, such that a license from the DOC was required for the

export or reexport to Russia of this item at all times relevant to this Indictment.

36. On or about January 11 , 2023, relying on the above-referenced misrepresentations

by ARTHUR PETROV, the defendant, to U.S. Distributor-I about the nature of Astrafteros and

the final destination of the goods, U.S. Distributor-I shipped the 90 controlled microcontrollers

from the United States to PETROV at Astrafteros's address in Cyprus. On the invoice for the

order provided to PETROV, U.S. Distributor-I expressly noted that the microcontrollers are

controlled under ECCN 3A991.a.2 and that the export of the microcontrollers is contr?lled by the

U.S. Government, authorized "only to the country of ultimate destination for use by the ultimate

consignee or end-user(s) herein identified," and that the items are prohibited from being "resold,

transferred, or otherwise disposed of, to any other country or to any person other than the

authorized ultimate consignee or end-user(s)."

37. On or about January 31 , 2023, ARTHUR PETROV, the defendant, shipped the 90

controlled microcontrollers to Juzhoi in Tajikistan, and updated his superior at Electrocom,

RUSLAN ALMETOV, the defendant, about the status of the shipment. ZHANNA

SOLDATENKOV A, the defendant, participated in ensuring that the shipment reached Russia;

among other things, SOLDATENKOV A emailed ALMETOV a contract between Electrocom and

Juzhoi for the microcontrollers. The consignee on the contract, which was not provided to U.S.

Distributor-I , was listed as Electrocom alongside its address in Saint Petersburg, Russia.

3 8. Over the following weeks, ZHANNA SOLD A TENKOV A, the defendant, apprised

her Electrocom colleagues, including RUSLAN ALMETOV, the defendant, of the shipment of the

90 microcontrollers. For example, on or about February 8, 2023 , SOLDATENKOV A emailed

ALMETOV the shipping label for the shipment that included the microcontrollers.

SOLD A TENKOV A was also tracking other Russia-bound shipments around this time. On or

about February 27, 2023, SOLDATENKOVA emailed an employee of Aviasystems, a Russian

aerospace company and military supplier that focuses on aircraft navigational support, flight

controls, and landing equipment, to advise that a shipment of goods had arrived at Russian

customs, and a second shipment was on the border. SOLDATENKOV A wrote, "Due to the fact

that they are dual-use, we try to make certificates for them," an apparent reference to the military

applications for the goods and SOLDATENKOVA's efforts around this time to facilitate shipment

of such goods to Electrocom in Russia.

39. On or about March 1, 2023 , RUSLAN ALMETOV, the defendant, sent a Juzhoi

employee two emails reflecting that Export #3 involved Cyprus, Tajikistan, and

Russia. ALMETOV attached "invoices from Cyprus to Dushanbe, as well as from Dushanbe to

Russia," referring to the city in Tajikistan where Juzhoi is based. He attached the Astrafteros

invoice that listed the 90 controlled microcontrollers, and indicated that Electrocom was buying

the goods from Juzhoi. ALMETOV added, "They have items that need to be left in a warehouse

in Dushanbe," and stated that "The remaining positions," which ALMETOV made clear included

the 90 controlled microcontrollers, "must be shipped to Russia on the provided invoice."

40. In or about early March 2023, the Export #3 microcontrollers arrived at

Electrocom's address in Saint Petersburg, Russia.

41. A DOC license was not applied for, or obtained, in connection with the export of

the microcontrollers in Export #3.

42. On or about August 26, 2023, ARTHUR PETROV, the defendant, was arrested in

the Republic of Cyprus at the request of the United States. He was later extradited and first brought

to and arrested in the Southern District of New York on August 8, 2024.

STATUTORY ALLEGATIONS

COUNT ONE
(Conspiracy to Defraud the United States)

43. The allegations contained in paragraphs 1 through 42 of this Indictment are

incorporated as though fully set forth herein.

44. From at least in or about 2022, up to and including in or about August 2023, in the

Southern District of New York, Cyprus, Russia, Latvia, Tajikistan, Lithuania, and elsewhere, and

in an offense begun and committed out of the jurisdiction of any particular State or district of the

United States, ARTHUR PETROV, ZHANNA SOLDATENKOVA, and RUSLAN ALMETOV,

the defendants, and others known and unknown, at least one of whom was first brought to and

arrested in the Southern District of New York, knowingly and intentionally combined, conspired,

confederated, and agreed together and with each other to defraud the United States and agencies

thereof, by impairing, impeding, obstructing, and defeating, through deceitful and dishonest

means, the lawful functions of the U.S. Department of Commerce, an agency of the United States,

in the enforcement and issuance of licenses relating to the export of goods.

45. In furtherance of the conspiracy and to effect the illegal object thereof, ARTHUR

PETROV, ZHANNA SOLDATENKOVA, and RUSLAN ALMETOV, the defendants, and others

known and unknown, committed the overt acts set forth in paragraphs 16, 18 through 21 , 23

through 26, 28 through 32, 34, and 36 through 39 of this Indictment, among others.

(Title 18, United States Code, Sections 371 and 3238.)
'

COUNT TWO
(Conspiracy to Violate ECRA)

The Grand Jury further charges:

46. The allegations contained in paragraphs 1 through 42 of this Indictment are

incorporated as though fully set forth herein.

47. From at least in or about 2022, up to and including in or about August 2023 , in the

Southern District of New York, Cyprus, Russia, Latvia, Tajikistan, Lithuania, and elsewhere, and

in an offense begun and committed out of the jurisdiction of any particular State or district of the

United States, ARTHUR PETROV, ZHANNA SOLDATENKOVA, and RUSLAN ALMETOV,

the defendants, and others known and unknown, at least one of whom was first brought to and

arrested in the Southern District of New York, knowingly and willfully combined, conspired,

confederated, and agreed together and with each other to violate, and to cause a violation of,

licenses, orders, regulations, and prohibitions issued under the Export Control Reform Act.

48. It was a part and an object of the conspiracy that ARTHUR PETROV, ZHANNA

SOLDATENKOVA, and RUSLAN ALMETOV, the defendants, and others known and unknown,

would and did export and cause to be exported from the United States to Russia items controlled

under Subchapter I of the Export Control Reform Act, to wit, electronics components on the

Commerce Control List set forth in Title 15, Code of Federal Regulations, Part 774, Supplement

Number 1, without having first obtained a license for such export from the U.S. Department of

Commerce, in violation of Title 50, United States Code, Section 4819(a)(2)(A), (B), (C), (D), (E),

(F), and (G), and Title 15, Code of Federal Regulations, Sections 736.2(b)(l ), 746.8(a)(l), and

764.2.

(Title 50, United States Code, Sections 4819(a)(l), 4819(a)(2)(A)-(G), and 4819(b); Title 15,
Code of Federal Regulations, Sections 736.2(b)(l), 746.8(a)(l), and 764.2; and Title 18, United

States Code, Section 3238.)

COUNT THREE
(Violation ofECRA-Export #1)

The Grand Jury further charges:

49. The allegations contained in paragraphs 1 through 42 of this Indictment are

incorporated as though fully set forth herein.

50. From at least in or about April 2022, up to and including in or about October 2022,

in the Southern District of New York, Cyprus, Russia, Latvia, Lithuania, and elsewhere, and in an

offense begun and committed out of the jurisdiction of any particular State or district of the United

States, ARTHUR PETROV and ZHANNA SOLDATENKOVA, the defendants, and others

known and unknown, at least one of whom was first brought to and arrested in the Southern District

ofNew York, knowingly and willfully exported and caused to be exported, and attempted to export

and cause to be exported, from the United States to Russia items controlled under Subchapter I of

the Export Control Reform Act, to wit, microcontrollers on the Commerce Control List set forth

in Title 15, Code of Federal Regulations, Part 774, Supplement Number 1, controlled under Export

Control Classification Number 3A991.a.2, without having first obtained a license for such export

from the U.S. Department of Commerce, and aided and abetted the same.

(Title 50, United States Code, Sections 4819(a)(l ), 4819(a)(2)(A)-(G), and 4819(b); Title 15,
Code of Federal Regulations, Sections 736.2(b)(l), 746.8(a)(l), and 764.2; and Title 18, United

States Code, Sections 2 and 3238.)

COUNT FOUR
(Violation of ECRA - Export #2)

The Grand Jury further charges:

51. The allegations contained in paragraphs 1 through 42 of this Indictment are

incorporated as though fully set forth herein.

52. From at least in or about July 2022, up to and including in or about October 2022,

in the Southern District of New York, Cyprus, Russia, Latvia, and elsewhere, and in an offense

begun and committed out of the jurisdiction of any particular State or district of the United States,

ARTHUR PETROV and ZHANNA SOLDATENKOVA, the defendants, and others known and

unknown, at least one of whom was first brought to and arrested in the Southern District of New

York, knowingly and willfully exported and caused to be exported, and attempted to export and

cause to be exported, from the United States to Russia items controlled under Subchapter I of the

Export Control Reform Act, to wit, integrated circuits on the Commerce Control List set forth in

Title 15, Code of Federal Regulations, Part 774, Supplement Number 1, controlled under Export

Control Classification Number 3A991 .b. l .a, without having first obtained a license for such export

from the U.S. Department of Commerce, and aided and abetted the same.

(Title 50, United States Code, Sections 4819(a)(l ), 4819(a)(2)(A)-(G), and 4819(b); Title 15,
Code of Federal Regulations, Sections 736.2(b)(l), 746.8(a)(l), and 764.2; and Title 18, United

States Code, Sections 2 and 3238.)

COUNT FIVE
(Violation of ECRA - Export #3)

The Grand Jury further charges:

53. The allegations contained in paragraphs 1 through 42 of this Indictment are

incorporated as though fully set forth herein.

54. From at least in or about April 2022, up to and including in or about March 2023,

in the Southern District of New York, Cyprus, Russia, Latvia, Tajikistan, and elsewhere, and in an

offense begun and committed out of the jurisdiction of any particular State or district of the United

States, ARTHUR PETROV, ZHANNA SOLDATENKOVA, and RUSLAN ALMETOV, the

defendants, and others known and unknown, at least one of whom was first brought to and arrested

in the Southern District of New York, knowingly and willfully exported and caused to be exported,

and attempted to export and cause to be exported, from the United States to Russia items controlled

under Subchapter I of the Export Control Reform Act, to wit, microcontrollers on the Commerce

Control List set forth in Title 15, Code of Federal Regulations, Part 774, Supplement Number 1,

controlled under Export Control Classification Number 3A991.a.2, without having first obtained

a license for such export from the U.S. Department of Commerce, and aided and abetted the same.

(Title 50, United States Code, Sections 4819(a)(l), 4819(a)(2)(A)-(G), and 4819(b); Title 15,
Code of Federal Regulations, Sections 736.2(b)(l), 746.8(a)(l), and 764.2; and Title 18, United

States Code, Sections 2 and 3238.)

COUNT SIX
(Conspiracy to Smuggle Goods from the United States)

The Grand Jury further charges:

55. The allegations contained in paragraphs 1 through 42 of this Indictment are

incorporated as though fully set forth herein.

56. From at least in or about February 2022, up to and including in or about August

2023, in the Southern District of New York, Cyprus, Russia, Latvia, Tajikistan, Lithuania, and

elsewhere, and in an offense begun and committed out of the jurisdiction of any particular State or

district of the United States, ARTHUR PETROV, ZHANNA SOLDATENKOVA, and RUSLAN

ALMETOV, the defendants, and others known and unknown, at least one of whom was first

brought to and arrested in the Southern District of New York, knowingly and intentionally

combined, conspired, confederated, and agreed together and with each other to commit an offense

against the United States, to wit, smuggling goods from the United States in violation of Title 18,

United States Code, Section 554.

57. It was a part and an object of the conspiracy that ARTHUR PETROV, ZHANNA

SOLD A TENKOV A, and RUSLAN ALMETOV, the defendants, and others known and unknown,

would and did fraudulently and knowingly export and send from the United States, attempt to

export and send from the United States, and cause to be exported and sent from the United States,

merchandise, articles, and objects, to wit, items controlled under Subchapter I of the Export

Control Reform Act, namely, electronics components on the Commerce Control List set forth in

Title 15, Code of Federal Regulations, Part 774, Supplement Number 1, contrary to laws and

regulations of the United States, to wit, the Export Control Reform Act and associated regulations,

Title 50, United States Code, Sections 4819(a)(l), 4819(a)(2)(A)-(G), and 4819(b), and Title 15,

Code of Federal Regulations, Sections 736.2(b)(l), 746.8(a)(l), and 764.2, and fraudulently and

knowingly receive, conceal, buy, sell, and in any manner facilitate the transportation, concealment,

and sale of such merchandise, articles, and objects, prior to exportation, knowing the same to be

intended for exportation contrary to such laws and regulations of the United States.

2058. In furtherance of the conspiracy and to effect the illegal objects thereof, ARTHUR

PETROV, ZHANNA SOLDATENKOVA, and RUSLAN ALMETOV, the defendants, and others

known and unknown, committed the overt acts set forth in paragraphs 16, 18 through 21 , 23

through 26, 28 through 32, 34, and 36 through 39 of this Indictment, among others.

(Title 18, United States Code, Sections 371 and 3238.)

COUNT SEVEN
(Smuggling Goods from the United States - Export #1)

The Grand Jury further charges:

59. The allegations contained in paragraphs 1 through 42 of this Indictment are

incorporated as though fully set forth herein.

60. From at least in or about April 2022, up to and including in or about October 2022,

in the Southern District of New York, Cyprus, Russia, Latvia, Lithuania, and elsewhere, and in an

offense begun and committed out of the jurisdiction of any particular State or district of the United

States, ARTHUR PETROV and ZHANNA SOLDATENKOVA, the defendants, and others

known and unknown, at least one of whom was first brought to and arrested in the Southern District

of New York, fraudulently and knowingly exported and sent from the United States, attempted to

export and send from the United States, and caused to be exported and sent from the United States,

merchandise, articles, and objects, to wit, items controlled under Subchapter I of the Export

Control Reform Act, namely, microcontrollers on the Commerce Control List set forth in Title 15,

Code of Federal Regulations, Part 774, Supplement Number 1, controlled under Export Control

Classification Number 3A991.a.2, contrary to laws and regulations of the United States, to wit, the

Export Control Reform Act and associated regulations, Title 50, United States Code, Sections

4819(a)(l), 4819(a)(2)(A)-(G), and 4819(b), and Title 15, Code of Federal Regulations, Sections

736.2(b)(l), 746.8(a)(l), and 764.2, and fraudulently and knowingly received, concealed, bought,

sold, and in any manner facilitated the transportation, concealment, and sale of such merchandise,

articles, and objects, prior to exportation, knowing the same to be intended for exportation contrary

to such laws and regulations of the United States.

(Title 18, United States Code, Sections 554(a), 2, and 3238.)

COUNT EIGHT
(Smuggling Goods from the United States - Export #2)

The Grand Jury further charges:

61. The allegations contained in paragraphs 1 through 42 of this Indictment are

incorporated as though fully set forth herein.

62. From at least in or about July 2022, up to and including in or about October 2022,

in the Southern District of New York, Cyprus, Russia, Latvia, and elsewhere, and in an offense

begun and committed out of the jurisdiction of any particular State or district of the United States,

ARTHUR PETROV and ZHANNA SOLDATENKOVA, the defendants, and others known and

unknown, at least one of whom was first brought to and arrested in the Southern District of New

York, fraudulently and knowingly exported and sent from the United States, attempted to export

and send from the United States, and caused to be exported and sent from the United States,

merchandise, articles, and objects, to wit, items controlled under Subchapter I of the Export

Control Reform Act, namely, integrated circuits on the Commerce Control List set forth in Title

15, Code of Federal Regulations, Part 774, Supplement Number 1, controlled under Export Control

Classification Number 3A991.b.1.a, contrary to laws and regulations of the United States, to wit,

the Export Control Reform Act and associated regulations, Title 50, United States Code, Sections

4819(a)(l), 4819(a)(2)(A)-(G), and 4819(b), and Title 15, Code of Federal Regulations, Sections

736.2(b)(l), 746.8(a)(l), and 764.2, and fraudulently and knowingly received, concealed, bought,

sold, and in any manner facilitated the transportation, concealment, and sale of such merchandise,

articles, and objects, prior to exportation, knowing the same to be intended for exportation contrary

to such laws and regulations of the United States.

(Title 18, United States Code, Sections 554(a), 2, and 3238.)

COUNT NINE
(Smuggling Goods from the United States - Export #3)

The Grand Jury further charges:

63. The allegations contained in paragraphs 1 through 42 of this Indictment are

incorporated as though fully set forth herein.

64. From at least in or about April 2022, up to and including in or about March 2023 ,

in the Southern District of New York, Cyprus, Russia, Latvia, Taj ikistan, and elsewhere, and in an

offense begun and committed out of the jurisdiction of any particular State or district of the United

States, ARTHUR PETROV, ZHANNA SOLDATENKOVA, and RUSLAN ALMETOV, the

defendants, and others known and unknown, at least one of whom was first brought to and arrested

in the Southern District of New York, fraudulently and knowingly exported and sent from the

United States, attempted to export and send from the United States, and caused to be exported and

sent from the United States, merchandise, articles, and objects, to wit, items controlled under

Subchapter I of the Export Control Reform Act, namely, microcontrollers on the Commerce

Control List set forth in Title 15, Code of Federal Regulations, Part 774, Supplement Number 1,

controlled under Export Control Classification Number 3A991.a.2, contrary to laws and

regulations of the United States, to wit, the Export Control Reform Act and associated regulations,

Title 50, United States Code, Sections 4819(a)(l), 4819(a)(2)(A)-(G), and 4819(b), and Title 15,

Code of Federal Regulations, Sections 736.2(b)(l), 746.8(a)(l ), and 764.2, and fraudulently and

knowingly received, concealed, bought, sold, and in any manner facilitated the transportation,

concealment, and sale of such merchandise, articles, and objects, prior to exportation, knowing the

same to be intended for exportation contrary to such laws and regulations of the United States.

(Title 18, United States Code, Sections 554(a), 2, and 3238.)

COUNT TEN
(Conspiracy to Commit Wire Fraud)

The Grand Jury further charges:

65. The allegations contained in paragraphs 1 through 42 of this Indictment are

incorporated as though fully set forth herein.

66. From at least in or about February 2022, up to and including in or about August

2023 , in the Southern District of New York, Cyprus, Russia, Latvia, Tajikistan, Lithuania, and

elsewhere, and in an offense begun and committed out of the jurisdiction of any particular State or

district of the United States, ARTHUR PETROV, ZHANNA SOLDATENKOVA, and RUSLAN

ALMETOV, the defendants, and others known and unknown, at least one of whom was first

brought to and arrested in the Southern District of New York, knowingly and willfully combined,

conspired, confederated, and agreed together and with each other to commit wire fraud in violation

of Title 18, United States Code, Section 1343.

67. It was a part and an object of the conspiracy that ARTHUR PETROV, ZHANNA

SOLDATENKOVA, and RUSLAN ALMETOV, the defendants, and others known and unknown,

having devised and intending to devise a scheme and artifice to defraud, and for obtaining money

and property by means of false and fraudulent pretenses, representations, and promises, would and

did transmit and cause to be transmitted by means of wire communication in interstate and foreign

commerce, writings, signs, signals, pictures, and sounds for the purpose of executing such scheme

and artifice, in violation of Title 18, United States Code, Section 1343.

(Title 18, United States Code, Sections 1349 and 3238.)

COUNT ELEVEN
(Conspiracy to Commit Money Laundering)

The Grand Jury further charges:

68. The allegations contained in paragraphs 1 through 42 of this Indictment are .

incorporated as though fully set forth herein.

69. From at least in or about February 2022, up to and including in or about August

2023, in the Southern District of New York, Cyprus, Russia, Latvia, Tajikistan, Lithuania, and

elsewhere, and in an offense begun and committed out of the jurisdiction of any particular State or

district of the United States, ARTHUR PETROV, ZHANNA SOLDATENKOVA, and RUSLAN

ALMETOV, the defendants, and others known and unknown, at least one of whom was first

brought to and arrested in the Southern District of New York, knowingly and intentionally

combined, conspired, confederated, and agreed together and with each other commit money

laundering in violation of Title 18, United States Code, Section 1956(a)(2)(A).

70. It was a part and an object of the conspiracy that ARTHUR PETROV, ZHANNA

SOLDATENKOVA, and RUSLAN ALMETOV, the defendants, and others known and unknown,

would and did transport, transmit, and transfer, and attempt to transport, transmit, and transfer,

monetary instruments and funds to places in the United States from and through places outside the

United States, in amounts exceeding $10,000, with the intent to promote the carrying on of

specified unlawful activity, to wit, (a) smuggling goods from the United States, as charged in

Counts Seven through Nine of this Indictment, and (b) wire fraud, in violation of Title 18, United

States Code, Section 1343.

(Title 18, United States Code, Sections 1956(h), 1956(f), and 3238.)

FORFEITURE ALLEGATIONS

71. As a result of committing the ECRA offenses alleged in Counts Two through Five

of this Indictment, ARTHUR PETROV, ZHANNA SOLDATENKOVA, and RUSLAN

ALMETOV, the defendants, shall forfeit to the United States, pursuant to Title 50, United States

Code, Section 4819( d), all property (i) used or intended to be used, in any manner, to commit or

facilitate the offenses alleged in Counts Two through Five; (ii) constituting or traceable to the gross

proceeds taken, obtained, or retained, in connection with or as a result of the offenses alleged in

Counts Two through Five; and (iii) constituting an item or technology that was exported or

intended to be exported in violation of Title 50, United States Code, Chapter 58, Subchapter I,

including but not limited to a sum of money representing the amount of proceeds obtained as a

result of these offenses.

72. As a result of committing the wire fraud offense alleged in Count Ten of this

Indictment, ARTHUR PETROV, ZHANNA SOLDATENKOV A, and RUSLAN ALMETOV, the

defendants, shall forfeit to the United States, pursuant to Title 18, United States Code, Sections

981(a)(l)(C) and 982(a)(2)(A), and Title 28, United States Code, Section 246l(c), any and all

property, real and personal, that constitutes or is derived from proceeds traceable to the

commission of said offense, including but not limited to a sum of money representing the amount

of proceeds obtained as a result of the offense.

73. As a result of committing the money laundering offense alleged in Count Eleven of

this Indictment, ARTHUR PETROV, ZHANNA SOLDATENKOV A, and RUSLAN ALMETOV,

the defendants, shall forfeit to the United States, pursuant to Title 18, United States Code, Section

982(a)(l), all property, real and personal, involved in the money laundering offense and all

property traceable to such property, including but not limited to a sum of money representing the

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amount of property that was involved in the money laundering offense or is traceable to such

property.

Substitute Assets Provision

74. If any of the above-described forfeitable property, as a result of any act or omission

of the defendants:

a) cannot be located upon the exercise of due diligence;

b) has been transferred or sold to, or deposited with, a third person;

c) has been placed beyond the jurisdiction of the court;

d) has been substantially diminished in value; or

e) has been commingled with other property which cannot be subdivided
without difficulty;

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p) and

Title 28, United States Code, Section 2461(c), to seek forfeiture of any other property of said

defendants up to the value of the above forfeitable property.

REERSON

(Title 18, United States Code, Sections 981, 982;
Title 21, United States Code, Section 853;
Title 28, United States Code, Section 2461;
Title 50, United States Code, Section 4819.)

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DAMIAN WILLIAMS
United States Attorney

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