UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

-v.-

JOHN HANTCK,
a/k/a “Jack Hanick,”
Defendant.

COUNT ONE .

(Violation of the International Emergency Economic Powers Act)

The Grand Jury charges:

Be
~--- The Defendant ee ~
a

1. JOHN HANICK, a/k/a “Jack Hanick,” the defendant, is

a United States citizen. From in or around 1996 through in- or

around 2011, HANICK worked as a producer for a United States cable

television network located in New York, New York. Thereafter, from

in or about 2013 through in or about 2017, HANICK worked in support

of the efforts of a Russian national who was subjected to economic

Sanctions as of December 2014, to establish and develop media

outlets in Russia, Greece, Bulgaria, and elsewhere.
The International Emergency Economic Powers Act and the Relevant
Sanctions Orders and Regulations

2. The International Emergency Economic Powers Act

(“IEEPA”), codified at Title 50, United States Code, Sections 1701-

1708, confers upon the President authority to deal with unusual

and extraordinary threats to the national security and foreign

policy of the United States. Section 1705 provides, in part, that

“Ti]t shall be unlawful for a person to violate, attempt to

violate, conspire to violate, or cause a violation of any license,

order, regulation, or prohibition issued under this chapter.” 50

U.S.C. § 1705(a). |

3. In 2014, pursuant to his authorities under the

IEEPA, the President issued Executive Order 13,660, which declare

d

national emergency with respect to the situation in Ukraine.

To
a

address this national emergency, the President blocked all

property and interest in property that were then or thereafter

came within the United States or the possession or control of any

United States person, of individuals determined by the Secre

tary

of the Treasury to meet one or more enumerated criteria. These

criteria include, but are not limited to, individuals determined

to be responsible for or complicit in, or who engage in, actions

‘or policies that threaten the peace, security, stability,

sovereignty, or territorial integrity of Ukraine; or who

materially assist, sponsor, or provide financial, material, or

technological support for, or goods or services to, individuals or

entities engaging in such activities. Executive Order 13,660

prohibits, among other things, the making of any contribution or

provision of funds, goods, or services by, to, or for the benefit

of any person whose property and interests in property are blocked,

and the receipt of any contribution or provision of funds, goods,

or services from any such person.

4. The national emergency declared in Executive Order

13,660 with respect to the situation in Ukraine has remained

in

continuous effect since 2014, and was most recently continued on

March 2, 2021.

5. The President twice expanded the scope of the

national emergency declared in Executive Order 13,660, through:

(1) Executive Order 13,661, issued on March 16, 2014, which

addresses the actions and policies of the Russian Federation with

respect to Ukraine, including the deployment of Russian Federation

military forces in the Crimea region of Ukraine; and (2) Executive

Order 13, 662, issued on March 20, 2014, which addresses the actions

and policies of the Government of the Russian Federation, including

its purported annexation of Crimea and its use of force in Ukraine.

Executive Orders 13,660, 13,661, and 13,662 are collectively

referred to as the “Ukraine-Related Executive Orders.”
6. The Ukraine-Related Executive Orders authorized the

Secretary of the Treasury to take such actions, including the

promulgation of rules and regulations, and to employ all powers

granted to the president under the IEEPA, as may be necessary to

carry out the purposes of ‘those orders. The Ukraine-Related

Executive Orders further authorized the Secretary of, the Treas

ury

to redelegate any of these functions to other offices and agencies

of the United States Government.

 7. To implement the Ukraine-Related Executive Orders,

the Department of the Treasury’s Office of Foreign Assets Control

(“OFAC”) issued certain Ukraine-Related Sanctions Regulations.

These regulations incorporate by reference the definition of

prohibited transactions set forth in the Ukraine-Related Executive

Orders. See 31 C.F.R. § 589.201. The regulations also provide that

-the names of persons designated directly by the Ukraine-Related

Executive Orders, or by OFAC pursuant to the Ukraine-Related

Executive Orders, whose property and interests are therefore

blocked, are published in the Federal Register and incorporated

Specially Designated Nationals (“SDN”) and Blocked
into: the

Persons List (the “SDN List”), which is published on OFAC’s

website. Id. Note l.

8. According to the Ukraine-Related Sanctions

Regulations, a person whose property and interest in property is

pursuant to the Ukraine-Related Executive Orders is

blocked

treated as having an interest in all property and interests in

property of any entity in which the person owns, directly or

indirectly, a 50 percent or greater interest. See 31 C.EF.R.

§ 589.406. Accordingly, such an entity is deemed a person whose

property and interests in property are blocked, regardless of

whether the name of the entity is incorporated into OFAC’s SDN

List. Td.

9. On or about December 19, 2014, OFAC designated

Konstantin Malofeyev (“Malofeyev”) as an SDN pursuant to Executive

Order 13,660. In so designating Malofeyev, OFAC explained that

Malofeyev was one of the main sources of financing for Russians

promoting separatism in Crimea, and was designated as an SDN

because he was responsible for or complicit in, or has engaged in,

actions or polices that threaten the peace, security, stability,

sovereignty, or territorial ‘integrity of Ukraine and _ has

materially assisted, sponsored, or provided financial, material,

or technological support for, or goods or to

services or in support

of the so-called Donetsk People’s Republic.

The Sanctions Violations

10. From at least in or about 2013, through at least in

or about 2017, JOHN HANICK, a/k/a “Jack Hanick,” the defendant,

provided funds, goods, and services to and for the benefit of

Malofeyev and companies owned and controlled by Malofeyev, and

received, funds, goods, and services from Malofeyev. HANICK

continued to engage in this conduct after OFAC listed Malofeyev as

a SDN, in violation of the Ukraine-Related Sanctions Regulations.

HANICK’s Work for Malofeyev_on the Russian TV Network

11. In or about February 2013, JOHN HANICK, a/k/a “Jack

Hanick,” the defendant, traveled from New York, New York, to

Moscow, Russia. As HANICK himself recounted in an unpublished

“memoir” discovered by investigators through the judicially

authorized search of HANICK’s email account, HANICK ostensibly
traveled to Russia at this time to speak at a conference, but was

e of
informed by an associate of Malofeyev that “the real purpos

the trip” was to introduce [HANICK] to investors” in a planned

television news network in Russia. Between February 2013 and June

2013, HANICK made four further trips to Russia. During these trips,

met with Malofeyev and associates of Malofeyev to discuss

he

Malofeyev’s plan to create a new Russian cable television news

network (the “Russian TV Network”).

12. At all times relevant to this Indictment,

Malofeyev is and has been the Chairman of the Board of Directors
of a corporate group, which has a public website that lists the

Russian TV Network as one of its projects. The Russian TV Network

also has its own website, which, as of the date of this Indictment,
lists Malofeyev as the Founder of the Russian TV Network.

13. Beginning in at least the first half of 2013, JOHN

HANICK, a/k/a “Jack Hanick,” the defendant, began corresponding

with Malofeyev and associates of Malofeyev regarding HANICK’s plan

to work for Malofeyev on the Russian TV Network. On or about April

27, 2013, HANICK sent Malofeyev an email in which HANICK stated

that he “came to Russia to work for you.” Shortly thereafter,

HANICK and others exchanged email messages containing draft

organizational charts for the Russian TV Network that listed

at the top
Malofeyev of the organizational chart with the title of

“Analytical News Director,” and listed HANICK as the Managing

Director reporting directly to Malofeyev.

14. In or about July 2013, JOHN HANICK, a/k/a “Jack

Hanick,” the defendant, moved to Russia. Prior to moving there,

HANICK negotiated the terms of his employment directly with

Malofeyev, including the salary he would receive, the payment for

about May
his housing in Moscow, and his Russian work visa. In or

2013, HANICK sent an email to Malofeyev to confirm their agreement

on HANICK’ s salary, a $5,000 monthly housing stipend, and health

insurance, so that Malofeyev’s attorney could prepare HANICK’ s

“work contract for my visa.” An attorney at a Malofeyev-owned

investment company subsequently emailed HANICK a draft employment

contract between a separate Russian entity and HANICK, that

reflected the terms that HANICK had agreed with Malofeyev.

15. Upon his move to Russia in or around July 2013,

JOHN HANICK, a/k/a “Jack Hanick,” the defendant, primarily worked

for Malofeyev on the project of starting up the Russian TV Network.

In his work, HANICK routinely referred to Malofeyev as the

“investor” or the “shareholder” in the Russian TV Network, and

received
discussed instructions for the network that HANICK had

Malofeyev. In around May 2014, HANICK sent an email in

from or

which he stated that “[t]he issue for our investor is how important

4t is to be on the air in September. There is a worldwide conference

in September which he is sponsoring bringing people from all over

world to Moscow.” This was a ‘reference to a conference

the
sponsored in September 2014 by a foundation created and funded by

Malofeyev. In or about January 2015, HANICK wrote to Malofeyev

that the Russian TV Network would “implement your vision” and that

HANICK wanted to “emphasize to all that you are not an investor in

someone [else’s] ideas.” HANICK also communicated Malofeyev’s

instructions to other employees at the Russian TV Network. In or.

about July 2014, HANICK wrote to others that “[o]lur investor

expects to see many stories on our youtube channel by August 1.”

16. On or about December 19, 2014, OFAC designated

asev
‘Malofey an SDN. Nonetheless, JOHN HANICK, a/k/a “Jack Hantcky"
the defendant, continued to work for Malofeyev on the Russian TV

Network and reported directly to Malofeyev. In or about January

2015, HANICK sent Malofeyev a draft of a » Russian TV Network]

Board News Policy.” HANICK wrote that the policy was meant “to

implement your vision and to provide you with information for you

to make decisions . . . You are the founder and chief architect of

the project. We, as board members have the responsibility to direct

implement your instructions.” Later in or about

the staff to

January 2015, HANICK sent an email to Malofeyev regarding the ~

“Funding of [the Russian TV Network],” in which HANICK noted that

money account” and “You said when we had a

“there is 0 on our

problem to contact you directly.”

17. The Russian TV Network went on the air in Russia in

or about April 2015. JOHN HANICK, a/k/a “Jack Hanick,” the

 leadership the network. In emails
‘defendant, played a role at

spanning from 2015 through 2017, HANICK was at different times

described as “Board Chairman, [Russian TV Network],” “General

Producer” of the Russian TV Network, “chairman of the HR committee”

for the Russian TV Network, and “General Advisor” to the Russian

TV Network. HANICK also sent Malofeyev regular emails containing

HANICK’s analysis of the network's television ratings.

18. JOHN HANICK, a/k/a “Jack Hanick,” the defendant,

was generally responsible for the technical and operational

aspects of the Russian TV Network, pursuant to a plan developed

with Malofeyev. For example, in or about August 2016, HANICK wrote

HANICK
an email to another Russian TV Network employee in which

“When with Konstantin, we agreed that we would

wrote: we were

discuss editorial function of new studio and only then create the

technical task. . . . [another Russian TV Network employee] does

editorial content without our interference, you do administrative

and. financial without interference, and 1 do production and

operations.”
19. JOHN HANICK, a/k/a “Jack Hanick,” the defendant,

was paid for his work for the Russian TV Network through two

Russian entities. From in or about 2013 through in or about

February 2016, HANICK was paid by a Russian entity (“Russian

Entity-1”). From in or about May 2016 through 2018, HANICK was

paid by another Russian entity (“Russian Entity-2”). This

compensation was overseen by Malofeyev, however. In 2013, HANICK

negotiated his salary directly with Malofeyev, and an attorney

t contract
employed by Malofeyev sent Hanick the draft employmen

with Russian Entity-1. Later, when his pay was coming from Russian

Entity-2, HANICK continued to report to Malofeyev. In or about May

2018, HANICK sent an email to Malofeyev, writing “At the end of

May, I’1l be finished with [Russian Entity-2]. This means that my

visa to stay in Russia will end. We need help to stay. Can [Russian

Entity-2] extended my employment without pay? My visa with them is

HANICK was paid in Russia for his work for Malofeyev and held the
ed
payments ina Russian. bank account. However, HANICK return
some

of these funds to the United States. In or about March 2017, HANICK

wired a portion of the payments he had received from Russian

Entity-2 from his Russian bank account to a bank account he held

at a bank located in New York, New York.

HANICK’s Work For Malofeyev on the Greek TV Network

20. While working for Malofeyev on the Russian TV

Network, JOHN HANICK, a/k/a “Jack Hanick,” the defendant, also

worked for Malofeyev on a project to establish and run a Greek

television network (the “Greek TV Network”) as a joint venture

between Malofeyev and a Greek associate of Malofeyev (the “Greek

Business Partner”). “According to HANICK’s unpublished memoir,

10
Malofeyev introduced HANICK to the Greek Business Partner at a

social event hosted by Malofeyev in Moscow.

21. In or about November or December 2014, JOHN HANICK,

a/k/a “dack Hanick,” the defendant, began traveling from Mosco

w to

Greece to meet with the Greek Business Partn

er and explore the

idea of pbuilding a Greek television network that would partner

with the Russian TV Network. Malofeyev’s personal assistants

arranged and booked HANICK’s travel to and from Greece, and HANICK

trips directly to Malofeyev. In or about December

reported on his

2014, HANICK sent an email to Malofeyev and the Greek Business

—

Partner to report on a visit that HANICK and the Greek. Business

Partner had made to a local television station in Greece, which

HANICK referred to as “the station which we will own.”

oo. In or about May 2015, JOHN HANICK, a/k/a “dack

Hanick,” the defendant, relocated from Moscow to Greece to work

primarily on the Greek TV Network, while continuing to work for

TV Network well. Shortly before the move, the Greek

‘the Russian as

Business Partner wrote an email to HANICK stating that “Both K.

and I want you in Greece.”

23. JOHN HANICK, a/k/a “Jack Hanick,” the defendant,

primarily resided in Greece from in or about May 2015 through in

or about February 2016. During that time, HANICK reported regularly

to Malofeyev on his work on the Russian TV Network and the Greek

Network, and routinely emphasized the corporate synergy betwe

en
TV

11
 two networks. In about November 2015, HANICK wrote to
the or

Malofeyev that the Greek TV Network was an “opportunity to detail

Russia’s point of view on Greek TV,” and emphasized “our vision of

2015, HANICK wrote to

cooperation.” Also in or about November

Malofeyev that “In order to, facilitate the synergy between media

holdings, [the Russian TV Network] and [the Greek TV Network] shall

provide all resources possible to help each other achieve their

goals.” In or about December 2015, in response to an inquiry about

the Greek TV Network from a representative of Malofeyev, HANICK

wrote that “The news about Russia_is reported from a Russian —

reporter from the Russian point of view.”

HANICK’s Work for Malofeyev on the Bulgarian TV Network

24. Beginning in or about January 2015, JOHN HANICK,

a/k/a “Jack Hanick,” the defendant, began assisting Malofeyev in

Malofeyev’s efforts to acquire a Bulgarian television network (the

“Bulgarian TV Network”). publicly, the Greek Business Partner

claimed to be the person who was attempting to acquire the

Bulgarian TV Network, but HANICK was privately working on

Malofeyev’s behalf to acquire the network. |

25. In or about January 2015, JOHN HANICK, a/k/a “Jack

Hanick, ” the defendant, wrote in an email that Malofeyev had “asked

me to go to Bulgaria to see the station, evaluate the equipment,

and personnel.” The following day, HANICK sent an email to an

employee of Malofeyev’s investment company to ask if they had

12
contacted the prospective business partner in Bulgaria (the

“Bulgarian Business Partner”). HANICK explained that “I must see

the station before [the Bulgarian Business Partner’s] visit to

Moscow on Tuesday. . . . Konstantin needs this information from

me.”

-26. After visiting the Bulgarian TV Network station in

Bulgaria on or about February 5, 2015, JOHN HANICK, a/k/a “Jack

Hanick,” the defendant, wrote a report of his visit to Malofeyev,

Russian TV Network
including HANICK’s recommendation that the

begin producing Russian language programming to be broadcast on

the Bulgarian TV Network. On or about February 16, 2015, HANICK

wrote to the Greek Business Partner, explaining that HANICK was

with Malofeyev, who wanted HANICK to travel to Bulgaria the next

day “to deal with bank to buy Bulgaria tv and restructure loan.”

HANICK went on to explain that the Greek Business Partner should

send someone to travel with HANICK to help to conceal Malofeyev’s

role in the acquisition: “He asked me to ask you if someone from

your company could come with me to talk to the bank since we

understand you cannot go. The buyer should not be Russian but

Greek. . . . Please call me or Konstantin directly.”

27. In or about April 2015, JOHN HANICK, a/k/a “Jack

Hanick,” the defendant, wrote an email to update Malofeyev on the

Bulgarian TV Network negotiations, outlining the structure of the

I told you
proposed deal. Malofeyev responded “No. It is wrong.

13
“the correct way to follow in my office.” Hanick replied “Thank

you, We will proceed as your plan!” About two weeks after this

-exchange, the Bulgarian police raided the Bulgarian TV Network

bank. The day

station to seize equipment on behalf of its creditor
Malofeyev translation of a Polish-
after the raid, HANICK sent a

article that apparently reported that Malofeyev was

language news

Bulgarian TV Network deal,

rumored to be the true financier of the

despite the Greek Business Partner purportedly being the buyer.

cement
HANICK’s False Statements to United States Law Enfor

28. On or about Februar

2021, JOHN 2,
y HANICK, a/k/a

“Jack Hanick,” the defendant, was interviewed by Special Agents

from the Federal Bureau of Investigation. During this interview,

the interviewing agents informed HANICK that they were conducting

the interview in connection with a criminal investigation and that

the FBI Field Office in New York, New York. During

they worked in
interview, HANICK acknowledged that he had learned that
the

Malofeyev was subject to United States sanctions within several

months of when they were announced in December 2014, and that he

knew that United States persons were not permitted to do business

with persons who were sanctioned. HANICK also falsely stated, in

in part, that Malofeyev had no involvement in

substance and

HANICK’s travel to Bulgaria in connection with the Bulgarian TV

Network deal, and that HANICK did not know that Malo
feyev had any

connection to the Bulgarian TV Network until read

ing about it

14
afterward in the press.
Statutory Allegations

29: From at least in or about 2015 through in or about

2018, in the Southern District of New York and elsewhere, JOHN

a/k/a “Jack Hanick,” the defendant, who was a United States

HANICK,

person, unlawfully, willfully, and knowingly violated the IEEPA,

and the regulations promulgated thereunder, as described above, to

wit, HANICK willfully and knowingly provided and caused others to

provide funds, goods, and services to and for the benefit of

Konstantin Malofeyev, whom OFAC had listed as a Specially.

National, and companies owned and controlled by
Designated
Malofeyev, and received funds, goods, and services from Malofeyev,

without first obtaining the: required approval of OFAC, and evaded

and avoided the requirements of United States law with respect to

the provision of funds, goods, and services to and for the benefit

of Malofeyev, in violation of Executive Orders 13,660, 13,661, and

13,662, and 31 C.F.R. § 589.201. ,

(Title 50, United Section 1705; Executive orders

States Code,
al
13,660, 13,661, and 13,662, and Title 31, Code of Feder
Regulations § 589.201)

COUNT TWO

(False Statements)

The Grand Jury further charges:

30. The allegations set forth above in Paragraphs 1

realleged and incorporated by reference as if set

through 30 are

15
fully forth herein.
|
31. On or about February 2, 2021, in the Southern

District of New York and elsewhere, JOHN HANICK, a/k/a “Jack

Hanick,” the defendant, in a matter within the jurisdiction of the

executive branch of the Government of the United States, did

knowingly and willfully make materially false, fictitious, and

fraudulent statements and representations, to wit, when

interviewed by Special Agents from the Federal Bureau of

Investigation, HANICK falsely stated that Konstantin Malofeyev had

0 involvement in HANICK’s travel to Bulgaria in connection with

the Bulgarian TV Network deal, and that HANICK did not know that

Malofeyev had any connection to the Bulgarian TV Network until

reading about it afterward in the press coverage; when in truth,

and in fact, and as HANICK well knew, Malofeyev was among the

individuals involved in attempting to acquire the Bulgarian TV

Network, and was among the individuals with whom HANICK conferred

and from whom HANICK received instructions regarding that

attempted purchase for the purpose of expanding Malofeyev’s media

network.

(Title 18, United States Code, Section 1001.)

FORFEITURE ALLEGATION |

32. As a result of committing the offense alleged in

Count One of this Indictment, JOHN HANICK, a/k/a “Jack Hanick,”

the defendant, shall forfeit to the United States, pursuant to

16
Title 18, United States Code, Section 981(a) (1) (C), and Title 28,

United States Code, Section 2461, all property, real and personal,

which constitutes or is derived from proceeds traceable to the

commission of the offense alleged in Count One, including but not

limited to a sum of money in United States currency. representing

.
the amount of proceeds traceable to the commission of said offense

substitute Asset Provision

33. If any of the property described above as being

subject to forfeiture, as a result of any act or omission of JOHN

HANICK, a/k/a_“Jack Hanick,” the defendant,

a. cannot be located upon the exercise of due

diligence;
b. has been transferred or sold to, or

deposited with, a third party;

Cc. 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 divided 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 to seek

17
forfeiture of any other property of the defendants up to the value

of the forfeitable property described above.

(Title 18, United States Code, Sections 981;

Title 21, United States Code, Section 853;
Title 28, United States Code, Section 2461.)

Vowrian Mi
WILLIAMS
ah
DAMIAN
L United States Attorney

18
 UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

=-V =

JOHN HANICK,
a/k/a “Jack Hanick,”
Defendant.

SEALED INDICTMENT

21 Cr.

(50 U.S.C. § 1705; Executive Orders 13,660, 13,661, and 13,

662;
31 C.F.R. § 589.201; 18 U.S.C. § 1001)

DAMIAN WILLIAMS
United States Attorney.

ws Foreperson.