A network of limited liability companies, offshore accounts, shell corporations and other secretive entities spending on interests related to former Ukrainian Prime Minister Yulia Tymoshenko has spent over $1 million on influence in the United States—but the source of funding for recent foreign influence operations remains a mystery.

Tymoshenko—a longtime Ukrainian politician who gained international attention after she was imprisoned for corruption charges from 2011 until 2014—has remained a public figure and recently announced her plans to run in Ukraine’s next presidential election.

On May 7, 2018, a limited liability corporation named ITBC LLC was formed in the state of Maryland. Weeks later, using the name Innovative Technology and Business Consulting, the LLC had already inked a $50,000-per-month contract—including a six-figure payment upfront at the time of signing—to pay the Livingston Group, a lobbying firm run by former Congressman Bob Livingston (R-La.) for “government affairs representation and lobbying services before the federal government on promotional issues related to Ukraine and any other matters mutually agreed upon.”

The Livingston Group’s FARA registration paperwork primarily refers to the foreign principal’s name as “Innovative Technology and Business Consulting LLC,” but parts of their contract on file with the Justice Department refers to the entity as “International Technology and Business Consulting LLC” and Maryland business records simply refer to the entity by its initials, “ITBC LLC.”

ITBC LLC has no website under any of its currently known nom de plumes and Maryland’s business entity search engine lists the office address as a suite in Pikesville that houses other LLCs, law firms, and provides “serviced offices to rent.” The LLC’s resident agent is Sergei Krasnitsk, whose signature is also on the contract with Livingston Group in FARA records, according to FARA disclosures on file with the Department of Justice and made available through the Center for Responsive Politics’ Foreign Lobby Watch tool. Krasnitsk is also listed as an agent for another Maryland company called 4G Development which was incorporated in 2011.

The Livingston Group’s paperwork registering as a foreign agent of ITBC LLC includes no mention of Tymoshenko.

The LLC’s work to reportedly promote Tymoshenko’s interests only came to light in informational materials filed with the Justice Department as an amendment. The informational materials contained a letter from Livingston stating Tymoshenko’s intent to travel to Washington, D.C. in July and offering to travel to the United States before President Donald Trump’s meeting with Russian President Vladimir Putin on July 16 “if it would be helpful.”

“I know you will enjoy meeting her. I will be calling your office to secure an appointment with you and whomever you might wish to include,” Livingston’s letter reads. No recipient of the letter is disclosed and may not be until Livingston Group’s next supplemental statement report is filed with the Justice Department.

Curiously, the letter spells Yulia Tymoshenko’s name as “Julia Timoshenko.”

Tymoshenko claims she did not sign any contracts and the information is “not true,” repudiating the letter as a “fake.” Referring to the effort as a “special operation for my discrediting,” Tymoshenko pledged, “We will look for these people, we will refute this information and will demand that they also refute it.”

This is not the first allegation Tymoshenko has made about professed disinformation campaigns trying to discredit her. Documents obtained by the Guardian recently revealed that Tymoshenko was the target of extensive clandestine media strategy involving planted articles in major newspapers, social media targeting, and other “black ops” orchestrated by Paul Manafort.

As a part of Manafort’s work on behalf of former Ukrainian President Viktor Yanukovych and the Party of Regions, which was allegedly paid for by moving millions of dollars into offshore shell companies, Manafort’s indictment notes that he retained a law firm to “write a report on the trial of Tymoshenko, among other things.” Tymoshenko’s name appears multiple times on the proposed evidence list for Paul Manafort’s upcoming trial September 24.

The unwanted gift that keeps on giving

In April 2018, Avenue Strategies Global LLC, a firm started by Trump campaign veterans Corey Lewandowski and Barry Bennett, abruptly terminated its contract to promote Tymoshenko’s interests in the United States after only a matter of weeks.

Avenue Strategies had initially filed paperwork with the Department of Justice registering to work to promote Tymoshenko’s interests in March 2018 “through Two Paths LLC,” according to its FARA disclosures.

Two Paths LLC is incorporated in Delaware, a state that requires minimal disclosure from limited liability companies, allowing them to incorporate without even having to name the LLC’s owner and adding an extra layer of opacity to the money trail. FARA disclosures list its address as a New York City condo owned by Ukrainian-American lawyer Marlen Kruzhkov, whose signature also appears on the contract on file with the Justice Department.

Kruzhkov is a self-proclaimed advisor to “Russian oligarchs” who boasts of work for “high net-worth individuals in Russia, the Ukraine and other countries in the former Soviet Union.” In articles and content on the websites of law firms where he has been a partner.

Although the contract between Avenue Strategies and Two Paths LLC included a retainer of $65,000 per month, Avenue Strategies only reported an initial $130,000 signing payment before terminating the arrangement on May 11 without “engaging in political or other activities.”

After Avenue Strategies’ work for Two Paths LLC began garnering media attention, Tymoshenko announced that she had notified Two Paths LLC that the contract was entered without her knowledge and declined the advocacy on her behalf because it would violate a Ukrainian law.

Tymoshenko did, however, express she is “grateful” to Avenue Strategies and “the people who financed the contract with the lobbyists”—people whose identities have not been publicly disclosed.

Former Congressman Jim Slattery (D-Kan.), a partner at Wiley Rein who has represented Tymoshenko’s interests for a number of years, told the Daily Beast, “I can only speculate that perhaps somebody else thought they were doing her a favor.”

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These are not the oligarchs you’re looking for

Yulia Tymoshenko’s history with Wiley Rein can be traced back to at least to 2011, when Oleksandr Tymoshenko—her husband—was seeking U.S. support for Yulia Tymoshenko to be released from prison. She was convicted on corruption charges following a long track record of charges for which she has been under criminal investigation in Ukraine, including intent to bribe Ukrainian Supreme Court judges, abuse of office over a natural gas imports contract signed with Russia, tax evasion, misappropriation of public funds, and alleged involvement in the 1996 murder of oligarch Yevhen Shcherban.

Despite adamantly claiming that she currently “cannot work with lobbyists,” Tymoshenko is not without her own long history of spending on foreign influence campaigns in the United States through LLCs and shell companies.

A group with a London address and the stated mission of promoting “a free, independent and democratic Ukraine,” referred to as the Trident Foundation, began showing up as the foreign principal listed in Wiley Rein’s FARA disclosures mentioning Tymoshenko in 2014—the year Yulia Tymoshenko was released from prison. MKW Group, another go-to firm of the Tymoshenkos, also signed Trident Foundation the following year.

The Trident Foundation’s contract with both MKW Group and Wiley Rein included “providing political consulting services to Yulia Tymoshenko,” according to FARA disclosures on file with the Department of Justice and made available through the Center for Responsive Politics’ Foreign Lobby Watch full-text search tool.

Mikhail Sokolov—a Ukrainian citizen who was most recently listed as the deputy chairman of the All-Ukrainian Agricultural Council, which works to promote the interests of Ukraine’s agricultural sector—is listed as the founder, director and chairman of the Trident Foundation.

Other reported members of the Trident Foundation include Igor Lepeskin, Oleg Kohan and Dmitry Logvin—Ukrainian citizens with little digital footprint.

“These are independent businessmen in Ukraine who want to be involved in the process,” Slattery told The Hill in 2014 regarding Wiley Rein’s work for the Trident Foundation, “These are not these oligarchs that we’ve been hearing about.”

In some FARA disclosures from 2014, receipts from the Trident Foundation are labeled “Payment for Tymoshenko representation” alongside payments from Oleksandr Yefremov—former chairman of the Party of Regions—also labeled as “for Tymoshenko representation.”

Some of the payments were also reported from other entities, many of which appear to be shell companies serving little other function than to transfer sums of money.

One such entity used to transfer funds with the reported purpose of advocating for Tymoshenko was Wargrave Trading LLP, which is the same name as an offshore shell company allegedly used to transfer funds by former Ukrainian MP Mykola Martynenko. Martynenko is under investigation for embezzling money and taking millions of dollars in bribes from a Czech company angling to supply equipment for Ukraine’s nuclear power plants.

On February 29, 2016, MKW Group terminated activities acting as a foreign agent on behalf of the Trident Foundation. Less than a month later, Wiley Rein followed suit, terminating the Trident Foundations contract on March 14, 2016. Days later, on March 17, Wiley Rein reported inking a deal with a new foreign client: Aveiro LP.

Aveiro LP, a foreign principal that has since been linked to Tymoshenko but provided no indication of those ties in FARA disclosures, was formed as a limited partnership with the London address listed housing at least 45 other groups, according to the United Kingdom’s registrar of companies.

Like many of the other documents on file from foreign agents reporting spending on Tymoshenko’s interests, disclosures referencing Aveiro LP include alternate spellings of names seemingly referring to the same entity; such as “AVERIO LP” being listed multiple times in a contract from March 2016 in a FARA filing with the foreign principal clearly labeled Aveiro LP. One earlier filing also listed the Trident Foundation as the “Tirdent Foundation.”

MKW Group paid Wiley Rein $20,000 for “legal fees” on March 7, 2017, according to the firm’s FARA disclosure reporting activities acting as a foreign agent of Aveiro LP. Wiley Rein’s only other receipts for that reporting period included $74,216 from Tiara Business Ltd and $47,000 from Balfern LP—but no receipts from Aveiro LP, the sole foreign principal MKW Group reported working for in that disclosure.

A FARA disclosure reporting Wiley Rein’s work for Aveiro LP for the first half of 2018 through June 30, 2018 reflects payments from an entity called Vizientas Pte Ltd—which appears to be little more than a shell company with no paper trail—totaling $29,000. As in prior disclosures reporting activities to influence U.S. policy or public opinion on behalf of Aveiro LP, Wiley Rein reported no receipts directly from Aveiro LP for that reporting period.

In the case of Two Paths LLC, FARA filings for Avenue Strategies disclosed the name of the foreign principal as “Yulia Tymoshenko (through Two Paths, LLC).”

For Innovative Technology & Business Consulting LLC, however, that link is less apparent and Tymoshenko’s denial of involvement in spending by either group on her behalf further complicates the already complex rigmarole of spending on her interests.

The use of shell companies and other secretive entities in almost every case of recent spending on interests related to Tymoshenko makes it difficult to distinguish between spending Tymoshenko has orchestrated and spending she says was never unauthorized—leaving the source of funding behind TBC LLC and Two Paths LLC unknown.

Yulia Tymoshenko, Jim Slattery, and Avenue Strategies did not respond to OpenSecrets’ requests for comment.



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