Manafort and Gates superseding indictment

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 17 of 37 Payee Transaction Originating Account Country of Amount of Date Holder Origination Transaction 4/26/2012 Bletilla Ventures Limited Cyprus $26,455 5/30/2012 Bletilla Ventures Limited Cyprus $15,000 5/30/2012 Lucicle Consultants Limited Cyprus $14,650 6/27/2012 Bletilla Ventures Limited Cyprus $18,745 8/2/2012 Bletilla Ventures Limited Cyprus $28,745 8/30/2012 Bletilla Ventures Limited Cyprus $38,745 9/27/2012 Bletilla Ventures Limited Cyprus $32,345 10/31/2012 Bletilla Ventures Limited Cyprus $46,332 11/20/2012 Bletilla Ventures Limited Cyprus $48,547 11/30/2012 Bletilla Ventures Limited Cyprus $38,532 12/21/2012 Bletilla Ventures Limited Cyprus $47,836 12/28/2012 Bletilla Ventures Limited Cyprus $47,836 2012 Tax Year Total $651,448 Richard Gates 1/11/2013 Bletilla Ventures Limited Cyprus $47,836 United Kingdom 1/22/2013 Bletilla Ventures Limited Cyprus $34,783 Bank Account B 1/30/2013 Bletilla Ventures Limited Cyprus $46,583 2/22/2013 Bletilla Ventures Limited Cyprus $46,233 2/28/2013 Bletilla Ventures Limited Cyprus $46,583 3/1/2013 Bletilla Ventures Limited Cyprus $42,433 3/15/2013 Bletilla Ventures Limited Cyprus $37,834 4/15/2013 Bletilla Ventures Limited Cyprus $59,735 4/26/2013 Bletilla Ventures Limited Cyprus $48,802 5/17/2013 Olivenia Trading Limited Cyprus $57,798 5/30/2013 Actinet Trading Limited Cyprus $45,622 6/13/2013 Lucicle Consultants Limited Cyprus $76,343 8/7/2013 Pompolo Limited United $250,784 Kingdom 9/6/2013 Lucicle Consultants Limited Cyprus $68,500 9/13/2013 Cypriot Agent Cyprus $179,216 Jemina LLC 7/8/2013 Marziola Holdings Limited Cyprus $72,500 United States 9/4/2013 Marziola Holdings Limited Cyprus $89,807 Bank Account D 10/22/2013 Cypriot Agent Cyprus $119,844 11/12/2013 Cypriot Agent Cyprus $80,000 12/20/2013 Cypriot Agent Cyprus $90,000 2013 Tax Year Total $1,541,237 Jemina LLC 2/10/2014 Cypriot Agent Cyprus $60,044 United States 4/29/2014 Cypriot Agent Cyprus $44,068 Bank Account D 10/6/2014 Global Endeavour Inc. Grenadines $65,000 17

2 * * * * * * * * * * * * * * * * * * * * * * * * * * * COUNT 26: 18 U.S.C. §§ 1349 and 3551 et seq . Bank Fraud Conspiracy COUNT S 27: 18 U.S.C. §§ 1344, 2, and 3551 et seq . Bank Fraud COUNT 28–29: 18 U.S.C. §§ 1349 and 3551 et seq . Bank Fraud Conspiracy COUNT 30: 18 U.S.C. §§ 1344, 2, and 3551 et seq . Bank Fraud COUNT 31: 18 U.S.C. §§ 1349 and 3551 et seq . Bank Fraud Conspiracy COUNT 32: 18 U.S.C. §§ 1344, 2, and 3551 et seq . Bank Fraud FORFEITURE NOTICE ******* SUPERSEDING INDICTMENT February 2018 Term – At Alexandria, Virginia THE GRAND JURY CHARGES THAT : Introduction At all times relevant to this Superseding Indictment: 1. Defendant s PAUL J. MANAFORT, JR. (MANAFORT) and RICHARD W. GATES III (GATES) served for years as political consultant s and lobbyist s. B etween at least 2006 and 2015, Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 2 of 37

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 3 of 37 MANAFORT and GATES acted as unregistered agents of a foreign government and foreign political parties. Specifically, they represented the Government of Ukraine, the President of Ukraine (Victor Yanukovych, who was President from 2010 to 2014), the Party of Regions (a Ukrainian political party led by Yanukovych), and the Opposition Bloc (a successor to the Party of Regions after Yanukovych fled to Russia). 2. MANAFORT and GATES generated tens of millions of dollars in income as a result of their Ukraine work. From approximately 2006 through the present, MANAFORT and GATES engaged in a scheme to hide income from United States authorities, while enjoying the use of the money. During the first part of the scheme between approximately 2006 and 2015, MANAFORT, with GATES’ assistance, failed to pay taxes on this income by disguising it as alleged “loans” from nominee offshore corporate entities and by making millions of dollars in unreported payments from foreign accounts to bank accounts they controlled and United States vendors. MANAFORT also used the offshore accounts to purchase United States real estate, and MANAFORT and GATES used the undisclosed income to make improvements to and refinance their United States properties. 3. In the second part of the scheme, between approximately 2015 and at least January 2017, when the Ukraine income dwindled after Yanukovych fled to Russia, MANAFORT, with the assistance of GATES, extracted money from MANAFORT’s United States real estate by, among other things, using those properties as collateral to obtain loans from multiple financial institutions. MANAFORT and GATES fraudulently secured more than twenty million dollars in loans by falsely inflating MANAFORT’s and his company’s income and by failing to disclose existing debt in order to qualify for the loans. 4. In furtherance of the scheme, MANAFORT and GATES funneled millions of dollars in 3

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 4 of 37 payments into numerous foreign nominee companies and bank accounts, opened by them and their accomplices in nominee names and in various foreign countries, including Cyprus, Saint Vincent & the Grenadines (Grenadines), and the Seychelles. MANAFORT and GATES hid the existence and ownership of the foreign companies and bank accounts, falsely and repeatedly reporting to their tax preparers and to the United States that they had no foreign bank accounts. 5. In furtherance of the scheme, MANAFORT used his hidden overseas wealth to enjoy a lavish lifestyle in the United States, without paying taxes on that income. MANAFORT, without reporting the income to his tax preparer or the United States, spent millions of dollars on luxury goods and services for himself and his extended family through payments wired from offshore nominee accounts to United States vendors. MANAFORT also used these offshore accounts to purchase multi-million dollar properties in the United States and to improve substantially another property owned by his family. 6. In furtherance of the scheme, GATES used millions of dollars from these offshore accounts to pay for his personal expenses, including his mortgage, children’s tuition, and interior decorating and refinancing of his Virginia residence. 7. In total, more than $75,000,000 flowed through the offshore accounts. MANAFORT, with the assistance of GATES, laundered more than $30,000,000, income that he concealed from the United States Department of the Treasury (Treasury), the Department of Justice, and others. GATES obtained more than $3,000,000 from the offshore accounts, income that he too concealed from the Treasury, the Department of Justice, and others. 4

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 7 of 37 Cypriot Entities Entity Name Date Created Incorporation Location Actinet Trading Limited (PM, RG) May 2009 Cyprus Black Sea View Limited (PM, RG) August 2007 Cyprus Bletilla Ventures Limited (PM, RG) October 2010 Cyprus Cavenari Investments Limited (RG) December 2007 Cyprus Global Highway Limited (PM, RG) August 2007 Cyprus Leviathan Advisors Limited (PM, RG) August 2007 Cyprus LOAV Advisors Limited (PM, RG) August 2007 Cyprus Lucicle Consultants Limited (PM, RG) December 2008 Cyprus Marziola Holdings Limited (PM) March 2012 Cyprus Olivenia Trading Limited (PM, RG) March 2012 Cyprus Peranova Holdings Limited (Peranova) June 2007 Cyprus (PM, RG) Serangon Holdings Limited (PM, RG) January 2008 Cyprus Yiakora Ventures Limited (PM) February 2008 Cyprus Other Foreign Entities Entity Name Date Created Incorporation Location Global Endeavour Inc. (also known as Unknown Grenadines Global Endeavor Inc.) (PM) Jeunet Ltd. (PM) August 2011 Grenadines Pompolo Limited (PM, RG) April 2013 United Kingdom 7

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 6 of 37 Entity Name Date Created Incorporation Location August 2008 Virginia Daisy Manafort, LLC (PM) March 2011 Florida Davis Manafort International LLC March 2007 Delaware (PM) March 2005 Virginia DMP (PM) March 2011 Florida October 1999 Delaware Davis Manafort, Inc. (PM) November 1999 Virginia June 2011 Delaware DMI (PM) March 2012 Florida Global Sites LLC (PM, RG) July 2008 Delaware Jemina LLC (RG) July 2008 Delaware Jesand Investment Corporation (PM) April 2002 Virginia Jesand Investments Corporation (PM) March 2011 Florida April 2006 Virginia John Hannah, LLC (PM) March 2011 Florida Jupiter Holdings Management, LLC January 2011 Delaware (RG) Lilred, LLC (PM) December 2011 Florida LOAV Ltd. (PM) April 1992 Delaware MC Brooklyn Holdings, LLC (PM) November 2012 New York January 2012 Florida MC Soho Holdings, LLC (PM) April 2012 New York Smythson LLC (also known as July 2008 Delaware Symthson LLC) (PM, RG) 6

7 Cypriot Entities Entity Name Date Created Incorporation Location Actinet Trading Limited (PM, RG ) May 2009 Cyprus Black Sea View Limited (PM, RG ) August 2007 Cyprus Bletilla Ventures Limited (PM, RG ) October 2010 Cyprus Cavenari Investments Limited (RG) December 2007 Cyprus Global Highway Limited (PM, RG ) August 2007 Cyprus Leviathan Advisors Limited (PM, RG ) August 2007 Cyprus LOAV Advisors Limited (PM, RG ) August 2007 Cyprus Lucicle Consultants Limited (PM, RG ) December 2008 Cyprus Marziola Holdings Limited (PM) March 2012 Cyprus Olivenia Trading Limited (PM, RG ) March 2012 Cyprus Peranova Holdings Limited (Peranova) (PM, RG ) June 2007 Cyprus Serangon Holdings Limited (PM, RG ) January 2008 Cyprus Yiakora Ventures Limited (PM) February 2008 Cyprus Other Foreign Entities Entity Name Date Created Incorporation Location Global Endeavour Inc. (also known as Global Endeavor Inc.) (PM) Unknown Grenadines Jeunet Ltd. (PM) August 2011 Grenadines Pompolo Limited ( PM, RG) April 2013 United Kingdom Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 7 of 37

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 8 of 37 13. The Internal Revenue Service (IRS) was a bureau in the Treasury responsible for administering the tax laws of the United States and collecting taxes owed to the Treasury. The Tax Scheme MANAFORT And GATES’ Wiring Money From Offshore Accounts Into The United States 14. In order to use the money in the offshore nominee accounts of the MANAFORT–GATES entities without paying taxes on it, MANAFORT and GATES caused millions of dollars in wire transfers from these accounts to be made for goods, services, and real estate. They did not report these transfers as income. 15. From 2008 to 2014, MANAFORT caused the following wires, totaling over $12,000,000, to be sent to the vendors listed below for personal items. MANAFORT did not pay taxes on this income, which was used to make the purchases. Payee Transaction Originating Account Country of Amount of Date Holder Origination Transaction Vendor A 6/10/2008 LOAV Advisors Limited Cyprus $107,000 (Home 6/25/2008 LOAV Advisors Limited Cyprus $23,500 Improvement 7/7/2008 LOAV Advisors Limited Cyprus $20,000 Company in the 8/5/2008 Yiakora Ventures Limited Cyprus $59,000 Hamptons, New 9/2/2008 Yiakora Ventures Limited Cyprus $272,000 York) 10/6/2008 Yiakora Ventures Limited Cyprus $109,000 10/24/2008 Yiakora Ventures Limited Cyprus $107,800 11/20/2008 Yiakora Ventures Limited Cyprus $77,400 12/22/2008 Yiakora Ventures Limited Cyprus $100,000 1/14/2009 Yiakora Ventures Limited Cyprus $9,250 1/29/2009 Yiakora Ventures Limited Cyprus $97,670 2/25/2009 Yiakora Ventures Limited Cyprus $108,100 4/16/2009 Yiakora Ventures Limited Cyprus $94,394 5/7/2009 Yiakora Ventures Limited Cyprus $54,000 5/12/2009 Yiakora Ventures Limited Cyprus $9,550 6/1/2009 Yiakora Ventures Limited Cyprus $86,650 6/18/2009 Yiakora Ventures Limited Cyprus $34,400 7/31/2009 Yiakora Ventures Limited Cyprus $106,000 8

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 9 of 37 Payee Transaction Originating Account Country of Amount of Date Holder Origination Transaction 8/28/2009 Yiakora Ventures Limited Cyprus $37,000 9/23/2009 Yiakora Ventures Limited Cyprus $203,500 10/26/2009 Yiakora Ventures Limited Cyprus $38,800 11/18/2009 Global Highway Limited Cyprus $130,906 3/8/2010 Global Highway Limited Cyprus $124,000 5/11/2010 Global Highway Limited Cyprus $25,000 7/8/2010 Global Highway Limited Cyprus $28,000 7/23/2010 Leviathan Advisors Limited Cyprus $26,500 8/12/2010 Leviathan Advisors Limited Cyprus $138,900 9/2/2010 Yiakora Ventures Limited Cyprus $31,500 10/6/2010 Global Highway Limited Cyprus $67,600 10/14/2010 Yiakora Ventures Limited Cyprus $107,600 10/18/2010 Leviathan Advisors Limited Cyprus $31,500 12/16/2010 Global Highway Limited Cyprus $46,160 2/7/2011 Global Highway Limited Cyprus $36,500 3/22/2011 Leviathan Advisors Limited Cyprus $26,800 4/4/2011 Leviathan Advisors Limited Cyprus $195,000 5/3/2011 Global Highway Limited Cyprus $95,000 5/16/2011 Leviathan Advisors Limited Cyprus $6,500 5/31/2011 Leviathan Advisors Limited Cyprus $70,000 6/27/2011 Leviathan Advisors Limited Cyprus $39,900 7/27/2011 Leviathan Advisors Limited Cyprus $95,000 10/24/2011 Global Highway Limited Cyprus $22,000 10/25/2011 Global Highway Limited Cyprus $9,300 11/15/2011 Global Highway Limited Cyprus $74,000 11/23/2011 Global Highway Limited Cyprus $22,300 11/29/2011 Global Highway Limited Cyprus $6,100 12/12/2011 Leviathan Advisors Limited Cyprus $17,800 1/17/2012 Global Highway Limited Cyprus $29,800 1/20/2012 Global Highway Limited Cyprus $42,600 2/9/2012 Global Highway Limited Cyprus $22,300 2/23/2012 Global Highway Limited Cyprus $75,000 2/28/2012 Global Highway Limited Cyprus $22,300 3/28/2012 Peranova Cyprus $37,500 4/18/2012 Lucicle Consultants Limited Cyprus $50,000 5/15/2012 Lucicle Consultants Limited Cyprus $79,000 6/5/2012 Lucicle Consultants Limited Cyprus $45,000 6/19/2012 Lucicle Consultants Limited Cyprus $11,860 9

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 10 of 37 Payee Transaction Originating Account Country of Amount of Date Holder Origination Transaction 7/9/2012 Lucicle Consultants Limited Cyprus $10,800 7/18/2012 Lucicle Consultants Limited Cyprus $88,000 8/7/2012 Lucicle Consultants Limited Cyprus $48,800 9/27/2012 Lucicle Consultants Limited Cyprus $100,000 11/20/2012 Lucicle Consultants Limited Cyprus $298,000 12/20/2012 Lucicle Consultants Limited Cyprus $55,000 1/29/2013 Lucicle Consultants Limited Cyprus $149,000 3/12/2013 Lucicle Consultants Limited Cyprus $375,000 8/29/2013 Global Endeavour Inc. Grenadines $200,000 11/13/2013 Global Endeavour Inc. Grenadines $75,000 11/26/2013 Global Endeavour Inc. Grenadines $80,000 12/6/2013 Global Endeavour Inc. Grenadines $130,000 12/12/2013 Global Endeavour Inc. Grenadines $90,000 4/22/2014 Global Endeavour Inc. Grenadines $56,293 8/18/2014 Global Endeavour Inc. Grenadines $34,660 Vendor A Total $5,434,793 Vendor B 3/22/2011 Leviathan Advisors Limited Cyprus $12,000 (Home 3/28/2011 Leviathan Advisors Limited Cyprus $25,000 Automation, 4/27/2011 Leviathan Advisors Limited Cyprus $12,000 Lighting and 5/16/2011 Leviathan Advisors Limited Cyprus $25,000 Home 11/15/2011 Global Highway Limited Cyprus $17,006 Entertainment 11/23/2011 Global Highway Limited Cyprus $11,000 Company in 2/28/2012 Global Highway Limited Cyprus $6,200 Florida) 10/31/2012 Lucicle Consultants Limited Cyprus $290,000 12/17/2012 Lucicle Consultants Limited Cyprus $160,600 1/15/2013 Lucicle Consultants Limited Cyprus $194,000 1/24/2013 Lucicle Consultants Limited Cyprus $6,300 2/12/2013 Lucicle Consultants Limited Cyprus $51,600 2/26/2013 Lucicle Consultants Limited Cyprus $260,000 7/15/2013 Pompolo Limited United $175,575 Kingdom 11/5/2013 Global Endeavour Inc. Grenadines $73,000 Vendor B Total $1,319,281 Vendor C 10/7/2008 Yiakora Ventures Limited Cyprus $15,750 (Antique Rug 3/17/2009 Yiakora Ventures Limited Cyprus $46,200 Store in 4/16/2009 Yiakora Ventures Limited Cyprus $7,400 Alexandria, 4/27/2009 Yiakora Ventures Limited Cyprus $65,000 Virginia) 5/7/2009 Yiakora Ventures Limited Cyprus $210,000 10

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 11 of 37 Payee Transaction Originating Account Country of Amount of Date Holder Origination Transaction 7/15/2009 Yiakora Ventures Limited Cyprus $200,000 3/31/2010 Yiakora Ventures Limited Cyprus $140,000 6/16/2010 Global Highway Limited Cyprus $250,000 Vendor C Total $934,350 Vendor D (Related to 2/28/2012 Global Highway Limited Cyprus $100,000 Vendor C) Vendor D Total $100,000 Vendor E 11/7/2008 Yiakora Ventures Limited Cyprus $32,000 (Men’s Clothing 2/5/2009 Yiakora Ventures Limited Cyprus $22,750 Store in New 4/27/2009 Yiakora Ventures Limited Cyprus $13,500 York) 10/26/2009 Yiakora Ventures Limited Cyprus $32,500 3/30/2010 Yiakora Ventures Limited Cyprus $15,000 5/11/2010 Global Highway Limited Cyprus $39,000 6/28/2010 Leviathan Advisors Limited Cyprus $5,000 8/12/2010 Leviathan Advisors Limited Cyprus $32,500 11/17/2010 Global Highway Limited Cyprus $11,500 2/7/2011 Global Highway Limited Cyprus $24,000 3/22/2011 Leviathan Advisors Limited Cyprus $43,600 3/28/2011 Leviathan Advisors Limited Cyprus $12,000 4/27/2011 Leviathan Advisors Limited Cyprus $3,000 6/30/2011 Global Highway Limited Cyprus $24,500 9/26/2011 Leviathan Advisors Limited Cyprus $12,000 11/2/2011 Global Highway Limited Cyprus $26,700 12/12/2011 Leviathan Advisors Limited Cyprus $46,000 2/9/2012 Global Highway Limited Cyprus $2,800 2/28/2012 Global Highway Limited Cyprus $16,000 3/14/2012 Lucicle Consultants Limited Cyprus $8,000 4/18/2012 Lucicle Consultants Limited Cyprus $48,550 5/15/2012 Lucicle Consultants Limited Cyprus $7,000 6/19/2012 Lucicle Consultants Limited Cyprus $21,600 8/7/2012 Lucicle Consultants Limited Cyprus $15,500 11/20/2012 Lucicle Consultants Limited Cyprus $10,900 12/20/2012 Lucicle Consultants Limited Cyprus $7,500 1/15/2013 Lucicle Consultants Limited Cyprus $37,000 2/12/2013 Lucicle Consultants Limited Cyprus $7,000 2/26/2013 Lucicle Consultants Limited Cyprus $39,000 9/3/2013 Global Endeavour Inc. Grenadines $81,500 11

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 12 of 37 Payee Transaction Originating Account Country of Amount of Date Holder Origination Transaction 10/15/2013 Global Endeavour Inc. Grenadines $53,000 11/26/2013 Global Endeavour Inc. Grenadines $13,200 4/24/2014 Global Endeavour Inc. Grenadines $26,680 9/11/2014 Global Endeavour Inc. Grenadines $58,435 Vendor E Total $849,215 Vendor F 4/27/2009 Yiakora Ventures Limited Cyprus $34,000 (Landscaper in 5/12/2009 Yiakora Ventures Limited Cyprus $45,700 the Hamptons, 6/1/2009 Yiakora Ventures Limited Cyprus $21,500 New York) 6/18/2009 Yiakora Ventures Limited Cyprus $29,000 9/21/2009 Yiakora Ventures Limited Cyprus $21,800 5/11/2010 Global Highway Limited Cyprus $44,000 6/28/2010 Leviathan Advisors Limited Cyprus $50,000 7/23/2010 Leviathan Advisors Limited Cyprus $19,000 9/2/2010 Yiakora Ventures Limited Cyprus $21,000 10/6/2010 Global Highway Limited Cyprus $57,700 10/18/2010 Leviathan Advisors Limited Cyprus $26,000 12/16/2010 Global Highway Limited Cyprus $20,000 3/22/2011 Leviathan Advisors Limited Cyprus $50,000 5/3/2011 Global Highway Limited Cyprus $40,000 6/1/2011 Leviathan Advisors Limited Cyprus $44,000 7/27/2011 Leviathan Advisors Limited Cyprus $27,000 8/16/2011 Leviathan Advisors Limited Cyprus $13,450 9/19/2011 Leviathan Advisors Limited Cyprus $12,000 10/24/2011 Global Highway Limited Cyprus $42,000 11/2/2011 Global Highway Limited Cyprus $37,350 Vendor F Total $655,500 Vendor G 9/2/2010 Yiakora Ventures Limited Cyprus $165,000 (Antique Dealer 10/18/2010 Leviathan Advisors Limited Cyprus $165,000 in New York) 2/28/2012 Global Highway Limited Cyprus $190,600 3/14/2012 Lucicle Consultants Limited Cyprus $75,000 2/26/2013 Lucicle Consultants Limited Cyprus $28,310 Vendor G Total $623,910 Vendor H 6/25/2008 LOAV Advisors Limited Cyprus $52,000 (Clothing Store 12/16/2008 Yiakora Ventures Limited Cyprus $49,000 in Beverly Hills, 12/22/2008 Yiakora Ventures Limited Cyprus $10,260 California) 8/12/2009 Yiakora Ventures Limited Cyprus $76,400 5/11/2010 Global Highway Limited Cyprus $85,000 11/17/2010 Global Highway Limited Cyprus $128,280 12

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 13 of 37 Payee Transaction Originating Account Country of Amount of Date Holder Origination Transaction 5/31/2011 Leviathan Advisors Limited Cyprus $64,000 11/15/2011 Global Highway Limited Cyprus $48,000 12/17/2012 Lucicle Consultants Limited Cyprus $7,500 Vendor H Total $520,440 Vendor I (Investment 9/3/2013 Global Endeavour Inc. Grenadines $500,000 Company) Vendor I Total $500,000 Vendor J 11/15/2011 Global Highway Limited Cyprus $8,000 (Contractor in 12/5/2011 Leviathan Advisors Limited Cyprus $11,237 Florida) 12/21/2011 Black Sea View Limited Cyprus $20,000 2/9/2012 Global Highway Limited Cyprus $51,000 5/17/2012 Lucicle Consultants Limited Cyprus $68,000 6/19/2012 Lucicle Consultants Limited Cyprus $60,000 7/18/2012 Lucicle Consultants Limited Cyprus $32,250 9/19/2012 Lucicle Consultants Limited Cyprus $112,000 11/30/2012 Lucicle Consultants Limited Cyprus $39,700 1/9/2013 Lucicle Consultants Limited Cyprus $25,600 2/28/2013 Lucicle Consultants Limited Cyprus $4,700 Vendor J Total $432,487 Vendor K 12/5/2011 Leviathan Advisors Limited Cyprus $4,115 (Landscaper in 3/1/2012 Global Highway Limited Cyprus $50,000 the Hamptons, 6/6/2012 Lucicle Consultants Limited Cyprus $47,800 New York) 6/25/2012 Lucicle Consultants Limited Cyprus $17,900 6/27/2012 Lucicle Consultants Limited Cyprus $18,900 2/12/2013 Lucicle Consultants Limited Cyprus $3,300 7/15/2013 Pompolo Limited United $13,325 Kingdom 11/26/2013 Global Endeavour Inc. Grenadines $9,400 Vendor K Total $164,740 Vendor L 4/12/2012 Lucicle Consultants Limited Cyprus $83,525 (Payments 5/2/2012 Lucicle Consultants Limited Cyprus $12,525 Relating to Three 6/29/2012 Lucicle Consultants Limited Cyprus $67,655 Range Rovers) Vendor L Total $163,705 Vendor M 11/20/2012 Lucicle Consultants Limited Cyprus $45,000 12/7/2012 Lucicle Consultants Limited Cyprus $21,000 13

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 14 of 37 Payee Transaction Originating Account Country of Amount of Date Holder Origination Transaction (Contractor in 12/17/2012 Lucicle Consultants Limited Cyprus $21,000 Virginia) 1/17/2013 Lucicle Consultants Limited Cyprus $18,750 1/29/2013 Lucicle Consultants Limited Cyprus $9,400 2/12/2013 Lucicle Consultants Limited Cyprus $10,500 Vendor M Total $125,650 Vendor N 1/29/2009 Yiakora Ventures Limited Cyprus $10,000 (Audio, Video, 3/17/2009 Yiakora Ventures Limited Cyprus $21,725 and Control 4/16/2009 Yiakora Ventures Limited Cyprus $24,650 System Home 12/2/2009 Global Highway Limited Cyprus $10,000 Integration and 3/8/2010 Global Highway Limited Cyprus $20,300 Installation 4/23/2010 Yiakora Ventures Limited Cyprus $8,500 Company in the Hamptons, New 7/29/2010 Leviathan Advisors Limited Cyprus $17,650 York) Vendor N Total $112,825 Vendor O (Purchase of 10/5/2012 Lucicle Consultants Limited Cyprus $62,750 Mercedes Benz) Vendor O Total $62,750 Vendor P (Purchase of 12/30/2008 Yiakora Ventures Limited Cyprus $47,000 Range Rover) Vendor P Total $47,000 Vendor Q 9/2/2010 Yiakora Ventures Limited Cyprus $10,000 (Property 10/6/2010 Global Highway Limited Cyprus $10,000 Management 10/18/2010 Leviathan Advisors Limited Cyprus $10,000 Company in 2/8/2011 Global Highway Limited Cyprus $13,500 South Carolina) 2/9/2012 Global Highway Limited Cyprus $2,500 Vendor Q Total $46,000 2/9/2011 Global Highway Limited Cyprus $17,900 Vendor R (Art Gallery in 2/14/2013 Lucicle Consultants Limited Cyprus $14,000 Florida) Vendor R Total $31,900 9/26/2011 Leviathan Advisors Limited Cyprus $5,000 Vendor S 9/19/2012 Lucicle Consultants Limited Cyprus $5,000 14

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 15 of 37 Payee Transaction Originating Account Country of Amount of Date Holder Origination Transaction (Housekeeping 10/9/2013 Global Endeavour Inc. Grenadines $10,000 in New York) Vendor S Total $20,000 16. In 2012, MANAFORT caused the following wires to be sent to the entities listed below to purchase the real estate also listed below. MANAFORT did not report the money used to make these purchases on his 2012 tax return. Property Payee Date Originating Country of Amount Purchased Account Origin Howard Street DMP Condominium International 2/1/2012 Peranova Cyprus $1,500,000 (New York) LLC Union Street Attorney 11/29/2012 Actinet Trading Cyprus $1,800,000 Brownstone, Account Of Limited (New York) [Real Estate 11/29/2012 Actinet Trading Cyprus $1,200,000 Attorney] Limited Arlington Real Estate Lucicle Consultants House Trust 8/31/2012 Limited Cyprus $1,900,000 (Virginia) Total $6,400,000 17. MANAFORT and GATES also disguised, as purported “loans,” more than $10 million transferred from Cypriot entities, including the overseas MANAFORT–GATES entities, to domestic entities owned by MANAFORT. For example, a $1.5 million wire from Peranova to DMI that MANAFORT used to purchase real estate on Howard Street in Manhattan, New York, was recorded as a “loan” from Peranova to DMI, rather than as income. The following loans were shams designed to reduce fraudulently MANAFORT’s reported taxable income. 15

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 16 of 37 Year Payor / Ostensible Payee / Ostensible Country of Total Amount “Lender” “Borrower” Origin of “Loans” 2008 Yiakora Ventures Limited Jesand Investment Cyprus $8,120,000 Corporation 2008 Yiakora Ventures Limited DMP Cyprus $500,000 2009 Yiakora Ventures Limited DMP Cyprus $694,000 2009 Yiakora Ventures Limited Daisy Manafort, LLC Cyprus $500,000 2012 Peranova DMI Cyprus $1,500,000 2014 Telmar Investments Ltd. DMI Cyprus $900,000 2015 Telmar Investments Ltd. DMI Cyprus $1,000,000 Total $13,214,000 18. 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. Payee Transaction Originating Account Country of Amount of Date Holder Origination Transaction Richard Gates 3/26/2010 Serangon Holdings Limited Cyprus $85,000 United Kingdom 4/20/2010 Serangon Holdings Limited Cyprus $50,000 Bank Account A 5/6/2010 Serangon Holdings Limited Cyprus $150,000 Richard Gates 9/7/2010 Serangon Holdings Limited Cyprus $160,000 United Kingdom 10/13/2010 Serangon Holdings Limited Cyprus $15,000 Bank Account B Richard Gates United States 9/27/2010 Global Highway Limited Cyprus $50,000 Bank Account C 2010 Tax Year Total $510,000 Jemina LLC United States 9/9/2011 Peranova Cyprus $48,500 Bank Account D Richard Gates United Kingdom 12/16/2011 Peranova Cyprus $100,435 Bank Account B 2011 Tax Year Total $148,935 Richard Gates 1/9/2012 Global Highway Limited Cyprus $100,000 United Kingdom 1/13/2012 Peranova Cyprus $100,435 Bank Account B 2/29/2012 Global Highway Limited Cyprus $28,500 3/27/2012 Bletilla Ventures Limited Cyprus $18,745 16

17 Payee Transaction Date Originating Account Holder Country of Origin ation Amount of Transaction 4/26/2012 Bletilla Ventures Limited Cyprus $ 26,455 5/30/2012 Bletilla Ventures Limited Cyprus $ 15,000 5/30/2012 Lucicle Consultants Limited Cyprus $ 14,650 6/27/2012 Bletilla Ventures Limited Cyprus $ 18,745 8/2/2012 Bletilla Ventures Limited Cyprus $ 28,745 8/30/2012 Bletilla Ventures Limited Cyprus $ 38,745 9/2 7 /2012 Bletilla Ventures Limited Cyprus $32,345 1 0 / 3 1/2012 Bletilla Ventures Limited Cyprus $46,3 3 2 11/20/2012 Bletilla Ventures Limited Cyprus $ 48,547 11/30/2012 Bletilla Ventures Limited Cyprus $ 38,532 12/21/2012 Bletilla Ventures Limited Cyprus $ 47,836 12/28/2012 Bletilla Ventures Limited Cyprus $ 47,836 2012 Tax Year Total $651,4 4 8 Richard Gates United Kingdom Bank Account B 1/11/2013 Bletilla Ventures Limited Cyprus $ 47,836 1/22/2013 Bletilla Ventures Limited Cyprus $ 34,783 1/30/2013 Bletilla Ventures Limited Cyprus $ 46,583 2/22/2013 Bletilla Ventures Limited Cyprus $ 46,233 2/28/2013 Bletilla Ventures Limited Cyprus $ 46,583 3/1/2013 Bletilla Ventures Limited Cyprus $ 42,433 3/15/2013 Bletilla Ventures Limited Cyprus $ 37,834 4/15/2013 Bletilla Ventures Limited Cyprus $ 59,735 4/26/2013 Bletilla Ventures Limited Cyprus $ 48,802 5/17/2013 Olivenia Trading Limited Cyprus $57,798 5/30 /2013 Actinet Trading Limited Cyprus $ 45,622 6/13/2013 Lucicle Consultants Limited Cyprus $ 76,343 8/7/2013 Pompolo Limited United Kingdom $250,784 9/6/2013 Lucicle Consultants Limited Cyprus $ 68,500 9/13/2013 C ypriot Agent Cyprus $179,216 Jemina LLC United States Bank Account D 7/8/2013 Marziola Holdings Limited Cyprus $ 72,500 9/4/2013 Marziola Holdings Limited Cyprus $ 89,807 10/22/2013 Cypriot Agent Cyprus $ 119,844 11/12/2013 Cypriot Agent Cyprus $ 80,000 12/20/2013 Cypriot Agent Cyprus $ 90,000 2013 Tax Year Total $1,541,237 Jemina LLC United States Bank Account D 2/10/2014 Cypriot Agent Cyprus $ 60,044 4/29/2014 Cypriot Agent Cyprus $ 44,068 10/6/2014 Global Endeavour Inc. Grenadines $ 65,000 Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 17 of 37

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 19 of 37 bank account, securities account, or other financial account?” If the answer was “Yes,” then the form required the taxpayer to enter the name of the foreign country in which the financial account was located. 22. For each year in or about and between 2008 through at least 2014, MANAFORT had authority over foreign accounts that required an FBAR filing. Specifically, MANAFORT was required to report to the Treasury each foreign bank account held by the foreign MANAFORT– GATES entities noted above in paragraph 12 that bears the initials PM. No FBAR filings were made by MANAFORT for these accounts. 23. For each year in or about and between 2010 through at least 2013, GATES had authority over foreign accounts that required an FBAR filing. Specifically, GATES was required to report to the United States Treasury each foreign bank account held by the foreign MANAFORT– GATES entities noted above in paragraph 12 that bears the initials RG, as well as United Kingdom Bank Accounts A and B noted in paragraph 18. No FBAR filings were made by GATES for these accounts. 24. Furthermore, in each of MANAFORT’s tax filings for 2008 through 2014, MANAFORT, with the assistance of GATES, represented falsely that he did not have authority over any foreign bank accounts. MANAFORT and GATES had repeatedly and falsely represented in writing to MANAFORT’s tax preparer that MANAFORT had no authority over foreign bank accounts, knowing that such false representations would result in false tax filings in MANAFORT’s name. For instance, on October 4, 2011, MANAFORT’s tax preparer asked MANAFORT in writing: “At any time during 2010, did you [or your wife or children] have an interest in or a signature or other authority over a financial account in a foreign country, such as a bank account, securities account or other financial account?” On the same day, MANAFORT falsely responded “NO.” 19

19 bank account, securities account, or other financial account?” If the answer was “Yes,” then the form required the taxpayer to enter the name of the foreign country in which the financial account was located. 22. For each year in or about and between 2008 through at least 2014, MANAF ORT had authority over foreign accounts that required an FBAR filing . Specifically, MANAFORT was required to report to the Treasury each foreign bank account held by the foreign MANAFORT – GATES entities noted above in paragraph 12 that bear s the initials PM . No FBAR filings were made by MANAFORT for these accounts. 23. For each year in or about and between 2010 through at least 2013, GATES had authority over foreign accounts that required an FBAR filing . Specifically, GATES was required to report to the United States Treasury each foreign bank account held by the foreign MANAFORT – GATES entities noted abo ve in paragraph 12 that bear s the initials RG, as well as United Kingdom Bank Accounts A and B noted in paragraph 18. No FBAR filings were made by GATES for these accounts. 24. Furthermore, in each of MANAFORT’s tax filings for 2008 through 2014, MANAFORT , with the assistance of GATES , represented falsely that he did not have authority over any foreign bank accounts. MANAFORT and GATES had repeatedly and falsely represented in writing to MANAFORT’s tax preparer that MANAFORT had no authority over foreign bank accounts, knowing that such false representations would result in false tax filings in MANAFORT’s name. For instance, on October 4, 2011, MANAFORT’s tax preparer asked MANAFORT in writing: “At any time during 2010, did you [or your wife or children] have an interest in or a signature or other authority over a financial account in a foreign country, such as a bank account, securities account or other financial account?” On the same day, MANAFORT falsely responded “NO.” Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 19 of 37

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 20 of 37 MANAFORT responded the same way as recently as October 3, 2016, when MANAFORT’s tax preparer again emailed the question in connection with the preparation of MANAFORT’s tax returns: “Foreign bank accounts etc.?” MANAFORT responded on or about the same day: “NONE.” 25. In each of GATES’ tax filings for 2010 through 2013, GATES represented falsely that he did not have authority over any foreign bank accounts. GATES had repeatedly and falsely represented to his tax preparers that he had no authority over foreign bank accounts, knowing that such false representations would result in false tax filings. As recently as October 2017, in preparation for his amended 2013 tax filing, GATES was asked by his tax preparer: “Did you have any foreign assets/bank accounts during 2013 or 2014?” to which he responded “no.” The Financial Institution Scheme 26. Between in or around 2015 and the present, both dates being approximate and inclusive, in the Eastern District of Virginia and elsewhere, MANAFORT, GATES, and others devised and intended to devise, and executed and attempted to execute, a scheme and artifice to defraud, and to obtain money and property, by means of false and fraudulent pretenses, representations, and promises, from banks and other financial institutions. As part of the scheme, MANAFORT and GATES repeatedly provided and caused to be provided false information to banks and other lenders, among others. MANAFORT And GATES’ Fraud To Access Offshore Money 27. When they were flush with Ukraine funds, MANAFORT, with the assistance of GATES, used their offshore accounts to purchase and improve real estate in the United States. When the income from Ukraine dwindled in 2014 and 2015, MANAFORT, with the assistance of GATES, obtained millions of dollars in mortgages on the United States properties, thereby allowing 20

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 21 of 37 MANAFORT to have the benefits of liquid income without paying taxes on it. MANAFORT and GATES defrauded the lenders in various ways, including by lying about MANAFORT’s and DMI’s income, lying about their debt, and lying about MANAFORT’s use of the property and the loan proceeds. For example, MANAFORT and GATES submitted fabricated profit and loss statements (P&Ls) that inflated income, and they caused others to provide doctored financial documents. A. The Loan From Lender A On The Union Street Property 28. In 2012, MANAFORT, through a corporate vehicle called “MC Brooklyn Holdings, LLC” owned by him and his family, bought a brownstone on Union Street in the Carroll Gardens section of Brooklyn, New York. He paid approximately $3,000,000 in cash for the property. All of that money came from a MANAFORT–GATES entity in Cyprus. After purchase of the property, MANAFORT began renovations to transform it from a multi-family dwelling into a single-family home. MANAFORT used proceeds of a 2015 loan obtained from a financial institution to make the renovations. In order to obtain that loan, MANAFORT falsely represented to the bank that he did not derive more than 50% of his income/wealth from a country outside the United States. 29. In late 2015 through early 2016, MANAFORT sought to borrow cash against the Union Street property from Lender A. Lender A provided greater loan amounts for “construction loans”—that is, loans that required the loan funds to be used to pay solely for construction on the property and thus increase the value of the property serving as the loan’s collateral. The institution would thus loan money against the expected completed value of the property, which in the case of the Union Street property was estimated to be $8,000,000. In early 2016, MANAFORT was able to obtain a loan of approximately $5,000,000, after promising Lender A that approximately $1,400,000 of the loan would be used solely for construction on the Union Street property. 21

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 22 of 37 MANAFORT never intended to limit use of the proceeds to construction as required by the loan contracts and never did. In December 2015, before the loan was made, MANAFORT wrote his tax preparer, among others, that the “construction mortgage will allow me to pay back [another Manafort apartment] mortgage in full. . . .” Further, when the construction loan closed, MANAFORT used hundreds of thousands of dollars for purposes unrelated to the construction of the property. B. The Loan From Lender B On The Howard Street Property 30. In 2012, MANAFORT, through a corporate vehicle called “MC Soho Holdings, LLC” owned by him and his family, bought a condominium on Howard Street in the Soho neighborhood of Manhattan, New York. He paid approximately $2,850,000. All the money used to purchase the condominium came from MANAFORT–GATES entities in Cyprus. MANAFORT used the property from at least January 2015 through at least August 2017 as an income-generating rental property, charging thousands of dollars a week on Airbnb, among other places. On his tax returns, MANAFORT took advantage of the beneficial tax consequences of owning this rental property. 31. In late 2015 through early 2016, MANAFORT applied for a mortgage on the Howard Street condominium from Lender B for approximately $3.4 million. Because the bank would permit a greater loan amount if the property were owner-occupied, MANAFORT falsely represented to the lender and its agents that it was a secondary home used as such by his daughter and son-in-law and was not held as a rental property. In an email on January 6, 2016, MANAFORT noted: “[i]n order to have the maximum benefit, I am claiming Howard St. as a second home. Not an investment property.” Later, on January 26, 2016, MANAFORT wrote to his son-in-law to advise him that when the bank appraiser came to assess the condominium, his son-in-law should “[r]emember, he believes that you and [MANAFORT’s daughter] are living there.” 22

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 23 of 37 32. MANAFORT, with GATES’ assistance, also made a series of false and fraudulent representations to the bank in order to secure the millions of dollars in financing. For example, MANAFORT falsely represented the amount of debt he had by failing to disclose on his loan application the existence of the Lender A mortgage on his Union Street property. That liability would have risked his qualifying for the loan. Through its own due diligence, Lender B found evidence of the existing mortgage on the Union Street property. As a result, Lender B wrote to MANAFORT and GATES that the “application has the following properties as being owned free & clear . . . Union Street,” but “[b]ased on the insurance binders that we received last night, we are showing that there are mortgages listed on these properties, can you please clarify[?]” 33. To cover up the falsity of the loan application, GATES, on MANAFORT’s behalf, caused an insurance broker to provide Lender B false information, namely, an outdated insurance report that did not list the Union Street loan. MANAFORT and GATES knew such a representation was fraudulent. After GATES contacted the insurance broker and asked her to provide Lender B with false information, he updated MANAFORT by email on February 24, 2016. MANAFORT replied to GATES, on the same day: “good job on the insurance issues.” 34. MANAFORT and GATES submitted additional false and fraudulent statements to Lender B. For example, MANAFORT submitted 2014 DMI tax returns to support his 2016 loan application to Lender B. Those tax returns included as a purported liability a $1.5 million loan from Peranova. Peranova was a Cypriot entity controlled by MANAFORT and GATES. On or about February 1, 2012, Peranova transferred $1.5 million to a DMI account in the United States, denominating the transfer as a loan so that MANAFORT would not have to declare the money as income. MANAFORT used the “loan” to acquire the Howard Street property. 35. When MANAFORT needed to obtain a loan from Lender B, the existence of the Peranova 23

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 24 of 37 “loan” undermined his creditworthiness. As a result of the listed Peranova liability, Lender B was not willing to make the loan to MANAFORT. To circumvent this issue, MANAFORT and GATES caused MANAFORT’s tax accountant to send to Lender B back-dated documentation that falsely stated that the $1.5 million Peranova loan had been forgiven in 2015, and falsely inflated income for 2015 to mask MANAFORT’s 2015 drop in income. 36. In March 2016, Lender B approved the loan in the amount of approximately $3.4 million (the $3.4 million loan). C. The Loan From Lender C 37. In approximately February 2016, MANAFORT applied for a business loan from Lender C. MANAFORT made a series of false statements to Lender C. For example, MANAFORT submitted a false statement of assets and liabilities that failed to disclosed the Lender A loan on the Union Street property and misrepresented, among other things, the amount of the mortgage on the Howard Street property. 38. Further, in approximately March 2016, MANAFORT and GATES submitted a doctored 2015 DMI P&L that overstated DMI’s 2015 income by more than $4 million. GATES asked DMI’s bookkeeper to send him a “Word Document version of the 2015 P&L for [DMI]” because MANAFORT wanted GATES “to add the accrual revenue which we have not received in order to send to [Lender C].” The bookkeeper said she could send a .pdf version of the P&L. GATES then asked the bookkeeper to increase the DMI revenue, falsely claiming that: “[w]e have $2.4m in accrued revenue that [MANAFORT] wants added to the [DMI] 2015 income. Can you make adjustments on your end and then just send me a new scanned version[?]” The bookkeeper refused since the accounting method DMI used did not permit recording income before it was actually received. 24

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 25 of 37 39. Having failed to secure a falsified P&L from the bookkeeper, GATES falsified the P&L. GATES wrote to MANAFORT and another conspirator, “I am editing Paul’s 2015 P&L statement.” GATES then sent the altered P&L to Lender C, which claimed approximately $4.45 million in net income, whereas the true P&L had less than $400,000 in net income. D. The Loan From Lender B On The Union Street Property 40. In March 2016, MANAFORT, with the assistance of GATES and others, applied for a $5.5 million loan from Lender B on the Union Street property. As part of the loan process, MANAFORT submitted a false statement of assets and liabilities that hid his prior loan from Lender A on the Union Street property, among other liabilities. In addition, another conspirator on MANAFORT’s behalf submitted a falsified 2016 DMI P&L. The falsified 2016 DMI P&L overstated DMI’s income by more than $2 million, which was the amount that Lender B told MANAFORT he needed to qualify for the loan. When the document was first submitted to Lender B, a conspirator working at Lender B replied: “Looks Dr’d. Can’t someone just do a clean excel doc and pdf to me??” A subsequent version was submitted to the bank. E. The Loans From Lender D On The Bridgehampton And Union Street Properties 41. In 2016, MANAFORT sought a mortgage on property in Bridgehampton, New York from a financial institution. In connection with his application, MANAFORT falsely represented to the bank that DMI would be receiving $2.4 million in income later in the year for work on a “democratic development consulting project.” To support this representation, GATES, on MANAFORT’s behalf, provided the bank with a fake invoice for $2.4 million, directed “To Whom It May Concern,” for “[s]ervices rendered per the consultancy agreement pertaining to the parliamentary elections.” The bank, unwilling to rely on the invoice to support MANAFORT’s stated 2016 income, requested additional information. The bank was unable to obtain satisfactory 25

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 26 of 37 support for the stated income, and the loan application was denied. 42. 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. The doctored 2015 DMI P&L submitted to Lender D was the same false statement previously submitted to Lender C, which overstated DMI’s income by more than $4 million. The doctored 2016 DMI P&L was inflated by MANAFORT by more than $3.5 million. To create the false 2016 P&L, on or about October 21, 2016, MANAFORT emailed GATES a .pdf version of the real 2016 DMI P&L, which showed a loss of more than $600,000. GATES converted that .pdf into a “Word” document so that it could be edited, which GATES sent back to MANAFORT. MANAFORT altered that “Word” document by adding more than $3.5 million in income. He then sent this falsified P&L to GATES and asked that the “Word” document be converted back to a .pdf, which GATES did and returned to MANAFORT. MANAFORT then sent the falsified 2016 DMI P&L .pdf to Lender D. 44. In addition, Lender D questioned MANAFORT about a $300,000 delinquency on his American Express card, which was more than 90 days past due. The delinquency significantly affected MANAFORT’s credit rating score. MANAFORT falsely represented to Lender D that he had lent his credit card to a friend, GATES, who had incurred the charges and had not reimbursed him. MANAFORT supplied Lender D a letter from GATES that falsely stated that 26

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 27 of 37 GATES had borrowed MANAFORT’s credit card to make the purchases at issue and would pay him back by a date certain. Statutory Allegations COUNTS ONE THROUGH FIVE (Subscribing to False United States Individual Income Tax Returns For 2010–2014 Tax Years) 45. Paragraphs 1 through 44 are incorporated here. 46. On or about the dates specified below, in the Eastern District of Virginia and elsewhere, defendant PAUL J. MANAFORT, JR., willfully and knowingly did make and subscribe, and aid and abet and cause to be made and subscribed, United States Individual Income Tax Returns, Forms 1040 and Schedule B, for the tax years set forth below, which returns contained and were verified by the written declaration of MANAFORT that they were made under penalties of perjury, and which returns MANAFORT did not believe to be true and correct as to every material matter, in that the returns (a) claimed that MANAFORT did not have a financial interest in and signature and other authority over a financial account in a foreign country and (b) failed to report income, whereas MANAFORT then and there well knew and believed that he had a financial interest in, and signature and other authority over, bank accounts in a foreign country and had earned total income in excess of the reported amounts noted below: COUNT TAX APPROX. FILING FOREIGN ACCOUNT TOTAL INCOME YEAR DATE REPORTED REPORTED (Sch. B, Line 7a) (Line 22) 1 2010 October 14, 2011 None $504,744 2 2011 October 15, 2012 None $3,071,409 3 2012 October 7, 2013 None $5,361,007 4 2013 October 6, 2014 None $1,910,928 5 2014 October 14, 2015 None $2,984,210 (26 U.S.C. § 7206(l); 18 U.S.C. §§ 2 and 3551 et seq.) 27

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 28 of 37 COUNTS SIX THROUGH TEN (Assisting in the Preparation of False United States Individual Income Tax Returns For 2010–2014 Tax Years) 47. Paragraphs 1 through 44 are incorporated here. 48. On or about the dates specified below, in the Eastern District of Virginia and elsewhere, defendant RICHARD W. GATES III willfully and knowingly did aid and assist in, and procure, counsel, and advise the preparation and presentation to the Internal Revenue Service, of a United States Individual Income Tax Return, Form 1040 and Schedule B, of PAUL J. MANAFORT, JR., for the tax years set forth below, which returns were false and fraudulent as to a material matter, in that the returns (a) claimed that MANAFORT did not have a financial interest in, and signature and other authority over, a financial account in a foreign country and (b) failed to report income, whereas GATES then and there well knew and believed that MANAFORT had a financial interest in, and signature and other authority over, bank accounts in a foreign country and had earned total income in excess of the reported amounts noted below: COUNT TAX APPROX. FILING FOREIGN ACCOUNT TOTAL INCOME YEAR DATE REPORTED REPORTED (Sch. B, Line 7a) (Line 22) 6 2010 October 14, 2011 None $504,744 7 2011 October 15, 2012 None $3,071,409 8 2012 October 7, 2013 None $5,361,007 9 2013 October 6, 2014 None $1,910,928 10 2014 October 14, 2015 None $2,984,210 (26 U.S.C. § 7206(2); 18 U.S.C. § 3551 et seq.) COUNTS ELEVEN THROUGH FOURTEEN (Failure To File Reports Of Foreign Bank And Financial Accounts For Calendar Years 2011–2014) 49. Paragraphs 1 through 44 are incorporated here. 50. On the filing due dates listed below, in the Eastern District of Virginia and elsewhere, 28

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 29 of 37 defendant PAUL J. MANAFORT, JR., unlawfully, willfully, and knowingly did fail to file with the Treasury an FBAR disclosing that he had a financial interest in, and signature and other 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: COUNT YEAR DUE DATE TO FILE FBAR 11 2011 June 29, 2012 12 2012 June 30, 2013 13 2013 June 30, 2014 14 2014 June 30, 2015 (31 U.S.C. §§ 5314 and 5322(a); 18 U.S.C. §§ 2 and 3551 et seq.) COUNTS FIFTEEN THROUGH NINETEEN (Subscribing to False United States Individual Income Tax Returns For 2010–2014 Tax Years) 51. Paragraphs 1 through 44 are incorporated here. 52. On or about the dates specified below, in the Eastern District of Virginia and elsewhere, defendant RICHARD W. GATES III willfully and knowingly did make and subscribe, and aid and abet and cause to be made and subscribed, United States Individual Income Tax Returns, Forms 1040 and Schedule B, for the tax years set forth below, which returns contained and were verified by the written declaration of defendant GATES that they were made under penalties of perjury, and which returns defendant GATES did not believe to be true and correct as to every material matter, in that the returns (a) claimed that GATES did not have a financial interest in, and signature and other authority over, a financial account in a foreign country and (b) failed to report income, whereas GATES then and there well knew and believed that he had a financial interest in, and signature and other authority over, a financial account in a foreign country and had earned total income in excess of the reported amounts noted below: 29

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 30 of 37 COUNT TAX APPROX. FILING FOREIGN ACCOUNT TOTAL INCOME YEAR DATE REPORTED REPORTED (Sch. B, Line 7a) (Line 22) 15 2010 July 26, 2011 None $194,257 16 2011 October 11, 2012 None $250,307 17 2012 October 15, 2013 None $365,646 18 2013 October 15, 2014 None $307,363 19 2014 October 14, 2015 None $292,892 (26 U.S.C. § 7206(l); 18 U.S.C. §§ 2 and 3551 et seq.) COUNT TWENTY (Subscribing to a False Amended United States Individual Income Tax Return For 2013 Tax Year) 53. Paragraphs 1 through 44 are incorporated here. 54. On or about October 25, 2017, in the Eastern District of Virginia and elsewhere, defendant RICHARD W. GATES III willfully and knowingly did make and subscribe, and aid and abet and cause another to make and subscribe, a United States Individual Income Tax Return, Form 1040X, for the 2013 tax year, which return contained and was verified by the written declaration of defendant GATES that it was made under penalties of perjury, and which return defendant GATES did not believe to be true and correct as to every material matter, in that the return failed to report income, whereas GATES then and there well knew and believed that he had earned adjusted gross income in excess of the reported amount on Line 1C, to wit: $292,055. (26 U.S.C. § 7206(l); 18 U.S.C. §§ 2 and 3551 et seq.) COUNTS TWENTY-ONE THROUGH TWENTY-THREE (Failure To File Reports Of Foreign Bank And Financial Accounts For Calendar Years 2011–2013) 55. Paragraphs 1 through 44 are incorporated here. 56. 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 30

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 31 of 37 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: COUNT YEAR DUE DATE TO FILE FBAR 21 2011 June 29, 2012 22 2012 June 30, 2013 23 2013 June 30, 2014 (31 U.S.C. §§ 5314 and 5322(a); 18 U.S.C. §§ 2 and 3551 et seq.) COUNT TWENTY-FOUR (Bank Fraud Conspiracy / Lender B / $3.4 million loan) 57. Paragraphs 1 through 44 are incorporated here. 58. On or about and between December 2015 and March 2016, both dates being approximate and inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J. MANAFORT, JR., and RICHARD W. GATES III did knowingly and intentionally conspire to execute a scheme and artifice to defraud one or more financial institutions, to wit: Lender B, 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. (18 U.S.C. §§ 1349 and 3551 et seq.) COUNT TWENTY-FIVE (Bank Fraud / Lender B / $3.4 million loan) 59. Paragraphs 1 through 44 are incorporated here. 60. On or about and between December 2015 and March 2016, both dates being approximate 31

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 32 of 37 and inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J. MANAFORT, JR., and RICHARD W. GATES III did knowingly and intentionally execute and attempt to execute a scheme and artifice to defraud one or more financial institutions, to wit: Lender B, 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. (18 U.S.C. §§ 1344, 2, and 3551 et seq.) COUNT TWENTY-SIX (Bank Fraud Conspiracy / Lender C / $1 million loan) 61. Paragraphs 1 through 44 are incorporated here. 62. On or about and between March 2016 and May 2016, both dates being approximate and inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J. MANAFORT, JR., and RICHARD W. GATES III did knowingly and intentionally conspire to execute a scheme and artifice to defraud one or more financial institutions, to wit: 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. (18 U.S.C. §§ 1349 and 3551 et seq.) COUNT TWENTY-SEVEN (Bank Fraud / Lender C / $1 million loan) 63. Paragraphs 1 through 44 are incorporated here. 64. On or about and between December 2015 and March 2016, both dates being approximate and inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J. 32

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 33 of 37 MANAFORT, JR., and RICHARD W. GATES III did knowingly and intentionally execute and attempt to execute a scheme and artifice to defraud one or more financial institutions, to wit: 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. (18 U.S.C. §§ 1344, 2, and 3551 et seq.) COUNT TWENTY-EIGHT (Bank Fraud Conspiracy / Lender B / $5.5 million loan) 65. Paragraphs 1 through 44 are incorporated here. 66. On or about and between March 2016 and August 2016, both dates being approximate and inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J. MANAFORT, JR., and RICHARD W. GATES III did knowingly and intentionally conspire to execute a scheme and artifice to defraud one or more financial institutions, to wit: Lender B, 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. (18 U.S.C. §§ 1349 and 3551 et seq.) COUNT TWENTY-NINE (Bank Fraud Conspiracy / Lender D / $9.5 million loan) 67. Paragraphs 1 through 44 are incorporated here. 68. On or about and between April 2016 and November 2016, both dates being approximate and inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J. MANAFORT, JR., and RICHARD W. GATES III did knowingly and intentionally conspire to 33

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 34 of 37 execute a scheme and artifice to defraud one or more financial institutions, to wit: Lender D, 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. (18 U.S.C. §§ 1349 and 3551 et seq.) COUNT THIRTY (Bank Fraud / Lender D / $9.5 million loan) 69. Paragraphs 1 through 44 are incorporated here. 70. On or about and between April 2016 and November 2016, both dates being approximate and inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J. MANAFORT, JR., and RICHARD W. GATES III did knowingly and intentionally execute and attempt to execute a scheme and artifice to defraud one or more financial institutions, to wit: Lender D, 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. (18 U.S.C. § 1344, 2, and 3551 et seq.) COUNT THIRTY-ONE (Bank Fraud Conspiracy / Lender D / $6.5 million loan) 71. Paragraphs 1 through 44 are incorporated here. 72. On or about and between April 2016 and January 2017, both dates being approximate and inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J. MANAFORT, JR., and RICHARD W. GATES III did knowingly and intentionally conspire to execute a scheme and artifice to defraud one or more financial institutions, to wit: Lender D, the deposits of which 34

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 35 of 37 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. (18 U.S.C. §§ 1349 and 3551 et seq.) COUNT THIRTY-TWO (Bank Fraud / Lender D / $6.5 million loan) 73. Paragraphs 1 through 44 are incorporated here. 74. On or about and between April 2016 and January 2017, both dates being approximate and inclusive, in the Eastern District of Virginia and elsewhere, defendants PAUL J. MANAFORT, JR., and RICHARD W. GATES III did knowingly and intentionally execute and attempt to execute a scheme and artifice to defraud one or more financial institutions, to wit: Lender D, 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. (18 U.S.C. §§ 1344, 2, and 3551 et seq.) FORFEITURE NOTICE 75. Pursuant to Fed. R. Crim. P. 32.2, notice is hereby given to the defendants that the United States will seek forfeiture as part of any sentence in accordance with Title 18, United States Code, Section 982(a)(2), in the event of the defendants’ convictions under Counts Twenty-Four through Thirty-Two of this Superseding Indictment. Upon conviction of the offenses charged in Counts Twenty-Four through Thirty-Two, defendants PAUL J. MANAFORT, JR., and RICHARD W. GATES III shall forfeit to the United States any property constituting, or derived from, proceeds 35

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 36 of 37 obtained, directly or indirectly, as a result of such violation(s). Notice is further given that, upon conviction, the United States intends to seek a judgment against each defendant for a sum of money representing the property described in this paragraph, as applicable to each defendant (to be offset by the forfeiture of any specific property). 76. The grand jury finds probable cause to believe that the property subject to forfeiture by PAUL J. MANAFORT, JR., includes, but is not limited to, the following listed assets: a. All funds held in account number XXXXXX0969 at Lender D, and any property traceable thereto. Substitute Assets 77. If any of the property described above as being subject to forfeiture, as a result of any act or omission of any defendant a. cannot be located upon the exercise of due diligence; b. has been transferred or sold to, or deposited with, a third party; 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 that cannot be subdivided without difficulty; it is the intent of the United States of America, pursuant to Title 18, United States Code, Section 982(b) and Title 28, United States Code, Section 2461(c), incorporating Title 21, United States Code, Section 853, to seek forfeiture of any other property of said defendant. (18 U.S.C. § 982) 36

Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 37 of 37 Robert S. M Her, III Special Counsel Department of Justice A TRUE BILL: Foreperson Date: February 22, 2018 37

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