George Nader Indictment

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Holding a Criminal Term

Grand Jury Sworn in on May 7, 2019
SEALED
UNITED STATES OF AMERICA : Criminal No.
V. : INDICTMENT
AHMAD "ANDY" KHAWAJA, •

• Counts 1 and 13: 18 U.S.C. § 371
GEORGE NADER, •
• (Conspiracy)
ROY BOULOS,
RUDY DEKERMENJIAN, Counts 2, 15-20, 25, 27, 30, 33, 36, 38, 41,
MOHAMMAD "MOE" DIAB, and 44: 52 U.S.C. §§ 30122 and 30109
RANI EL-SAADI, (Contributions in the Name of Another)
STEVAN HILL, and
THAYNE WHIPPLE, Counts 3, 5, 7, 9, 11, 21, 23, 28, 31, 34, 39,
42, 45, and 47: 18 U.S.C. §§ 1001(a)(2) and
Defendants. 2
(False Statements)
Counts 4, 6, 8, 10, 12, 22, 24, 29, 32, 35, 40,

43, 46, and 48: 18 U.S.C. §§ 1519 and 2
(Destruction, alteration, or falsification of
records)
Counts 14, 26, and 37: 52 U.S.C. §§ 30116

and 30109
(Excessive Contributions)
Counts 49-53: 18 U.S.C. § 1503

(Obstruction)
Case 1:19-cr-374
U.S. District and Bankruptcy CO Lii Ls Assigned to: Judge Randolph D. Moss
for the District of Columbia
Date Assigned: 11/07/2019
A TRUE COPY
Clerk Description: Indictment (B)
ANGELA D. CAESAR,
By
eputy Clerk
INDICTMENT
The Grand Jury charges that:
1. At all times relevant to this indictment:
Introduction
2. Defendant Ahmad "Andy" KHAWAJA was a resident of Los Angeles, California,
and the Chief Executive Officer of an online payment processing company headquartered in
West Hollywood, California ("Company A").
3. Defendant George NADER was the owner of a business entity in Foreign Country
A ("Company B"), and a self-described advisor to certain foreign governments in the Middle
East, including Foreign Country A.
4. Defendant Roy BOULOS was a resident of Las Vegas, Nevada, and the owner of
a liquor, wine, and cigar store in the Las Vegas-area.
5. Defendant Rudy DEKERMENJIAN was a resident of Glendale, California, an
attorney in the Los Angeles-area, and an attorney for Company A.
6. Defendant Mohammad "Moe" DIAB was a resident of Glendale, California, the
cousin of KHAWAJA, and the Chief Operating Officer of Company A.
7. Defendant Rani EL-SAADI was the owner of travel services provider located in
Los Angeles, California.
8. Defendant Stevan HILL was a resident of Santa Monica, California, and an
associate of KHAWAJA, who became a Managing Director at Company A in or about 2017.
9. Defendant Thayne WHIPPLE was a resident of Ojai, California, and was an
outside contractor for Company A.
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10. Candidate 1 was a candidate for the Office of the President of the United States in
the 2016 election. In addition to his/her official campaign committee, Candidate 1 had two joint
fundraising committees ("Political Committee 1" and "Political Committee 2") supporting
his/her candidacy in 2016. Both committees were registered with the Federal Election
Commission and subject to specified contribution limits, limiting the allowable contributions by
individuals in the 2016 election cycle. Individual 1 was Candidate l's spouse.
11. Candidate 2 was a candidate for the Office of the President of the United States in
the 2016 election.
12. Elected Official 1 was an elected, federal official.
13. Elected Official 2 was an elected, federal official.
14. Political Committee 3 was a political committee formed to raise money for a
national political party's national convention in 2016. It was registered with the Federal Election
Commission.
15. Political Committee 4 was a super-political action committee or - super PAC"
registered with the Federal Election Commission.
16. Political Committee 5 was the governing body for a national political party. It
was registered with the Federal Election Commission as a national political party committee and
subject to specified contribution limits, limiting the allowable contributions by individuals in
2016.
17. Political Committee 6 was the governing body for a national political party. It
was registered with the Federal Election Commission as a national political party committee and
subject to specified contribution limits, limiting the allowable contributions by individuals in
2017.
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18. Political Committee 7 was national political party committee registered with the
Federal Election Commission and subject to specified contribution limits, limiting the allowable
contributions by individuals in 2018.
19. Political Committee 8 was a joint fundraising committee registered with the
Federal Election Commission.
20. The Federal Election Campaign Act of 1971, as amended, Title 52, United States
Code, Sections 30101, et seq. ("Election Act"), limited financial influence in the election of
candidates for federal office, including the office of the President of the United States, and
provided for public disclosure of the financing of federal election campaigns, as follows:
a. The Election Act limited the amount and source of money that may be
contributed to a federal candidate or that candidate's authorized campaign
committee and political committees established and maintained by a national
political party.
b. The Election Act expressly states that contributions made through an
intermediary are treated as contributions from the original payor.
21. The Federal Election Commission ("FEC") was an agency and department of the
United States with jurisdiction to enforce the limits and prohibitions of the Election Act, and to
compile and publicly report accurate information about the source and amounts of contributions.
The Election Act required committees to file campaign finance reports accurately disclosing
activity related to contributions, expenditures, debts, and loans of the committee.
COUNT ONE
18 U.S.C. § 371
(Conspiracy to Make Conduit Contributions, Cause False Statements, and Cause False
Entries in Records)
22. Paragraphs 1 through 21 are realleged and incorporated herein by reference.
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23. From in or about March 2016 through in or about January 2017, in the District of
Columbia and elsewhere, the defendants,
AHMAD "ANDY" KHAWAJA, and

GEORGE NADER,
knowingly conspired and agreed together and with each other, and with other persons both
known and unknown to the Grand Jury, to commit offenses against the United States, that is:
a. willfully making contributions in the name of another person and permitting
one's name to be used to effect such contributions, and causing another to
accept contributions made by one person in the name of another person, which
contributions aggregated $25,000 and more in calendar year 2016, in violation
of 52 U.S.C. §§ 30109(d)(1)(A)(i) and 30122, and 18 U.S.C. § 2;
b. willfully causing the submission of material false, fictitious, and fraudulent
statements and representations in a matter within the jurisdiction of the
executive branch of the government of the United States, in violation of 18
U.S.C. §§ 1001(a)(2) and 2; and
c. with the intent to impede, obstruct, and influence, and in relation to and
contemplation of, the investigation and proper administration of matters
within the jurisdiction of departments and agencies of the United States,
knowingly causing the concealment, covering up, falsifying, and making of
false entries in records, documents, and tangible objects, in violation of 18
U.S.C. §§ 1519 and 2.
PURPOSES OF THE CONSPIRACY
24. It was a purpose of the conspiracy to facilitate unlawful campaign contributions
from NADER, through KHAWAJA, to political committees, including Political Committee 1,
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Political Committee 2, Political Committee 3, and Political Committee 4, in order for
KHAWAJA and NADER to gain access to and influence with Candidate 1 and others during and
following the 2016 U.S. Presidential election.
25. It was a purpose of the conspiracy for NADER and KHAWAJA to use their
access to Candidate 1 to gain favor with, and potential financial support from, the government of
Foreign Country A.
26. It was a purpose of the conspiracy to cause Political Committee 1, Political
Committee 2, Political Committee 3, and Political Committee 4 to unwittingly file false
campaign finance reports concealing these unlawful campaign contributions from the FEC and
the public by falsely stating that the contributions were made by KHAWAJA and Company A
when in reality they were funded by NADER.
27. It was a purpose of the conspiracy to conceal the co-conspirators' unlawful
activity.
MANNER AND MEANS
28. The manner and means of the conspiracy included, but were not limited to, the
following:
a. The conspirators caused more than $3.5 million in contributions to Political
Committee 1, Political Committee 2, Political Committee 3, and Political
Committee 4, all funded with monies funneled by NADER to KHAWAJA for
contribution;
b. The conspirators made the millions of dollars in contributions to access—and,
at times, to host—political events in an effort to gain influence with high-level
political figures, including Candidate 1;
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c. The conspirators concealed their scheme by surreptitiously communicating
about the funneling of monies from NADER to KHAWAJA, as well as their
attendance at and hosting of political events, through the use of an encrypted
messaging system and coded language;
d. The conspirators created a false licensing agreement and invoice to disguise
approximately $4.9 million in payments from NADER to KHAWAJA as a
legitimate commercial transaction; and
e. The conspirators caused Political Committee 1, Political Committee 2,
Political Committee 3, and Political Committee 4 to submit reports to the FEC
unwittingly stating falsely that the contributions were made by KHAWAJA
and Company A.
OVERT ACTS
29. In furtherance of the conspiracy, and to accomplish its purpose, the defendants,

GEORGE NADER,
and others known and unknown to the Grand Jury, committed, and caused to be committed, in
the District of Columbia, and elsewhere, the following overt acts:
Initial Communications About NADER Sending Money for Contribution
a. On or about April 16, 2016, KHAWAJA, DEKERIVIENJIAN, and NADER
attended an event in support of Candidate 1. In March and April 2016,
KHAWAJA had contributed at least $275,000 to Political Committee 2, and
he brought NADER as his guest to the event. Following the event, on or
about April 17, NADER reported to an official from Foreign Country A's
7
government via WhatsApp message that he had a "Wonderful meeting with
• the Big Lady. . . Can't wait to tell you all about it"
b. On or about May 6, NADER attended an event at KHAWAJA's home with an
official from Candidate l's campaign and another high-profile elected official.
On or about May 7, NADER reported to an official from Foreign Country A's
government via WhatsApp message that he, "Had a magnificent sessions with
Big Lady's key people. . . . You will be most amazed by my progress on that
side!"
c. On or about May 15, KHAWAJA sent NADER a WhatsApp message about
arranging a private event with Candidate 1, stating: "The birthday party has
been set up. 3 party have been arranged for my sister and it's going to be
huge for her. She is very excited and happy. All arranged buddy:) as you
will see I'm a man of my word." In these messages, "sister" is a reference to
Candidate 1.
d. On or about May 22, NADER sent KHAWAJA a WhatsApp message about
money he was planning to send to KHAWAJA for contribution in support of
Candidate 1, stating: "I am following up with my people on making sure the
goodies arrive later this week in time for the Party! That is for sure and I shall
definitely be with you early next month in preparation and celebration !" On
or about May 31, NADER wrote, "Package was authorized and sent!
Expected sometimes this week! Are we still on for first party on June 6?"
KHAWAJA responded, "Yes we are on for the 6th."

e. On or about June 2, KHAWAJA met with an official from Candidate l's
campaign and, in an effort to ingratiate himself with the campaign, promised
to contribute $1 million.
f. In early June 2016, KHAWAJA and NADER continued to communicate via
WhatsApp about the status of the money NADER promised to send. On or
about June 2, KHAWAJA wrote, "Hi George the package still did not arrive."
NADER responded, "Not to worry my Dear. Consider it done." On or about
June 3, KHAWAJA wrote, "George my people tell me the delivery still did
not arrive.. Was suppose to arrive yesterday.." NADER responded: "I
know! I repeat don't worry about it! It is done! Just had to come on certain
truck and delivery that is taken couple extra days for delicacy and since it is
very fragile! So consider it done and it will be there in next couple of days or
so! It has to be handled very very carefully! I explain when I see you in
person soon!"
g. On or about June 2, NADER reported to an official from Foreign Country A's
government via WhatsApp message that he was "leaving very early morning
to catch up with big Lady over the weekend. . . . Can I come over for 10
minutes. . . to get your blessings and instruction before I leave please?"
h. On or about June 6, KHAWAJA attended an event in support of Candidate 1.
On or about June 7, KHAWAJA wrote a check for $250,000 to Political
Committee 2, falsely representing that it was a contribution from him and his
wife, when it was, in fact, made with the expectation that it would reimbursed
in full by monies to be funneled to him by NADER. This caused Political

Committee 2 to unwittingly file a false report with the FEC stating that the
contribution was from KHAWAJA and his wife, when it was not.
i. On or about June 7, NADER reported to an official from Foreign Country A's
goverment via WhatsApp message that he, "Had a terrific meeting with my
Big Sister H You will be most delighted!"
j. On or about June 10, KHAWAJA again informed NADER via WhatsApp
message that the "package" had not arrived.
KHAWAJA Seeks Funds for Private Event, and the Conspirators Create a Fake
Commercial Transaction to Disguise the Transfer
k. KHAWAJA arranged to host a private fundraiser at his home on June 26, for
Candidate 1 featuring Individual 1. In order to host the event, KHAWAJA
was required to contribute or raise $1 million for Political Committee 1 and
Political Committee 2.
I. On or about June 11, KHAWAJA told NADER in a WhatsApp message about
the June 7.6 event, and stated that there would be an event on June 28 with
Candidate 1.
m. On or about June 13, KHAWAJA complained in a WhatsApp message to
NADER, "no package arrived today either." NADER responded, "I told them
about the upcoming deadline and events and they assure me that it will be
over there in coming days! It will be over there in time for the 26th
event! That is all!" KHAWAJA responded, "Just make sure you guys don't
look bad buddy .. I did not part and more. It's all up in your hands now."
NADER responded: "Good! I am sure you can take care of it till the package
arrive! No way I can press them anymore! You have to understand that will
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backfire if I push anymore! It will be there! I have seeing the approval of the
first package! I am not worry about it at all I hope you deliver as promised!"
n. On or about June 14, KHAWAJA and NADER discussed via WhatsApp a
false invoice to disguise the payments from NADER as a legitimate
commercial transaction. NADER wrote: "Hi Andy As per our conversation
and agreement for consultation and services provided by your company kindly
send me the bill to my email address (Rudy has it) so we can take care of it
ASAP! Specify in bill method and full details of payment please. As already
mentioned half of 10 to be paid upon receipt and second half by 15 August!"
On or about June 15, DEKERMENJIAN sent NADER an email attaching an
invoice from Company A for €10 million for a supposed license of Company
A's software by one of NADER's companies. On or about June 15,
KHAWAJA confirmed, "Invoice was sent last night from Rudy."
o. On or about June 16, KHAWAJA wrote in a WhatsApp message, - Rudy
resent you the updates address on the invoice. All good now. Please send the
package ASAP. I'm on my way back to la now. Everything is planned and
confirmed. This is going to be very large and private events. Will maximize
it as much as possible."
p. On or about June 22, KHAWAJA wrote, "Hi George, 4 days left for the
Sunday event and Still nothing arrived yesterday or today??" NADER
responded, in part, - The issue has been taken care of and is in order! Nothing
more can be done about it! I have also discussed the company issue and will
send you a note on the matter as per HEI instruction!" On or about June 24,
KHAWAJA continued to complain that the "package" had not arrived.
q. On or about June 24, NADER reported to an official from Foreign Country
A's government via WhatsApp message that he was "traveling on Sat
morning to catch up with our Big Sister and her husband: I am seeing him on
Sunday and her in Tuesday Sir! Would love to see you tomorrow at your
convenience. . . for your guidance, instruction and blessing!"
r. On or about June 26, KHAWAJA hosted a fundraiser at his home for
Candidate 1, which featured Individual 1. KHAWAJA, NADER,
DEKERMENJIAN, and other guests invited by KHAWAJA attended.
s. On or about June 27, NADER reported to an official from Foreign Country
A's government via WhatsApp message, "Meeting with [Individual 1] was
superb!" On or about June 29, NADER reported to an official from Foreign
Country A's government via WhatsApp message, "Meeting with Big Lady
went extremely well."
t. KHAWAJA contributed almost $1 million in connection with the June 26
event, including $400,800 to Political Committee 1 and $407,000 to Political
Committee 2. At the time, this represented the maximum contributions that
could be made under KHAWAJA and his wife's names to Political
Committee 1 and Political Committee 2.
u. As part of the contributions in connection with the June 26 event, on or about
June 28, KHAWAJA wrote a $157,000 check to Political Committee 2,
falsely representing that it was a contribution from his wife, when it was, in
12
fact, made with the expectation that it would reimbursed in full by monies to
be funneled to him by NADER. This caused Political Committee 2 to
unwittingly file a false report with the FEC stating that the contribution was
from KHAWAJA's wife, when it was not.
v. Also as part of the contributions in connection with the June 26 event, on or
about July 1, KHAWAJA wrote a $400,800 check to Political Committee 1,
falsely representing that it was a contribution from him and his wife, when it
was, in fact, made with the expectation that it would reimbursed in full by
monies to be funneled to him by NADER. This caused Political Committee 1
to unwittingly file a false report with the FEC stating that the contribution was
from KHAWAJA and his wife, when it was not.
KHAWAJA Seeks Reimbursement and NADER Seeks Additional Private Events
w. In early July 2016, KHAWAJA and NADER continued to communicate via
WhatsApp about the status of the money from NADER. On or about July 1,
KHAWAJA complained that the "delivery" had not arrived; NADER
responded, "I shall pursue it vigorously!" On or about July 3 and 4,
KHAWAJA again complained that there had been no "delivery." On or about
July 6, NADER asked: "Do you have anybody here you can trust so I can
either hand him over or pass on the partial Baklava gift that is at least good
and enough for the upcoming dinner with our Sister? Since it will be easier
and fresh and he can pass it on to you! otherwise I will have to transfer it
directly from me to your address you gave me! What you recommend?
13
Friends prefer that comes from me directly to you !" KHAWAJA responded,
"Send me the gift to me by mail. I have no one I can trust over there."
x. On or about July 7, 11, and 12, KHAWAJA again complained via WhatsApp
messages that no "delivery" had arrived. NADER asked, "When exactly is
the private event at the house with only 3 people please?" KHAWAJA
responded, "July 29," and NADER stated: "Very well: I will make sure you
get a nice tray of Baklava before that date."
y. Between July 13 and 15, NADER and DEKERMENJIAN engaged in further
communications about the false invoice between Company A and Company
B. The final invoice provided for half of the invoice to be paid within 48
hours and half by August 15, 2016. The invoice falsely purports to be for a
one-year license for Company A's software to Company B. No transfer of
software ever occurred.
z. On or about July 14, 2016, KHAWAJA caused Company A to write a
$550,000 check to Political Committee 3 to purchase box seats to a political
party's national convention. This check falsely represented that it was a
contribution from Company A, when it was, in fact, made with the
expectation that it would reimbursed in full by monies to be funneled to
KHAWAJA by NADER. This caused the Political Committee 3 to
from Company A, when it was not.
aa. According to a WhatsApp message between NADER and one of his
associates, NADER considered attending the political party's national
14
convention. NADER wrote, "I have a dilemma: invited to attend the []
convention next week with Andy as a VIP guest where I meet all the major
principles! On 29/30 July invited to a very small dinner with the Lady: just 5
people altogether![Foreign Country A Official] cautious and not terribly
excited about the big event. He thinks I am better of with the smaller private
one but the convention you are too exposed!" NADER did not attend the
event.
bb. On or about July 14, NADER stated in a WhatsApp message to KHAWAJA:
"Fresh hand made Baklava on the way designed especially for that private
event at your house later this month! First tray on the way! . . . You have got
to lose some weight for the upcoming tray of Baklava next week. Once you
taste it and you like the choices more on the way soon." On or about July 18,
KHAWAJA confirmed, "Small baklava arrived. 2.7 pieces arrive this
morning." On or about July 18, Company A received a €2.5 million wire
transfer from Company B.
cc. On or about July 19, NADER sent an official from Foreign Country A's
government via WhatsApp message photos of himself with Individual 1 in
KHAWAJA's home. On or about July 27, NADER reported to an official
from Foreign Country A's government via WhatsApp message that he was
"catching up with key figures in both camps and have been developing a
steady, consistent and constructive relationship with both camps!"
dd. On or about July 31, KHAWAJA sent NADER a WhatsApp message stating,
"That's why we need birthday gift, If [Candidate 2] gets elected its over for
15
the Arabs." NADER responded, "Let us hope we put a good one in next
couple of weeks and to follow up fast and immediate with a new tray of
Cookies!" KHAWAJA responded, "Agree..... I did a lot from me already."
ee. KHAWAJA continued to pursue a private event with Candidate 1. On or
about August 2, KHAWAJA wrote in a WhatsApp message, "All set.. It's
going to be the 23rd at llam my house 3 people only you me and my wife and
Juju :) will be up to 2 hours breakfast. . . . and then at 1pm we go for lunch
with her at [] the actor .. It's at his house up the from my me. It will be larger
crowd :) so private breakfast then a lunch with others." Approximately one
hour later, however, KHAWAJA wrote, "Was too hard to get it set up. Too
small of birthday gift and the time is worth 5 times more they say .." NADER
wrote on the same date: "As a show of appreciation, respect and total
confidence in You body, and for having set up the private event with Only
you, wife, Juju and me Only, I will press the bakery to prepare me another
tray of Baklawa to arrive in time for that event! I will do my best to get
something in time! Don't know how big since the second tray was prepared
immediately after the Birthday party but I trust my Friend that I can arrange a
bit more Baklawa, especially so that I know Juju loves it." KHAWAJA
responded, "Please do and it will make us all look good if you know what I
mean."
ff. On or about August 4, NADER sent KHAWAJA a WhatsApp message stating
he had met with "1-111," "And as soon as we get back to [a foreign city]
prepare something with bakery for the upcoming event. . . With pleasure and
stressed important and unique role you are playing."
gg. In further messages, KHAWAJA encouraged NADER to ensure the
"baklawa" arrived before the 22nd. On or about August 21, NADER wrote,
"A package of Baklava was prepared today as promised and sent DIFL It
should arrive in time for the event with your Sister, Wife and Juju."
KHAWAJA responded, "Ok buddy please make sure u in la no later then
3pm. I will pick u up at 4pm. We go to meet sister at event at 5pm :)"
hh. On or about August 22, KHAWAJA, co-hosted an event in support of
Candidate 1; DEKERMENJIAN and NADER attended. On or about August
22, NADER reported to an official from Foreign Country A's government via
WhatsApp message, "I am on my way to catch up with Big Sister and Family
in NY Sir."
ii. On or about August 23, KHAWAJA and NADER attended another event in
support of Candidate 1. On or about August 23, NADER reported to an
official from Foreign Country A's government via WhatsApp message, "I just
had dinner with my Big Sister and had a very very productive discussion with
her."
jj. On or about August 24, Company A received a €1,941,939.92 wire transfer
from Company B.
kk. On or about August 27, NADER sent a WhatsApp message to KHAWAJA
stating, "I have conveyed to HR your commitment and promise to hold the
upcoming two events in coming weeks." NADER went on to mention events
in "LF" and "NY."
KHAWAJA Arranges Another Private Event in Las Vegas
11. KHAWAJA arranged to host a private fundraiser for Candidate 1 in Las
Vegas, Nevada in September 2016. In order to host the event, KHAWAJA
was required to contribute or raise $500,000 for Political Committee 1 and
Political Committee 2. Due to his prior contributions and the contribution
limits, KHAWAJA could not contribute the full amount in his name or his
wife's name. Instead, he was able to contribute $130,000 under his name and
his wife's name. To evade contribution limits, KHAWAJA gave an additional
$1 million to seven associates for them to make contributions to Political
Committee 2 in their names, thereby concealing from the committee, the
public, and the FEC the true source of the contributions. This caused Political
Committee 2 to unwittingly file a false report with the FEC stating that the
contributions were from KHAWAJA's seven associates when they were not.
mm. On or about September 8, NADER wrote in a WhatsApp message, "Don't
give up any Baklava in my name till I come over and discuss it in person! You
handle it for now in your resilient and creative manner !" KHAWAJA
confirmed, "Don't worry Will not."
nn. On or about September 9, KHAWAJA wrote a $130,000 check to Political
Committee 2, falsely representing that it was a contribution from him and his
wife, when it was, in fact, made with monies funneled to him by NADER.
This caused Political Committee 2 to unwittingly file a false report with the
18
FEC stating that the contribution was from KHAWAJA and his wife, when it
was not.
oo. On or about September 12, KHAWAJA sent NADER a WhatsApp message
stating that he was on the telephone with the campaign and the Las Vegas
meeting was postponed. KHAWAJA recorded part of his telephone call with
the campaign and sent it to NADER. NADER forwarded the recording to an
official from Foreign Country A's government via WhatsApp.
pp. On or about September 27, KHAWAJA wrote a check for $1 million to
Political Committee 4. The memorandum line of the check contained
Candidate l's name. This check falsely represented that it was a contribution
from KHAWAJA, when it was, in fact, made with monies funneled to him by
NADER. This caused Political Committee 4 to unwittingly file a false report
with the FEC stating that the contribution was from KHAWAJA, when it was
not.
qq. On or about October 12, KHAWAJA hosted an event for Candidate 1 in Las
Vegas, Nevada, which was rescheduled from its original September 14 date.
Prior to the event, representatives of Candidate 1 requested that NADER not
attend, as he had not contributed anything. KHAWAJA demanded that
NADER be permitted to attend as his guest. KHAWAJA, NADER,
DEKERMENJIAN, and others invited by KHAWAJA attended this event.
rr. Following the event, on or about October 13, NADER reported to an official
from Foreign Country A's government via WhatsApp message, "Had a simply
Terrific Magnificent brainstorming and discussion with the Big Lady This
evening!"
ss. On or about October 16, NADER wrote in a WhatsApp message to
KHAWAJA, "I am leaving early morning back to join HH Have already told
him about the Wonderful Event with Our Sister and he was thrilled and want
to know all about it in person."
tt. On or about November 2, KHAWAJA wired $100,000 to Political Committee
4, falsely representing that it was a contribution from KHAWAJA, when it
was, in fact, made with monies funneled to him by NADER. This caused
Political Committee 4 to unwittingly file a false report with the FEC stating
that the contribution was from KHAWAJA, when it was not.
uu. Following the 2016 election, KHAWAJA caused Company A to contribute $1
million to the U.S. President-Elect's inaugural committee. In connection with
his contribution, KHAWAJA obtained tickets to the 2017 U.S. Presidential
inauguration in January 2017. He attended the inauguration with NADER and
DEKERMENJIAN as his guests.
All in violation of Title 18, United States Code, Section 371.
COUNT TWO
52 U.S.C. §§ 30122 and 30109(d)(1)(A)(i); 18 U.S.C. § 2
(Making Conduit Contributions and Aiding and Abetting)
31. From in or about June 2016 through in or about November 2016, in the District of

GEORGE NADER,
20
willfully made contributions in the name of another person, and willfully permitted
KHAWAJA's name to be used to effect such contributions, to Political Committee 2, Political
Committee 4, and Political Committee 5, and willfully caused the same entities to unwittingly
accept contributions made by one person in the name of another person, which aggregated
$25,000 and more in calendar year 2016.
All in violation of Title 52, United States Code, Sections 30122 and
30109(d)(1)(A)(i), and Title 18, United States Code, Section 2.
COUNT THREE
18 U.S.C. §§ 1001(a)(2) and 2
(False Statements and Aiding and Abetting)
33. On or about July 8,2016, and September 9,2016, in the District of Columbia and
elsewhere, the defendant,
GEORGE NADER,
knowingly and willfully, caused the submission of a material false, fictitious, and fraudulent
statement and representation in a matter within the jurisdiction of the executive branch of the
government of the United States, to wit, causing Political Committee 2 to unwittingly, falsely
record in a report to the Federal Election Commission dated October 15, 2016, that KHAWAJA
and his wife contributed $287,000 when the contributions actually came from someone other
than KHAWAJA and his wife.
All in violation of Title 18, United States Code, Sections 1001(a)(2) and 2.
COUNT FOUR
18 U.S.C. §§ 1519 and 2
(Causing False Records and Aiding and Abetting)
34. Paragraphs I through 29 are realleged and incorporated herein by reference.
21
35. On or about July 8,2016, and September 9, 2016, in the District of Columbia and
elsewhere, the defendant,
GEORGE NADER,
with the intent to impede, obstruct, and influence, and in relation to and contemplation of, the
investigation and proper administration of matters within the jurisdiction of departments and
agencies of the United States, knowingly concealed, covered up, falsified, and made a false entry
in a record, document, and tangible object, to wit, causing Political Committee 2 to unwittingly,
falsely record in a report to the Federal Election Commission dated October 15, 2016, that
KHAWAJA and his wife contributed $287,000 when the contributions actually came from
someone other than KHAWAJA and his wife, which falsification the defendant well knew and
contemplated was related to the proper administration of Political Committee 2's required
disclosures under the Election Act by the Federal Election Commission.
All in violation of Title 18, United States Code, Sections 1519 and 2.
COUNT FIVE
18 U.S.C. §§ 1001(a)(2) and 2
37. On or about July 8, 2016, in the District of Columbia and elsewhere, the
defendants,
AHIV1AD "ANDY" KHAWAJA, and

GEORGE NADER,
22
than KHAWAJA and his wife.
COUNT SIX
18 U.S.C. §§ 1519 and 2
defendants,

GEORGE NADER,
KHAWAJA and his wife contributed $400,800 when the contributions actually came from
someone other than KI-TAWAJA and his wife, which falsification the defendants well knew and
contemplated was related to the proper administration of Political Committee l's required
COUNT SEVEN
18 U.S.C. §§ 1001(a)(2) and 2
23
defendants,

GEORGE NADER,
record in a report to the Federal Election Commission dated September 26, 2016, that Company
A contributed $550,000 when the contribution actually came from someone other than Company
A.
COUNT EIGHT
18 U.S.C. §§ 1519 and 2
' defendants,
AH1VIAD "ANDY" KHAWAJA, and

GEORGE NADER,
falsely record in a report to the Federal Election Commission dated September 26, 2016, that
Company A contributed $550,000 when the contribution actually came from someone other than
24
Company A, which falsification the defendants well knew and contemplated was related to the
proper administration of Political Committee 3's required disclosures under the Election Act by
the Federal Election Commission.
Al! in violation of Title 18, United States Code, Sections 1519 and 2.
COUNT NINE
18 U.S.C. §§ 1001(a)(2) and 2
45. On or about September 30, 2016, in the District of Columbia and elsewhere, the
defendants,

GEORGE NADER,
goverment of the United States, to wit, causing Political Committee 4 to unwittingly, falsely
contributed $1,000,000 when the contribution actually came from someone other than
KHAWAJA.
COUNT TEN
18 U.S.C. §§ 1519 and 2
defendants,
25
GEORGE NADER,
KHAWAJA contributed $1,000,000 when the contribution actually came from someone other
than KHAWAJA, which falsification the defendants well knew and contemplated was related to
the proper administration of Political Committee 4's required disclosures under the Election Act
by the Federal Election Commission.
COUNT ELEVEN
18 U.S.C. §§ 1001(a)(2) and 2
(False Statements and Aiding and Abetting) "
49. On or about November 2, 2016, in the District of Columbia and elsewhere, the
defendants,

GEORGE NADER,
record in a report to the Federal Election Commission dated December 8, 2016, that KHAWAJA
contributed $100,000 when the contribution actually came from someone other than
KHAWAJA.
26
COUNT TWELVE
18 U.S.C. §§ 1519 and 2
defendants,

GEORGE NADER,
falsely record in a report to the Federal Election Commission dated December 8, 2016, that
KHAWAJA contributed $100,000 when the contribution actually came from someone other than
KHAWAJA, which falsification the defendants well knew and contemplated was related to the
COUNT THIRTEEN
18 U.S.C. § 371
(Conspiracy to Make Conduit Contributions, Make Excessive Contributions, Cause False
Statements, and Cause False Entries in Records)
53. From in or about March 2016 through in or about June 2018, in the District of
_ 27
AHMAD "ANDY" KHAWAJA,
ROY BOULOS,
RUDY DEKERMENJT AN,
MOHA_MMAD "MOE" DIAB,
RANI EL-SAADI,
STEVAN HILL, and
THAYNE WHIPPLE,
knowingly conspired and agreed together and with each other, and with other persons both
known and unknown to the Grand Jury, to commit offenses against the United States, that is:
a. willfully making contributions in the name of another person and permitting
one's name to be used to effect such contributions, and causing another to
accept contributions made by one person in the name of another person, which
contributions aggregated $25,000 and more in calendar years 2016, 2017, and
2018, in violation of 52 U.S.C. §§ 30109(d)(1)(A)(i) and 30122, and 18
U.S.C. § 2;
b. willfully causing a political committee to accept contributions in excess of the
limits of the Election Act, which aggregated $25,000 and more in calendar •
years 2016, 2017, and 2018, in violation of 52 U.S.C. §§ 30109(d)(1)(A)(i)
and 30116(f), and 18 U.S.C. § 2;
c. willfully causing the submission of material false, fictitious, and fraudulent
statements and representations in a matter within the jurisdiction of the
executive branch of the government of the United States, in violation of 18
U.S.C. §§ 1001(a)(2) and 2; and
d. with the intent to impede, obstruct, and influence, and in relation to and
contemplation of, the investigation and proper administration of matters
within the jurisdiction of departments and agencies of the United States,
28
knowingly causing the concealment, covering up, falsifying, and making of
false entries in records, documents, and tangible objects, in violation of 18
U.S.C. §§ 1519 and 2.
PURPOSES OF THE CONSPIRACY
54. It was a purpose of the conspiracy to facilitate unlawful campaign contributions
from KHAWAJA through the other conspirators to various political committees in order for
KHAWAJA and others to gain access to and host events featuring prominent politicians, in an
effort to gain influence with those politicians and others.
55. It was a purpose of the conspiracy to cause Political Committee 2, Political
Committee 6, Political Committee 7, and Political Committee 8 to unwittingly file false
campaign finance reports concealing these unlawful campaign contributions from the FEC and
the public by falsely stating that the contributions were made by various co-conspirators other
than KHAWAJA when in reality they were funded by KHAWAJA.
56. It was a purpose of the conspiracy to conceal the co-conspirators' unlawful
activity.
MANNER AND MEANS
57. The manner and means of the conspiracy included, but were not limited to, the
following:
a. KHAWAJA funneled more than $1.8 million to the conspirators to contribute
to political committees under their names as he directed;
b. The conspirators caused the monies funneled to them by KHAWAJA to be
contributed to various political committees under their own names;
29
c. The conspirators caused the political committees to unwittingly submit reports
to the FEC falsely stating that the contributions were made by the other
conspirators when they were actually made by KHAWAJA; and
d. The conspirators attempted to further conceal the contributions by falsely
claiming that the payments from KHAWAJA were legitimate, when in
actuality, the payments were to illegally fund KHAWAJA's political
contributions in the names of the other conspirators.
OVERT ACTS
58. In furtherance of the conspiracy, and to accomplish its purpose, the defendants,

ROY BOULOS,
RUDY DEKERMENJIAN,
MOHA1VIMAD "MOE" DIAB,
RANI EL-SAADI,
STEVAN HILL, and
THAYNE WHIPPLE,
and others known and unknown to the Grand Jury, committed, and caused to be committed, in
the District of Columbia, and elsewhere, the following overt acts:
KHAWAJA Gives His Co-Conspirators Money to Contribute to His Private Fundraiser
a. KHAWAJA arranged to host a private fundraiser for Candidate 1 in Las
Vegas, Nevada in September 2016. In order to host the event, KHAWAJA
was required to contribute or raise $500,000 for Political Committee 1 and
Political Committee 2. Due to his prior contributions and the contribution
limits, KHAWAJA was not able to contribute the full amount in his name or
his wife's name. As a result, KHAWAJA provided the other co-conspirators
30
with money to contribute to Political Committee 1 and Political Committee 2
in their names to meet the fundraising requirement for the event.
b. On or about August 1, 2016, KHAWAJA wrote a $196,000 check to DIAB.
On or about August 2, 2016, DIAB wrote a $100,000 check to Political
Committee 2 in connection with the event to be hosted by KHAWAJA. The
check falsely represented that it was a contribution from DIAB, when it was,
in fact, made with monies funneled to him by KHAWAJA for the purpose of
making the contribution and to avoid and exceed the personal contribution
limits set by federal law. This caused Political Committee 2 to unwittingly
file a false report with the FEC stating that the contribution was from DIAB,
when it was not.
c. On or about August 6, 2016, KHAWAJA wrote a $30,000 check to HILL, and
on or about August 18, 2016, KHAWAJA wrote a $75,000 check to HILL.
On or about August 28, 2016, HILL wrote a $100,000 check to Political
check falsely represented that it was a contribution from HILL, when it was,
file a false report with the FEC stating that the contribution was from HILL,
when it was not.
d. On or about August 15, 2016, KHAWAJA caused Company A to send a
$100,000 check, signed by DIAB, to Co-Conspirator A. On or about August
31
18, 2016, Co-Conspirator A wrote a $133,000 check to Political Committee 2
in connection with the event to be hosted by KHAWAJA and another political
event attended by Co-Conspirator A and KHAWAJA. The check falsely
represented that it was a contribution from Co-Conspirator A, when it was, in
fact, made with monies funneled to him by KHAWAJA for the purpose of
file a false report with the FEC stating that the contribution was from Co-
Conspirator A, when it was not. On or about August 23, 2016, KHAWAJA
wrote a $10,000 check to Co-Conspirator A.
e. On or about August 17, 2016, KHAWAJA wrote a $44,000 check to
WHIPPLE. On or about September 8, 2016, DIAB wrote a $50,000 check to
WHIPPLE at KHAWAJA's direction. On or about September 8, 2016,
WHIPPLE wrote a $100,000 check to Political Committee 2 in connection
with the event to be hosted by KHAWAJA. The check falsely represented
that it was a contribution from WHIPPLE, when it was, in fact, made with
monies funneled to him by KHAWAJA for the purpose of making the
contribution and to avoid and exceed the personal contribution limits set by
federal law. This caused Political Committee 2 to unwittingly file a false
report with the FEC stating that the contribution was from WHIPPLE, when it
was not.
f. On or about August 25, 2016, KHAWAJA caused Company A to wire
transfer $294,965 to BOULOS. On or about September 8, 2016, BOULOS
32
wrote a $300,000 check for contribution to Political Committee 2 in
connection with the event to be hosted by KHAWAJA. The check falsely
represented that it was a contribution from BOULOS, when it was, in fact,
made with monies funneled to him by KHAWAJA for the purpose of making
the contribution and to avoid and exceed the personal contribution limits set
by federal law. This caused Political Committee 2 to unwittingly file a false
report with the FEC stating that the contribution was from BOULOS, when it
was not.
g. On or about September 9, 2016, KHAWAJA caused Company A to wire
transfer $148,965 to EL-SAADI's company. On or about the same date, EL-
SAADI transferred $150,000 from his company's account to his personal
account, and wrote a check for $150,000 to Political Committee 2 in
connection with the event to be hosted by KHAWAJA. The check falsely
represented that it was a contribution from El-SAADI, when it was, in fact,
made with monies funneled to him by KHAWAJA for the purpose of making
the contribution and to avoid and exceed the personal contribution limits set
by federal law. This caused Political Committee 2 to unwittingly file a false
report with the FEC stating that the contribution was from EL-SAADI, when
it was not.
h. On or about September 9, 2016, KHAWAJA wrote a $185,000 check to
DIAB. On or about the same date, DIAB wrote a $100,000 check to Political
check falsely represented that it was a contribution from DIAB, when it was,
33
file a false report with the FEC stating that the contribution was from DIAB,
when it was not.
i. On or about September 9, 2016, KHAWAJA wrote a $130,000 check to
Political Committee 2 in connection with the event he was hosting. The
memorandum line of the check stated, "Vegas."
j. On or about October 2, 2016, KHAWAJA wrote a $165,000 check to DIAB.
On or about October 7, 2016, DIAB wrote a $50,000 check to
DEKERMENJIAN at KHAWAJA's direction (and had previously written a
$50,000 check to WHIPPLE at KHAWAJA's direction). On or about October
13, 2016, DEKERMENJIAN wrote a $50,000 check for contribution to
Political Committee 2 in connection with the event to be hosted by
KHAWAJA. The check falsely represented that it was a contribution from
DEKERMENJIAN, when it was, in fact, made with monies funneled to him
by KHAWAJA for the purpose of making the contribution and to avoid and
exceed the personal contribution limits set by federal law. This caused
that the contribution was from DEKERMENJIAN, when it was not.
k. On or about October 12, 2016, KHAWAJA hosted an event for Candidate 1 in
Las Vegas, Nevada, which was rescheduled from its original September 14
date. BOULOS, DEKERMENJIAN, DIAB, El-SAADI, HILL, NADER, and
34
WHIPPLE attended the event along with KHAWAJA. Co-Conspirator A did
not attend the event.
KHAWAJA Gives HILL, WHIPPLE, DIAB, and BOULOS Money to Contribute
1. In or about March 2017, KHAWAJA caused the contribution of $250,000 to
Political Committee 6 on behalf of himself and his wife.
m. On or about June 16, 2017, HILL wrote a $50,000 check to Political
Committee 6, which posted on June 21, 2017. The check falsely represented
that it was a contribution from HILL, when it was, in fact, made with monies
funneled to him by KHAWAJA for the purpose of making the contribution
and to avoid and exceed the personal contribution limits set by federal law.
FEC stating that the contribution was from HILL, when it was not. On or
about June 19, 2017, KHAWAJA wrote a $60,000 check to HILL.
n. On or about September 14, 2017, WHIPPLE wrote a $100,000 check to
Political Committee 6. The check falsely represented that it was a
contribution from WHIPPLE and his wife, when it was, in fact, made with
monies to be funneled to him by KHAWAJA for the purpose of making the
report with the FEC stating that the contribution was from WHIPPLE and his
wife, when it was not. On or about October 13, 2017, KHAWAJA caused a
company he controlled to write a $100,000 check to WHIPPLE.
35
o. On or about November 29, 2017, KHAWAJA caused a company he
controlled to write a $214,000 check to a company controlled by DIAB. On
or about the same date, DIAB wrote a $100,000 check to Political Committee
6. The check falsely represented that it was a contribution from DIAB, when
it was, in fact, made with monies funneled to him by KHAWAJA for the
purpose of making the contribution and to avoid and exceed the personal
contribution limits set by federal law. This caused Political Committee 6 to
from DIAB, when it was not.
p. On or about March 5, 2018, KHAWAJA caused Company A to wire transfer
$275,000 to BOULOS. On or about the same date, BOULOS wrote a
$250,000 check to Political Committee 6. The check falsely represented that
it was a contribution from BOULOS, when it was, in fact, made with monies
funneled to him by KHAWAJA for the purpose of making the contribution.
FEC stating that the contribution was from BOULOS, when it was not.
KHAWAJA Gives HILL and DEKERMENJIAN Money to Contribute for His

Private Fundraising Dinner
q. On or about January 19, 2018, KHAWAJA wrote a $50,000 check to HILL.
On or about January 28, 2018, HILL wrote a $50,000 check to Political
Committee 7 in connection with an event hosted by KHAWAJA at his home
for Elected Official 1 on or about March 11, 2018. The check falsely
represented that it was a contribution from HILL, when it was, in fact, made
with monies funneled to him by KHAWAJA for the purpose of making the
36
report with the FEC stating that the contribution was from HILL, when it was
not.
r. On or about January 19, 2018, KHAWAJA wrote a $45,000 check to
DEKERMEJIAN. On or about January 30, 2018, DEKERMENHAN wrote a
$50,000 check to Political Committee 7 in connection with an event hosted by
KHAWAJA at his home for Elected Official 1 on or about March 11, 2018.
The check falsely represented that it was a contribution from
DEKERMENJIAN, when it was, in fact, made with monies funneled to him
by KHAWAJA for the purpose of making the contribution and to avoid and
exceed the personal contribution limits set by federal law. This caused
that the contribution was from DEKERMENJIAN, when it was not.
s. On or about March 10, 2018, KHAWAJA wrote a $237,000 check to Political
Committee 7 in connection with an event hosted by KHAWAJA at his home
for Elected Official 1 on or about March 11, 2018.
KHAWAJA Gives DIAB Money to Contribute for Another Political Event
t. On or about June 20, 2018, KHAWAJA caused a company he controlled to
write a $225,000 check to a company controlled by DIAB. On or about June
25, 2018, DIAB wrote a $225,000 check to Political Committee 8 in
connection with an event featuring Elected Official 2 on or about June 18,
2018. The check falsely represented that it was a contribution from DIAB,
37
when it was, in fact, made with monies funneled to him by KHAWAJA for
the purpose of making the contribution. This caused Political Committee 8 to
from DIAB, when it was not. As a result of the contribution, KHAWAJA was
invited to the aforementioned event. Although he did not attend the event
itself, he did attend a private meeting with Elected Official 2 on the very same
date.
COUNT FOURTEEN
52 U.S.C. §§ 30116(1) and 30109(d)(1)(A)(i); 18 U.S.C. § 2
(Causing Excessive Contributions and Aiding and Abetting)
59. Paragraphs 1 through 29 and 52 through 58 are realleged and incorporated herein
by reference.
'60. From in or about August 2016 through in or about November 2016, in the District
of Columbia and elsewhere, the defendant,
willfully caused Political Committee 2 and Political Committee 5 to unwittingly accept
contributions in excess of the limits of the Election Act, which aggregated $25,000 and more in
calendar year 2016.
All in violation of Title 52, United States Code, Sections 30116(0 and
38
COUNT FIFTEEN
52 U.S.C. §§ 30122 and 30109(d)(1)(A)(i); 18 U.S.C. § 2
by reference.
62. From in or about August 2016 through in or about November 2016, in the District
ROY BOULOS,
willfully permitted his name to be used to effect contributions of another to Political Committee
2 and Political Committee 5, and willfully caused the same entities to unwittingly accept
contributions made by one person in the name of another person, which aggregated $25,000 and
more in calendar year 2016.
COUNT SIXTEEN
52 U.S.C. §§ 30122 and 30109(d)(1)(A)(i); 18 U.S.C. § 2
63. Paragraphs I through 29 and 52 through 58 are realleged and incorporated herein
by reference.
RUDY DEK_ER1VIENJIAN,
39
COUNT SEVENTEEN
52 U.S.C. §§ 30122 and 30109(d)(1)(A)(i); 18 U.S.C. § 2
by reference.
MOHAMMAD "MOE" DIAB,
COUNT EIGHTEEN
52 U.S.C. §§ 30122 and 30109(d)(1)(A)(i); 18 U.S.C. § 2
by reference.
40
RANI EL-SAADI,
Al! in violation of Title 52, United States Code, Sections 30122 and
COUNT NINETEEN
52 U.S.C. §§ 30122 and 30109(d)(1)(A)(i); 18 U.S.C. § 2
by reference.
STEVAN HILL,
41
COUNT TWENTY
52 U.S.C. §§ 30122 and 30109(d)(1)(A)(i); 18 U.S.C. § 2
by reference.
THAYNE WHIPPLE,
COUNT TWENTY-ONE
18 U.S.C. §§ 1001(a)(2) and 2
by reference.
74. On or about July 8, 2016, August 2, 2016, August 23, 2016, and September 9,
2016, in the District of Columbia and elsewhere, the defendant,
42
record in a report to the Federal Election Commission dated October 15, 2016, that KHAWAJA,
his wife, DIAB, EL-SAADI, Co-Conspirator A, HILL, and WHIPPLE contributed $970,000
when the contributions actually came from someone other than the reported contributors.
COUNT TWENTY-TWO
18 U.S.C. §§ 1519 and 2
by reference.
76. On or about July 8, 2016, August 2, 2016, August 23, 2016, and September 9,
2016, in the District of Columbia and elsewhere, the defendant,
KHAWAJA, his wife, DIAB, EL-SAADI, Co-Conspirator A, HILL, and WHIPPLE contributed
$970,000 when the contributions actually came from someone other than the reported
contributors, which falsification the defendant well knew and contemplated was related to the
43
COUNT TWENTY-THREE
18 U.S.C. §§ 1001(a)(2) and 2
by reference.
78. On or about October 5, 2016, and October 13, 2016, in the District of Columbia
and elsewhere, the defendant,
record in a report to the Federal Election Commission dated October 27, 2016, that BQULOS
and DEKERMENJIAN contributed $350,000 when the contributions actually came from
someone other than BOULOS and DEKERMENJIAN.
COUNT TWENTY-FOUR
18 U.S.C. §§ 1519 and 2
by reference.
80. On or about October 5, 2016, and October 13, 2016, in the District of Columbia
and elsewhere, the defendant,
AH1VIAD "ANDY" KHAWAJA,
44
BOULOS and DEKERMENJIAN contributed $350,000 when the contributions actually came
from someone other than BOULOS and DEKERMENJIAN, which falsification the defendant
well knew and contemplated was related to the proper administration of Political Committee 2's
required disclosures under the Election Act by the Federal Election Commission.
COUNT TWENTY-FIVE
52 U.S.C. §§ 30122 and 30109(d)(1)(A)(i); 18 U.S.C. § 2
by reference.
Columbia and elsewhere, the defendant,
willfully made contributions in the name of another person to Political Committee 6, and
willfully caused the same entity to unwittingly accept contributions made by one person in the
name of another person, which aggregated $25,000 and more in calendar year 2017.
45
COUNT TWENTY-SIX
52 U.S.C. §§ 30116(f) and 30109(d)(1)(A)(i); 18 U.S.C. § 2
by reference.
willfully caused Political Committee 6 to unwittingly accept contributions in excess of the limits
of the Election Act, which aggregated $25,000 and more in calendar year 2017.
All in violation of Title 52, United States Code, Sections 30116(f) and
COUNT TWENTY-SEVEN
52 U.S.C. §§ 30122 and 30109(d)(1)(A)(i); 18 U.S.C. § 2
by reference.
86. In or about June 2017, in the District of Columbia and elsewhere, the defendant,
STEVAN HILL,
in
6, and willfully caused the same entity to unwittingly accept contributions made by one person
the name of another person, which aggregated $25,000 and more in calendar year 2017.
46
COUNT TWENTY-EIGH1
18 U.S.C. §§ 1001(a)(2) and 2
by reference.
88. On or about June 21, 2017, in the District of Columbia and elsewhere, the
defendant,
record in a report to the Federal Election Commission dated July 20, 2017, that HILL contributed
$50,000 when the contribution actually came from someone other than HILL.
COUNT TWENTY-NINE
18 U.S.C. §§ 1519 and 2
by reference.
defendant,
47
falsely record in a report to the Federal Election Commission dated July 20, 2017, that HILL
contributed $50,000 when the contribution actually came from someone other than HILL, which
falsification the defendant well knew and contemplated was related to the proper administration
of Political Committee 6's required disclosures under the Election Act by the Federal Election
Commission.
COUNT THIRTY
52 U.S.C. §§ 30122 and 30109(d)(1)(A)(i); 18 U.S.C. § 2
by reference.
92. In or about September 2017, in the District of Columbia and elsewhere, the
defendant,
THAYNE WHIPPLE,
6, and willfully caused the same entity to unwittingly accept contributions made by one person in
COUNT THIRTY-ONE
18 U.S.C. §§ 1001(a)(2) and 2
by reference.
48
defendant,
statement and representation in a matter within the jurisdiction-of the executive branch of the
record in a report to the Federal Election Commission dated October 20, 2017, that WHIPPLE
than WHIPPLE and his wife.
COUNT THIRTY-TWO
18 U.S.C. §§ 1519 and 2
by reference.
defendant,
WHIPPLE and his wife contributed $100,000 when the contributions actually came from
49
someone other than WHIPPLE and his wife, which falsification the defendant well knew and
contemplated was related to the proper administration of Political Committee 6's required
COUNT THIRTY-THREE
52 U.S.C. §§ 30122 and 30109(d)(1)(A)(i); 18 U.S.C. § 2
by reference.
98. In or about November 2017, in the District of Columbia and elsewhere, the
defendant,
MOHAMMAD "MOE" DIAB,
COUNT THIRTY-FOUR
18 U.S.C. §§ 1001(a)(2) and 2
by reference.
defendant,
50
record in a report to the Federal Election Commission dated December 20, 2017, that DIAB
contributed $100,000 when the contribution actually came from someone other than DIAB.
COUNT THIRTY-FIVE
18 U.S.C. §§ 1519 and 2
(Causing False Records and Aiding and Abetting) _
by reference.
defendant,
falsely record in a report to the Federal Election Commission dated December 20, 2017, that
DIAB contributed $100,000 when the contribution actually came from someone other than
DIAB, which falsification the defendant well knew and contemplated was related to the proper
administration of Political Committee 6's required disclosures under the Election Act by the
51
COUNT THIRTY-SIX
52 U.S.C. §§ 30122 and 30109(d)(1)(A)(i); 18 U.S.C. § 2
by reference.
104. From in or about January 2018 through in or about March 2018, in the District of
willfully made contributions in the name of another person to Political Committee 6 and Political
Committee 7, and willfully caused the same entities to unwittingly accept contributions made by
one person in the name of another person, which aggregated $25,000 and more in calendar year
2018.
COUNT THIRTY-SEVEN
52 U.S.C. §§ 30116(f) and 30109(d)(1)(A)(i); 18 U.S.C. § 2
by reference.
willfully caused Political Committee 7 to unwittingly accept contributions in excess of the limits
of the Election Act, which aggregated $25,000 and more in calendar year 2018.
52
All in violation of Title 52, United States Code, Sections 30116(f) and
COUNT THIRTY-EIGHT
52 U.S.C. §§ 30122 and 30109(d)(1)(A)(i); 18 U.S.C. § 2
by reference.
108. In or about March 2018, in the District of Columbia and elsewhere, the defendant,
ROY BOULOS,
COUNT THIRTY-NINE
18 U.S.C. §§ 1001(a)(2) and 2
by reference.
110. On or about March 15, 2018, in the District of Columbia and elsewhere, the
defendant,
53
record in a report to the Federal Election Commission dated April 20, 2018, that BOULOS
contributed $250,000 when the contribution actually came from someone other than BOULOS.
COUNT FORTY
18 U.S.C. §§ 1519 and 2
by reference.
defendant,
falsely record in a report to the Federal Election Commission dated April 20, 2018, that
BOULOS contributed $250,000 when the contribution actually came from someone other than
BOULOS, which falsification the defendant well knew and contemplated was related to the
54
COUNT FORTY-ONE
52 U.S.C. §§ 30122 and 30109(d)(1)(A)(i); 18 U.S.C. § 2
by reference.
STEVAN HILL,
COUNT FORTY-TWO
18 U.S.C. §§ 1001(a)(2) and 2
by reference.
defendant,
55
record in a report to the Federal Election Commission dated April 20, 2018, that HILL
contributed $50,000 when the contribution actually came from someone other than HILL.
COUNT FORTY-THREE
18 U.S.C. §§ 1519 and 2
by reference.
defendant,
falsely record in a report to the Federal Election Commission dated April 20, 2018, that HILL
contributed $50,000 when the contribution actually came from someone other than HILL, which
falsification the defendant well knew and contemplated was related to the proper administration
of Political Committee 7's required disclosures under the Election Act by the Federal Election
Commission.
56
COUNT FORTY-FOUR
52 U.S.C. §§ 30122 and 30109(d)(1)(A)(i); 18 U.S.C. § 2
by reference.
RUDY DEKERMENJIAN,
COUNT FORTY-FIVE
18 U.S.C. §§ 1001(a)(2) and 2
by reference.
defendant,
record in a report to the Federal Election Commission dated April 20, 2018, that
57
DEKERMENJIAN contributed $50,000 when the contribution actually came from someone
other than DEKERMENJIAN.
COUNT FORTY-SIX
18 U.S.C. §§ 1519 and 2
by reference.
defendant,
AHIVIAD "ANDY" KHAWAJA,
falsely record in a report to the Federal Election Commission dated April 20, 2018, that
DEKERMENJIAN contributed $50,000 when the contribution actually came from someone
other than DEKERMENJIAN, which falsification the defendant well knew and contemplated
was related to the proper administration of Political Committee 7's required disclosures under
the Election Act by the Federal Election Commission.
58
COUNT FORTY-SEVEN
18 U.S.C. §§ 1001(a)(2) and 2
by reference.
defendant,
record in a report to the Federal Election Commission dated July 13, 2018, that DIAB
contributed $225,000 when the contribution actually came from someone other than DIAB.
COUNT FORTY-EIGHT
18 U.S.C. §§ 1519 and 2
by reference.
defendant,
59
falsely record in a report to the Federal Election Commission dated July 13, 2018, that DIAB
contributed $225,000 when the contribution actually came from someone other than DIAB,
which falsification the defendant well knew and contemplated was related to the proper
administration of Political Committee 8's required disclosures under the Election Act by the
COUNT FORTY-NINE
18 U.S.C. § 1503
(Obstruction)
by reference.
defendant,
ROY BOULOS,
corruptly influenced, obstructed, and impeded, and endeavored to influence, obstruct, and
impede, the due administration of justice, to wit, a federal grand jury investigation pending in the
District of Columbia. With knowledge that his statements would be transmitted to the grand jury
in the District of Columbia, BOULOS falsely told FBI Agents that he requested money from
KHAWAJA so that he could make a contribution to Political Committee 2; and that KHAWAJA
never asked or directed him to make the contribution.
60
COUNT FIFTY
18 U.S.C. § 1503
(Obstruction)
by reference.
defendant,
MOHA1VIMAD "MOE" DIAB,
in the District of Columbia, DIAB falsely told FBI Agents that KHAWAJA did not give him
money in order to make political contributions; that DIAB's political contributions were all made
with his own money; and that all of the checks DIAB received from KHAWAJA in 2016 were
for DIAI3's salary and bonuses from work at Company A, not reimbursement for political
contributions.
COUNT FIFTY-ONE
18 U.S.C. § 1503
(Obstruction)
by reference.
defendant,
STEVAN HILL,
61
in the District of Columbia, HILL falsely told FBI Agents that nobody gave him the money he
contributed to the Political Committee 2 in 2016; that the money he received from KHAWAJA
in 2016 had nothing to do with the $100,000 HILL contributed to Political Committee 2; and that
any checks he received from KHAWAJA were investments in HILL's business, bonuses, or
reimbursement for invoices HILL had to pay in connection with a joint venture he had with
KHAWAJA.
COUNT FIFTY-TWO
18 U.S.C. § 1503
(Obstruction)
by reference.
defendant,
THAYNE VVHIPPLE,
in the District of Columbia, WHIPPLE falsely told FBI Agents that WHIPPLE's political
contributions were made with his own money; that any checks he received from KHAWAJA in
62
2016 were in connection with work WHIPPLE performed for Company A; and that WHIPPLE
was not reimbursed for the political contribution he made to Political Committee 2.
COUNT FIFTY-THREE
18 U.S.C. § 1503
(Obstruction)
by reference.
138. Between on or about June 26, 2019, and on or about July 18, 2019, in the District
District of Columbia. With knowledge that Individual 2 was testifying before the federal grand
jury in the District of Columbia regarding matters contained in this Indictment, KHAWAJA
provided Individual 2 with a false factual narrative, including that Company A had a user
guide—that predated the "NextGen User Guide"—for its legacy software; that the NextGen User
Guide was constantly being revised; that the NextGen User Guide was a blueprint to Company
A's software, which would enable a developer to steal Company A's software; and that NADER
had stolen Company A's software. When KHAWAJA provided these false facts to Individual 2,
63
KHAWAJA knew then and there that the statements were false. KHAWAJA also directed
Individual 2 to be careful what he said.
A RUE BILL.
Dated:
GRAND JURY FOREPERSON
SON
Integrity Section
By:
John'b. Keller
Deputy Chief
James C Mann
Trial Attorney
Public Integrity Section
Criminal Division
U.S. Department of Justice
64

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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

Holding a Criminal Term

AHMAD "ANDY" KHAWAJA, •

Counts 4, 6, 8, 10, 12, 22, 24, 29, 32, 35, 40,

Counts 14, 26, and 37: 52 U.S.C. §§ 30116

Counts 49-53: 18 U.S.C. § 1503

The Grand Jury charges that:

1. At all times relevant to this indictment:

2. Defendant Ahmad "Andy" KHAWAJA was a resident of Los Angeles, California,

West Hollywood, California ("Company A").

East, including Foreign Country A.

a liquor, wine, and cigar store in the Las Vegas-area.

5. Defendant Rudy DEKERMENJIAN was a resident of Glendale, California, an

attorney in the Los Angeles-area, and an attorney for Company A.

6. Defendant Mohammad "Moe" DIAB was a resident of Glendale, California, the

cousin of KHAWAJA, and the Chief Operating Officer of Company A.

Los Angeles, California.

8. Defendant Stevan HILL was a resident of Santa Monica, California, and an

associate of KHAWAJA, who became a Managing Director at Company A in or about 2017.

9. Defendant Thayne WHIPPLE was a resident of Ojai, California, and was an

outside contractor for Company A.

the 2016 election.

12. Elected Official 1 was an elected, federal official.

13. Elected Official 2 was an elected, federal official.

15. Political Committee 4 was a super-political action committee or - super PAC"

registered with the Federal Election Commission.

subject to specified contribution limits, limiting the allowable contributions by individuals in

subject to specified contribution limits, limiting the allowable contributions by individuals in

contributions by individuals in 2018.

Federal Election Commission.

contributed to a federal candidate or that candidate's authorized campaign

committee and political committees established and maintained by a national

b. The Election Act expressly states that contributions made through an

intermediary are treated as contributions from the original payor.

activity related to contributions, expenditures, debts, and loans of the committee.

22. Paragraphs 1 through 21 are realleged and incorporated herein by reference.

Columbia and elsewhere, the defendants,

AHMAD "ANDY" KHAWAJA, and

a. willfully making contributions in the name of another person and permitting

one's name to be used to effect such contributions, and causing another to

contributions aggregated $25,000 and more in calendar year 2016, in violation

of 52 U.S.C. §§ 30109(d)(1)(A)(i) and 30122, and 18 U.S.C. § 2;

b. willfully causing the submission of material false, fictitious, and fraudulent

statements and representations in a matter within the jurisdiction of the

executive branch of the government of the United States, in violation of 18

U.S.C. §§ 1001(a)(2) and 2; and

contemplation of, the investigation and proper administration of matters

within the jurisdiction of departments and agencies of the United States,

knowingly causing the concealment, covering up, falsifying, and making of

false entries in records, documents, and tangible objects, in violation of 18

U.S.C. §§ 1519 and 2.

PURPOSES OF THE CONSPIRACY

24. It was a purpose of the conspiracy to facilitate unlawful campaign contributions

from NADER, through KHAWAJA, to political committees, including Political Committee 1,

following the 2016 U.S. Presidential election.

26. It was a purpose of the conspiracy to cause Political Committee 1, Political

Committee 2, Political Committee 3, and Political Committee 4 to unwittingly file false

when in reality they were funded by NADER.