v. 24 Cr.

ec aps, 24 CRIM 556

Defendant.

orien
1 In 2014, ERIC ADAMS, the defendant, became Brooklyn Borough President.
“Thereafter, for nearly a decade, ADAMS sought and accepted improper valuable benefits, such as
luxury international travel, including from wealthy foreign businesspeople and at least one Turkish
goverment official seeking to gain influence over him. By 2018, ADAMS—who had by then
‘made known his plans to run for Mayor
of New York City—not only accepted, but sought illegal
campaign contributions to his 2021 mayoral campaign, as well as other things of value, from

‘sought to cash in on their corrupt relationships with him, particularly when, in 2021, it became
clear that ADAMS would become New York City’s mayor. ADAMS agreed, providing favorable

York City, ADAMS soon began preparing for his next election, including by planning to solicit
‘more illegal contributions and granting requests from those who supported his 2021 mayoral
‘campaign with such donations.

2. ERIC ADAMS, the defendant, sought and accepted illegal campaign contributions

their money through nominal donors, who falsely certified they were contributing their own
money. By smuggling their contributions to ADAMS through U.S. based straw donors,
ADAMS’s overseas contributors defeated federal laws that serve to prevent foreign influence on
US. elections. Wealthy individuals evaded laws designed to limit their power over elected
officials by restricting the amount any one person can donate to a candidate. And businesses
circumvented New York City’s ban on corporate contributions by funneling their donations
through multiple employees, frustrating a law that secks to reduce corporate power in politics
ADAMS increased his fundraising by accepting these concealed, illegal donations —at the cost of
giving his secret patrons the undue influence over him that the law tries to preven.
3. BRIC ADAMS, the defendant, compounded his gains from the straw contributions
by using them to defraud New York City and steal public funds. New York City has a matching
funds program that matches small-dollar contributions from individual City residents with up to
eight times their amount in public funds, to give New Yorkers a greater voice in clections.
ADAMS's campaigns applied for matching funds based on known straw donations, fraudulently
obtaining as much as $2,000 in public funds for cach illegal contribution. ADAMS and those
working athisdirection falsely certified compliance with applicable campaign finance regulations
despite ADAMS’s repeated acceptance ofstrawdonations, relying on the concealed nature ofthese
illegal contributions to falsely portray his campaigns as law-abiding. As a result of those false
certifications, ADAMS"s 2021 mayoral campaign received more than $10,000,000 in public funds.
4. ERIC ADAMS, the defendant, also sought and received other improper benefits
from some of the same co-conspirators who funneled straw donations to his campaigns. In
particular,a senior official in the Turkish diplomatic establishment (the “Turkish Official”), who
facilitated many straw donations to ADAMS, also arranged for ADAMS and his companions to
receive freeo discounted travel on Turkey's national airline (the “Turkish Airline”), which is

2
owned in significant part by the Turkish government, to destinations including France, China, Sri
Lanka, India, Hungary, and Turkey itself. The Turkish Official and other Turkish nationals further
amanged for ADAMS and his companions to receive, among other things, free rooms at opulent
hotels, free meals at high-end restaurants, and free luxurious entertainment while in Turkey.
5. ERIC ADAMS, the defendant, and others working at his direction, repeatedly took
steps to shield his solicitation and acceptanceof these benefits from public scrutiny. ADAMS did
not disclose the travel benefits he had obtained in annual financial disclosures he was required to
file asa New York City employee. Sometimes, ADAMS agreed topay a nominal fee tocreatethe
appearance of having paid for travel that was in fact heavily discounted. Other times, ADAMS
created and instructed others to create fake paper trails, falsely suggesting that he had paid, or
planned to pay, for travel benefits that were actually free. And ADAMS deleted messages with
others involved in his misconduct, including, in one instance, assuring a co-conspirator in writing
that he “always” deleted her messages.
6. In September 2021, the Turkish Official told ERIC ADAMS, the defendant, that it
was his turn to repay the Turkish Official, by pressuring the New York City Fire Department
(“FDNY”) to facilitate the opening ofa new Turkish consularbuilding—a 36-story skyseraper—
without a fire inspection, in time for a high-profile visi by Turkey's president. At the time, the
building would have failed an FDNY inspection. In exchange for free travel and other travel-
related bribes in 2021 and 2022 arranged by the Turkish Official, ADAMS did as instructed.
Because of ADAMS’ pressure on the FDNY, the FDNY official responsible for the FDNY's
assessment of the skyscraper’s fire safety was told that he would lose his job if he failed to
acquiesce, and, after ADAMS intervened, the skyscraper opened as requested by the Turkish
Official.

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 New York City's Public Matching Funds Program
7. The New York City Campaign Finance Board (“CFB”) oversees and administers a
publicly funded campaign finance system for municipal elections in New York City, including a
matching funds program (the “Matching Funds Program”) that provides eligible candidates with
public funds to match small-dollar contributions from New York City residents (“Matching
Funds”). The Matching Funds Program is intended to incentivize candidates to finance their
‘campaigns by engaging with average New Yorkers, instead of secking large contributions from a
limited number of influential donors, and to empower more candidates to run for office, even
without access to wealth. For mayoral candidates in the 2021 and 2025 election cycles, the
Matching Funds Program operated, as relevant here, in the following manner:
a. Candidates that collected a minimum number of contributions and raised a
minimum amount of qualifying contributions from New York City residents were eligible to opt
into the Matching Funds Program.
b. Candidates that opted into the Matching Funds Program were required to
file a signed and notarized certification attesting, among other things, that they understood that
they were responsible for reading, understanding, and complying with, and ensuring their
campaigns’ compliance with, various statutes and rules; that submitting fraudulent claims for
Matching Funds or otherwise fumishing false information to the CFB would constitute a
fundamental breachofthe obligations affirmed as partof the certification; and that, in the event of
such a breach, they would be ineligible to receive additional Matching Funds and would be
required to return all Matching Funds previously received.
©. The Matching Funds Program would provide up to $8 in Matching Funds
for cach $1ofeligible contributions up to $250 from New York City residents. In other words,

4
for cach eligible contributionofat least $250,a participating candidate could collect up to $2,000
in Matching Funds. The Matching Funds Program would provide up to $12,952,888 in Matching
Funds for qualifying mayoral candidates during the primary and general elections in the 2021
election cycle, and upto $14,101,334 in Matching Funds for qualifying mayoral candidates during
the primary and general elections in the 2025 election cycle.
d. Certain kindsofcontributions were prohibited entirely, including (i) straw.
contributions; (ii) contributions from a person who was not a United States citizen or a lawful
permanent resident ofthe United States; (ii) contributions from foreign entities and organizations;
(iv) contributions from corporations; and (v) contributions that were made, received, solicited, or
otherwise obtained in violationofany local, state, or federal law.
e. Through its Campaign Finance Handbook, the CFS informed candidates
and their campaignstaff that straw contributions were not only prohibited, but also illegal.
f. Candidates that opted into the Matching Funds Program were required to
regularly submit to the CFB disclosure statements that, among other things, identified all
contributions received during a particular reporting period, regardless of whether those
contributions were eligible for matching funds. These disclosure statements were required to be
submited electronically by either the candidate or thecampaign'streasurer using a unique login.
In order to submit a disclosure statement, the filer was required to (i) identify him or herself as
either the candidate or the treasurer and (ii) electronically sign a verification stating, “This
disclosure statementi true and correct to the bestofmy knowledge, information andbeliefand |
understand that by clicking *Verify® below [am electronically signing my disclosure statement,
which shall have the same validity and effect as a signature affixed by hand.”

5
 8. ERIC ADAMS, the defendant, was aware that the law prohibited foreign, conduit,
and corporate contributions. At least a carly as 2018, ADAMS, began raising money to fund his
first mayoral campaign (the “2021 Campaign”). In September 2019, ADAMS submitted the
required certification to opt into the Matching Funds Program. During the 2021 election cycle,
ADAMS and persons acting at his direction regularly submitted and signed disclosure statements
attesting (0 the veracityofthe information being provided to the CFB. ADAMS won his party's
primary election in July 2021, and was elected Mayor in November 2021. Whileserving as Mayor,
ADAMS again opted into the Matching Funds Program and began fundraising for his 2025
reelection campaign (the “2025 Campaign,” and together with the 2021 Campaign, the “Adams
Campaigns”), continuing at least to the dateofthis Indictment.
ADAMS Travels to Turkey and Begins Accepting legal Campaign Contributions and
Personal Benefits
9. Within a year of becoming Brooklyn Borough President, ERIC ADAMS, the
defendant, began building relationships with foreign nationals who were secking influence with
him. In the years that followed, ADAMS solicited and knowingly accepted illegal campaign
contributions and improper personal benefits from those foreign nationals.
In 2015, ADAMS travels to Turkey andestablishes corrupt relationships
10. In2015, ERIC ADAMS, the defendant, took two official trips to Turkey. His first
trip, in August 2015, was arranged by the Turkish Consulate General in New York City (the
“Turkish Consulate”) and paid for in part by the Turkish Consulate and in part by a for-profit
educational conglomerate based in Istanbul (the “Turkish University”). The second trip, in
December 2015, was arrangedby the Turkish Official and aTurkish entrepreneur (the Promoter”)
‘whose business includes organizing events to introduce Turkish corporations and businesspeople
to politicians, celebrities, and others whose influence may benefit the corporations and
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businesspeople. For both tips, ADAMS received free business class tickets on the Turkish
Airline. Unlike ADAMS's subsequent travel with the Turkish Airline, ADAMS reported his 2015
travel to Turkey on financial disclosure forms filed with the New York City Conflict of Interest
Board (the “COIB”), as he was required todoannually at all times relevant to this Indictment.
1. The 2015 travel to Turkey by ERIC ADAMS, the defendant, involved several
people relevant to events described in this Indictment, including:
a. The Turkish Official, who helped arrange ADAMS’s travel to and within
Turkey in 2015, and who later steered illegal contributions and improper gifts to ADAMS to gain
influence with and, eventually, to obtain corrupt official action from ADAMS.
b. The Promoter, who arranged straw contributions to both of the Adams
Campaigns and favorable treatment in Turkey for ADAMS in 2017 and 2019, hoping to leverage
ADAMS’s considerable fame in Turkey to benefit the Promoters clients.
©. Theowner and chairmanofthe Turkish University (“Businessman-1"), who
met with ADAMS in Istanbul in 2015 and again in Brooklyn, New York in 2018. Businessman-1,
‘who was considering a business venture in Brooklyn, and also sought to enhance his own status
by befriending ADAMS, later made illegal contributions to the 2021 Campaign.
dA volunteer at Brooklyn Borough Hall (the “Adams Staffer”), who then
served as ADAMS’ “Liaison to Easter Europe Muslim Countries,” including Turkey. The
Adams Staffer subsequently became a paid member ofADAMS’sstaff at Borough Hall and, later,
City Hall. The Adams Staffer accompanied ADAMS on his 2015 travel to Turkey, and later, at
ADAMS’s direction, coordinated many of the illegal campaign contributions and improper
personal travel benefits relevant to this Indictment,

7
 e. Awealthy Turkish businesswoman (the “Businesswoman®), who later gave
ADAMS multiple free or steeply discounted stays in a luxury hotel she owned, and organized
contributions to the 2021 Campaign.
In 2016, ADAMS secretly begins acceptingfree lxury travel
12. After ERIC ADAMS, the defendant, first traveled to Turkey in 2015, the Turkish
Official introduced ADAMS to the Turkish Airline’s general manager in the New York City arca
(the “Airline Manager”). In 2016 and twice in 2017, ADAMS solicited and accepted free and
heavily discounted luxury air travel from the Turkish Airline, as part of the Turkish Official’s
efforts to gain influence over ADAMS, on three separate trips:
a. In October 2016, ADAMS and his domestic partner (“Adams's Partner”)
traveled to India. Adams's Partner purchased economy class tickets forherself and ADAMS on
the Turkish Airline for approximately $2,286. Two days before their flight was scheduled to
depart, ADAMS accepted upgrades forhimselfand his partner by the Turkish Airline to business
class at no cost. Business class i the highest class offered by the Turkish Airline. Had ADAMS
and his partner purchased their business class tickets, the tickets would have cost approximately
$15,000 total.
bh. InJulyand August 2017, ADAMS, aclose relative ofADAMS (the “Adams
Relative”), and a member of ADAMS’staffwho has served as ADAMS’s liaison to the Asian-
American communities in New York City (the “Adams Liaison”) traveled to Nice, France;
Istanbul, Turkey; Columbo, Sr Lanka; and Beijing, China. ADAMS accepted free business class
tickets from the Turkish Airline, worth more than $35,000 total, for himself and his companions.
© InOctober 2017, ADAMS and the Adams Liaison traveled to Nepal through
Istanbul and Beijing. ADAMS accepted fice business class tickets from the Turkish Airline for

8
himself and the Adams Liaison forthe flights from New York to Istanbul and Istanbul 0 Beijing,
and for the corresponding retum flights, worth more then $16,000 total.
13. Because the Turkish Airline provided free travel benefits worth tensof thousands
of dollars to ERIC ADAMS, the defendant, he flew the Turkish Airline cven when doing so was
otherwise inconvenient. For example, during the July and August 2017 trip, Adams's Partner was
surprised to learn that ADAMS was in Turkey when she had understood him to be flying from
New York to France. ADAMS responded, in a text message, “Transferring here. You know first
stop is always instanbul [sic].” When Adams's Partner later inquired about planning a trip to
Easter Island, Chile, ADAMS repeatedly asked her whether the Turkish Airline could be used for
their flights, requiring her 10 call the Turkish Airline to confirm that they did not have routes
between New York and Chile.
14. ERIC ADAMS, the defendant, also accepted valuable travel and hospitality
benefits forhimself and his companions during their time in Turkey. For example, during a stay
in Istanbul during the July and August 2017 trip, ADAMS, the Adams Relative, and the Adams
Liaison accepted a heavily discounted stay at the St. Regis Istanbul, arranged by the Promoter.
The St. Regis Istanbul is owned by the Businesswoman, who sought (0 ingratiate herself with
ADAMS. ADAMS stayed in the “Bentley Suite,” portions of whichare depicted here:

9
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‘BentleySuite Bathroom " ;
Although booking the Bentley Suite for two nights would have cost approximately $7,000,
ADAMS paida total of less than $600.

10
 15. In order to conceal the valuable flight, hotel, and other travel benefits that ERIC
ADAMS, the defendant, accepted from foreign nationals scking influence over him, he did not
disclose anyofthese trips on his annual disclosure forms, despite a legal requirement to do so.
a. By law, certain New York City elected officials and candidates for elected
office are required to file annual reports with the COIB disclosing their financial information and
outside positions and interests, as well as those of their spouses or domestic partners and
unemancipated children. The purpose of the annual disclosure law is to provide transparency to
ensure that there are no prohibited conflictsof interest between public servants’ official duties and
their private interests.
b. Atall times relevant o this Indictment, ADAMS was an elected New York
City offical required to file annual disclosure forms with the COIB.
c. Onhis2016and 2017 COIB Annual Disclosure Forms, ADAMS was asked
whether he had received “any gifto gifts from the same person, enity or donor or affliated donors
who had no business dealings with the City, other than a relative, in the total amountorwitha total
value of $1,000 or more during” the year. ADAMS answered “no.” ADAMS also answered “no”
toa similar question askingwhetherhe had received any gifts worth $50 or more from “a person,
entity, donor, or affliated donors” who did have business with New York City.
4. The valuable travel benefits ADAMS solicited and accepted—including the
free business class upgrade for two for travel from New York to India; the fiee business class
tickets for three from New York to France, Turkey, Sri Lanka, and China; the heavily discounted
stay in the Bentley Suite; and the free business class tickets for two from New York to China
through Turkey—for each of the 2016 and 2017 trips described in paragraphs 12 through 14 cach

hl
exceed $1,000 in value, as would be obvious to anyone who, like ADAMS, had extensive
experience traveling overseas.
16. ERIC ADAMS, the defendant, also sought to conceal the luxury travel benefits he
solicited and accepted from foreign nationals by creating fake paper tails, which members of
ADAMS’sstaff assisted in at his direction.Forexample, ADAMS attempted to createa fake paper
trail suggesting he had paid for his 2017 flights on the Turkish Airline, when in fit he had not.
a. As Brooklyn Borough President, ADAMS employeda scheduler (the
“Adams Scheduler”) who managed his appointments, meetings, and other official events. Despite
her status as a New York City employee, the Adams Scheduler was used by ADAMS 10 perform
personal tasks for him, such as collecting rent at a Brooklyn property he owned. ADAMS also
assigned the Adams Scheduler to pay various personal expenses for him, after which ADAMS
would reimburse the Adams Scheduler in cash.
b. In2017, ADAMS senta seriesofemails o the Adams Scheduler, dirceting
the Adams Scheduler to pay forthe free 2017 flightsheand his companions had already taken on
the Turkish Airline. But the emails provided inconsistent explanations: in some, ADAMS
suggested that the Adams Scheduler should pay by using ADAMS’s credit card, while in others,
ADAMS claimed to have left cash in an envelope for the Adams Scheduler to send to the Turkish
Airline.
c. For example, on November 25,2017, ADAMS sent an email to the Adams.
Scheduler saying that with respect tothe “July trip,” meaning the July and August 2017 rip on the
Turkish Airline, “let you the money for the international airline in an envelope in your top desk
draw. [sic] Please send it to them.” Given the costof the international business class tickets for
ADAMS alone, ADAMS'’s email suggested that he lef, at a minimum, wellover$10,000 in cash

2
 |

|
in the AdamsScheduler’s desk drawer 10 “send” tothe Turkish Airline aspayment for lights taken |
monthsearlier. He did not do that, as records from the Turkish Airline confirm that ADAMS did |
not pay the airline, in cash or otherwise, because the tickets were complimentary. |
17. In retum for travel benefits the Turkish Official provided or arranged in or about
2015 and 2016, ERIC ADAMS, the defendant, granted a political request from the Turkish
Official. Priorto ADAMS’ 2015 travel to Turkey—which ADAMS knew, and disclosed to the
COIB, had been funded by, among other entites, the Turkish Consulate, the Turkish Airline, and |
three separate municipalities in Turkey—ADAMS had maintained a relationship with a Turkish
tg tt IAS |
told ADAMS that the Community Center was affiliated with a Turkish political movement that |
was hostile to Turkey's government, and that if ADAMS wished to continue receiving support
from the Turkish government, ADAMS could no longer associate with the Community Center.
ADAMS acquiesced.
ADAMS begins accepting straw contributions and continues to receive luxury travel benefits
18. By 2018, ERIC ADAMS, the defendant, began raising funds for the 2021
Campaign. ADAMS was closely involved in the details of fundraising, which he regarded as vital
to his success. Ashe texted a close supporter late in the campaign: “You win the race by rising
money... Have to raise money. Everything clsc is uff” ADAMS further explained, “I have
7 millon dollar race. have a clear plan o aise it and each ight we are out excauting the plan.”
“Throughout the 2021 Campaign, ADAMS solicited and knowingly accepted straw donations,
including from foreign sources, while continuing to secretly accept free and heavily discounted
travel benefits fromthe Turkish Official, the Promoter, and the Arline Manager

13
 19, As partof these efforts, ERIC ADAMS, the defendant, solicited and knowingly
accepted straw donations to the 2021 Campaign that were facilitated by the Turkish Official and |
the Aine Manager, among others.
a Beginning at leas as carly as April 2018, ADAMS asked the Ailine
Manager to fundraise for the 2021 Campaign, and the Airline Manager sought to organize
fundraiser.
b. On June 14,2018, the Turkish Offical exchanged messages with the Adams
Staffer, asking “how much can companies donate? The Adams Staffer explained that only
individuals could donate to the 2021 Campaign.
c. On June 22,2018, ADAMS attended a fundraiser for the 2021 Campaign.
“The Ailine Managr, among others, organized and attended the vent, Following the event, the
“Turkish Offical messaged the Adams Staffer, asking forthe “listofthe participants ofthe June 22
mecting.” The Adams Staller the sent he Turkish Official “The list for 6/22/18. which included
the names of various persons who donated to the 2021 Campaign in the preceding days or who
donated inthe Following days, rising in excess of $15,000.
4. A promotional fier for the June 22, 2018 fundraiser listed as one ofthe
fundraiser’ hosts a rind of the Airline Manager who owned an aiport transportation business
(“Businessman-2®). In a sries of messages exchanged with the Adams Staffer, Businessman
tated that he had ciliated a straw donation through an associate. Records from the CFB show
that the associate ultimately donated $3,000 in his own name and described himself as
unemployed.

7 Many ofthe conversations quoted inthis Indictment, including this conversation between
the Adams Staffer and the Turkish Offical, were held ina language othr than English.
1
 20. ERIC ADAMS, the defendant, also sought to arrange for his campaigns to receive
unlawful contributions from Turkish nationals, which would be routed through U.S.-based straw
donors.
a. On June 22, 2018—the same day as the fundraising event just described—
the Adams Staffer and the Promoter discussed by text message a possible trip by ADAMS to
Turkey. The Promoter stated, in part, “Fund Raising in Turkey is not legal, butI think I can raise:
money for your campaign off the record.” The Adams Staffer inquired, “How will [ADAMS]
declare that money here?” The Promoter responded, “He won't declare it... Or... We'll make
the donation through an American citizen in the US... A Turk... Pll give cash to him in Turkey
Or Pll send ittoan American... He will make a donation to you.” The Adams Staffer replied,
“I think he wouldn't get involved in such games. They might cause a big stink later on,” but “Cll
ask anyways.” The Adams Staffer then asked, “how much do you think would come from you?
$7" The Promoter responded, “Max S100K.” The Adams Staffer wrote, “100K? Do you have a
chance to transfer that here?.. . We can’t do it while Eric is in Turkey,” to which the Promoter
replied, “Let's think.” After ths conversation, the Adams Staffer asked ADAMS whether the
Adams Staffer should pursue the unlawful foreign contributions offered by the Promoter, and
contrary to the Adams Staffers expectations, ADAMS directed that the Adams Staffer pursue the
Promoter's illegal scheme.
b. In November 2018, Businessman-1—the wealthy Turkish national who
owned the Turkish University, a for-profit educational conglomerate in Turkey, and whom
ADAMS met there in 2015—visited New York City. ADAMS and the Adams Staffer met with
Businessman-1 at Brooklyn Borough Hall. At the closeofthe meting, Businessman-1 offered to
contribute funds to the 2021 Campaign. Although ADAMS knew that Businessman-1 was a

1s
 |

Turkish national who could not lawfully contribute to U.S. elections, ADAMS directed the Adams
Staffer to obtain the illegal contributions offered by Businessman-1. Following up on this
directive, ADAMS wrote to the Adams Staffer that Businessman-1 “is ready to help. I don’t want
hiswilling to help be waisted [sic].” As ADAMS directed, the Adams Staffer maintained contact
with Businessman-1 through intermediaries, culminating in ADAMS accepting straw donations of
Businessman-1’s money, discussed below.
21. 1n2018, ERIC ADAMS, the defendant, also continued to secretly solicit and accept
free and heavily discounted luxury travel benefits provided by the Turkish Official and the Airline
Manager. In January 2018, ADAMS and Adams'sPartnertraveled to Budapest, Hungary, through
Istanbul. Several months carlir, Adams's Partner had purchased two economy class tickets on
the Turkish Airline for approximately $360 each. Tn December 2017, the Adams Staffer, acting at
ADAMS’s direction, asked the Airline Manager to upgrade the tickets to business class, which he
did for free. Had ADAMS and Adams’s Partner purchased their businessclass tickets, the tickets
would have cost more than $14,000 total. Consistent with his prior actions, ADAMS concealed
this free and heavily discounted travel the Turkish Airline provided by omitting it from his 2018
COIB disclosure form, despite the requirement (0 report it
As the 2021 Mavoral Election Approaches, ADAMS Continues to Solicit and Accept legal
‘Campaign Contributions
In 2019, ADAMS travels to Istanbul and solicitsforeign contributions
22. In January 2019, ERIC ADAMS, the defendant, and Adams’s Partner traveled to
Turkey, Jordan, and Oman with the assistanceof the Promoter. Because ADAMS made his travel
arrangements through the Promoter and not through the Airline Manager, the Airline Manager did
not upgrade ADAMS’s economy class tickets on the Turkish Airline, instead arranging a full
upgrade only for Adams's Partner. Had Adams's Pactner purchased her business class ticket, it
16
would have cost at least approximately $7,000. In an effort to monopolizeflight travelas a method
of gaining influence with ADAMS, the Airline Manager observed that difficulty arose in
upgrading ADAMS because the arrangements had been made through others. When exchanging
messages about another potential trip later in 2019, the Adams Staffer requested an upgrade for
ADAMS from the Airline Manager and explained, in par, that “He Ieamed his lesson last time.
We're writing directly to you this time.” After the 2019 trip, ADAMS exclusively arranged his
flights on the Turkish Airline through the Airline Manager, allowing the Airline Manager, the
Turkish Official, and the Turkish government
to increase their influenceover ADAMS.
23. During his 2019 trip, ERIC ADAMS, the defendant, solicited and accepted travel
benefits from the Promoter—the Turkish entrepreneur who, as described above, facilitated

ADAMS’s second 2015 trip to Turkey and in 2018 proposed to ADAMS via the Adams Staffer
raising campaign contributions illegally in Turkey. Specifically, ADAMS solicited and accepted

free hotel stays, dinners, and a boat trip, among other things, from the Promoter, including a free
two-night stay in the Cosmopolitan Suite of the St. Regis Istanbul, depicted below:

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Had ADAMS paid fora two-day stay in this luxury suite, the cost would have been approximately |
$3,000 total. ADAMS also solicited and accepted from the Promoter free transportation, meals,

and entertainment, including a car and driver, a boat tour to the Princes’ Islands in the Sea of

Marmara, a Turkish bath at a seaside hotel, and at least one meal at a high-end restaurant.

24. ERIC ADAMS, the defendant, did not report any of the free travel benefits he

ied dg 201 sal 1s2019 CO isos orn.

25. ERIC ADAMS, the defendant, also solicited unlawful foreign campaign

contributions while in Istanbul in January 2019. During ADAMS’s trip, the Promoter arranged
for ADAMS to meet a wealthy Turkish businessman (“Businessman-3"). The Turkish Official,

through the Adams Staffer, discouraged ADAMS from meeting Businessman-3, who was then
under suspicion ofwrongdoing. ADAMS did so nonethless. During their meeting, ADAMS and
the Promoter solicited campaign contributions from Businessman-3, who as a Turkish national

could not lawfully contribute to any U.S. campaign. During the meeting, Businessman-3 agreed

"
to contribute $50,000 or more to the 2021 Campaign, believing that ADAMS might one day be
the President of the United States and hoping to gain influence with ADAMS. In subsequent
messages, the Promoter and the Adams Staffer discussed how to funnel Businessman-3's planned
contributions to the 2021 Campaign through U.S. sraw donors. Before anyofthe discussed straw
donations could occur, however, Businessman-3's legal troubles in Turkey and the United States
became more public. ADAMS declined to meet with Businessman-3 when Businessman-3 later
visited New York, and Businessman-3 did not ultimately contribute to the 2021 Campaign.
26. Businessman-3 was not the only wealthy Turkish national from whom ERIC
ADAMS, the defendant, sought illegal campaign contributions. Also in January 2019, ADAMS.
continued to seck the illegal foreign contributions promised by Businessman-1 (the Turkish
national who owned the Turkish University), telling the Adams Staffer in ext message o confirm
Businessman-1’s continued willingness to support the 2021 Campaign.
27. ERIC ADAMS, the defendant, continued to conceal the benefits he received from
foreign nationals seeking to gain influenceover him.ADAMS did not report anyofthe 2019 gifts
he received from the Airline Manager or the Promoter on his annual disclosure form. In addition,
in March 2019, while exchanging text messages to plan another possible 0 rip to Turkey in which
the Airline Manager would arrange travel for ADAMS, the Adams Staffer texted ADAMS, “To
be of the] safe side Please Delete all messages you send me.” ADAMS responded, “Always do.”
In December 2020, ADAMS solicits and accepts straw contributionsfrom a New York
construction company
28. 1n2020, ERIC ADAMS, the defendant, solicited and received straw donations from
a businessman who operated a construction company in the New York City area
(“Businessman-4”). Although Businessman-4 was not part of New York's Turkish community,
his contributions were sought and made for similar reasons (0 the many Turkish nationals and
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 Turkish Americans whom the Turkish Official and the Promoter induced to make illegal
contributionsto the 2021 Campaign: Businessman-4 was prominent memberof adifferent ethnic
community in New York City, and he was told by ADAMS’s representatives that straw
contributions would increase Businessman-4’s influence, and the standing of his community, with
ADAMS.
a In December 2020, twovolunteers for the 2021 Campaign who later became
employees of ADAMS at City Hall (“Adams Employee-I” and “Adams Employee-2”, and
together, the “Adams Employees”) asked Businessman-4 to contribute $10,000 to the 2021
Campaign. The Adams Employees were liaisons to Businessman-4’s community, playing roles
similar to the Adams Staffer’s role in the Turkish community. The Adams Employees told
Businessman-4, among other things, that donating $10,000 would give Businessman-4 influence
with ADAMS, which would help Businessman-4’s business interests and his community when
ADAMS became mayor, and that gaining such influence with ADAMS would be more expensive
ata later date.
b. Businessman-4 agreed to contribute and offered to write a $10,000 check
from his company’s bank account. The Adams Employees informed Businessman-4 that he could
not donate through his corporate bank account.
© Businessman-4 then offered to write a $10,000 check from his personal
bank account. The Adams Employees informed Businessman-4 that he could not donate more
than $2,000. The Adams Employees then explained that Businessman-4 should instead direet his
employees to contribute to the 2021 Campaign and then reimburse the employees.
4 Businessman followed the Adams Employees’ directions.
Businessman-4 personally contributed $2,000 to the 2021 Campaign and reimbursed four of his

20
employees for their $2,000 contributions to the 2021 Campaign. Businessman-4 and his
employees made these contributions at a fundraiser that ADAMS personally attended, which was
held at Businessman-4’s offices.
e. The 2021 Campaign requested, and received, Matching Funds for these
straw donations.
f. After ADAMS was elected mayor, Businessman-4 sought to benefit from
the influcnce with ADAMS that the Adams Employees assured Businessman-4 would result from
the straw contributions. Amongotherthings, Businessman-4 sought assistance from ADAMS and
the Adams Employees with arranging events celebrating the national heritage of Businessman-4s
ethnic community, and ADAMS and the Adams Employees worked with Businessman-4 to
arrange such events with City sponsorship.
& Businessman-4 also sought and received assistance resolving issues with
the New York City Department of Buildings (“DOB”), including from ADAMS himself. On
February 5, 2023, Businessman-4 sent a text message to ADAMS saying, among other things, “1
always supported you,” but that Businessman-4 was “having a hard time with DOB” getting a
stop-work order lifted, and that although ADAMS’staffhad assisted, “we reached a certain limit
that only you can it.” ADAMS responded, “Let me look into this.” Approximately a week and
a halflater, Businessman repliedto ADAMS “Mayor, brother I want o thank you for your help.
DOB issue partially resolved and they promised to expedite the process. Thank you, you have my
continued support”
In May 2021, ADAMS receives straw contributionsfrom another New York
construction company, as arranged by the Turkish Official
29. ERIC ADAMS, the defendant, accepted support from the Turkish Official
throughout the 2021 Campaign, and the Turkish Official repeatedly informed ADAMS thathewas
21
providing such support. Whena fundraising effort organizedorfacilitated by the Turkish Official |
failed (0 raise the amount of funds that the Turkish Official had promised ADAMS, the Turkish |
Official told ADAMS and the Adams Staffer that he would “close the gap” by obtaining sufficient |
funds from other sources to reach the promised amount |
30. In May 2021, ERIC ADAMS, the defendant, sought and accepted straw donations |
from another businessman (“Businessman-S”) who operated another construction company in the |
New York City area. Businessman-5 is a prominent member of New York City’s Turkish
‘community and made these donations at the behest of the Turkish Offical.
a In January 2021, the Turkish Official messaged the Adams Staffer, asking
for a meeting with ADAMS. The Turkish Official and the Adams Staffer then exchanged the
following messages:
Adams Staffer: ‘What wil the topic be?
Turkish Oficial The election
that’s what
Adams Staffer okay
Turkish Official: Nov 2nd 2021 [the date of the 2021 mayoral election]
Adams Staffer His favorite topic
Turkish Official: “Turkish community support to him
‘What can we do, lets talk
Adams Staffer: okay
b. ADAMS, the Turkish Official, the Airline Manager, the Adams Staffer, and
the lead fundraiser for the 2021 Campaign (the “Adams Fundraiser”) met at a restaurant for dinner
on February 14, 2021. At the dinner, the Turkish Official committed to “support” the 2021
Campaign.

2
 ©. The Turkish Official then organized a larger dinner to plan specific
donations 10 the 2021 Campaign. Businessman-S, the Turkish Official, ADAMS, the Adams
Fundraiser, and the Adams Staffer attended that dinner, which occurred on April 2, 2021. At the
dinner, ADAMS explained the Matching Funds Program and solicited contributions from
Businessman-S. The Turkish Official told ADAMS, “we arc supporting you.”
4. After the April 2, 2021 dinner, Businessman-5 worked with the Turkish
Official, the Adams Fundraiser, and the Adams Staffer, among others, 10 plan a fundraiser for
ADAMS. Businessman-S attempted to recruit others in the construction industry and the Turkish
‘community, writing, in par, this “may feel like swimming against the current but unfortunately
this is how things work in this country.” ‘The day before the scheduled fundraiser, the Turkish
Official sent Businessman-S at least one check, and Businessman-5 sent the Turkish Official a
message confirming that “Asofnow, the checks that reached us are 17,000.”
ec. OnMay7, 2021, Businessman-S held a fundraiser for the 2021 Campaign
at his construction company’s offices. ADAMS, Businessman-S, the Adams Fundraiser, and the
Adams Staffer attended. The Turkish Official did not attend but sent his driver to deliver several
additional contribution checks. Prior to the fundraiser, Businessman-S’s construction company, at
the directionof Businessman-S, had provided $1,250 per employee to ten of ts employes. Each
of those employees then contributed that amount tothe 2021 Campaign, with the exceptionofone
employee who donated in his wife’s name, and another who donated $1,200 of the funds. The
‘Adams Staffer sent the Turkish Officiala list of the contributions collected at the fundraiser.
f. Following the fundraiser, the Turkish Official sent Businessman-5 a
‘message asking, “how much is the total?” to which Businessman-S replied, “I think I got to 221]
He just lefi(] The girls, [ADAMS's] assistants, were very happy[.]” The Turkish Official

23
subsequently asked the Adams Staffer o tell ADAMS, “we will continue supporting you,” which
the Adams Staffer did,
& The 2021 Campaign requested Matching Funds for eightofthese straw
donations that were made in the names ofNew York City residents, fraudulently obtaining public:
funds to which the campaign was not entitled.
In September 2021, ADAMS accepts straw contributionsfrom a Turkish national
31. In2021, Businessman-1—the Turkish national who owned the Turkish University,
as described above attempted to make good on his earlier commitments to contribute to ERIC
ADAMS, the defendant. ADAMS and Businessman-1 used the Promoter and the Adams Staffer,
among others, to devise and execute a plan to funnel Businessman-1’s money to the 2021
Campaign, knowing full well that these donations would violate the law against US. political
‘campaigns receiving contributions from foreign nationals.
a. On luly 9, 2021, the Adams Staffer exchanged messages with ADAMS
about raising funds from the Turkish University, among other sources. ADAMS explained that he
was “Not doing [an] in person fundraiser for less than S25K.”
bo OnlJuly 11,2021, the Adams Staffer asked the Promoter how much would
be donated, explaining in a message that she needed to “tell [ADAMS] a net number.” When the
Promoter estimated between $35,000 and $50,000, the Adams Staffer replied that the Promoter
carlier “had mentioned 200K.” When the Promoter explained that the requisite number of straw
donors could not be gathered, the Adams Staffer offered to help with that aspect of the scheme.
“The Promoter responded, “Hmmm then great,” and when the Adams Staffer then wrote “From
whatI gathered you'll distribute the money,” the Promoter responded “Yes.” The Adams Staffer
later told ADAMS that the estimated total amountofthe foreign donations would be $45,000.

2
 |

|
In August 2021, the Promoter, the Adams Staffer, and the president of the
Turkish University’s American campus (the “University President”) exchanged messages and
voice notes explicitly discussing the plan to funnel Businessman-1's contribution to the 2021 |
Campaign through the Turkish University’s U.S.-based employees. The Promoter assured the
Adams Staffer that those employees are [U.S] citizens and green card holders.” The Adams
Staffer told ADAMS about the plan to funnel Businessman- 1's contribution through U.S.-based
straw donors,and ADAMS approved theplan, knowing that Businessman wasa Turkish citizen.
4. On August 27,2021, the University President messaged the Adams Staffer |
thatthe Turkish University would donate $20,000 to the 2021 Campaign by “dividing it amongst
our employees in appropriate amounts.” The Adams Staffer responded that “ifthe donation is not
more than $25K, then Mr. President” referring to ADAMS, who was then Brooklyn Borough
President—“docs not participate in person.” The University President then informed the Adams
Staffer that in addition to the Turkish University’s contribution, thers would donateto reach the
$25,000 threshold.
c. On August 27,2021, the University President informed the Adams Staffer
tha the Turkish University would donate only $10,000. Because that meant that ADAMS would
no longer appear at an in-person event, the Adams Staffer asked the Adams Fundraiser o create
an internet lnk through which the Turkish University’s straw donors could contribute. Tnaseries
of messages with ADAMS and the Adams Staffer, the Adams Fundraiser sent the link to the
Adams Staffer. To remind the Adams Stafferofthe mechanics of the plan they had discussed—
that the foreign donations would be concealed by routing them through U.S.-based straw donors
who could lawfully contribute in their own names—ADAMS wrote o the Adams Staffer and the
‘Adams Fundraiser, “We can’t take any money from people who are not US citizens.” The Adams

25
Staffer inquired, “What about green card holders?” The Adams Fundraiser responded, “Yes we
can,” confirming that the Promoter's plan to use green card holders as straw donors would work.
The Turkish University ultimately made its straw contributions on
‘September 27, 2021, when three U.S.-based employees of the Turkish University made $2,000
contributions to the 2021 Campaign and were then reimbursed, asdirected by Businessman-1 and
the University President. The University President and another U.S.-based employee of the
Turkish University each also made $2,000 contributions from their own funds. The contributions
occurred during a period when the 2021 Campaign had begun to wind down fundraising and were
ultimately refunded by the campaign, but not before ADAMS submitteda disclosure statement to
the CFB that falsely claimed the U.S.-based Turkish University employees were the truc donors.
© On November 2, 2021, ADAMS was declared the winner of the 2021
mayoral election. The next day, Businessman-1 and the Promoter exchanged the following
messages:
Promoter: Good morning
‘The president is our brother from now on, sir.
Businessman-1: Good morning
Promoter: May itbe auspicious for all of us.
‘We messaged cach other.
Businessman-1: Are the elections over?
Promoter: It was yesterday, sir
Everyone messaged me that he was elected.
Congratulations messages
He is most likely going 10 assign me as a representative, sir.
Pm going to go and talk to our elders in Ankara about how
wecan turn this into an advantage for our country's lobby.
Businessman-l: That would be nice

2%
tellingothers including ADAMS himself —that ADAMS would soon be Presidentof the United
States. Similarly, the Turkish Official wrote to the Adams Staffer that given ADAMS’s increasing
prominence, “at this point” the Foreign MinisterofTurkey “is personally paying attention to him”
‘and ADAMS “should not bother with” his other Turkish benefactors.
32. Alltold, the 2021 Campaign reapedover$10 million in Matching Funds based on
the false certifications that the campaign complied with the law, when in fit ERIC ADAMS, the
defendant, knowingly and repeatedly relied on llegal contributions
10.2021, ADAMS Accepts Bribes From the Turkish Official and Inervenes on the Turkish
‘Official’s Behalfwith the Fire Prevention Chief
33. In 2021, ERIC ADAMS, the defendant, intervened with the FONY to permit the
“Turkish Consulate 0 occupy a skyscraper that had not passed a fire safety inspection, in exchange
for, among other things, luxury travel benefits provided by the Turkish Official and the Airline
Manager.
34. Inlate June 2021, ERIC ADAMS, the defendant, sought luxury travel to Turkey
aranged by the Turkish Official and the Airline Manager. When the Adams Staffer began
coordinating this travel for ADAMS, at ADAMS's direction, ADAMS again attempted to create a
false record suggesting that he would pay his own way, when, in fact, ADAMS had the Adams
Staffer coordinate with the Airline Manager to provide ADAMS with free and steeply discounted
travel benefits. ADAMS approved the itinerary, and, to create the false impression of payment,
the Turkish Official, ADAMS, and the Adams Staffer agreed that ADAMS would collect invoices
from vendors in Turkey regardlessof whether he actually paid and would make some small credit
card payments to conceal the fact that he was taking a vacation that was mostly paid for by the
Turkish government.
2
 a. OnJune 22,2021, ADAMS, through the Adams Staffer, requested that the |
Airline Managerbook flights to Istanbul for ADAMS. In order to conceal the favorable treatment,
the Adams Staffer requested that theAirline Manager charge ADAMS what wouldappear to be a |
“real” price: |
Adams Staffer: ‘How much does he owe? |
Please, let them call me and I will make the payment.
Airline Manager: It is very expensive because it is last minute. 1am working.
ona discount
Adams Staffer: Okay.
Thank you.

Airline Manager: 1am going to charge $50

Adams Staffer: No
Airline Manager: That would work wouldn't it |
Adams Staffer: No, dear. $507 What? |
Quote a proper price.
Airline Manager: How much should I charge? :)
Adams Staffer: His every step is being watched right now |
$1,000 or so
Let it be somewhat real.
‘We don’t want them to say he is flying for fre.
Atthe moment, the media’s attention is on Eric. |
ADAMS paid approximately $1,100 each for roundtrip economy tickets on the Turkish Airline for
himselfand Adams's Partner, which were immediately upgraded to business class at no cost. Had
ADAMS purchased business class tickets on the open market, they would have cost more than
$15,000 total.

2
 |

b. AUADAMS’s direction, the AdamsStaffer also coordinated luxury lodging

for ADAMS and Adams's Partner, which would be secretly provided at no cost to ADAMS, as the:
Adams Staffer and the Airline Manager discussed:
Adams Staffer: He is also asking where else they can go in Turkey
Do you have a recommendation?
Airline Manager: Four Seasons
Adams Staffer: Is too expensive
Airline Manager: Why does he care?
He is not going to pay
His name
will not be on anything.
either
Adams Staffer: Super
© The Turkish Official also amanged an itinerary for ADAMS and Adams's
Partner in Turkey, which, in addition o the stay at the Four Seasons, would include a yacht tour,
a three-day stay ata luxury beach resort, and a car and driver, as well as a domestic flight between
Istanbul and the resort. The Adams Staffer forwarded details of this itinerary to ADAMS. To
assist ADAMS in concealing the nature and extent of the travel benefits he was soliciting and
accepting, the Turkish Official suggested a nominal priceofapproximately $720, although the true:
price of thi itinerary would in fact have been approximately $8,500 or more. ADAMS approved
the itinerary and the nominal price.
4. On June 26,2021 (the same day the trip was supposed to star), the Adams
Staffer informed the Turkish Official and the Airline Manager that ADAMS was cancelling his
tip. The Turkish Airline refunded ADAMS’s payment for economy classtickets—the only
payment ADAMS had made for the late June 2021 tripto Istanbul.

2
 35. At around the time of this cancellation, ERIC ADAMS, the defendant, solicited
various travel benefits for the Adams Fundraiser—the 2021 Campaign's chief fundraiser who, as
noted above, helped coordinate the straw contributions from Businessman-5’s construction
company one month carlir in May 2021-—from the Turkish Official and the Airline Manager.
Continuing their efforts to influence ADAMS, the Turkish Official and the Airline Manager
ultimately provided the Adams Fundraiser with transportation from the airport, a free hotel, and
free useof a VIP room in the Turkish Airline’s business class lounge.
a. On June 27,2021, when the Adams Fundraiser was scheduled to travel to
Istanbul, ADAMS created a message thread between himself, the Adams Fundraiser, and the
Turkish Official. ADAMS informed the Turkish Official that the Adams Fundraiser would be
arriving in Istanbul shortly and needed transportation from the airport and a hotel, which the
Turkish Offical promptly amranged. When ADAMS suggested that ADAMS would pay for the
Adams Fundraisers expenses, theTurkish Official told ADAMS, “Eric no prob, it was set through
Turkish Hospitality Services. I hope she enjoyed her stay.” ADAMS responded, “It was amazing.
“Thanks for all the coordination and attention.” In the same message thread with ADAMS, the
‘Turkish Official also provided the Adams Fundraiser witha fake bil for the hotel say, to allow
ADAMS and the Adams Fundraiser to create the appearance that the Adams Fundraiser had paid
for her hotel stay, when in ict, as ADAMS knew, she had not.
b. On the day the Adams Fundraiser was scheduled to depart Istanbul,
ADAMS created a message thread between himself, the Adams Fundraiser, and the Airline
Manager. ADAMS wrote, “{Adams Fundraiser] this is [the Airline Manager]. 1. He will uy to
help the issue with the form(] 2. He can see about a hotel or the business class lounge.” The
Airline Manager then arranged for the Adams Fundraiser—who was otherwise flying on an

30
economy ticket—o have access not only to the Turkish Airline’s business lounge, but also to an
exclusive private suite inside the lounge, complete with abed and free food. The Airline Manager
‘explained, “This is our suite for our VIPs [alnd we want you to feel your self [sic] Vip :) > At
another point in this exchange, ADAMS wrote, “Thanks a million [Airline Manager]. My
Brother,” to which the Airline Manager responded, “Anytime brother.”
36. ERIC ADAMS, the defendant, and the Turkish Official understoodthat inexchange.
forthe benefits described in paragraphs 34 and 35, and future travel benefits for ADAMS, ADAMS
‘was expected to assist the Turkish Official in the operation ofthe Turkish Consulate in New York.
37. On July 6, 2021, ERIC ADAMS, the defendant, declared victory in his party’s
‘mayoral primary. On the momingof July 7, 2021, theAirline Managersent ADAMSthe following
text message: “Brother congratulations.” ADAMS responded, “Cannot thank you enough.”
38. In September 2021, ERIC ADAMS, the defendant, agreed to pressure a New York
City agency to help the Turkish Consulate secure a temporary certificate of occupancy (“TCO”)
fora building it owned and operated. |
a As Brooklyn Borough President, ADAMS had authority under the New
York City Charter to affect the administration of City services within his Borough, such as those:
provided by the FDNY and other ity agencies, including through: holding public hearings;
introducing legislation before the City Council; overseeing the coordination ofa borough-wide
public service complaint program; and consulting with the Mayor ofthe City of New York on the
executive capital budget and other budget recommendations. In addition to, or in the course of,
the performance of these duties, as Brooklyn Borough President, ADAMS met with members of
the FDNY from time to time.

31
 b. In 2017, construction began on a 36-story building located at 821 United

Nations Plaza, New York, New York, and referred to a th Turkish House or Turkeni Centr (the
“Turkish House”). The Turkish House was designed to serve as, and now serves as, the
headquartersofmultiple Turkish diplomatic missions, including the Turkish Consulate. The cost

ofthe Turkish House was significant and was a topicofpolitical debate in Turkey.

EN on

Te al 4]

FETTER L.
el
RE
EA rs hv
TLE a
ae
- The Turkish House wn
che Tukish Consulate planned 10 open the Turkish Howse on
‘September 20, 2021, so that Turkey's President could formally open the building during his visit

for that year's opening of the United Nations General Assembly. Ensuring the Turkish House
»
opened on schedule was a priority for the Turkish Oficial, who was at his time Turkey's Consul
General in New York.
4 Asof August 31, 2021, construction on the Turkish House was complete,
but the DOB had not yet issued a TCO for the building. Without a TCO, the Turkish House could
not open during the Turkish President’ impending visit
The DOB had not issued a TCO because the FONY had not yet conducted
an inspection and issued what the FDNY refers to as a “letterofdefect,” which was a prerequisite
to the issuance of a TCO for the Turkish House. Issuing a letter of defect is a regular FDNY
procedure which, in substance, identifies remaining defects in a buildingsfire safety systems, but
also serves to signal that the defects are sufficiently limited that the building can be safely
occupied.
£. Fromonor about August31,2021, through onor aboutSeptember9,2021,
various NewYorkCity officials and employees, among others,soughttohelp the Turkish Official
obtain a TCO for the Turkish House by lobbying the chief of the FDNY’s Bureau of Fire
Prevention (the “Fire Prevention Chief”) to provide a letter ofdefect. ‘The Fire Prevention Chief
refused, citing numerous reported fire safety defects, someof which were serious, a the Turkish
House, and the likelihood that the building would fail any FDNY inspection.
& On or about Sepiember 5, 2021, the Turkish Official began asking
ADAMS, both directly and through the Adams Staffer, 0 intervene with the Commissioner ofthe
FDNY (the “FDNY Commissioner”) in order to secure a TCO for the Turkish House. ADAMS,
the Turkish Official, and the Adams Staffer discussed these requests through phone calls and
electronic messages. na phone call o the Adams Staffer, the Turkish Official stated that because:

3
 §

Turkey had supported ADAMS, it was now “his tum” to support Turkey. The Adams Staffer
relayed this message to ADAMS, and ADAMS responded, “ know.”
h. On September 6, 2021, ADAMS messaged the Adams Stafer that he would
contact the FDNY Commissioner.
i. On September 7, 2021, ADAMS messaged the Adams Stafer that he had |
scheduled call with the FDNY Commissioner late tht dy. |
J On September 8, 2021, ADAMS messaged the FDNY Commissioner,
asking him to call ADAMS. Until that point, the messages between the FDNY Commissioner and
ADAMS had consisted of () an August 3, 2021 message from the FDNY Commissioner to
ADAMS, requesting to continue scrving as FONY commissioner after ADAMS became mayor, |
and stressing that he was “loyal and trustworthy,” to which ADAMS sent a noncommittal response,
and (i) a September 5, 2021 invitation to a September 11 memorial service from the FONY |
Commissioner to ADAMS, to which ADAMS responded that he would try to atend and wished
10 speak with the FDNY Commissioner for “ahalf hour . .. about FDNY.” |
kK. Also on September §, 2021, ADAMS messaged the FDNY Commissioner, |
stating, in part, “They said they necded a letter ofDefect from FDNY to DOB. They know they
have some issues but according to them with the letter the DOB will] giv the TCO.” The FONY
Commissioner responded, “We will get on it tomorrow.” Through the Adams Staffer, ADAMS
assured the Turkish Official, “Don’t worry,” I am on top ofthis.”
I. On September 9, 2021, after contractor working for the Turkish Consulate
Sent the FDNY a letter describing the status of the Turkish House's fir alarm system, an FDNY
employee with responsibility for inspecting the system sentth Fire PreventionChiefthe following
email:

3
 ‘Subject: FW Turkish Embas y -Fire Alarm Request
-821 1at Avenue (21021)

wowould be wil0 accept They have some major sues le conta

Shee:evining neler, do not see any way
SECRET LePou ee 0rea ur focus
i ove WiIbeleve t

m. On the morning of September 10, 2021, ADAMS messaged the FONY

Commissioner, stating that the Turkish Official had understood that the FDNY was going to

inspect the Turkish House the previous day, and “They really need someone . . . by today if

possible. Ifitis[ imJpossible please let me know and I will manage their expectation.” The FDNY
Commissioner wrote back that “There seems to bea differenceofopinion between the inspector”

and the private alarm engineer responsible for the building, but that the FDNY Commissioner was.
“trying to iron it out.”
n. Shortly after noon on September 10, 2021, ADAMS messaged the FONY

Commissioner, “They said the hire [sic] ups at FDNY did not give the inspector authorization to
come. The inspector indicated he needs authority to come to day [sic].” The FDNY Commissioner
responded, “Working on that as we speak.” At approximately 2:06 p.m., ADAMS messaged the

‘Adams Staffer that ADAMS had againspokenwith the FON'Y Commissioner, and “He again told

me he is on the phone as we speak to try and resolve this.”

o. Also on the afternoon of September 10, 2021, the FDNY Chief of

Department summoned the Fire Prevention Chief to a meeting. The ChiefofDepartment was the

FDNY Commissioner's direct subordinate and the Fire Prevention Chief's superior. TheChief of

Department informed the Fire Prevention Chief, in substance, that if the FDNY did not assist the

ofDepartment and the Fire Prevention Chief

Turkish Consulate in obtaining a TCO, both the Chief

‘would lose their jobs. The Fire Prevention Chief then drafted a “conditional letter of no objection”
35
 |
for the Turkish House. The Fire Prevention Chief had never before written a “conditional letter of
no objection,” which was not standard FDNY procedure. Instead, the Fire Prevention Chief wrote.
this letter, which he later described as “unprecedented,” to inform the DOB that FDNY did not
object to issuing the TCO, provided that the private engineers affirmed that the fire alarm system
functioned properly, and “assumfing] the Department of Buildings has inspected, tested and
approved the installed water-based fire suppression systems.”
pb. AU2:17 pm on September 10, 2021, the FDNY Commissioner wrote
ADAMS, “Letter being draficd now. Everything should be good to go Monday moming.” Four
minutes later, ADAMS messaged the Turkish Official, “From the commissioner: Letter being
drafted now. Everything shouldbe good togo Monday moming.” The Turkish Official responded,
“You are Great Eric, we are so happy to hear that JyJy. You are a true friendofTurkey.”
ADAMS replied, “Yes even more a true fiiend of yours. You are my brother. 1am hear [sic] to
help.” At2:30 pm, the Turkish Official confirmed, “You arc such
a friend 3.” At 2:31 pan. the
Fire Prevention Chief sent the “conditional letterof no objection’ to the private alarm engineer.
39. After ERIC ADAMS, the defendant, pressured the FDNY to permit a TCO to be
issued for the Turkish House, the Turkish Official continued to fulfill his endof the bargain, by
providing additional luxury travel benefits to ADAMS. These benefits,which ADAMS accepted,
were worth more than $14,000.
a. On September 14, 2021—four days after ADAMS caused the FDNY to
acquiesce in the TCO—ADAMS messaged the Adams Staffer, dirceting her to secure tickets to
Pakistan fora trip from November 30 to December 8, 2021. The Adams Staffer relayed the request
tothe Airline Manager, stating, “He'll pay the economy class price,” but asking, “Can we upgrade
ater?” The Airline Manager replied, “Ofcourse.”

36
 b. On September21, 2021, the Turkish Official messaged the Adams Staffer,
seeking a meeting at aparticular time between ADAMS and a Turkish Deputy Minister. The
Turkish Official wrote, “This is very important. He"—the Deputy Minister—*is the person who
‘makes allthearrangements with one phone call in Turkey.Flight, yacht tour, hotels, ental cars...”
“The meeting did not oceur, because ADAMS was scheduled to meet with a former President of
the United States at the time requested for the meeting with the Deputy Minister.
©. Aferthe Airline Manager and the Adams Staffer further discussed the price
and timing of ADAMS’s tickets, on September 28, 2021, ADAMS purchased two roundtrip
conoms class tickets on the Turkish Airline from New York to Pakistan—arriving in Lahore and
departing from Islamabad—fora total priceof$1,436. On November 17, 2021, the Adams Staffer
messaged ADAMS to confirm that he still intended to travel and that she should therefore have his
tickets upgraded to business class. ADAMS responded, “Ok, do 50.” On November 18,2021, the
Adams Staffer messaged the Airline Manager, requesting the upgrade. The Turkish Airline
upgraded ADAMS's tickets to business class at no cost to ADAMS.
d. On November 25, 2021—four days before he was scheduled to depart for
Pakistan— ADAMS asked that his destinationbechanged to Ghana. TheAirline Manager changed
ADAMS’s and Adams's Partner's tickets to business class flights to Ghana at no cost to ADAMS.
Had ADAMS paid full price for the business class tickets to Ghana, they would have cost more
than $14,000 total.
On November 26, 2021, the Turkish Official informed the Adams Staffer
that “we will take care of the layover in Istanbul,” referring to a ninc-hour layover in Istanbul
during ADAMS's just-scheduled flight from New York to Ghana. The Turkish Official then
offered various arrangements for ADAMS, including an escort to meet ADAMS and Adams's

37
Partner at the gateofthe Istanbul airport, pickup at the Istanbul airport by “luxury vehicle" later
specified as a “BMW 7"—witha driver, dinner at a high-end restaurant where ADAMS would

‘meeta Turkish govemmentofficial, drinks ataseparate location,a boat tourofthe Bosporus Strait,
and return to the airport in time for ADAMS's business class flight from Istanbul to Ghana.

ADAMS selected the airport escort, driver, and dinner, but declined the Bosporus Strait cruise,

explaining that he has “done the boat tour a few times.” In touting the benefits he provided, the
“Turkish Official messaged the Adams Staffer, “don’t let [the Airline Manager) and others confuse
[ADAMS]. We are the state.”

f. On November 30, 2021, the Adams Staffer relayed to the Turkish Official

requests by ADAMS that his excursion into Istanbul receive no media attention, including social
media. The Turkish Official agreed that it would be “confidential.” Accordingly, the Turkish
Official confirmed that during ADAMS"s dinner at the Istanbul restaurant, the Turkish Official’s
“team did not let anyone take any pictures.” This was in stark contrast to the Ghana portion of

ADAMS’s trip, for which ADAMS actively sought and obtained press coverage, and which
ADAMS posted sbout on his social media account.
g After ADAMS completed the layover, the Turkish Official and the Adams
Staffer exchanged the following messages:
“Turkish Official: Was Eric satisfied?

Adams Staffer: It was great. Thank you for everything.

Turkish Official: BDA
it’s okayifhe is happy

I Eric happy then?

Adams Staffer: Hes very happy. He is sending you his thanks.

38
 |
40. During and shortly after the travel to Ghana and Istanbul described in the preceding
paragraphs, ERIC ADAMS, the defendant, took additional actions for those who provided him
travel benefits, in exchange for those benefits
a Incarly December 2021, ADAMS announced the membersofhis transition
committees, which were established to advise the mayor-clect and his team on policies and
appointments before he took office. Initially, there were no members ofthe Turkish community
on any of the committees.
b. On December8, 2021, the Adams Staffer sent the Airline Manager alink to
alist ofADAMS's transition committees and asked the Airline Manager, “Have you looked at the
list?" The Airline Manager responded, “It would suit me well to be lead Or Senior Advisor.” Two
days late, the Airline Manager sent a message reiterating, “Lead Plz :) Otherwise scat number 52
is cmpty .. On the way back,” meaning that if the Airline Manager was not given a position on a
transition committee, it would affect ADAMS’ travel benefits from the Turkish Airline.
©. On December 17, 2021, the Adams Staffer sent ADAMS a lst ofmembers
of the Turkish community to add to ADAMS’s transition committees, with the Airline Manager
as the top name. ADAMS informed the Adams Staffer that he had sent the lit 10 the persons
responsible for organizing his transition committees. ADAMS sent the lst 0a staffmember with
the direction “Add to transition.” The Airline Manager was subsequently added to ADAMS’s
Infrastructure, Climate and Sustainability Committee transition committee.
4. On December 23, 2021, a senior Turkish government official sent the
Airline Manager a series of text messages, noting the Airline Manager's membership on
ADAMS's Infrastructure, Climate and Sustainability Committee and sending applause emis.
‘The Airline Manager responded that his membership on thetransition committee wasinservice of

39
 |
“Turkey: “Thank you, brother. We are doing ourbest to serve our country adequately. Your support |
gives us strength here. Thank you. You are always there for us, and we're trying tobe worthy.”
41. ERIC ADAMS, the defendant, continued to conceal the luxury travel benefits he
accepted in exchange for taking actions favorable to the Turkish Official, the Airline Manager,
and others, by once again not reporting these gifts on his 2021 annual disclosure form. In total,
from 2016 through 2021, ADAMS received the following benefits from the Turkish Official, the
Airline Manager, the Promoter, and others, noneofwhich he reported on annual disclosure forms:

I
 |
[ FE Fr

India (via | Free upgrade to business class for two on

2016| Turey) |roundirip from New York to India Sepa.

France, | Free business clas tickets for three on roundirip

France, | fom New York to France, Turkey, and China;
heavily
ina | Regis
2017|Tuskers discounted say in Bently Suc orse. | #1000" | No
i Istanbul

China (via | Free business clas tickets for two on roundicip

217| Turkey) | from New York to China $8004

business clas
Hungary | Free upgrade toNew to for two on
Hungary $12000¢| No
2018| (via Turkey)|roundirp from York

Free upgrade to business class for one on light

from New York to Turkey; fice stay at
2019|Turkey | Cosmopolitan SuiteofSt. Regis Istanbul; free | $9,000 | No
meals, transportation, and entertainment in
Istanbul
Turkey
(solicited | Free upgrade to business class for two on
and roundirip from New York to Turkey; fee or
2021 | 2cepted but | steeply discounted luxury hotel and resort stays, |$20000% | Ne
then transportation, entertainment, and meals
canceled
Ghana (via | Free upgrade 0 business las fortwo on
2001 | hie | roundup rom New York to Ghana fee meal and| $12,000
¥) transportation during Istanbul layover

4
 ADAMS Continues His Corrupt Relationships After Becoming Mayor.
After his inauguration, ADAMSfavors those who provided him with illegal benefits over those
whofell short
42. On January 1, 2022, ERIC ADAMS, the defendant, was inaugurated as Mayor of
New York City. ADAMS soon began preparing for his next election, in part by planning to solicit
more straw contributions, and in part by granting requests by those who supported the 2021
Campaign with significant straw donations, while denying requests from those who fell short.
a On January 11,2022, ADAMS met the Promoter, the Adams Staffer, and
others at a high-end New York City restaurant frequented by ADAMS. At one point during the
‘meeting, ADAMS, the Promoter, and the Adams Staffer met separately in a private arca. There,
thePromoter discussed his prior efforts to collect campaign contributions for ADAMS in Turkey,
stated that he could collect more foreign contributions in the future, and indicated that he would
be able to raise more money for the 2025 Campaign if ADAMS visited Turkey and met with
Turkish businesspeople. ADAMS welcomed the offer of forcign contributions and told the
Promoter to coordinate with the AdamsStafferto arrange the contributions.
b. On April 21,2022, the Turkish Official messaged the Adams Staffer, noting
that Armenian Genocide Remembrance Day was approaching, and repeatedly asked the Adams
Staffer for assurances that ADAMS would not make any statement about the Armenian Genocide.
The Adams Staffer confirmed that ADAMS would not make a statement about the Armenian
Genocide. ADAMS did not make such a statement.
© On November 21, 2022, the Promoter messaged the Adams Staffer that
Businessman-1 was visiting New York, and asked that ADAMS meet with Businessman-1.. In
Support of the requested meting, the Promoter stated that the Turkish University “gave support,
albeita little” ADAMS declined the meeting, stating that “they didn’t keep their word,” meaning
2
 |

hat Businessman-1 and the Turkish University had failed to fulfil their commitment to make at
Teast $25,000 in donations to the 2021 Campaign.
43. ERIC ADAMS, the defendant, also continued his agreement with the Turkish |
Official to assst in New York City's regulation of the Turkish House in exchange for frec or
heavily discounted trav benefits from the Turkish Airline for ADAMS and his associates
a. From on or about July §, 2022, to on or about July 12, 2022, the Turkish
Official exchanged messages with the Adams Staffer conceming business class upgrades on the
“Turkish Airline for intemational travel by four of ADAMS'sclose associates.
b. On July 11,2022, the Turkish Official met with ADAMS’ senior advisor
and the Adams Staffer, among others,a the Turkish House. In a message, the Adans Staffer
referred the Turkish Official to ADAMS's senior advisor, telling the Turkish Official, “ask [the
senior advisor] al your pending problems regarding tis building [that is, the Turkish House] .
Like FDNY approvals...”
In 2023 and2024, ADAMSsolicits and acceptsstraw contributionsfor his 2025 re-clecion
campaign
44. In 2023 and 2024, ERIC ADAMS, the defendant, again solicited and knowingly
accepted straw and foreign contributions, as part of his efforts (© raise funds for the 2025
Campaign.
45. In 2023, ERIC ADAMS, the defendant, directed his staf (0 devise a plan for
ADAMS to sccrely obtain llgal foreigndonationsoffered by the Promoter, and then Knowingly
accepted donations of foreign money through raw donors. ADAMS then attended a fundraiser
whereh thanked th true donors, who he knevw 10 be wealthy foreign nationals.
a In the summer of 2023, the Promote informed the Adams Staffer that he
could secure contributions tothe 2025 Campaign from Turkish nationals ifADAMS would attend
©
 |

an vent withthe foreign donors The Adams Staffer brought this opportunity to ADAMS, who
todevise plan to obian the legal
directed the Adams Staffer to work with the Adams Fundrsser
donations.
b The Adams Fundraiser suggested tha th tru forcign donors make thei |
contributions through straw donors considerably in advanceofthe vent at which ADAMS would
meet th true foreign donors, o that th event did not appear connected 0 the contributions. As
he Adams Staffer explained o the Adams Fundraiser in a text message regarding th planned
attendees, “Mayor knows most ofthem from turkey(.| The People who has business here as wel.”
“The Adams Stafferand the Promote agreed fo exceute tis plan, which ADAMS approved
The Adams Fundraise, the Promoter, and the Adams Stafer scheduled an
event for September 20, 2023 ina private oom at a Manhattan hotel, To conceal he event's ruc
purpose, the Promoter provided a PowerPoint presentation billing the event as dine hosted by
“Intemational Sustainability Leaders” with the subjct “Sustainable Destinations” and an
attendance pice of$5,000. The event was no publicizedo listed on ADAMS’s public calendar
“The Adams Fundraiser entered th event on ADAMS's private calendaras a “Fundraise for Eric
Adams 2025," withthe hos std as the Promote, a goal of“25k. and th note “Toal Submited
befor the event: $22,800."
4 Prior to the scheduled fundraiser, the Promoter collec payments of
$5,000 or more from attendees, manyof whom were forsign nationals. The Promoter then uscd
portion ofth atendecs” payments fo make straw donations o the 2025 Campaign, by sending
cash from the foreign national donors o the Adams Staffer, The Adams Staffer the dissibuied
$2,100 in cash foa eat thr straw donors who cach made an onlin 2,100 contribution (0 the
2025 Campaign.

“
 On September 20, 2023, the Promoter hosted the fundraiser, which
ADAMS, the Adams Fundraiser, the Adams Staffer, and foreign nationals who had contributed to
the 2025 Campaign via straw donors attended. In one videoof the event, the Promoter introduced
aforeign-national attendee to ADAMS, explaining that the attendee owned abusiness and lived in
London and Istanbul. ADAMS proceeded to thank the attendee.
46. On October 9, 2023, ERIC ADAMS, the defendant, attended a fundraiser at which
attendees agreed to make, and ADAMS agreed to accept, straw donations. The fundraiser was
organized by a Turkish American public relations representative (the “PR Representative”) and
the publisher ofa magazine targeted at Turkish Americans (the “Publisher”), both of whom were
associates of the Turkish Official, and hosted by the owner of a logistics company
(“Businessman-6"), who is part ofthe Turkish-American community in the New York City area.
a. From late August 2023 through early September 2023, the Adams Staffer
and the Adams Fundraiser discussed the particulars of the fundraiser, including the creation of a
unique fundraising link for the event, which the Adams Fundraiser ultimately created.
b. On September 12,2023, the PR Representative and thePublisherinstructed
Businessman-6 on how to make straw donations to the 2025 Campaign, using a system under
which the 2025 Campaign routed foreign donations through U.S. citizens, to make it appear that
the contribution came from a lawful source.
©. Beginning at least as early as September 29, 2023, the Adams Staffer sent
the Adams Fundraiser updates regarding how much money was being raised in connection with
the planned fundraiser. On October 8, 2023, the day before the event, the Adams Staffer and the
Adams Fundraiser exchanged the following messages:
Adams Fundraiser: And okay are they going to make the limit?

4s
 Adams Staffer: Yes] They said as agreed we will collet the 25K.
Adams Fundraisers Ok pers |
d. Also on October 8, 2023, the Airline Manager sent the Turkish Official the
unique fundraising link for the event.
At the October 9, 2023 fundraiser, Businessman told ADAMS that
Businessman-6 owned a large corporation and wished to contribute significant amounts ofmoney
o the 2025 Campaign. ADAMS told Businessman-6 to coordinate with the Adams Staffer
Busincssman-6 then explained to the Adams Staffer that his company employed many drivers and
that Businessman-6 would contribute to the 2025 Campaign through those employees. ADAMS
scheduled adinner with Businessman for carly November, which was canceled aft the federal
investigation into ADAMS’s conduct became public.
ADAMS and His Co-Conspirators Attempt to Conceal Their Criminal Conduct
47. Throughout the commission of the conduct described in paragraphs 1 through 46
of this Indictment, ERIC ADAMS, the defendant, and his agents and co-conspirators sought to
conceal their wrongful conduct from scrutiny by the public and law enforcement. As described
above, ADAMS repeatedly did not disclose the free and heavily discounted travel benefits he
accepted from the Turkish Official, the Promoter, and the Airline Manager; created a falsc paper
trail 0 suggest he had paid for this travel when, in fact, he had not; assured the Adams Staffer that
he had a practice of deleting all his messages with the Adams Staffer; and directed the Adams
Staffer to ensure that his activities in Turkey in 2021 were shielded from public view. Tn addition,
the purposeofconducting the straw donations discussed throughout this Indictment was to allow
ADAMS to benefit from illegal campaign contributions by concealing their true source.

6
 48. ERIC ADAMS, the defendant, and his co-conspirators and agents continued their
efforts to defeat scrutinyoftheir criminal conduct after the federal investigation into those crimes.
became known to them. On November 2, 2023, Special Agents of the Federal Bureau of
Investigation (th “FBI") exceed search warrants at, among other locations, the residences ofthe
Adams Fundraiser, Businessman-5, and the Adams Staffer. Fach took actions to conceal the.
criminal conduct they had committed with ADAMS.
a After leaming that FBI agents had arived at her residence, but before
answering their repeated knocks at her door, the Adams Fundraiser called ADAMS five times,
even though the agents had not yet given the Adams Fundraiser any indicationofthe purpose for
their visit, When the Adams Fundeaiser then spoke with the FBI agents, she agreed o discuss
many subjects, but refused to say who had paid for her 2021 travel to Turkey. As the FBL agents
departed the Adams Fundraiser’s residence, ADAMS attempted to call the Adams Fundraiser’s
phone. On the moming that the FBI agents executed this search, ADAMS had flown to
Washington, D.C. fora publicized official meeting, but upon learning about the search, ADAMS
canceled the meting and immediately returned 0 New York City
b. Businessman also agreed to speak with FBIagentsand acknowledged that
he and his employees had contributed to the 2021 Campaign. Businessman-5 further
acknowledged that he had spoken with the Turkish Official about his construction company's
fundraiser for the 2021 Campaign. But Businessman-5 led in order toconcealthe straw donations
he orchestrated, falsely denying that he caused his construction company to reimburse his
employees fortheircontributions and that he knew why the company had issued identical checks
10 ten employees for the amount of their contributions shortly before the fundraiser.

a
 |
c. ‘The Adams Staffer also agreed to speak with FBI agents and falsely denied
the criminal conduct of herself and ADAMS, among others. At one point during her voluntary |
interview, the Adams Staffer excused herself to abathroom and, while there, deleted the encrypted
messaging applications she had used to communicate with ADAMS, the Promoter, the Turkish
Official, the Airline Manager, and others,
4. On November 6, 2023, FBI agents executed a search warrant for the
electronic devices used by ERIC ADAMS, the defendant. Although ADAMS was carrying several
electronic devices, including two cellphones,hewas not carrying his personal cellphone, which is
the deviceheusedto communicate about theconductdescribed in this indictment. When ADAMS
produced his personal cellphone the next day in response to a subpoena, it was “locked,” such that
the device required a password to open. ADAMS claimed that after he leamed about the
investigation into his conduct, he changed the password on November 5, 2024, and increased the
‘complexityofhis password from four digits to six. ADAMS had done this, he claimed, to prevent
membersofhisstaff from inadvertentlyor intentionally deleting the contentsofhis phone because,
according to ADAMS, he wished to preserve the contents of his phone due to the investigation.
But, ADAMS further claimed, he had forgotten the password he hadjust set, and thus was unable
to provide the FBI with a password that would unlock the phone.
49. As the federal investigation into the criminal conduct of ERIC ADAMS, the
defendant, continued, so did efforts to frustrate that investigation.
a. On June 13, 2024, FBI agents interviewed Businessman-4 and the four
employeesofhis company through whom Businessman-4 had made straw donations to the 2021
‘Campaign, most of whom denied making straw contributions. Businessman-4 then contacted
Adams Employee-1, who, as discussed above, had asked Businessman-4 to make the straw

a
 |

donations
tothe 2021 Campaign. Later that day, Adains Employee-1 visited Businessman-4 at his
company’s offices. Adams Employee- stated that he had just met with ADAMS at City Hall.
Adams Employee-1 proceeded to discuss with Businessman-4 what had happened with the FBI
and encouraged Busincsman-4 to le to federal investigators. Adams Employee! then asked to
address Businessman-4's four employees who had made straw donations (0 the 2021 Campaign
and encouraged them 10 lic to federal investigators as well. Adams Employee-1 then took |
Photographsof the subpocna that had been issued to Businessman-4 0 send to ADAMS.
b. Onthe following day, Businessman-4 met again with Adams Employee-1.
‘Adams Employee-1 told Businessman-4 that he had met with ADAMS at City Hall earlier that day :
and that they had left their cellphones outside the room in which they metso that it wouldbe “safe”
to talk. Adams Employce-1 explained to Businessman-4 that although ADAMS was upset that |
law enforcement had approached Businessman-4, ADAMS believed that Businessman-4 would i
not cooperate with law enforcement, |
STATUTORY ALLEGATIONS
COUNT ONE
(Conspiracy to Commit Wire Fraud, Federal Program Bribery, and to Receive Campaign
Contributions By Foreign Nationals)
“The Grand Jury charges:
50. The allegations contained in paragraphs | through 49 of this Indictment are
repeated and realleged asifset forth fully herein.
SI. From at least in or about 2015 through at least in or about 2024, in the Southern
District of New York and elsewhere, ERIC ADAMS, the defendant, and others known and
unknown, willfully and knowingly combined, conspired, confederated, and agreed together and
with each other to commit offenses against the United States, o wit:

[3
 a wire fraud, in violationof Title 18, United States Code, Section 1343;
b. soliciting, accepting, and receiving a campaign contribution by a forcign
national, in violationofTile 52, United States Code, Section 30121(a)(2); and
c. bribery, in violationofTile 18, United States Code, Section 666a)(1)(B).
52. It was a part and object of the conspiracy that ERIC ADAMS, the defendant, and
others known and unknown, knowingly having devised and intending to devise scheme and
artifice to defraud, and for obiaining money and property by means of false and fraudulent
pretenses, representations, and promises, would and did transmit and cause to be transmitted by
meansofwir, radio, and television commanication in intesta and foreign commerce, writings,
signs, signal, pictures, and sounds, for the purpose of executing such scheme and artifice, in
violation of Tite 18, United Stats Code, Section 1343
53. Itwas furthera pat and objet ofthe conspiracy that ERIC ADAMS, th defendant,
and others known and unknown, would and did knowingly and willfully solicit, accept, and
receive, directly and indirectly, a contribution and donation from foreign national, and xpress
and implied promises 0 make a contribution and donation, in connection witha local election, 10
wit, mayoral clctions in the CityofNew York, aggregating $25,000 and mor in a calendar year,
in violation of Tit 52, United States Code, Sections 30121(1)2) and 30109(d)(1)(AYi)
54. Itwas further apart and objet ofthe conspiracy that ERIC ADAMS, th defendant,
being an agent ofa local government, 0 wit, the Cityof New York, which, in a one-year period,
received benefits in excess of$10,000 under afederal program involvingagran, contract, subsidy,
loan, guarantee, insurance, and other form of federal assistance, corruptly solicited and demanded
for the benefit of a person, and accepted and agreed to accept, 4 thing of value from a person,
intending to be influenced and rewarded in connection with. business, a transaction, and a series

50
of transactionsofthe City ofNew York involving a thingofvalueof$5,000 and more, in violation
of Title 18, United States Code, Section 666@)(1)(B).
OvertActs
55. In furtherance of the conspiracy and to effect the illegal objects thereof, the
following overt acts, among others, were committed by ERIC ADAMS, the defendant, in the
‘Southern Districtof New York and elsewhere:
a In 2016, ADAMS accepted free upgrades to business class forhimself and
a companion on roundtrip flights from New York to India.
b. In July 2017, ADAMS accepted free business tickets forhimself and two
companions on roundtrip flights from New York to France, Turkey, Sri Lanks, and China.
In July 2017, ADAMS accepted a steeply discounted stay at the Bentley
Suiteofthe St. Regis Istanbul.
4. InOctober2017, ADAMS accepted free business tickets for himself and a
‘companion on roundirip flights from New York to China.
en January 2018, ADAMS accepted free upgrades to business class for
himselfand a companion on roundiip flights from New York to Hungary.
f. In November 2018, ADAMS directed the Adams Staffer to arange to
aceept contributionsofforeign funds from Businessman-1.
© InJanuary 2019, ADAMS accepted a free stay at the Cosmopolitan Suite of
a luxury hotel in Istanbul.
ho In January 2019, ADAMS met with Businessman-3 in Istanbul, where
ADAMS agreed to accept campaign contributionsofforeign money.

51
 i In December 2020, the Adams Employees solicited straw donations to
ADAMS’s campaign from Businessman-4.
i. In May 2021, ADAMS attended a fundraiser organized by the Turkish
Official, among others, where ADAMS accepted straw donations from Businessman-S.
kK InMay 2021, ADAMS submitted a false disclosure statement to the CFB
that concealed the straw donations from Businessman-S.
IL In June 2021 ADAMS solicited steeply discounted business class tickets,
stays ata luxury hotel and luxury resort, and transportation (including a domestic light and a car
and driver).
m. InJune 2021, ADAMS solicited a free hotel stay and freeuseofa VIP room
ina business class loungeofthe Turkish Airlines for the Adams Fundraiser.
n. In or about August 2021, ADAMS directed the Adams Staffer 10 obtain
contributions of foreign funds from the Turkish University
0. InSeptember 2021, ADAMS caused the FDNY to issue a letteracquiescing
inthe occupationofthe Turkish House.
Pp. In September 2021, ADAMS solicited and accepted steeply discounted
business clas tickets for himselfand a companion on roundtrip fights from New York to Pakistan.
4. In October 2021, ADAMS submitted a false disclosure statement 0 the
CFB that concealed the straw donations from the Turkish University.
vIn November 2021, ADAMS solicited and accepted a free car and driver
‘and meal ata luxury restaurant for himself and his companion in Istanbul.
s. In January 2022, ADAMS attended a meeting with the Promoter, among
others, where he agreed to accept contributions of foreign money to the 2025 Campaign.

52
 In July 2022, ADAMS’s senior advisor and the Adams Staffer met the
Turkish Official at the Turkish House, and the Adams Staffer identified ADAMS’s senor official
as the pointof contact forthe Turkish Official’s “pending problems regarding” the Turkish House
such as “FDNY approvals”
uw. In July 2022, the Turkish Official arranged to provide business class
upgrades on the Turkish Airline for four ofADAMS’s close associates.
Vv. In Seplember 2023, ADAMS attended a fundraiser where he thanked
foreign donors for contributions of foreign money to the 2025 Campaign made through straw
donors.
Ww. In October 2023, ADAMS attended a fundraiser where he directed the
Adams Staffer to coordinate the receiptofstraw donations from Busincssman-6
(Title 18, United States Code, Section 371.)
COUNTTWO
(Wire Fraud)
The Grand Jury further charges:
56. The allegations contained in paragraphs | through 49 of this Indictment are
repeated and realleged as ifset forth fully herein.
57. From at least in or about 2018 through at least in or about 2024, in the Southern
District of New York and elsewhere, ERIC ADAMS, the defendant, knowingly having devised
and intending to devise a scheme and artifice to defraud, and for obtaining money and property by
means of false and fraudulent pretenses, representations, and promises, transmitted and caused to
be transmitted by means of wire, radio, and television communication in interstate and foreign
commerce, writings, signs, signals, pictures, and sounds, or the purpose ofexecuting such scheme
and artifice, to wit, ADAMS participated in a scheme to fraudulently obtain Matching Funds for
53
the Adams Campaigns by falsely claiming that contributions qualified for Matching Funds when,
in fact thosecontributionsdid not.
(Title 18, United States Code, Sections 1343 and 2.)

COUNT THREE
(Solicitation ofa Contribution by a Foreign National)
“The Grand Jury further charges:
58. The allegations contained in paragraphs 1 through 49 of this Indictment arc
repeated and realleged as ifset forth fully herein.
59. In or about 2021, in the Southern District of New Yok and elsewhere, ERIC
ADAMS, the defendant, knowingly and willfully solicited, accepted, and received, and aided and
abetted and willfully caused the solicitation, acceptance and receipt of, contribution and donation
from a forcign national, and express and implied promises to make a contribution and donation, in
connection with a local election, to wit, mayoral elections in the City of New York, aggregating
$25,000 and more ina calendar year.
(Title 52, United States Code, Sections 30121 and 30109(d)(1)(A), and
“Title 18, United States Code, Section 2.)
COUNTFOUR
(Solicitation ofa Contribution by a Foreign National)
“The Grand Jury further charges:
60. The allegations contained in paragraphs 1 through 49 of this Indictment are
repeated and realleged as ifset forth fully herein.
61. In or about 2023, in the Souther District of New York and elsewhere, ERIC
ADAMS, the defendant, knowingly and willfully solicited, accepted, and received, and aided and
abetted and willfully caused the solicitation, acceptance and receipt of, a contribution and donation

54
 |

from a foreign national, and express and implied promises to make acontribution and donation, in
‘connection with a local election, to wit, mayoral elections in the City of New York, aggregating
$25,000 and more inacalendar year.
(Title 52, United States Code, Sections 30121 and 30109(d)(1)(A), and
“Title 18, United States Code, Section 2.)
COUNT FIVE
(Bribery)
“The Grand Jury further charges:
@. The allegations contained in paragraphs 1 through 49 of this Indictment are
repeated and realleged asifset forth fully herein.
63. From at least in or about the summer of 2021, through at least in or about the |
summer of 2022, in the Souther District of New York and elsewhere, ERIC ADAMS, the
defendant, being an agent ofa local goverment, to wit, the City of New York, which, in a one-
year period, received benefits in excessof $10,000 under a federal program involving a grant,
contract, subsidy, loan, guarantee, insurance, and other form of federal assistance, cormuptly
solicited and demanded for the benefit ofa person, and accepted and agreed to accep, a thing of
value from a person, intending to be influenced and rewarded in connection with business, a
transaction, and a series of transactions of the City of New York involving a thing of value of
$5,000 and more, to wit, ADAMS solicited and accepted free and heavily discounted luxury travel
benefits from the Turkish Official and others in exchange for intending to be influenced in
connection with the City of New York’s regulationofthe Turkish House, located at 821 United
Nations Plaza, New York, New York.
(Title 18, United States Code, Sections 66(a)(1)(B) and 2)

55
 FORFEITURE ALLEGATIONS
64. Asa resultofcommitting one or moreofthe offenses alleged in Counts One, Two,
and Five of this Indictment, ERIC ADAMS, the defendant, shall forfeit 10 the United States,
pursuant to Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United States Code,
Section 2461), any and all property, real and personal, that constitutes or is derived from
proceeds traceable to the commission ofsad offenses, including but not limited 10 a sumof money
in United States currency representing the amount ofproceeds traceable to the commissionof said
offenses.

56
 |

Substitute Assets Provision

65. Ifany of the above-described forfeitable property, as a resultof any act or omission
of the defendant
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third person;
c. has been placed beyond the jurisdiction of the Court;
d. has been substantially diminished in value; or
©. has been commingled with other property which cannot be subdivided
without difficulty;
itis the intent of the United States, pursuant to Title 21, United States Code, Section 853(p) and |
Title 28, United States Code, Section 2461(c), to seek forfeiture of any other property of the |
defendant up to the value of the above forfeitable property.
(Title 18, United States Code, Section 981;
“Title 21, United States Code, Section 853; and
Title 28, United States Code, Section 2461.)

——
_ _DimiopUelliomer |
FORE » DAMIAN WILLIAMS |
United States Attorney

57