Two questions for ACF (FBK)

Disclaimer
This text raises essential questions for the Russian opposition. Those aiming to gain power by promising to replace all the bad with the good must earn the trust of the citizens. Trust is not just a matter of belief, but also the matter of honesty and transparency. This discussion will focus on legal and financial transparency.
FBK is a Russian acronym for the Anti-Corruption Foundation.Editor's comment

"Treacherous" scheme

In the recent film series "Traitors" by Maria Pevchikh, significant attention is given to the dubious schemes for income legalization used in Russia during the 1990s. However, the legal structure of the Anti-Corruption Foundation (hereinafter referred to as FBK) in Europe raises similar questions.

Screenshot of the 2022 report
Screenshot of the 2022 report

A report from the non-profit organization Anti-Corruption Foundation Inc., which is the legal entity of FBK in the US (referred to as International FBK), appeared in the US tax registry. You can see the report here.

According to the report, the majority of the funds were not allocated to traditional democratic, anti-corruption, and anti-war projects typical for NPOs, but to "other" purposes.

Screenshot of the 2022 report
Screenshot of the 2022 report

The sizes and sources of major donations are restricted according to the report:

Screenshot of the 2022 report
Screenshot of the 2022 report

In 2022, almost $50,000 were spent on "representational expenses" for meetings with EU and US politicians. The report does not specify which meetings took place or their purposes.

Screenshot of the 2022 report
Screenshot of the 2022 report

Looking back at 2021, the tax report of International FBK for that year indicates nearly half a million dollars were spent on the Lithuanian company Posterum (Latin form "Future" or "Progeny") from Vilnius. According to the Lithuanian register of legal entities, this company provides legal and consulting services. However, to FBK, it provided different services—content creation for YouTube.

Screenshot of the 2021 report
Screenshot of the 2021 report

In 2022, transfers amounted to almost $1.4 million (out of approximately $1.8 million in total expenditures by the American FBK). The subject was similar — content production.

Screenshot of the 2022 report
Screenshot of the 2022 report

Thus, Posterum accounted for the majority of FBK's expenditures over two years.

Screenshot of the 2022 report
Screenshot of the 2022 report

The activities for which "Posterum" receives money from FBK resemble classic fee-for-service arrangements. However, in the financial reports, these transfers are marked as grants. Let's take a closer look at the grant recipient documentation.

Screenshot from the rekvizitai.vz.lt
Screenshot from the rekvizitai.vz.lt

In 2022 and 2023, "Posterum" recorded significant income. The workforce consists of ten employees, with an average salary of 4,300 euros.

Скриншот с сайта rekvizitai.vz.lt
Скриншот с сайта rekvizitai.vz.lt

The company's legal form is a non-profit organization (NPO), which means profit-making cannot be its primary activity.

The website looks like this:

Screenshot from the posterum.lt
Screenshot from the posterum.lt

It states that this is yet another anti-corruption organization.

Screenshot from the posterum.lt
Screenshot from the posterum.lt
WHOIS data from the  posterum.lt
WHOIS data from the posterum.lt

According to the WHOIS information for the company's website, it is the official informational resource of "Posterum." It also lists the cryptocurrency wallet address used by FBK.

Screenshot from the acf.international
Screenshot from the acf.international
Screenshot of Leonid Volkov’s tweet
Screenshot of Leonid Volkov’s tweet

Regardless of who uses the wallet (FBK's website, Volkov's Twitter, donations), the company claims it as its financial tool.

Judging by the Bitcoin address, the Lithuanian "Posterum," which receives grants from FBK, is an integral part of FBK. However, a wallet alone isn't enough to draw conclusions. So, let's visit the FBK merchandise store website.

Screenshot from navalny.shop
Screenshot from navalny.shop

Thus, by transferring money to "Posterum," FBK is essentially transferring money to itself.

Why does a non-profit organization with ten employees need millions of dollars? The money goes further. Let's look at the European transparency register.

Screenshot from transparency-register.europa.eu
Screenshot from transparency-register.europa.eu

This is the European branch of FBK. In 2023, it received substantial donations.

Screenshot from transparency-register.europa.eu
Screenshot from transparency-register.europa.eu

For instance, 4.5 million euros were received, presumably from "Posterum."

In other words, American funds are directed to a small NPO in Lithuania as a grant and then redirected to themselves as a donation. Both transfers are tax-exempt.

Why is this typically done, following business principles?

  1. Regulatory constraints. Not applicable here, as neither Lithuanian nor American law prohibits direct transfers between FBK entities;
  2. Tax optimization;
  3. Concealing financial connections and masking the source of funding. Complex chains can make it harder to trace the original source of funds;
  4. Money laundering. Funds don't necessarily have to be obtained illegally, but their distribution might have certain restrictions.

Any of these motives appear questionable for anti-corruption fighters.

The next connection between Posterum and FBK is dated July 2023, involving former FBK IT specialist and current security specialist Artem Ionov, linked to the "Navalny's SHIZO" installation incident:

On Friday night, a vandal who chalked the SHIZO (editor’s comment: SHIZO is an acronym of punishment cell in Russian )cell of Alexei Navalny was detained. Vilnius district police reported that on July 28, at 00:20, a man (born in 1974) chalked the sidewalk and the cell in a public place on Konstitucijos Avenue in Vilnius. The vandal was later identified as Mikhail Baranov, who regularly participated in actions against the Russian opposition, deeming it insufficiently pro-Ukrainian.

Ionov filed a complaint seeking Baranov's criminal prosecution:

Ionov requested Lithuanian police to initiate criminal proceedings against Baranov and deport him. Notably, Ionov filed the complaint on Posterum's letterhead, making the organization responsible for this complaint.

Our questions about our cooperation with «Posterum» Ionov read and said that he could not comment, but also he mentioned that "the document is protected from publication on the basis of the law of LR XI-1336 (Asmens duomenų apsauga tyrimo metu) and GDPR. Because this document contains my personal data. Therefore, please do not publish this document, thank you".

Our first question to FBK is: What is the purpose of using schemes involving substantial sums and tax loopholes? Why do they fund grants to themselves?

Who Actually Owns FBK?

Not Volkov, not Zhdanov, and not even Pevchikh. At least not in Europe.

Let's return to POSTERUM. Its director is a certain Justina Lapinskė, who shares a surname (considering Lithuanian language nuances) with Irena Lapinskiene, the head of the European FBK – Anti-corruption foundation Europe.

European FBK is located at Klaipėdos g. 7-18, LT-01117 Vilnius. Several other organizations are registered at this address. For example:

What about Posterum's address? Rugių g. 2, LT-08418 Vilnius. At the same address:

Screenshot from navalny.shop
Screenshot from navalny.shop

The purpose of transferring the store from commercial "Magna Futura" to non-profit "Posterum" remains unknown.

These are not all the companies registered at the mentioned addresses and related to various versions of the Lapinskas surname. But they are worth noting.

For instance, Digital duck, UAB is registered at Rugių g. 2, LT-08418 Vilnius, headed by Juliana Karlo. This company is noteworthy for its history – in 2021, after relocating to Lithuania, it was founded and led by Leonid Volkov.

Snapshot of rekvizitai.vz.lt / web.archive.org
Snapshot of rekvizitai.vz.lt / web.archive.org

After the asset ceased to be necessary for obtaining a residence permit, Volkov divested it.

At the address Rugių g. 2, LT-08418 Vilnius, another entity, Antidot Media, VšĮ, is registered, headed by the same Irena Lapinskiene. From the NPO's website, it's evident who the main content creator for this radio station is: Alexander Plyushchev.

Other media figures are also mentioned, including Michael Nacke and Valery Solovey. It’s worth noting that Leonid Volkov publicly claims, "Nacke is not an FBK employee."

Alexander Plyushchev did not respond to Sota's inquiries.

The chain of direct connections between legal entities associated with FBK and the Lapinskas family looks like this

Navis longa, UAB, founded by the Lapinskas family in 1994, owns Baltijos finansai, UAB. Baltijos finansai is the sole founder of Magna Futura, UAB, the former FBK merchandise store (in 2023 and early 2024). This former FBK merchandise store is the founder of... the European FBK.

We mention the cars indicated in brackets in the <a href=
We mention the cars indicated in brackets in the video (15:48)
Illustration by SOTA

Additionally, Posterum, which posted FBK's cryptocurrency wallet on its website and sells their merchandise, lists the email of "Baltijos Finansai" in its contact information.

The Lapinskas family are not nominal directors and founders: they have long been active in various activities, including political projects.

Justina Lapinske
@juste_kulbyte / instagram.com
Justina Lapinske
@juste_kulbyte / instagram.com

The aforementioned Demokratijos projektai, VšĮ, engages in political technology, while Every Human Being carries out human rights activities.

Connections with the Lapinskas family have been mentioned before in online publications. For instance, in a now-deleted (but preserved in screenshots and search engine references) Facebook post by Lithuanian Žilvinas Svitojus, which served as a source for Ionov's document regarding Baranov's deportation, their interactions were highlighted, and a partial schema of FBK's legal entities was presented. However, an erroneous conclusion was drawn about a connection between FBK and Khodorkovsky due to confusion with the legal names "Russia of the Future" (more on this later in the text).

Mindaugas Lapinskas. @mindaugas_lapinskas / instagram.com
Mindaugas Lapinskas. @mindaugas_lapinskas / instagram.com

A similar erroneous conclusion was made in a publication by the pro-Kremlin site FLB, which, without citing sources, described the familial ties of the Lapinskas. According to these sources, Mindaugas and Imantas are brothers, Irena is Imantas' wife, and Justina (Kulbite) is Mindaugas' wife.

It's noteworthy that Leonid Volkov follows these two people on Instagram and regularly likes Justina's posts, despite their non-political content.

Screenshot of Mindaugas' subscriber list on Instagram
Screenshot of Mindaugas' subscriber list on Instagram
Screenshot of Justina’s subscriber list on Instagram
Screenshot of Justina’s subscriber list on Instagram

Activists close to FBK told Sota that Mindaugas Lapinskas regularly collaborates with FBK and acts as a political strategist for various electoral campaigns involving its members, notably Irina Fatyanova's campaign in St. Petersburg in 2021. He allegedly proposed the slogan "I am not afraid, and you shouldn't be either." («Я не боюсь, и вы не бойтесь»)

Moreover, Lapinskas regularly participates in Free Russia Foundation accelerators, where Anna Veduta, former vice-president of FBK, transitioned to the role of director of strategic communications.

All Lapinskas family NPOs were established long before FBK appeared in Lithuania, even the organization that later became European FBK. Until February 2023, Anti-Corruption Foundation Europe, VšĮ, was named Future Russia Foundation, VšĮ.

The organization did not change its founder or director and has been controlled by the Lapinskas family since its inception. As mentioned earlier, it should not be confused with Mikhail Khodorkovsky's Future of Russia Foundation, registered in the UK—these are two completely different organizations, and the future European FBK has no connection to Khodorkovsky.

However, it is connected to FBK, as evidenced by the document fragment below.

It remains to be added that the NAVALNY brand is registered to Anti-Corruption Foundation Europe, whose ownership has been established above, and not to Alexei Navalny's heirs or the American FBK founded by the politician's associates.

FBK's question: What influence does the Lapinskas family have on FBK, do they lobby their interests through FBK, and why did they provide their business network for its operations?

Summary

Politics should be, if not transparent, then at least honest—especially for an opposition force whose goal is "not to lie and not to steal."

We do not know the reasons why FBK resorts to such unusual financial and legal schemes. As Russians whose interests are represented at meetings in Europe and the US by its members, we want to hear the politicians' answers to our questions.

Leonid Volkov immediately banned Sota's correspondent instead of engaging in dialogue.

Mindaugas Lapinskas did the same.