A Moldovan Politician's $85,000 PR Campaign - in America
December 20, 2024
Shortly before Moldova’s recent presidential elections and referendum on EU Accession, a high powered Washington DC based Public Relations and Lobbying firm was contracted to burnish the image of presidential hopeful Vasilie Tarlev and to arrange high level meetings for him with American political officials and think tanks.
The firm is Qorvis Holding Inc. and they signed an $85,000 contract in support of Mr. Tarlev on September 6th 2024. In compliance with the Foreign Agents Registration Act (FARA), Qorvis filed details about this contract with the Department of Justice.
This put Mr. Tarlev in an elite group of the prestigious firm’s clients who, in this reporting period, include the Kingdom of Saudi Arabia, government of Cambodia, Republic of Equatorial Guinea and others.
According to the contract the firm was to provide Mr. Tarlev with the following services over a proposed 8 week program (with the option to extend):
Under the proposed 8-week plan the firm would research Mr. Tarlev’s reputation and develop strategies for messaging and outreach to US Officials, Members of the House of Representatives and US Senate.
Qorvis received a $45,000 retainer fee on September 30th and was due to be paid the balance of $40,000 on October 10th.1
As part of Moldova Matters’ previous investigation into the foreign influence efforts of Stanislav Pavlovschi I contacted various US think tanks and found no indication that Mr. Tarlev had any meetings with them. Further, at least from public media, there is no indication that Mr. Tarlev ever made his planned trip to the US for high level meetings. Qorvis is a global firm and it is possible that priorities have changed and they are supporting him in the EU or elsewhere. Until additional filings are made or other facts come to light we cannot know what Mr. Tarlev has actually done under this contract.
What we can do is look into who signed an $85,000 contract on his behalf. But first…
Who is Vasilie Tarlev?
This was the question that had Moldova buzzing last June when Tarlev announced that he would be running for president as an independent. Tarlev had previously served as prime minister of Moldova from 2001 - 2008 under Voronin’s Communist government before beginning a long slide into political obscurity.
While prime minister Tarlev was a major support of closer ties with Russia and was decorated by Vladimir Putin with the “Order of Friendship” for:
"great contribution to the development of economic, humanitarian and business collaboration with the Russian Federation"
In 2012 he founded the “Renaissance" Party, leading it in the 2014 parliamentary elections and garnering 0% of the vote. He then tried to run for president in 2016 but did not gather enough signatures for ballot access.
In the years since, Tarlev disappeared from the political scene as his Renaissance Party became defunct and then was “acquired” by fugitive oligarch Ilan Shor. Under new management Renaissance gathered unto itself defecting Socialist Party MPs and became one of the core parties of Shor’s “Pobeda” (Victory) block.
Tarlev’s plan to run as an independent in 2024 was quashed by the Central Election Commission (CEC) which found him to be coordinating with the “Future of Moldova” party (which he also founded) and forced him to run under that branding.
As soon as he announced, Moldovan journalists began to find ties between Tarlev’s political resurgence and Ilan Shor. Newsmaker reported that Tarlev was chosen from a list of candidates Shor was considering supporting in the election and that his candidacy was decided in Moscow. His own party’s vice president asserted that Tarlev had joined Shor. During the campaign, investigative outlet CU Sens infiltrated parts of Shor’s voter bribery network and discovered that participants in Tarlev events were being illegally paid to be there. Tarlev denies any links to Ilan Shor
Tarlev ended the election with 3.19% of the vote. His campaign was reported to be over 500,000 lei in debt with the CEC referring questions about his campaign finance to Anti-Corruption Prosecutors.
So Who Paid Qorvis?
While it would be completely legal for Mr. Tarlev or his political party to pay Qorvis directly for these services they did not. Instead he has benefited from the support of a US based non-profit originally called the “American Charity Fund for Helping Children of Pridnestrovie and Moldova Inc.” (Pridnestrovie is the Russian name for Transnistria). This non-profit publicly rebranded in 2021 as the “American Charity Fund for Helping Children of Ukraine and Moldova Inc.” As such it goes by the rather clunky acronym ACFHCUM.
According to their website the organization was “established in 2014 after the conflict in Eastern Ukraine” and is “devoted to provide [sic] opportunities to young people in Ukraine and Moldova region.” They list their goals as supporting children’s education, preventing young people from being involved in illegal activities and setting:
“meetings with Government Officials, Cultural, Civic and Business Leaders to present the importance of the region to strategic U.S interests and explore potential avenues of cooperation between the region and the U.S.”
While the organization was formed in 2014 there was no mention of Ukraine in either their name or their mission at that time. There was also no mention of government contacts at that time with their original primary goals stated in non-profit tax filings as:
"Provide for the children of Prednestrovie and Moldova funds for daycares, schools and children's hospitals."
"Organize for the children of Pridnestrovoie and Moldova fun events and trips"
ACFHCUM lists 3 officers in their organization, Nina Morozova (President), Sam Alaverdov (Director) and Olga Morozova (Director).
The organization is registered at 33 Laurel Hill Dr, Valley Stream, NY 11581, USA which is also the home address of Sam Alaverdov. Mr. Alaverdov is listed as the primary contact for the organization on their website, facebook page and other public materials.
Why is ACFHCUM funding Vasilie Tarlev?
In order to better understand the relationship between this non-profit and Mr. Tarlev I sent emails with questions to Sam Alaverdov and to Olga Morozova. I was unable to find public contacts for Nina Morozova who appears to be Olga’s elderly mother.
Neither director responded to my email but I was able to reach Sam Alaverdov via Telegram. After introducing myself and Moldova Matters I asked him why the “American Charity Fund for Helping Children of Pridnestrovie and Moldova Inc.” was financing a PR contract for Vasilie Tarlev. Mr. Alaverdov initially claimed that ACFHCUM no longer exists.
After his initial claim that the non-profit no longer exists, and apparent attempt to deny the FARA filing, I sent Mr. Alaverdov a screen shot of his name and signature on the contract. He then told me I need to “Check the name of the company” to which I replied with screenshots of ACFHCUM’s name, address, his title, etc.
Note: It was possible that Mr. Alaverdov was referring to the name change where “Prednestrovie” was removed and “Ukraine” added. This did not actually constitute a change of company or legal entity in any way.
After this Mr. Alaverdov confirmed that this was him referenced in the contract. Asked why ACFHCUM was funding Mr. Tarlev he replied “I like him.”
Mr. Alaverdov refused to answer questions about the source of the money ACFHCUM was spending on Mr. Tarlev except when I asked whether the money came from outside the United States, to which he answered “No.”
After this he stopped answering questions and deleted his profile picture on Telegram.
Digging into The American Charity Fund for Helping Children of Pridnestrovie and Moldova Inc.
To try and understand why ACFHCUM chose to support Vasilie Tarlev’s PR campaign and where this funding originated from I took a closer look at this non-profit. This revealed a fairly unusual operational history, but before we get into that we need to look at some basics of how American non-profits are legally structured.
When most people think of a non-profit NGO in the US you are thinking of a 501c3 registered entity. 501c3’s are traditional charities or non-profit religious, educational, or scientific institutions. Their purpose is to support the general public and they are not required to pay federal income taxes. Additionally, donations to a 501c3 are tax-exempt meaning that donors get a tax write off for making donations.
The original 2014 goals of ACFHCUM are firmly within the normal uses of a 501c3 - gathering funds to support Moldovan and Transnistrian children, organizing kids events, etc. And between 2014 and 2020 ACFHCUM filed their form 990EZ IRS reports indicating that they are a 501c3 entity.
In these years ACFHCUM largely did nothing. In every year except 2019 they reported $0 raised, $0 spent or donated every year. The one exception was 2019 when ACFHCUM reported that they received $15,000 in “contributions, gifts, grants or similar” and they spent $15,000 in “professional fees and other payment to independent contractors.”
So in the early years of this non-profit they made no charitable donations and recorded only this one in-and-out donation and payment.
Changing the Non-Profit Focus
In ACFHCUM’s 2021 filing of form 990EZ there is an important change. The non-profit no longer lists itself as a 501c3 entity but is now listed as a 501c4. Unlike a 501c3 this organizational form has a mission of promoting social welfare which can include lobby and advocacy work, as well as some types of political activity, so long as they advance their social welfare mission. Importantly, while a 501c4 is exempt from Federal income taxes, donors to such an organization do not themselves get a tax write-off. This makes raising money through a 501c4 for charitable donations (e.g. funding a children’s hospital) much harder as the structure is not designed for it. This filing also reflected their name change.
In the years that follow ACFHCUM’s IRS 990EZ fillings show a very similar situation as before. There are neither donations nor expenditures in either 2021 or 2022 listed - an important issue that we will return to below. In 2023 they list $17,000 in “program service revenue” and $10,000 in payments of “professional fees and other payment to independent contractors.” An additional $6,974 are listed as other expenses, the bulk of which, $5,936 is categorized as “Automobile & Travel Expenses” and the rest is filing fees and accounting. The remaining $26 of the $17,000 is offset by a $25 debt from bank fees back in 2019 resulting in a net result of $1 on the balance sheet at the end of the year.
Taken together we have a non-profit that is mostly inactive except in 2 years when it receives income and expenses that neatly cancel each other out. There is no record of donations towards any of the causes that they claim that they support.2 The shift to a 501c4 would allow the support for Vasilie Tarlev if it is in line with their mission but there is no record in their tax filings indicating that they have done anything like this before.
But they have. Which gets us to some major discrepancies in the official tax filings of ACFHCUM - and some increasing and strange turns in this story.
2021 Congressional Delegation to Ukraine
In August 2021 a 501c3 organization called The Humpty Dumpty Institute (HDI) organized a congressional delegation (CODEL) to Ukraine. According to their press release the purpose of the trip was for the US congressmen to “get a better understanding of the complexities of the region through meetings with the Ukrainian government, business, and cultural leaders.” The trip was attended by Rep. Tony Gonzales (R-TX), Rep. Barry Moore (R-AL) and Rep. Troy Nehls (R-TX).
In addition to the congressmen, Sam Alaverdov attended the CODEL and can be seen in the left of the picture above.
According to trip filings with the House Committee on Ethics3 the American Charity Fund for Helping Children of Pridnestrovie and Moldova Inc. is listed as a secondary sponsor of the trip (under the old name). The Humpty Dumpty Institute was the primary trip sponsor with organizational responsibilities. They accepted a grant / donation from ACFHCUM in order to finance the trip as a secondary trip sponsor. A third sponsor is listed as the company Noosphere Ventures L.P. which provided in-kind support.
On these disclosure forms Sam Alaverdov claims that ACFHCUM is a 501c3 organization4 and that it has given a grant to HDI for organizing this trip. A press release about this CODEL is the only actual activity that is listed on the ACFHCUM website.
Referring to information we have already discussed above, ACFHCUM claimed neither income nor expenses in 2021 on their official tax filings. This CODEL was noted at the time as the most expensive of the year with costs for the congressmen and their wives / friends alone totaling more than $46,000. That is in addition to Sam Alaverdov’s travel and lodging as well as the HDI staff.
Sam Alaverdov, ACFHCUM and HDI all claim that the financing, in whole or part, came from ACFHCUM - but they did not report it in their available public filings.
Note: I wasn’t the first person to ask Mr. Alaverdov about this and there’s a bit more of a story around this CODEL but it goes outside of the remit of this article. I’ll leave a lengthy digression on this topic and the various controversies and characters in a footnote.5
Fundraising in Support of Ukrainians
Following the outbreak of the full scale invasion ACFHCUM setup a facebook page and a fundraiser on Fundly to raise money for “the citizens and children of Ukraine.” On the facebook page they claimed that they will “provide assistance in moving from this besieged territory, provide first aid and hygiene products, organise hot meals and many other forms of assistance.”
The Fundly campaign is now defunct and the website does not publicly show the results of closed projects. But based on snapshots from the wayback machine the fundraiser didn’t raise much money - around $1500 in the latest version available. Still, “not a lot” does not equal “zero” which is how much money ACFHCUM claims they received as donations in 2022 and 2023.
Bringing This All Together
The American Charity Fund for Helping Children of Ukraine and Moldova Inc. does not and has never operated like a typical non-profit. At no time in their history were they clearly raising money publicly for the causes that they claim to support or dispersing money as charitable donations. Most of their reported financial activity in 2019 and 2023 involved nearly identical sums moving in and out of the organization in the same year - mostly as round numbers, all towards contractors or expenses.
Also important is the apparent unreported financial activity - both in small dollar donations for Ukrainian children, and sponsoring the most expensive congressional delegation of 2021.
It is entirely possible that there are reasonable explanations for this unusual behavior, but given the opportunity Sam Alaverdov chose not to provide them to me.
Regarding our primary concern, the $85,000 PR contract supporting Vasilie Tarlev, we can also draw some conclusions. ACFHCUM did not just have extra money lying on the shelf and decide to support a politician because Sam Alaverdov “likes” him. Year after year this organization had no income at all and nothing on the balance sheet before suddenly signing a contract representing more than all of their (reported) past income combined.
It’s possible that these answers will be available next spring when ACFHCUM files its 2024 form 990 with the IRS. It is also possible that their past history of very questionable filings means that there won’t be much more information there.
Finally, because closed door meetings with politicians are, by their nature, non-public, we don’t know what Mr. Tarlev is doing with all of this expertise and sponsorship. He has not made any posts about politicians outside Moldova recently except one - a post praising Donald Trump on his re-election.
This payment cannot be confirmed yet as it rolled over into a new filing period. Qorvis closed this reporting period on September 30th and is due to make another supplemental filing in 6 months.
To be clear, this does not itself indicate wrong doing. Independent contractors could be consultants helping with orphanages, etc in line with their mission. Being an NGO that is bad at raising money isn’t all that uncommon. It is a bit strange to bear the expense of maintaining a non profit that does nothing (accounting fees, filing fees, bank fees, etc) but certainly not illegal.
You can see the filings from each of the 3 congressmen here.
We know that ACFHCUM filed their 2021 990EZ listing themselves as a 501c4. In order to transition from a 501c3 to a 501c4 an organization would need to file a final 990EZ terminating its past activities and then file new paperwork reflecting the change of mission, etc with the IRS for a new approval. There are no publicly available records showing that ACFHCUM did this. No documents on the termination of 501c3 status, final 990, new approval for 501c4, etc. Basically, at least according to what is findable online (and this all should be public) they just switched the checkbox on their 990 form between 2020 and 2021.
There is an additional issue because ACFHCUM is no longer listed as a tax exempt non-profit at the time of writing. There is also no listing of the organization under IRS databases of organization that had their tax exemption automatically revoked (for inactivity, etc).
Because of this we don’t know if ACFHCUM was a 501c3 when they “paid for” this congressional delegation or not. Or if they were compliant as a non-profit at all. There are too many gaps in the record - a record from the IRS that is not supposed to have gaps.
Researching this CODEL in order to better understand the role of ACFHCUM and Sam Alaverdov was very complicated. If you read the press releases from the Humpty Dumpty Institute (HDI), ACFHCUM and the House Ethics Committee pre-trip approval and post trip reports it all seems pretty run of the mill. Unfortunately there’s nothing unusual about non-profits and lobbyists paying for very comfortable travel arrangements for members of congress. Overall, the goals seem to be good - they met with Ukrainian officials and businesses as well as civil society actors around 6 months before the invasion began. Exchanges like this are a good thing. The main question here is what ACFHCUM and Sam Alaverdov were doing and where the money came from.
But an additional oddity was the presence of Noosphere Ventures LP as a cosponsor (in-kind) of the trip. Noosphere Ventures is an American company owned by a Ukrainian entrepreneur named Max Polyakov. They invest in space related technologies and were at the time the controlling shareholders of Firefly Aerospace, a company producing small scale rockets for launch into low earth orbit. This company is less well known than SpaceX (and much smaller) but is a big deal in the space world as a NASA partner on the Artemis program alongside SpaceX and Boeing. Parts of the CODEL involved meetings with the then head of Ukraine’s space agency and Max Polyakov attended the trip. None of the press releases or public photos show any HDI staff (they were there) or Max Polyakov or Noosphere staff - the only confirmation that he was actually there comes from the Ukrainian space agency’s press release.
Things went wrong for this CODEL after the fact when American conspiracy theorists started doing their thing and finding a lot of catnip for the addled mind. A “news” website called “The National File,” founded by Alex Jones in 2019, published an article about the CODEL which was then republished through all the worst parts of the internet. The match that lit this inferno is the fact that the director of HDI at the time was Mark Epstein, brother of Jeffery Epstein. This combined with an unknown non-profit with the word “children” in the title and you get implications that something nefarious with orphans is going on. Round that out with a mysterious space company and alleged globalist masterminds (Soros, the Vatican, Israel, China, Ukrainian Nazis, Zionists, the deep state, the Clintons, etc etc - in this article everyone gets a moment in the spotlight). Olga Morozova is also apparently a researcher focused on infectious diseases (aka vaccine adjacent) so you get the whole gamut of right wing fever dreams here.
Fever dream or not, the article wonders how a “supposedly cash-strapped, ‘children’s non-profits” could fund a $46,000+ bill for the trip - a good question. The National File claims that they requested ACFHCUM’s form 990s regarding the trip spending and that Sam Alaverdov demanded that they pay him $30,000 in writing for them. But let’s be clear - The National File is not a news site and this, like the rest of their conspiracies, may just be a lie.
An additional twist came shortly after the CODEL when the US government forced Max Polyakov and Noosphere Ventures to divest from Firefly Aerospace in December 2021 for reasons of national security. While it is unclear why this happened Snopes had released an investigation earlier in the year showing that Polyakov was likely behind a large network of fake / scam dating sites held through various offshore entities which were being used to fleece lonely people with (kinda weird) kinks.
The National File claims that all these congressmen actively concealed their participation in the CODEL by not posting about it on their social media. At this point it isn’t possible to know if they did or didn’t post originally, or if they just deleted everything when the lunatic mob descended on this particular topic.
Wow, talk about investigative journalism! Hats off to you David on a very interesting article and well done!
Congratulations on your deep dive into investigative reporting. Very interesting. I enjoyed it.