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16. On or about April 22, 2019, WeBuildTheWall, Inc. transferred $50,000 to a for-profit Entity known to
17. On or about April 26, 2019, Unindicted Co-Conspirator Entity 2 transferred $25,000 to a for-profit
18. On or about May 1, 2019, Entity 1 transferred $20,000 to pay off a balance on a credit card that
19. On or about May 21, 2019, WeBuildTheWall, Inc. transferred $30,000 to Unindicted Co-Conspirator
20. On or about June 5, 2019, Unindicted Co-Conspirator Entity 2 transferred $20,000 to Entity 1.
21. On or about June 6, 2019, Entity 1 transferred $20,000 to Unindicted Co-Conspirator 1.
22. On or about June 24, 2019, at a fundraising event for WeBuildTheWall, Inc., Bannon stated
23. On or about July 3, 2019, WeBuildTheWall, Inc. transferred $48,762 to Unindicted Co-Conspirator
24. On or about July 15, 2019, Unindicted Co-Conspirator Entity 2 transferred $20,000 to Entity 1.
25. On or about July 17, 2019, Entity 1 transferred $20,000 to Unindicted Co-Conspirator 1.
26. On or about July 1, 2019, WeBuildTheWall, Inc. transferred $50,000 to an account controlled by an
27. On or about July 23, 2019, the account controlled by Unindicted Co-Conspirator 3 transferred
28. On or about August 22, 2019, WeBuildTheWall, Inc. transferred $66,760.62 to Unindicted Co-
29. On or about September 13, 2019, Unindicted Co-Conspirator Entity 2 transferred $20,000 to Entity 1.
30. On or about September 17, 2019, Entity 1 transferred $20,000 to Unindicted Co-Conspirator 1.
the Grand Jury (“Unindicted Co-Conspirator Entity 2”);
Entity known to the Grand Jury which was controlled by Unindicted Co-Conspirator 1 (“Entity 1”).
belonged to Unindicted Co-Conspirator 1;
Entity 2.
“remember, all the money you give goes to building the wall;”
Entity 2.
associate of Unindicted Co-Conspirator 2 (“Unindicted Co-Conspirator 3”).
$20,000 to Unindicted Co-Conspirator 1.
Conspirator Entity 2.
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