UPDATED, 10/14/19, 3:15 PM:

The two men who set up a business in Nevada last year and who were indicted last week with two of Rudy Giuliani’s associates originally named it Cannabis Management Group.

The company was incorporated on Sept. 14, 2018. Ten days later, they changed the name to Strategic Investment Group, thus masking the true purpose, according to an amendment filed with the articles of incorporation. (The purpose of the company, as required by law to be listed on the articles, is: “Any legal purpose”.)

I see.

It’s unclear why they changed the name, although the original leaves little doubt as to the true purpose and the new one is as vague as can be. At some point much later, they realized they had missed the deadline to apply for a pot license and could only get one if “we change the rules” though influencing potential governor and then-Attorney General Adam Laxalt.

UPDATED, 10/14/19, noon:

I talked to Vincent Aiello, the lawyer whose email address is listed as the resident agent who set up the company for the two men indicted last week in connection with a campaign financing scheme. He is based in Las Vegas with Greenspoon Marder, a huge firm with offices across the country.

Aiello, oddly, told me he was "made aware" that his name was associated with the company -- he seemed surprised that the firm had listed his email -- and said, "I really can't tell you anything" about the two men. When I pressed, he said, "I cannot comment."

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Two men indicted this week along with a couple of Rudy Giuliani associates set up a business last year in Nevada around the same time prosecutors allege the quartet was trying to secure a pot dispensary license.

Records on file with the secretary of state show that David Correia and Andrey Kukushkin set up a business in September 2018 called Strategic Investment Group, Inc. It was incorporated on Sept. 14, 2018, and those men are the only listed officers.

The focus of most media accounts has been on Igor Fruman and Lev Parnas because of their connections to Giuliani, who is President Trump’s personal lawyer, and their role in what happened in Ukraine. But it appears to have been Kukushkin and Correia who established this Nevada business, which remains active on the secretary of state’s site, and also met with so-far unnamed Nevada officials.

The business was incorporated here at a time when prosecutors allege the four men and a foreign national were planning to try to win a pot dispensary license.

From the indictment:

In early September 2018, Parnas, Fruman, Correia, Kukushkin, and Foreign National-1 met in Las Vegas, Nevada, to discuss the Business Venture. While in Las Vegas, Parnas, Fruman and , and Kukushkin also attended a political fundraiser for a State candidate in Nevada (believed to be former gubernatorial candidate Adam Laxalt). Shortly after that meeting, (the four defendants) began to formalize the Business Venture with Foreign National-1 and fund their lobbying efforts…”

This would coincide with the time they set up Strategic Investment Group with the help of Vincent Aiello, a Las Vegas lawyer and a partner at Greenspoon Marder. (I have reached out to Aiello.)

It also dovetails with Parnas, Fruman and Kukushkin attending a fundraiser for Laxalt, according to the indictment. “Shortly after that meeting, (the four defendants) began to formalize the Business Venture with Foreign National-1 and fund their lobbying efforts…” 

The indictment alleges that the four men tried to hide the foreign national’s involvement in what they were trying to do, “including any political contributions associated with the Business Venture." Although Laxalt and Wes Duncan, who was running for attorney general, later accepted (and now say they have returned) maximum $10,000 contributions from Fruman, there is no record of Strategic Investment Group giving any money to candidates.

After the September meeting, the scheme crystallized, prosecutors allege. From our story this week:

According to the indictment, defendant David Correia drafted a “table of political donations and contributions” that he circulated to the other defendants and the Russian national, laying out a “multi-state license strategy” that contemplated between $1 to $2 million in political contributions to state and federal political committees. The indictment states that the Russian national transferred two $500,000 payments in September and October 2018 to a corporate bank account controlled by Fruman, which was then used as an “attempt to gain influence and the appearance of influence with politicians and candidates.”

The defendants soon learned they had missed the deadline to apply for a pot license, so they “noted that they needed a particular Nevada State official, the position for which (Laxalt) was running, to ‘green-light to implement this.’” Soon after that discussion, the donations came from Fruman, and the indictment says they sought more foreign money to give to Laxalt.

Kukushkin, who helped to set up the Nevada business here in mid-September of last year, is quoted in the indictment as saying he was “present at all the scheduled meetings with officials in Nevada.”

One Laxalt spokesman has said the former attorney general did not know Fruman, even though he gave the former attorney general a maximum contribution and attended a fundraiser for him. But it is not known yet whether Laxalt was one of the “officials in Nevada” that Kukushkin met with. Indeed, if Kukushkin met with several Nevada officials, the question remains: Who were they?

In what appears to be an unrelated twist, records show Fruman and one of his Ukranian associates set up a business in Nevada called Black Sea Prospects more than 20 years ago. It is now defunct.

Strategic Investment Group, Inc. by Jon Ralston on Scribd