The UN documents, and the “ten-year void”
The Government held the founding UN documents before indictment. The motion says it kept them from the jury, altered a letter, argued against its own exhibit, and told the jury the years in question were empty.
He named the UN officials on day one
On September 26, 2019, the day of the search, he called the prosecutor himself. Her handwritten notes of that call name his two UN contacts, and her notes add: “Shd talk to Mr Schatz.” (ECF 150-1 at 32, 35)
Asa Saint Clair with Roland Schatz, NYSE · ECF 135 at 171
Michael Møller (front row, under “Empower”) and Asa Saint Clair (right, tan jacket) · SDG Cities event · DX 22
Asa Saint Clair, then WSA Treasurer, with Kofi Annan, 7th UN Secretary-General · PricewaterhouseCoopers dinner held during the World Economic Forum, Davos, January 24, 2018
ECF 150-1 at 32 · “talked to UN, told me to cooperate” · “#2 man: Michael Muller … advisor Mr. Schatz”
ECF 150-1 at 35 · “Shd talk to Mr Schatz”What she wrote, and what followed
ECF 150-1 at 32, 35 · Tr. 666 · ECF 199
- ECF 150-1 at 32“talked to UN, told me to cooperate.”
- ECF 150-1 at 32“#2 man: Michael Muller [Møller]” — “called last Feb thru advisor Mr. Schatz.”
- ECF 150-1 at 35“Shd talk to Mr Schatz.” “Runs UN GSII” — “advisor to #2.”
- The motion · Memo at 3“The Government contacted neither Møller nor Schatz, sought no records, and pursued neither lead.”
- The case agent · Tr. 666The investigation “reached out to people” across the investments he “marketed or pitched.”
- Schatz · PX 700, ECF 199Has since sworn that no United States investigator ever contacted him or Møller.
Who are Michael Møller and Roland Schatz?
The notes call Møller the UN’s “#2 man” and Schatz his advisor. These were not staff-level contacts.
The Director-General of the United Nations Office at Geneva oversees all UN activities at Geneva and represents the Secretary-General there. The post carries the rank of Under-Secretary-General, the highest rank in the UN Secretariat below the Secretary-General and the Deputy Secretary-General.
Michael Møller
He was Director-General of the United Nations Office at Geneva from 2013 to 2019, holding that rank. A trial witness described him as “director general of the United Nations in Geneva” and “the driving force” behind UNGSII. (Tr. 784)
Schatz, his Senior Advisor, has sworn to three meetings between Møller and WSA. In August 2017 he introduced Saint Clair to Møller at WSA’s work apartment across the street from UN Headquarters, “in furtherance of the UNGSII-WSA relationship established via MOU the month prior.” (ECF 135 at 51 ¶ 21)
In October 2017, at Saint Clair’s request, Schatz arranged a meeting at the UN Geneva campus between Møller and WSA’s Secretary-General, Dr. Giles Klein, “to discuss the possibility of World Sports Alliance taking an office at the UN-Geneva Campus” to assist with the remodel of the Villa Bocage. (ECF 135 at 51 ¶ 23)
At the 2018 UNGSII event in Davos, Saint Clair “had an opportunity to deepen WSA’s relationship with UN Director-General Moller.” (ECF 135 at 52 ¶ 27)
Roland Schatz
“From 2013-2019 I was Sr. Advisor to then UN Director-General Michael Moller in the Geneva Office.” He founded and runs UNGSII, “a private foundation established by Director-General Moller.” (ECF 135 at 50; Decl. ¶ 3) WSA and UNGSII signed a joint venture agreement on July 24, 2017. (ECF 150-1 at 21–24) Schatz has sworn that he audited WSA’s cryptocurrency and assisted its launch, that “WSA was a real intergovernmental organization” that “did in fact work with the United Nations,” and that no United States investigator ever contacted him or Møller. (ECF 135 at 51; PX 700, ECF 199)
Roland Schatz’s UN pass: “Director-General” · ECF 135 at 173
Møller, as Acting Director-General, on the UN Global Sustainability Index, April 25, 2014 · ECF 135 at 111
The UNGSII–WSA joint venture, July 24, 2017 · ECF 150-1 at 21Who the investigation reached, and who it did not
ECF 150-1 at 32, 35 · Tr. 188, 207, 210 · PX 700
- Michael MøllerDirector-General, UN Office at Geneva; Under-Secretary-General rank. Never contacted. (PX 700)
- Roland SchatzSenior Advisor to the Director-General; ran UNGSII. Never contacted. (PX 700)
- Tr. 188A “senior intergovernmental affairs officer in the Economic and Social Council Affairs Branch” of one UN department.
- Tr. 207Searched ECOSOC and General Assembly records and found no record of WSA observer status.
- Tr. 210 · on crossAsked whether an IGO without observer status “doesn’t necessarily mean that that organization doesn’t work with the U.N.,” he answered: “Correct.” “It just means it doesn’t have observer status?” “Correct.”
The rest of this page follows those two leads. First, the founding UN instruments the Government already held before indictment (§ VI). Then the 2017–2019 UN work itself, including the joint venture with UNGSII, the institute founded by Møller and run by Schatz, the same two men in her notes (§ VII; ECF 150-1 at 32).
The exhibit
PX 700 · ECF 199 at 1 · the Schatz affidavit, June 2026Addresses, phone numbers, emails, account numbers and signatures are blacked out. Tap a page to read it full size.
“The substitution of the UN‑NGO‑IRENE MOU for argument”
The motion calls the Memorandum of Understanding the decisive link in a founding chain the Government held before indictment.
- July 5, 2006 · DX 11The UN ECOSOC record book
A self-authenticating UN publication documenting the launch of the World Sports Alliance “concept” at UN Geneva, co-hosted by UN‑NGO‑IRENE, “urg[ing] the creation of a World Sports Alliance” and “appreciat[ing] the support” of UN DESA.
- January 26, 2007 · ECF 135 at 116–18The MOU
Signed by the Chief of the NGO Section, DESA, it formalized the cooperation “established, in 2006,” identifies WSA as UN‑NGO‑IRENE’s partner (id. at 126–27), and remains in force until terminated by two months’ written notice. No termination notice exists in the record.
- May 29, 2007 · DX 2The Rabat Declaration, UN document E/2007/NGO/1
Circulated by the UN Secretary-General, it “welcome[s] the admission” of sovereign states into WSA and recalls “the understanding reached between WSA and UN‑NGO‑IRENE.”
“No partnership”
Tr. 29 · ECF 135 at 116–18
- Opening · Tr. 29The defendant “knew full well that WSA had no partnership with the United Nations.”
- Same statement“[T]he defendant knew it.”
- The MOUIdentifies WSA as a partner; never terminated. (ECF 135 at 116–18, 126–27)
- On appealExistence conceded. (No. 22-2100, Doc. 60 at 14)
- In 2025Recast as “cumulative.” (ECF 146 at 22)
- “Defunct”The Government has never produced evidence that UN‑NGO‑IRENE was “defunct,” or explained how an MOU signed by the Chief of the UN DESA NGO Section, and never terminated, could be nullified.
DX 11 at 213 · Morocco pledges its support to the creation of WSA
The MOU · ECF 135 at 116
DX 2 · UN document E/2007/NGO/1 · “the understanding reached between WSA and UN‑NGO‑IRENE”“The altered letter (GX 2706)”
The motion calls GX 2706 “the only physically altered document in this entire fraud case,” introduced by the Government.
The “Partners” column
GX 2706 · ECF 136 at 3–5 · PX 11 · Tr. 959–66
- GX 2706The body text of a WSA letter, with every institutional identifier removed.
- On cross · Tr. 959–66The prosecutor used the stripped version to question Saint Clair on “affiliation,” while the complete original stayed out of the jury’s view.
- The original · ECF 136 at 3–5UN references under “Partners” (UN DESA and UN‑NGO‑IRENE), WSA’s insignia, and the member-state roster.
- The Government’s response · ECF 146 at 17Argument, with no evidence on the point.
- WSA, on the record · PX 11The document appears altered “in a series of strikes that only hide the names of partners and member states.” (ECF 150-1 at 41–42)
The original
GX 2706, as shown at trial
Original · close-up
GX 2706 · close-up
PX 11 · July 30, 2025“The Charter (GX 306)” and “The accession instruments (DX 6)”
“To support, at all times,” the United Nations’ goals. Those are the words of WSA’s own Charter, Section II, Article 4(A), and the Government put that Charter in evidence as GX 306.
The Government’s own exhibit
GX 306 · DX 2 · DX 6 · Tr. 217
- Tr. 217The Rabat Declaration is “simply a statement of an NGO.”
- Preamble (K) · page 5WSA “has concluded a partnership with the United Nations Department of Economic and Social Affairs (UNDESA), through the UN‑NGO‑IRENE.”
- Article 1(A) · page 6WSA is an intergovernmental organization “having been constituted on 29 May 2007 by the Rabat Declaration (UN-ECOSOC-E/2007/NGO/1) referred to as its constitutive Act.”
- Section II, Article 4(A) · page 9“The goal of the WSA is to involve itself to support, at all times, one or more of the United Nations’ Millennium Development Goals (MDGs) and, since September 25, 2015 to support, at all times, one or more of the United Nations’ Sustainable Development Goals (SDGs).”
- DX 6The Rabat Declaration and the accession instruments of thirty-one sovereign states, each pledging “to unconditionally support” WSA in furtherance of the UN’s development goals. Received without a limiting instruction (Tr. 824). No instance of fraud or forgery in them was shown to the jury.
GX 306 · the cover, with the Government’s exhibit sticker
GX 306 at 5 · Preamble (K)
GX 306 at 6 · Article 1(A)
GX 306 at 9 · Section II, Article 4(A)Highlighting added. Tap any page to read it full size.
If WSA is “to support, at all times,” the United Nations’ goals, was Saint Clair arrested and sent to prison for merely doing his job?
The exhibit
DX 6 · the cover
DX 6 at 2 · the member statesTap a page to read it full size.
“The Government’s temporal wall is a fiction”
The Government’s claim that WSA performed “no UN work” until 2019 (ECF 146 at 13), the motion says, collapses under its own exhibit: under the Charter’s “at all times” mandate, “there is no category of WSA activity that is not UN-mandated activity.”
A. UNGSII
- Who runs itUNGSII was created by UN Director-General Møller and run by his Senior Advisor, Roland Schatz. (ECF 135 at 110, 172)
- July 24, 2017The WSA–UNGSII Joint Venture Agreement formalized joint projects benefiting the UN Geneva campus. (ECF 150-1 at 21–24)
- What Schatz sworeHe audited the cryptocurrency, assisted its launch, introduced Saint Clair to investors, and “WSA was a real intergovernmental organization” that “did in fact work with the United Nations.” (ECF 135 at 51 ¶¶ 16, 24, 46, 64, 70)
- The Government’s responseUNGSII is “not part of the UN” (ECF 146 at 23–24), without addressing the agreement’s content: a remodeling project at UN Geneva.
B. UNMAS
- After April 30, 2017The UN Office on Sport for Development and Peace closed, and WSA moved to “take over” (Tr. 969–70), as its Charter mandates.
- Held before indictmentA UNMAS award issued to Saint Clair personally (PX 33; ECF 136 at 6).
- Held before indictmentA UNMAS Letter of Understanding naming WSA a “Champion.” (PX 32; ECF 174 at 38)
- Held before indictmentPhotographs of WSA’s turf in the UN Visitor’s Lobby. (DX 17; ECF 174 at 28)
- Held before indictmentThe UN’s own “Collaborative Partner” signage: DX 19, redacted at trial; PX 34, unredacted. (ECF 174 at 29–32)
PX 33 · UNMAS award
DX 17 · UN Visitor’s Lobby
DX 19 · redacted, as shown at trial
PX 34 · the same sign, unredacted
PX 34 · close-up: “through collaborative partnerships with the World Sports Alliance”C. The continuous arc vs. the fabricated timeline
A decade of “non-existence”
Tr. 1041 · ECF 146 at 13–14 · Tr. 511–12, 574–75
- Closing · Tr. 1041“[N]o evidence of any interaction” between WSA and the UN from 2008 to 2018.
- 2025 · ECF 146 at 13–14No “UN-associated work” before April 2019.
- July 2017The UNGSII Joint Venture. (ECF 150-1 at 21–24)
- August 2017He met Director-General Møller, corroborated by Schatz. (ECF 135 at 33, 52)
- August 2017A defense witness met him inside the UN. (ECF 135 at 80)
- 2018 · a Government witness, on directShe went with him into UN headquarters to view event space for a WSA fundraiser, saw him interact with UN staff, and described it as “nothing abnormal.” (Tr. 574–75)
- 2018 · the Government’s cooperating insider, on crossHe had been inside UN headquarters with Saint Clair at a UN conference: “You understood that there was a relationship between the U.N. and World Sports Alliance; right? A. Yes, that was my understanding.” (Tr. 511–12)
- 2006 and 2019 · the same UN officialAmir Dossal is listed as a leader of the July 5, 2006 ECOSOC meeting where WSA was launched (PX 888 at 3). Schatz introduced him to Saint Clair in 2019 (ECF 135 at 50 ¶ 14).
- April 2019Photographs show them together inside UN headquarters on April 4, and outside it before the UN banner for the International Day of Sport for Development and Peace. (PX 878, 879; Saint Clair Decl. ¶¶ 8–9)
Exhibit A · the ten-year “void” vs. the documented UN engagements
Exhibit B · the unbroken arc, 2006–2019D. No falsity in his UN statements
- What he inherited in 2016“[A]n IGO with 30 plus member states, a 2007 UN-signed MOU designating WSA as a partner, ratified by official UN document DX 2 and a charter mandate to support the UN goals.”
- 2017–2019He raised funds on the basis of operating WSA as documented.
- 2019When WSA performed its chartered mission with UNMAS, the UN issued him a personal award (ECF 136 at 6), and inside the UN, WSA was a “Collaborative Partner.” (PX 34; ECF 174 at 31)
- The law“Where a defendant’s statement is capable of being true and later borne out by performance, the Government cannot prove falsity.” (United States v. Connolly, 24 F.4th 821, 835–36 (2d Cir. 2022))
Exhibit C · documented UN engagements, 2017–2019 · the Møller rows highlightedThe exhibit
PX 32 · ECF 174 at 39 · the UNMAS Letter of UnderstandingAddresses, phone numbers, emails, account numbers and signatures are blacked out. Tap a page to read it full size.