Justice Department's indictment of Semion Mogilevich

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16. YBM TECHNOLOGIES, INC. (“YBM TECHNOLOGIES”), a Pennsylvania corporation, was incorporated on May 13, 1991 and owned by defendant BOGATIN, who served as President at all times relevant to this Superseding Indictment until its assets were sold to YBM. YBM TECHNOLOGIES was located at 2935 Byberry Road in Hatboro, Pennsylvania. From approximately 1993 to August 1996, YBM TECHNOLOGIES served primarily as a purported vendor to YBM, providing consulting services, research and development, equipment and other magnetic products. YBM TECHNOLOGIES was not a YBM subsidiary company, but its assets were acquired by YBM from BOGATIN in or about August 1996. 17. TECHNOLOGY DISTRIBUTION LIMITED (“TDL”) was an offshore company incorporated in the Isle of Man, United Kingdom, in or about 1994. Defendant MOGILEVICH directed the creation of TDL, and at all times relevant to this Superseding Indictment was the beneficial owner and controlled its operations. From approximately 1995 to approximately February 1997, funds in TDL's bank accounts in Budapest were reported as cash assets on the books and records of ARIGON, and later UNITED TRADE. TDL served as an agent of UNITED TRADE from approximately April 1996 until early 1997. Thereafter, TDL acted as a purported vendor of UNITED TRADE. 18. ORIGON COMPANY LIMITED (“ORIGON”) was an offshore company incorporated on the island of Nevis in the Caribbean in or about June of 1995. FISHERMAN directed the creation of ORIGON. Defendants FISHERMAN and MOGILEVICH at all times relevant to this Superseding Indictment were the beneficial owners of ORIGON and controlled its operations. From approximately June of 1995 to approximately February 1997, funds in 10
ORIGON's bank account in Israel were reported as cash assets on the books and records of ARIGON, and later UNITED TRADE. ORIGON served as an agent of UNITED TRADE from approximately April 1996 until early 1997. Thereafter, ORIGON acted as a purported customer of UNITED TRADE. 19. BRITISH EUROPEAN MARKETING LTD. (“BEM”) was a private limited company incorporated in Cardiff, Wales, United Kingdom on or about January 19, 1996. BEM was formed by a former officer of ARIGON and a close associate of defendant MOGILEVICH to act as an agent of UNITED TRADE in the oil and petroleum industry. Its operations were conducted primarily in London, England. From approximately March of 1996 through May of 1997, funds in BEM’s bank account in London were reported as cash assets on the books and records of UNITED TRADE. BEM served as an agent of UNITED TRADE from approximately April 1996 until May 1997. The Securities Regulators 20. The United States Securities and Exchange Commission (“SEC”) was an independent agency of the United States government that regulated the securities industry within the United States. This included the regulation of the over-the-counter (“OTC”) securities market, that is, securities traded directly between securities brokerage firms and between brokerage firms and individuals. 21. The National Association of Securities Dealers, Inc. (“NASD”) was a self- regulatory organization of the United States securities industry responsible for the regulation of the OTC securities market, including the NASDAQ ("National Association of Securities Dealers Automated Quotation System") Stock Market. The NASD enforced its rules and regulations for 11
Page 1 and 2: IN THE UNITED STATES DISTRICT COURT
Page 3 and 4: operated businesses, described here
Page 5 and 6: Indictment, MOGILEVICH resided in B
Page 7 and 8: The Network of YBM Companies YBM Ma
Page 9: YBM Network of companies and did no
Page 13 and 14: 25. The Toronto Stock Exchange (“
Page 15 and 16: Network of YBM companies, including
Page 17 and 18: company ARIGON between approximatel
Page 19 and 20: for stock in YBM MAGNEX. As a resul
Page 21 and 22: investors, recorded, and caused to
Page 23 and 24: UNITED TRADE had a diverse customer
Page 25 and 26: productive between September and De
Page 27 and 28: UNITED TRADE and MAGNEX RT to be ap
Page 29 and 30: ARBAT, ARIGON, and MAGNEX RT; (2) e
Page 31 and 32: (b) On or about November 20, 1997,
Page 33 and 34: 43. At various times during the sch
Page 35 and 36: listed: Defendant Amount (a) FISHER
Page 37 and 38: and investing money received from t
Page 39 and 40: The Scheme To Defraud 9. The defend
Page 41 and 42: circumstances under which they were
Page 43 and 44: Bank of Scotland, London, England (
Page 45 and 46: 18 1/26/97 Facsimile of false audit
Page 47 and 48: (ph# 215-579-5695) to FISHERMAN, in
Page 49 and 50: Solis-Cohen, 111 South 15 th Street
Page 51 and 52: Overt Act Date Description Transfer
Page 53 and 54: Overt Act Date Description Transfer
Page 55 and 56: COUNTS TWO THROUGH TWENTY-THREE (Wi
Page 57 and 58: 8 7/2/97 Facsimile of false “sale
Page 59 and 60: 21 5/12/98 4:50 p.m. 22 5/13/98 9:1
Page 61 and 62:
Count 24 Date 3/5/95 Description Fa
Page 63 and 64:
3. The defendants violated those pr
Page 65 and 66:
COUNT THIRTY-TWO (Filing False Repo
Page 67 and 68:
THE GRAND JURY FURTHER CHARGES: COU
Page 69 and 70:
transportation, transmission and tr
Page 71 and 72:
10/28/96 Proceeds totaling approx.
Page 73 and 74:
Date Description Transferred from T
Page 75 and 76:
Date(s) Description Sold & Transfer
Page 78 and 79:
COUNTS THIRTY-SIX THROUGH THIRTY-NI
Page 80:
COUNTS FORTY THROUGH FORTY-FIVE (Mo
Page 83 and 84:
THE GRAND JURY FURTHER CHARGES: NOT
Page 85 and 86:
NOTICE OF FORFEITURE (Money Launder
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Justice Department's indictment of Semion Mogilevich

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