Justice Department's indictment of Semion Mogilevich

Network of YBM companies, including his beneficial ownership of YBM
stock;
(b) engaged in various deceptive business practices, including the creation of
fraudulent books and records, that were designed to conceal YBM’s
fraudulent operations from securities regulators, auditors and the investing
public. This included: (a) creating false bank statements, invoices,
customer lists, shipping documentation and audit confirmations to support
false claims of sales activities and revenues; and (b) funneling proceeds
from the sale of YBM stock to closely-related parties and entities to create
the false appearance of commercial transactions on YBM’s books and
records;
(c) used various techniques to fraudulently inflate the value of YBM stock and
to create market demand for the artificially inflated stock, in order to profit
from sales of YBM stock owned and controlled by the defendants, in that
the defendants falsely touted the business activity and financial performance
of the Network of YBM Companies through, among other things, the
issuance of press releases, shareholder presentations, and annual and
periodic reports filed with securities regulators; and
(d) implemented the scheme to defraud using companies and bank accounts in
over twenty different countries, including offshore locations such as the
Republic of Nauru in the South Pacific, the Cayman Islands and Nevis in
the Caribbean, as well as Canada, England, Hungary, Israel, Lithuania,
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