Justice Department's indictment of Semion Mogilevich
Justice Department's indictment of Semion Mogilevich
Justice Department's indictment of Semion Mogilevich
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(b) Defendants FISHERMAN, BOGATIN and TSOURA, in order to<br />
conceal the falsification <strong>of</strong> the books and records <strong>of</strong> the Network <strong>of</strong> YBM companies<br />
described below at paragraph 35(c), at various times between 1994 and 1998, routinely<br />
deceived, obstructed, and lied to the auditors, and to the forensic examiners who examined<br />
the books and records <strong>of</strong> YBM and its subsidiaries by, among other things:<br />
(1) falsely representing that the books and records <strong>of</strong> YBM and the<br />
Network <strong>of</strong> YBM Companies were accurate when they were not;<br />
(2) providing false financial records, bank statements, invoices,<br />
contracts, customer lists, shipping documentation and audit<br />
confirmations, which were created to support false claims <strong>of</strong> sales<br />
activity and revenues;<br />
(3) systematically withholding access to records and documentation<br />
essential to substantiate the accuracy <strong>of</strong> YBM’s statements <strong>of</strong> its<br />
financial condition, by using “put-<strong>of</strong>fs,” stalling tactics, and false<br />
promises <strong>of</strong> production; and<br />
(4) failing to disclose to the auditors the material matters as set forth in<br />
paragraph 37 below.<br />
Falsification <strong>of</strong> Books and Records<br />
(c) Defendants MOGILEVICH, FISHERMAN, BOGATIN and<br />
TSOURA, in order to make YBM’s financial statements look pr<strong>of</strong>itable and attractive to<br />
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