Justice Department's indictment of Semion Mogilevich

(3) payments by YBM and its subsidiaries of "magnet sales
commissions" which, in reality, either: (i) were never made; or (ii)
were disguised payments to close associates of defendants
MOGILEVICH, BOGATIN, FISHERMAN, and TSOURA.
(d) Defendants MOGILEVICH, FISHERMAN, BOGATIN and
TSOURA, in order to make YBM look profitable and attractive to investors, at various
times between 1994 and 1998, further falsified or caused YBM’s books and records to be
falsified by, among other things:
(1) creating false financial records, bank statements, invoices,
contracts, customer lists, shipping documentation and audit
confirmations, to support false claims of sales activity and revenues;
(2) disguising the fact that approximately $32 million had been falsely
reported on the books and records of UNITED TRADE and
deposited in a UNITED TRADE bank account for the year ended
December 31, 1997, and covering up the falsification by
orchestrating a sell-off of YBM stock by the defendants and their
nominees in early 1998, and then moving the proceeds into bank
accounts to create the appearance that the $32 million existed on
the books when it did not;
(3) moving funds in a circular flow to and from bank accounts of
UNITED TRADE, using bank accounts under the control of related
parties in Russia and Eastern Europe to create the illusion that
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