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Justice Department's indictment of Semion Mogilevich

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UNITED TRADE had a diverse customer and vendor base and<br />

conducted significant activity, including brokering <strong>of</strong> magnets,<br />

which was untrue;<br />

(4) destroying wire transfers and other documents that would<br />

otherwise track the flow <strong>of</strong> money through YBM bank accounts;<br />

(5) funneling proceeds generated from the sale <strong>of</strong> YBM stock to<br />

closely related parties and entities to create the false appearance <strong>of</strong><br />

commercial transactions on YBM's books and records;<br />

(6) routinely using cash withdrawals from bank accounts set up in<br />

foreign banks to make millions <strong>of</strong> dollars in disbursements to the<br />

defendants and other closely-related parties for purported business<br />

expenses that could not be traced or verified through the books and<br />

records; and<br />

(7) routinely and systematically failing to make and keep books,<br />

records and accounts, which, in reasonable detail, accurately and<br />

fairly reflected the transactions and disposition <strong>of</strong> the assets <strong>of</strong><br />

YBM, as required under the Securities Exchange Act <strong>of</strong> 1934,<br />

§13(b)(2)(A), under securities regulations in Canada, and in<br />

accordance with generally accepted accounting principles.<br />

E. MISREPRESENTATIONS OF YBM’s OPERATIONS AND FINANCIAL<br />

CONDITION TO SECURITIES REGULATORS AND INVESTMENT<br />

COMMUNITY<br />

23

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