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Justice Department's indictment of Semion Mogilevich

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• In reality, the defendants knew YBM’s North American magnet sales were<br />

less than $1.8 million in 1996; magnet imports into Canada, the United<br />

States and Mexico from the Budapest manufacturing plant were negligible;<br />

and the companies identified to regulators as North American customers<br />

were: (i) companies that purportedly did business in Russia and Eastern<br />

Europe that merely maintained registered addresses in the United States;<br />

(ii) legitimate United States companies that never purchased magnets from<br />

YBM; or (iii) sham customers;<br />

(g) Revenues totaled approximately $100 million between 1996 and June 1998,<br />

primarily from YBM’s magnet and oil sales through its subsidiary UNITED TRADE<br />

LIMITED.<br />

Assets<br />

• In reality, the defendants knew such revenues did not exist and were falsely<br />

recorded on YBM’s books to make the company look pr<strong>of</strong>itable.<br />

(h) The value <strong>of</strong> the start-up machinery and equipment as reported in YBM’s<br />

financial statements included Russian machinery and equipment contributed to ARIGON<br />

for the Budapest manufacturing plant in or about 1992, valued at approximately $14.5<br />

million (USD).<br />

• In reality, the defendants knew this value was based upon false and<br />

fraudulent documentation.<br />

(i) The depreciated value <strong>of</strong> machinery and equipment at the Budapest,<br />

Hungary plant as <strong>of</strong> December 31, 1997 was reported on the books and records <strong>of</strong><br />

26

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