Justice Department's indictment of Semion Mogilevich

functions for the various corporations, were placed in the Network of
YBM Companies by MOGILEVICH as “window dressing” for the public,
and took directions from MOGILEVICH to move money to and from the
corporate accounts of ARIGON, UNITED TRADE and TDL .
F. FAILURE TO DISCLOSE TO SECURITIES REGULATORS
37. The defendants MOGILEVICH, FISHERMAN, BOGATIN and TSOURA
failed to disclose the following material matters, among others, in public filings with securities
regulators :
over YBM management;
(a) Defendant MOGILEVICH controlled YBM through his control
(b) MOGILEVICH owned in excess of 10% of the shares of
PRATECS and YBM stock from between approximately April 1994 and approximately
January 1998. This was concealed by creating false documentation to show that others
owned a percentage of MOGILEVICH's stock when in fact the other persons were merely
nominees for MOGILEVICH;
(c) Fairfax Group Ltd ("Fairfax"), an international, forensic
investigative security firm conducted an investigation of YBM and presented investigative
findings to the YBM directors and management, including defendants FISHERMAN and
BOGATIN, in or about March 1997 that:
(1) the ARIGON shareholders, including defendant
MOGILEVICH, were members of a Russian organized
crime syndicate, and owned or controlled YBM subsidiaries,
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