Justice Department's indictment of Semion Mogilevich

FISHERMAN, BOGATIN and TSOURA and others known and unknown to the grand jury, took
steps to have YBM’s securities registered for trading with securities regulators in the United
States and listed on securities exchanges inside the United States in order to further exploit the
financial markets in the United States which offered greater access to investors. In this regard
they caused the following to be filed:
(a) On or about August 14, 1996, Registration Statement (Form 40-F)
was filed with the SEC to register YBM securities for sale in the United States pursuant to
Section 12(g) of the Securities Exchange Act of 1934, and an Application for Public
Securities (“NASDAQ Application”) was filed with the NASDAQ to obtain approval for a
listing of YBM’s stock on the NASDAQ. The Form 40-F was available to the public. As
part of the filings of the Form 40-F and the NASDAQ Application, the defendants
incorporated and included, and caused to be incorporated and included, the false and
fraudulent representations submitted to the OSC and TSE regarding the financial
condition of the Network of YBM companies, its business operations and ownership and
control of YBM stock as set forth in paragraphs 36 and 37 above.
(b) On or about November 27, 1996 and December 19, 1997, Forms 6-
K (Reports of Foreign Issuer) were filed with the SEC, which Reports were available to
the investing public. The Reports contained false and fraudulent representations of
financial condition and business operations including filings that falsely inflated sales
revenues and customer base, as set forth in paragraphs 36 and 37 above.
J. PROFITS TO DEFENDANTS FROM SCHEME TO DEFRAUD
Sale of YBM stock
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