Justice Department's indictment of Semion Mogilevich

43. At various times during the scheme to defraud the defendants sold large
amounts of YBM stock in order to profit from the scheme to defraud described herein. The
defendants and their nominees received in excess of $25 million in stock proceeds over the life of
the conspiracy.
44. Beginning in or about May 1994, defendants MOGILEVICH,
FISHERMAN, and BOGATIN established and used accounts at different brokerage firms in their
names and in the names of nominees, including “investment club” accounts described below.
These accounts were depositories for millions of shares of YBM stock. These accounts enabled
defendants MOGILEVICH, FISHERMAN and BOGATIN to coordinate and control the
distribution, transfer and sales of large blocks of YBM stock and to profit unjustly from the sale
of fraudulently inflated stock. The proceeds from these sales were disbursed to the defendants, to
their associates, and to shell companies set up and controlled, directly and indirectly, by
defendants MOGILEVICH and FISHERMAN.
Investment Clubs
45. The following investment clubs served as depositories for some of the
stock sold for the benefit of defendants MOGILEVICH, FISHERMAN and BOGATIN,
generating proceeds in excess of $15 million:
(a) The Anix Investment Club ("Anix") was established at First Canada
Securities in or about May 1994. In 1996, the Anix account was transferred to a series of
brokerage firms in the United States. Proceeds derived from the sales of YBM stock through
Anix totaled in excess of $1.5 million and were concealed by depositing monies in a foreign bank
account in the names of nominees closely associated with defendants MOGILEVICH and
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