Justice Department's indictment of Semion Mogilevich

THE GRAND JURY CHARGES:
COUNT ONE
(RICO Conspiracy)
1. Paragraphs 1 through 46 of the Introduction to this Superseding Indictment
are incorporated by reference herein.
THE ENTERPRISE
2. The Enterprise, also referenced herein as the “Mogilevich Enterprise,” was
an enterprise as defined in Title 18, United States Code, Section 1961(4), namely, a group of
individuals and corporations associated in fact, which was engaged in, and the activities of which
affected, interstate and foreign commerce, and which consisted of the following individuals and
legal entities, namely:
(a) Individuals: Defendants SEMION MOGILEVICH, IGOR
FISHERMAN, JACOB BOGATIN, ANATOLY TSOURA, and other
individuals known to the grand jury; and
(b) Legal Entities: YBM MAGNEX INTERNATIONAL, INC., its
predecessor company, PRATECS, and its subsidiary and related
companies, ARIGON, UNITED TRADE, MAGNEX RT, ARBAT, YBM
TECHNOLOGIES, YBM MAGNEX, TDL, ORIGON, and BEM.
3. The Mogilevich Enterprise constituted an ongoing organization whose
members functioned as a continuing unit for a common purpose of achieving the objectives of the
Enterprise. The Mogilevich Enterprise existed for the purposes of: (a) defrauding investors in the
United States, Canada, and elsewhere, through fraudulent schemes and material
misrepresentations and omissions, in order to obtain money and property; (b) receiving, holding
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