Justice Department's indictment of Semion Mogilevich

and investing money received from these fraudulent schemes; (c) disguising and concealing the
defendants' interest in, and control over the money and investments; and (d) spending and using
various amounts of money in ways that promoted the scheme and benefitted the individual
members and associates of the Mogilevich Enterprise.
4. Defendants SEMION MOGILEVICH, IGOR FISHERMAN, and JACOB
BOGATIN were leaders of the Mogilevich Enterprise who directed other members of the
Enterprise in carrying out unlawful and other activities in furtherance of the conduct of the
Enterprise’s affairs. Under the direction of the leaders of the Mogilevich Enterprise, defendant
ANATOLY TSOURA, and others known to the grand jury, participated in unlawful activities in
furtherance of the conduct of the Enterprise’s affairs.
THE RICO CONSPIRACY
5. From in or about 1993, continuously thereafter up to and
including in or about September 1998, in the Eastern District of Pennsylvania and elsewhere,
defendants
SEMION MOGILEVICH,
a/k/a "Simeon Mogilevitch"
a/k/a "Semjon Mogilevcs"
a/k/a "Shimon Makhelwitsch"
a/k/a "Seva"
IGOR FISHERMAN,
JACOB BOGATIN,
a/k/a "Yakov"
ANATOLY TSOURA
being persons employed by and associated with the Mogilevich Enterprise described above in
paragraphs 2 through 4 of Count One, an enterprise which was engaged in, and the activities of
which affected, interstate and foreign commerce, did unlawfully, willfully, and knowingly
37