Justice Department's indictment of Semion Mogilevich

The Scheme To Defraud
9. The defendants devised and intended to devise the scheme as set forth in
Paragraphs 1 through 46 of the Introduction to this Superseding Indictment.
Wire Transmissions
10. The defendants and others known and unknown to the grand jury, for the
purpose of executing the scheme to defraud, caused the interstate and foreign transmission of
writings, signs, signals and sounds, to and from the Eastern District of Pennsylvania, as follows:
(a) The defendants caused correspondence and documents to be transmitted
via facsimile, to and from various places in the United States, from and to
various places in foreign countries, including the United Kingdom, Canada,
Hungary and Russia, among others. The documents included, but were not
limited to, materially false and fictitious audit confirmations, press releases
and statements of YBM's financial condition and business operation.
(b) The defendants communicated between and among themselves and others,
by telephone and cellular phone, including calls made to and from various
places in the United States, and foreign countries, including Canada and
Hungary; and
(c) The defendants caused funds to be distributed between and among
themselves and other individuals and entities, via wire transfers to and from
bank accounts and brokerage accounts maintained in the United States,
Canada, the United Kingdom, Hungary and elsewhere. These funds were
used by the defendants for the following, among other things: (i) the
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