Justice Department's indictment of Semion Mogilevich

circumstances under which they were made, not misleading; and
(c) engaged in acts, practices and courses of business which operated and
would operate as a fraud and deceit upon a person, in connection with the
purchase and sale of shares of PRATECS/YBM by the investing public.
13. The defendants caused YBM’s financial condition and business operations
to be materially misrepresented in YBM’s annual reports, prospectuses, press releases and public
filings, to present a false appearance to investors and securities regulators that YBM was a
profitable and investment-worthy business which generated high revenues from the worldwide sale
and distribution of its magnets and other products. The defendants also failed to disclose the true
extent of MOGILEVICH’s ownership and control of YBM.
Financial Transactions
14. The defendants and others known and unknown to the grand jury caused
monetary instruments and funds to be transported, transmitted, and transferred from places in the
United States to and through places outside of the United States, and to places in the United States
from and through places outside the United States, with the intent to:
(a) promote the scheme to defraud through the payment of salaries, consulting
fees, commissions, mortgage, rent, advertising fees, and other expenses
necessary to support YBM's continued operation of the scheme; and
(b) conceal and disguise the nature, location, source, ownership and control of
the proceeds generated by the scheme to defraud through the use of foreign
bank accounts, and accounts held in the names of nominees, closely-related
parties and shell companies.
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