Justice Department's indictment of Semion Mogilevich

COUNT THIRTY-ONE
(Filing False Registration Statement with the Securities and Exchange Commission)
THE GRAND JURY FURTHER CHARGES:
1. Paragraphs 1 through 46 of the Introduction to this Superseding Indictment are
incorporated by reference herein.
2. On or about August 14, 1996, 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"
willfully and knowingly caused, and aided and abetted, the filing by YBM of an SEC Form 40-F, a
Registration Statement of a foreign issuer, which contained statements of material fact that were
false and misleading and that failed to contain material information necessary to make the required
statements, in light of the circumstances under which they were made, not misleading, in that,
among other things: YBM materially misrepresented the nature of its business operations and
financial condition, as set forth in paragraph 36 (a) through (e) and (h) through (l) in the
Introduction to this Superseding Indictment; and YBM failed to disclose the true extent of
MOGILEVICH's ownership and control of YBM, as set forth in paragraph 37 (a) and (b).
In violation of Title 15, United States Code, Sections 78l(g), 78ff(a) and 17 C.F.R.,
Section 240.12b-20, and Title 18, United States Code, Section 2.
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