Justice Department's indictment of Semion Mogilevich

transportation, transmission and transfer represented the proceeds of some
form of unlawful activity and knowing that such transportation,
transmission, and transfer was designed in whole or in part to conceal and
disguise the nature, the location, the source, the ownership, and the control
of the proceeds of specified unlawful activity, that is, mail fraud (Title 18,
United States Code, Section 1341); wire fraud (Title 18, United States
Code, Section 1343); and securities fraud (Title 15, United States Code,
Section 78j(b), 17 C.F.R., Section 250.10b-5), in violation of Title 18,
United States Code, Sections 1956(a)(2)(B)(i) and 2.
MANNER AND MEANS
3. Among the manner and means by which the defendants MOGILEVICH,
FISHERMAN and BOGATIN, and others known and unknown to the grand jury, caused and
attempted to cause the objectives of the conspiracy to be accomplished, were the following:
Promotion of Specified Unlawful Activity
4. The defendants transferred illegal proceeds generated by the scheme to
defraud with the intent to promote the continuation of the scheme and the carrying on of specified
unlawful activities, that is, mail fraud, wire fraud and securities fraud.
A. Proceeds from Offerings of YBM Stock
5. The illegal proceeds generated by the sale of fraudulently inflated stock in
connection with the Special Warrants Offering and the 1997 Offering, as described in the
Introduction to this Superseding Indictment, were used in part to pay overhead, payroll, vendors
and other expenses necessary for the promotion and continued operation of the Network of YBM
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