Justice Department's indictment of Semion Mogilevich

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for the forfeiture obligations as alleged above. Substitute Assets 4. In the event any of the above-described forfeitable property, as a result of any act or omission of the defendant: cannot be located upon the exercise of due diligence; has been transferred to, sold to, or deposited with a third person; has been placed beyond the jurisdiction of the Court; has been substantially diminished in value; and has been commingled with other property which can not be subdivided without difficulty; it is the intent of the United States, pursuant to Title 18, United States Code, Section 1963(m), to seek forfeiture of any other property of said defendant up to the value of the above forfeitable property. All pursuant to Title 18, United States Code, Sections 1962(d) and 1963. 84
NOTICE OF FORFEITURE (Money Laundering Forfeiture - 18 U.S.C. § 982) THE GRAND JURY FURTHER CHARGES: 1. Paragraphs 1 through 46 of the Introduction to this Superseding Indictment and Counts Thirty-Five through Forty-Five are incorporated by reference here. 2. From in or about May 1994, and continuously thereafter, up to and including in or about September 1998, in the Eastern District of Pennsylvania and elsewhere, the 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" violated Title 18, United States Code, Section 1956(a)(2) as alleged in Counts Thirty-Five through Forty-Five 3. Upon conviction of violating Title 18, United States Code, Section 1956, as alleged in Counts Thirty-Five through Forty-Five, each defendant shall forfeit to the United States the entirety of the defendant’s interest in all property, real and personal, involved in each violation, and any property traceable to such property. 4. The property subject to forfeiture includes, but is not limited to, United States currency and its equivalent, in at least the approximate amounts listed below, and all proceeds traceable to such sums, which the defendants obtained directly and indirectly as the result of the violations and which were involved in the violations described in Counts Thirty-Five through Forty-Five: 85
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IN THE UNITED STATES DISTRICT COURT
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operated businesses, described here
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Indictment, MOGILEVICH resided in B
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The Network of YBM Companies YBM Ma
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YBM Network of companies and did no
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ORIGON's bank account in Israel wer
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25. The Toronto Stock Exchange (“
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Network of YBM companies, including
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company ARIGON between approximatel
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for stock in YBM MAGNEX. As a resul
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investors, recorded, and caused to
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UNITED TRADE had a diverse customer
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productive between September and De
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UNITED TRADE and MAGNEX RT to be ap
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ARBAT, ARIGON, and MAGNEX RT; (2) e
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(b) On or about November 20, 1997,
Page 33 and 34: 43. At various times during the sch
Page 35 and 36: listed: Defendant Amount (a) FISHER
Page 37 and 38: and investing money received from t
Page 39 and 40: The Scheme To Defraud 9. The defend
Page 41 and 42: circumstances under which they were
Page 43 and 44: Bank of Scotland, London, England (
Page 45 and 46: 18 1/26/97 Facsimile of false audit
Page 47 and 48: (ph# 215-579-5695) to FISHERMAN, in
Page 49 and 50: Solis-Cohen, 111 South 15 th Street
Page 51 and 52: Overt Act Date Description Transfer
Page 53 and 54: Overt Act Date Description Transfer
Page 55 and 56: COUNTS TWO THROUGH TWENTY-THREE (Wi
Page 57 and 58: 8 7/2/97 Facsimile of false “sale
Page 59 and 60: 21 5/12/98 4:50 p.m. 22 5/13/98 9:1
Page 61 and 62: Count 24 Date 3/5/95 Description Fa
Page 63 and 64: 3. The defendants violated those pr
Page 65 and 66: COUNT THIRTY-TWO (Filing False Repo
Page 67 and 68: THE GRAND JURY FURTHER CHARGES: COU
Page 69 and 70: transportation, transmission and tr
Page 71 and 72: 10/28/96 Proceeds totaling approx.
Page 73 and 74: Date Description Transferred from T
Page 75 and 76: Date(s) Description Sold & Transfer
Page 78 and 79: COUNTS THIRTY-SIX THROUGH THIRTY-NI
Page 80: COUNTS FORTY THROUGH FORTY-FIVE (Mo
Page 83: THE GRAND JURY FURTHER CHARGES: NOT
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Justice Department's indictment of Semion Mogilevich

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