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Russian Oligarch Fridman, Corporation Sued for Racketeering, Fraud That Used U.S. Banks and Exchanges

‘Defen­dants’ Ten­ta­cles Reach Into and Injure Numer­ous Amer­i­cans’

NEW YORK, June 9 /PRNewswire/ — Russ­ian cor­po­ra­tion Alfa Group Con­sor­tium and its U.S. enti­ty, Alfa Cap­i­tal Mar­kets, Inc., are a crim­i­nal enter­prise that has used U.S. banks and stock exchanges as an inte­gral part of their theft schemes, cost­ing Amer­i­can tax­pay­ers and stock­hold­ers hun­dreds of mil­lions of dol­lars, IPOC Inter­na­tion­al Growth Fund, Ltd., alleges in a fed­er­al rack­e­teer­ing law­suit filed late Thurs­day.

The suit alleges that Alfa, one of the largest busi­ness con­glom­er­ates in the Russ­ian Fed­er­a­tion — along with Russ­ian oli­garch Mikhail Frid­man and U.S. cit­i­zen Leonid Rozhet­skin — engaged in a vast inter­na­tion­al mon­ey laun­der­ing and fraud scheme in an attempt to take con­trol of the Russ­ian cel­lu­lar indus­try. “By doing so, defen­dants’ con­duct has had a sub­stan­tial effect on the Unit­ed States and its cit­i­zens, and much of the crim­i­nal con­duct occurred in the Unit­ed States,” the suit, filed in U.S. Dis­trict Court for the South­ern Dis­trict of New York, said.

The crim­i­nal enter­prise affect­ed Amer­i­cans, U.S.-based investors and U.S. inter­ests in numer­ous ways, the com­plaint alleges, involv­ing the eva­sion of U.S. tax­es, insid­er trad­ing of shares on U.S. stock mar­kets, and wiring pay­ments through New York banks. The Alfa Group Con­sor­tium received sup­port from the Over­seas Pri­vate Invest­ment Cor­po­ra­tion, a U.S. gov­ern­ment devel­op­ment agency, to pro­vide a sig­nif­i­cant por­tion of fund­ing for one of Alfa’s relat­ed busi­ness­es.

“The com­plaint alleges that the rack­e­teer­ing and oth­er wrongs cit­ed in this case hurt U.S. investors, U.S. tax­pay­ers and U.S. finan­cial mar­kets,” said W. Gor­don Dobie, an attor­ney with Win­ston & Strawn LLP, which filed the case for IPOC Inter­na­tion­al Growth Fund, Ltd. “It’s my opin­ion that the defen­dants should be called to account in court for their con­duct.”

A Daisy Chain of Nine Shell Com­pa­nies

The suit details how Alfa, in a series of sham trans­ac­tions over a 10-day peri­od, know­ing­ly and fraud­u­lent­ly col­lud­ed to steal IPOC’s 25.1 per­cent stake in Rus­si­a’s third largest mobile tele­com com­pa­ny, Mega­Fon. IPOC had orig­i­nal­ly signed two options agree­ments to buy the stake from LV Finance, had paid for the shares and at all junc­tures hon­ored the terms of the agree­ments. At the final stage, IPOC dis­cov­ered that LV Finance, act­ing through its chair­man Leonid Rozhet­skin, had nego­ti­at­ed a pur­port­ed sale of LV Finance’s inter­est in Mega­Fon to Mikhail Frid­man’s Alfa Group, involv­ing a com­plex web of nine off­shore com­pa­nies. Both com­pa­nies are alleged to have been aware of IPOC’s pri­or own­er­ship rights, but rode roughshod over the agree­ment and fraud­u­lent­ly col­lud­ed to sell the same stake twice. They “bought” and “sold” the $50 mil­lion stake, and yet there is no evi­dence of mon­ey hav­ing changed hands through­out this daisy chain of sham trans­ac­tions.

“What was a legit­i­mate busi­ness oppor­tu­ni­ty for IPOC evolved into a vehi­cle for Rozhet­skin’s and Mikhail Frid­man’s theft and mis­ap­pro­pri­a­tion,” the suit alleges.

Scheme Con­cealed Wrong­do­ing

The suit alleges that at the cen­ter of the enter­prise was Frid­man, a major Vim­pel­Com share­hold­er, who used asso­ciates work­ing direct­ly for him and for Vim­pel­Com, to trans­fer the assets in the sum­mer of 2003. The scheme involved wiring pay­ments through New York banks, tak­ing the pro­ceeds, and then trans­fer­ring those pro­ceeds to var­i­ous off-shore com­pa­nies “to con­ceal wrong­do­ing from IPOC, Amer­i­can tax­ing author­i­ties, and oth­ers.”

The suit states that Rozhet­skin act­ed “as a point per­son to obtain addi­tion­al cel­lu­lar phone assets” and worked close­ly with Frid­man to assist with the sham trans­ac­tions. He lat­er relied on New York banks to laun­der the theft of $50 mil­lion, the mon­ey IPOC paid for the stake.

The com­plaint also alleges that Rozhet­skin and Frid­man were assist­ed by Hans Bod­mer, who served as escrow agent and sent instruc­tions to IPOC to wire mon­ey through banks in New York for the ben­e­fit of the defen­dants. Bod­mer recent­ly plead guilty to crim­i­nal con­spir­a­cy to laun­der mon­ey and con­spir­a­cy to vio­late the U.S. For­eign Cor­rupt Prac­tices Act in con­nec­tion with an unre­lat­ed scheme to bribe for­eign lead­ers.

Insid­er Deal­ing and Manip­u­la­tion of Vim­pel­Com Tax Inquiry

The suit also alleges that Frid­man and the Alfa Group attempt­ed to manip­u­late Vim­pel­Com’s share price for their own gain, in their posi­tion as major Vim­pel­Com share­hold­ers. On Dec. 8, 2004, the suit said, Vim­pel­Com, a New York Stock Exchange Com­pa­ny, dis­closed the Russ­ian tax author­i­ties were inves­ti­gat­ing the com­pa­ny for back tax­es car­ry­ing poten­tial for heavy fines and penal­ties.

The news coin­cid­ed with the auc­tion of a $10 bil­lion sub­sidiary of Russ­ian con­glom­er­ate Yukos to sat­is­fy back-dat­ed tax oblig­a­tions. Yukos lat­er went through an unprece­dent­ed bank­rupt­cy fil­ing in the Unit­ed States.

The suit claims that manip­u­la­tion was insid­er deal­ing that advanced the defen­dants’ goal of obtain­ing con­trol and con­sol­i­da­tion of the telecom­mu­ni­ca­tions mar­ket in Rus­sia, fur­ther­ing the abil­i­ty to raise prices for cel­lu­lar ser­vices through a near-monop­oly or oli­gop­oly.

Notes to Edi­tors * IPOC Inter­na­tion­al Growth Fund, Ltd. is an open-end­ed mutu­al fund com­pa­ny based in Bermu­da. * The suit, based on claims under the Rack­e­teer Influ­enced and Cor­rupt Orga­ni­za­tions (RICO) Act, charges that Frid­man con­spired with Rozhet­skin to steal IPOC’s inter­est through mon­ey laun­der­ing, bribery, wire fraud and oth­er crim­i­nal wrong­do­ings. Oth­er defen­dants are Alfa Cap­i­tal Mar­kets, Inc., a U.S. cor­po­ra­tion; Alfa Tele­com (n/k/a) Alti­mo; and Hans Bod­mer. * Alfa Group Con­sor­tium is an asso­ci­a­tion of var­i­ous com­pa­nies con­trolled by Frid­man. It con­trols major inter­na­tion­al cor­po­ra­tions trad­ed in the Unit­ed States, includ­ing Vim­pel­Com (NYSE) Rus­si­a’s sec­ond largest mobile tele­coms com­pa­ny, Gold­en Tele­com (NASDAQ) and Turk­cell (NYSE). * For more infor­ma­tion about IPOC, go to http://www.ipocfund.com. A copy of the law­suit is being post­ed on this Web site June 9. The Many Ties to the Unit­ed States As the law­suit states, “... defen­dants’ ten­ta­cles reach into and injure numer­ous Amer­i­cans....” The investors, tax­pay­ers and finan­cial mar­kets of the Unit­ed States have been harmed.

The below sets out the indi­vid­u­als and firms referred to in the law­suit, and pro­vides some fur­ther infor­ma­tion:

The Defen­dants:

Leonard Rozhet­skin: “Defen­dant Leonard Rozhet­skin is a for­mer direc­tor and prin­ci­pal share­hold­er of LV Finance Group Lim­it­ed (“LVFG”). He is a Unit­ed States tax­pay­er and cit­i­zen, owns prop­er­ty in the Dis­trict, and lived in the Dis­trict for more than a decade ... fea­tured on the cov­er of the Russ­ian edi­tion of Forbes with the title: ‘The Most Dan­ger­ous Shark in Our Waters.’... Rozhet­skin resides in the Unit­ed States....”[pg.6]”

Mikhail Frid­man: “Defen­dant Mikhail Frid­man cur­rent­ly serves as Chair­man of the Board of Direc­tors of co-con­spir­a­tor Alfa Bank and as Chair­man of the Board of Direc­tors of Defen­dant Con­sor­tium Alfa Group. Frid­man fur­ther served on the Board of Vim­pel­Com, a NYSE com­pa­ny, and has con­trol over Gold­en Tele­com, a NASDAQ com­pa­ny ... pur­chased the Unit­ed States trad­ing firm owned by Amer­i­can, Mark Rich, the one time com­modi­ties baron par­doned by Pres­i­dent Clin­ton with much con­tro­ver­sy. Frid­man pur­ports to have become a phil­an­thropist in the Unit­ed States” and is a mem­ber of the Board of the Coun­cil on For­eign Rela­tions based in New York. [pgs. 6–7]

Pyotr Aven: “Defen­dant Pyotr Aven also has been a major par­tic­i­pant in the scheme and worked direct­ly with Rozhet­skin and Frid­man in the mis­ap­pro­pri­a­tion and theft of IPOC monies. Aven is a direc­tor of Gold­en Tele­com, a NASDAQ com­pa­ny, which reg­u­lar­ly files with the Unit­ed States Secu­ri­ties Exchange Com­mis­sion. He is a con­tro­ver­sial fig­ure: As
observed by the Unit­ed States Dis­trict Court for the Dis­trict of Colum­bia, a Russ­ian ‘cor­rup­tion task force informed [the gov­ern­ment] that Aven was engaged in var­i­ous mis­deeds, includ­ing drug traf­fick­ing. See OAO Alfa Bank v. Cen­ter for Pub­lic Integri­ty, Civ. Action No. 00–2208 (JDB), Mem. Op., Sept. 22, 2005 at 11 n.26.” [pg. 8]

Hans Bod­mer: “Defen­dant Hans Bod­mer ... assist­ed Rozhet­skin and Frid­man with the Son­ic Duo/MegaFon theft scheme ... worked with his co-con­spir­a­tors to send instruc­tions to IPOC to wire mon­ey through banks in New York for the ben­e­fit of the Defen­dants. Bod­mer is no stranger to crim­i­nal pros­e­cu­tion in the Unit­ed States, hav­ing recent­ly pled guilty to the crim­i­nal con­spir­a­cy to laun­der mon­ey and con­spir­a­cy to vio­late the Unit­ed States For­eign Cor­rupt Prac­tices Act in con­nec­tion with the scheme to bribe for­eign lead­ers (along with Vic­tor Kozeny, who is cur­rent­ly being extra­dit­ed to New York from the Bahamas). Case No: 01: 05-CR-00518-RCC-ALL (S.D.N.Y.).” [pg. 9]

* Pub­licly List­ed U.S. Cor­po­ra­tions Affil­i­at­ed with Defen­dants:

Vim­pel-Com­mu­ni­ca­tions, Vim­pel­Com and Gold­en Tele­com, Inc. “... Defen­dant Frid­man has suc­cess­ful­ly obtained hun­dreds of mil­lions of dol­lars from Amer­i­can investors through the sale of inter­ests in his Russ­ian telecom­mu­ni­ca­tions empire — which includes New York Stock Exchange com­pa­ny Vim­pel-Com­mu­ni­ca­tions, also known as Vim­pel­Com, and Gold­en Tele­com, Inc., (“Gold­en Tele­com”), a NASDAQ com­pa­ny. [pg. 3]”

Vim­pel-Com­mu­ni­ca­tion­s/Vim­pel­Com Web site is http://www.vimpelcom.com/index.wbp Gold­en Tele­com, Inc. Web site is http://www.goldentelecom.com/?id=12

Alfa Cap­i­tal Mar­kets (USA), Inc: “Alfa Cap­i­tal Mar­kets (USA), Inc. (“Alfa Cap­i­tal Mar­kets”) is a mem­ber of the Alfa Group and is a cor­po­ra­tion orga­nized under the laws of the Unit­ed States with its prin­ci­pal place of busi­ness and office in New York City. Upon infor­ma­tion and belief, Alfa Cap­i­tal Mar­kets was used to struc­ture the laun­der­ing of the pro­ceeds of the Frid­man M.C. Enter­prise for invest­ment in the Unit­ed States, such as the recent acqui­si­tion of Gold­en Tele­com, Inc., a pub­licly held Amer­i­can com­pa­ny, con­trolled by the Alfa Group. On infor­ma­tion and belief, Alfa Cap­i­tal Mar­kets’ accounts were used to fund the mis­ap­pro­pri­a­tion of plain­tiffs’ prop­er­ty.” [pg. 9]

The Alfa Cap­i­tal Mar­kets (USA), Inc. Web site is http://www.alfabank.com/usa/

A Wide Vari­ety of U.S. Ties: * The U.S. Bank­ing Sys­tem and the U.S. Trea­sury: “... goal of cheat­ing the Amer­i­can gov­ern­ment of tax­es due and owing ....”: Rozhet­skin knew the assets were unlaw­ful­ly tak­en when he made use of the Unit­ed States to trans­fer the assets in inter­state com­merce. Fur­ther, Rozhet­skin’s actions were in fur­ther­ance of his goal of cheat­ing the Amer­i­can gov­ern­ment of tax­es due and owing on the trans­ac­tions.” [pg. 18]

“... mon­ey laun­der­ing and wire fraud that affect­ed inter­state and for­eign com­merce.” “Defen­dants con­spired to steal IPOC’s mon­ey and prop­er­ty, and to con­ceal their wrong­do­ing and the true own­er­ship of the pro­ceeds through a series of sham trans­ac­tions and trans­fer the stolen assets in inter­state and for­eign com­merce with the intent of car­ry­ing on and fur­ther­ing their unlaw­ful activ­i­ty. By doing so, Defen­dants engaged in mon­ey laun­der­ing and wire fraud that affect­ed inter­state and for­eign com­merce.” [pg. 20]

“... sub­stan­tial effect on the Unit­ed States and its cit­i­zens....”: “Their actions includ­ed assist­ing Rozhet­skin in an inter­na­tion­al mon­ey laun­der­ing scheme by which Rozhet­skin, using the Unit­ed States bank­ing sys­tems as an inte­gral part of his theft scheme, took the pro­ceeds of his crim­i­nal con­duct, and then trans­ferred them to var­i­ous off-shore com­pa­nies as part of an attempt to con­ceal wrong­do­ing from IPOC, Amer­i­can tax­ing author­i­ties, and oth­ers. By doing so, Defen­dants’ con­duct has had a sub­stan­tial effect on the Unit­ed States and its cit­i­zens, and much of the crim­i­nal con­duct occurred in the Unit­ed States.” [pg. 21]

“... (Rozhet­skin) defraud­ed the Unit­ed States of tax­es and his return.”: “Although Rozhet­skin claimed to have sold LVFG and 25% stake in Mega­Fon for hun­dreds of mil­lions of dol­lars, he defraud­ed the Unit­ed States of tax­es monies. He failed to pay tax­es on monies received from IPOC and from Frid­man and his shell com­pa­nies as part of their mon­ey laundering/fraud scheme. Defen­dant Rozhet­skin did so while rely­ing upon New York banks to laun­der the theft of Plain­tiffs’ mon­ey.” [pg. 23]

“... tax fraud against the Unit­ed States.”: “Defen­dant Rozhet­skin was aid­ed by co-Defen­dants who par­tic­i­pat­ed in a vari­ety of sham trans­ac­tions using hold com­pa­nies to col­lec­tive­ly assist Rozhet­skin in his tax fraud against the Unit­ed States.” [pg. 23]

* U.S. Lob­by­ing Firm and Cor­po­ra­tion:

Bar­bour Grif­fith and Rogers: “The Alfa Group con­ducts such sig­nif­i­cant and var­ied busi­ness in the Unit­ed States that it has actu­al­ly found it to be in its inter­est to spend mil­lions of dol­lars court­ing the Amer­i­can polit­i­cal elite through Wash­ing­ton D.C. based lob­by­ing firm of Bar­bour Grif­fith and Rogers, LLC which lob­bies Con­gress and oth­ers in Wash­ing­ton on its behalf.” [pgs. 7–8]

“In addi­tion to using his lob­by­ing firm, Alfa Group has retained Edward Rogers’ Wash­ing­ton D.C. based “inves­tiga­tive” firm, Dili­gence, Inc. — which has crim­i­nal­ly mis­ap­pro­pri­at­ed IPOC infor­ma­tion as described fur­ther below ....[pg. 8]

“Hav­ing cho­sen to spend mil­lions of dol­lars to influ­ence the Unit­ed States Con­gress and oth­ers, and hav­ing received mil­lions of dol­lars from the Amer­i­can gov­ern­ment and pri­vate cit­i­zens, it should not fair­ly be heard to com­plain of being called to task now in an Amer­i­can court­room.” [pg. 8]

Dili­gence, Inc.: “Defen­dants have also paid U.S.-based Dili­gence, Inc. to steal IPOC prop­er­ty in Bermu­da. Indeed, at the Frid­man M.C. Enter­prise’s direc­tion Dili­gence bribed offi­cials of an account­ing firm and/or oth­er­wise mis­ap­pro­pri­at­ed IPOC prop­er­ty. More specif­i­cal­ly, Dili­gence, Inc. describes itself on its web site and in its press releas­es as a com­pa­ny com­prised of for­mer Cen­tral Intel­li­gence Agency (“CIA”) and British MI5 oper­a­tives that ‘spe­cial­ize in obtain­ing non-pub­lic or hard-to-get infor­ma­tion on cor­po­ra­tions.’ See http://www.diligencecorp.com. Dili­gence, Inc. is owned in part by Edward Rogers who has also been paid mil­lions by defen­dants to lob­by Con­gress and con­sult for Alfa.” [pg. 24]

“In vio­la­tion of 18 U.S.C. sec­tion 912 and at Defen­dant Alfa’s instruc­tions, Dili­gence, Inc. posed as Unit­ed States Agents act­ing under the author­i­ty of the Unit­ed States to mis­ap­pro­pri­ate IPOC infor­ma­tion from an account­ing firm. Defen­dants fur­ther vio­lat­ed 18 U.S.C. sec­tion 913 by search­ing IPOC prop­er­ty while false­ly rep­re­sent­ing, through Dili­gence, Inc., to be agents of the Unit­ed States. By doing so, Defen­dants have had an effect on the Unit­ed States.”[pg. 24]

* U.S.-related Inves­ti­ga­tions:

Norex Case: “In fact, the Sec­ond Cir­cuit Court of Appeals recent­ly reversed a Dis­trict Court deci­sion which had dis­missed RICO claims against these Defen­dants based upon a RICO con­spir­a­cy to defraud Norex, its Cana­di­an part­ner, of its own­er­ship inter­est in anoth­er com­pa­ny. Dis­cov­ery is now pro­ceed­ing in that case. [pg. 5]

The rul­ing is avail­able at http://www.norexpetroleum.com/norex_vs_alfa/us_court_of_appeals_ruling/eng.pdf Oil for Food Pro­gram: “The Unit­ed Nations in New York, through for­mer Fed­er­al Reserve Board Chair­man, Paul Vol­ck­er, has named Defen­dant Alfa Group for crim­i­nal wrong­do­ing and cit­ed its $2.3 mil­lion in ille­gal kick­backs and bribes to Sad­dam Hus­sein in the Oil for Food Pro­gram. See Inde­pen­dent Inquiry Com­mit­tee into The Unit­ed Nations Oil-For Food Pro­gramme (“Vol­ck­er Report”) at 44–66 (Oct. 27, 2005), http://www.iicc-offp.org/story27oct05.htm; http://www.timesonline.co.uk/article/03–1846855,00.html (not­ing an Alfa pay­ment of $2.3 mil­lion). In light of the Vol­ck­er report and oth­er activ­i­ties in this Coun­try, Alfa has found it to be in its inter­est to retain its own polit­i­cal­ly c
onnect­ed Wash­ing­ton D.C. lob­by­ing firm to pro­tect its inter­est as dis­cussed fur­ther below.” [pg. 5]

Cen­ter for Pub­lic Integri­ty Case: “Recent­ly, Mikhail Frid­man along with Pyotr Aven availed them­selves of Amer­i­can courts as a plain­tiff in lit­i­ga­tion brought in Sep­tem­ber 2005. Frid­man and Aven lost that case on the mer­its at sum­ma­ry judg­ment. See OAO Alfa Bank v. Cen­ter for Pub­lic Integri­ty, 387 F. Supp. 2d 20 (D.D.C. 2005).” [pg. 7]

The open­ing para­graph of the court rul­ing states: Plain­tiffs are two Russ­ian busi­ness­men and their com­pa­nies who have sued the defen­dants, a pub­lic inter­est orga­ni­za­tion and its reporters, for defama­tion for pub­lish­ing an arti­cle alleg­ing that plain­tiffs have con­nec­tions to orga­nized crime and have engaged in nar­cotics traf­fick­ing. Defen­dants have filed a motion for sum­ma­ry judg­ment in which they argue, among oth­er things, that plain­tiffs are lim­it­ed pub­lic fig­ures, and that the evi­dence demon­strates as a mat­ter of law that defen­dants did not pub­lish the piece with actu­al mal­ice. The Court agrees. Although defen­dants’ actions are not beyond reproach, they do not rise to the lev­el of actu­al mal­ice that the Con­sti­tu­tion demands in order to pre­serve a vibrant exchange of ideas on issues of pub­lic con­cern. For this rea­son, the Court grants defen­dants’ motion for sum­ma­ry judg­ment on all plain­tiffs’ claims. The rul­ing is avail­able at www.dcd.uscourts.gov/opinions/2005/Bates/2000-CV-2208~12:14:20~9–27-2005‑a.pdf * U.S. Gov­ern­ment Agency Fund­ed Invest­ment Firm:

The Great Cir­cle Fund: The Alfa Group “[i]s also the region­al man­ag­er for a US/OPIC spon­sored invest­ment firm called ‘The Great Cir­cle Fund.’ The Alfa Group makes use of this Unit­ed State agen­cy’s (OPIC’s) sup­port to pro­vide a sig­nif­i­cant por­tion of the fund­ing to meet its invest­ment objec­tives.” [pg. 7]

Per the Over­seas Pri­vate Invest­ment Cor­po­ra­tion (OPIC) Web site, it was “estab­lished as a devel­op­ment agency of the U.S. gov­ern­ment in 1971. OPIC helps U.S. busi­ness­es invest over­seas, fos­ters eco­nom­ic devel­op­ment in new and emerg­ing mar­kets, com­ple­ments the pri­vate sec­tor in man­ag­ing the risks asso­ci­at­ed with for­eign direct invest­ment, and sup­ports U.S. for­eign pol­i­cy. OPIC eval­u­ates all project appli­ca­tions on the basis of their con­tri­bu­tion to eco­nom­ic devel­op­ment to ensure suc­cess­ful imple­men­ta­tion of the orga­ni­za­tion’s core devel­op­men­tal mis­sion, and pri­or­i­tizes the allo­ca­tion of scarce resources to projects on the basis of their devel­op­men­tal ben­e­fits.”

The Great Cir­cle Cap­i­tal Web site http://www.greatcirclecapital.com/ for the Great Cir­cle Fund LP states that “Great Cir­cle Cap­i­tal has appoint­ed Moscow-based Alfa Cap­i­tal as the region­al man­ag­er and Brus­sel’s based pro­bel (sic) Cap­i­tal Man­age­ment as invest­ment advi­sor. A sub­stan­tial por­tion of the fund’s cap­i­tal is pro­vid­ed by the Over­seas Pri­vate Invest­ment Cor­po­ra­tion (OPIC), an inde­pen­dent, devel­op­men­tal US gov­ern­ment agency.”

* Defen­dants Used U.S. Banks for Trans­fers. Some Exam­ples Fol­low:

Bar­clays Bank in New York and Cred­it Suisse First Boston: “On April 11, 2001, IPOC wired $5,065,000 from its bank in Bermu­da to Bar­clays Bank in New York for fur­ther trans­fer to the Cred­it Suisse First Boston account of Rozhet­skin.” [pg. 16]

Bar­clays Bank in New York and Chase Man­hat­tan: “Using a num­ber of inter­me­di­aries and at Rozhet­skin’s require­ment, such mon­ey was wired from IPOC’s account in Bermu­da through Bar­clays Bank in New York and Chase Man­hat­tan to Rozhet­skin and his designees in Novem­ber 2001.” [pg. 16]

Bank of New York and Cred­it Suisse First Boston. “[o]n Decem­ber 20, 2001, IPOC through inter­me­di­aries wired an addi­tion­al $3,070,000 to Rozhet­skin and his designees through the Bank of New York locat­ed at One Wall Street in New York to Cred­it Suisse First Boston.” [pg. 17]

“... using the Amer­i­can banks as a vehi­cle for the fraud scheme. ...”: “Plain­tiff IPOC made all such pay­ments and oth­ers through the Unit­ed States with­out knowl­edge that Defen­dants Rozhet­skin, Bod­mer, Frid­man, Alfa Group, Alfa Cap­i­tal and Alfa Tele­com were all con­spir­ing where­by Rozhet­skin, using the Amer­i­can banks as a vehi­cle for the fraud scheme, would obtain IPOC’s cash, while Frid­man through a labyrinth of asso­ciates and indi­vid­u­als would obtain effec­tive con­trol over Plain­tiffs’ inter­est in Son­ic Duo/MegaFon.” [pg. 17]

“... use of the Unit­ed States to trans­fer assets in inter­state com­merce”: “Rozhet­skin knew the assets were unlaw­ful­ly tak­en when he made use of the Unit­ed States to trans­fer the assets in inter­state com­merce. Fur­ther, Rozhet­skin’s actions were in fur­ther­ance of his goal of cheat­ing the Amer­i­can gov­ern­ment of tax­es due and owing on the trans­ac­tions.” [pg. 18]