The indictment claims that according to the terms of the transaction, it was agreed that the consideration would be paid by the method of documents to be collected.
On September 15, 1999, the goods in Israel were received by the freight forwarder, Orian Freight Forwarders (1985) Ltd. (hereinafter: "Orian Company"), and on September 28, 1999, the import documents were received from the Arab Bank in the city of Ramallah (hereinafter: "the Higher Bank"). In the indictment, it was alleged that the defendants took a photocopy of the bill of lading prepared for the order of the collecting bank, and stamped a forged bank stamp on it, without paying the consideration for the goods, without redeeming the bill of lading, and without the collecting bank converting it in their favor.
The defendants attached to the counterfeit bill of lading a document pretending to be a sales account, in the amount of $287,018, from Manhattan Electric Industries (hereinafter: "Manhattan"), which pretended to be the supplier of the goods. The indictment also states that the sales account is not genuine since the goods that are the subject of the import license were not purchased from the Manhattan company, but were supposed to be purchased from Rasco, for $405,861. It was further claimed that the forged bill of lading, the false bill of sale, and the packing list of the goods were handed over by the defendants to the customs broker, Shai Customs Agents (1997) Ltd., who prepared at their request an import license in the name of ICT Finance in a tax appeal (hereinafter: "ICT"), according to which the value of the goods was only $285,000. ICT is a corporation registered in Israel and its shareholders are Yan Schwartzman and Meir Ben Shimon, who serve as straw men, while the control of the corporation is, in fact, in the hands of the defendants.
In these actions, the defendants forged documents (the bill of lading bearing the forged bank stamp and the false sales account), used them and received the goods through them, as well as a reduction in import taxes, all fraudulently and under aggravated circumstances. The defendants falsely declared that the value of the goods was lower than the real value, and as a result, they reduced the import taxes to which they were liable, since the goods are subject to customs, purchase tax, and the appeal of import taxes. The indictment also alleges that defendants 1 and 2 committed the acts together with the aim of defrauding the supplier of the goods and in order to fraudulently evade the payment of import taxes.