Indictment — United States v. Fursov (Dkt. 1, E.D. Cal.)

Summary

An indictment returned by a grand jury in United States v. Oleg Gregorvich Fursov, Case No. 2:25-cr-0191 DJC, in the U.S. District Court for the Eastern District of California, filed August 14, 2025 as Document 1 and presented by U.S. Attorney Eric Grant and Assistant U.S. Attorney Jessica Delaney. It describes Fursov as an Elk Grove, California resident and the owner of Fresh Air Comfort LLC, a heating, ventilation and air conditioning company. It charges wire fraud under 18 U.S.C. § 1343, alleging that between in or about April 2020 and in or about May 2023 he set out to obtain money from the SBA by false pretenses and applied for and received an EIDL loan modification for over $1 million. The charged wire is a transfer of $1,004,600 from the SBA to the company's checking account, and the indictment seeks criminal forfeiture under 18 U.S.C. § 981(a)(1)(C).

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Record facts

Full text

Text recognized from a scanned document; may contain errors.

Case 2:25-cr-00191-DJC       Document1       Filed 08/14/25    Page1of7

                                                                              FILED

     ERIC GRANT                                                             cutns a barccur
     United States Attorney                                                EASTERN DISTRICT OF CALIFORNIA
     JESSICA DELANEY
     Assistant United States Attorney
     501 I Street, Suite 10-100
     Sacramento, CA 95814
     Telephone: (916) 554-2700
     Facsimile: (916) 554-2900

     Attorneys for Plaintiff
     United States of America

                              IN THE UNITED STATES DISTRICT COURT

                                 EASTERN DISTRICT OF CALIFORNIA

10   UNITED STATES OF AMERICA,                     CASENO. 2:25-cr-0191 DJC-

i                              Plaintiff,          18 U.S.C. § 1343 (Wire Fraud);
                                                   18 U.S.C. § 981(a)(1)(C) and
12                       Vv.                       28 U.S.C. § 2461(c) — Criminal Forfeiture

13   OLEG GREGORVICH FURSOV, -

14                            Defendant.

15                                        INDICTMENT

16         The Grand Jury charges:

17                            .     OLEG GREGORVICH FURSOV,

18   defendant herein, as follows:

19                          INTRODUCTION AND RELEVANT ENTITIES

20         At all times relevant to the Indictment:

21          1.    Defendant OLEG GREGORVICH FURSOV was a resident of Elk Grove, California, .

22   within the State and Eastern District of California.

23         2.     FURSOV was the owner and sole proprietor of Fresh Air Comfort LLC. Fresh Air

24   Comfort LLC was a heating, ventilation and air conditioning company, incorporated in Sacramento,

25   California.

26         3.     The Small Business Administration (“SBA”) was an executive-branch agency of the

27   United States government that provided support to entrepreneurs and small businesses. The mission of

28   the SBA was to maintain and strengthen the nation’s economy by enabling the establishment and

      INDICTMENT

10
ll
12
13
14
15
16
17
18
19
20
21

22

23
24
25
26
27
28

Case 2:25-cr-00191-DJC Document1 Filed 08/14/25 Page 2 of 7

viability of small businesses and by assisting in the economic recovery of communities after disasters.
The Economic Injury Disaster Relief Program
4, The Economic Injury Disaster Loan Program (“EIDL”) was a United States SBA
program that provided low-interest financing to small businesses, renters, and homeowners in regions
affected by declared disasters. |
5, The CARES Act authorized the SBA to provide EIDL loans to eligible small businesses
experiencing substantial financial disruption due to the COVID-19 pandemic.

6. To obtain an EIDL loan,.a qualifying business was required to submit an application to

|| the SBA and provide information about the business’s operations, such as the number of employees,

gross revenues for the 12-month period preceding the disaster, and cost of goods sold in the 12-month
period preceding the disaster. In the case of EIDL loans for COVID-19 relief, the 12-month period was
the 12-month period from January 31, 2019, to January 31,2020. The applicant was also required to
certify that all of the information in the application was true and correct to the best of the applicant’s
knowledge.

7. EIDL loan applications were submitted directly to the SBA and processed by the agency
with support from a government contractor. The amount of the loan, if the application was approved,

was determined based, in part, on the information provided by the applicant about employment, revenue,

| and cost of goods sold. Any funds issued under an EIDL loan were issued directly by the SBA.

8. EIDL loan funds could be used for payroll expenses and business expenses, such as, sick
leave, production costs, and business obligations, such as debts, rent, and mortgage payments.

9. In the EIDL application, the applicant was required to provide information as to whether
any other company or person assisted the applicant in completing the application. An applicant was also
required to acknowledge program rules and make certain affirmative certifications in order to be eligible
to obtain the loan. One such certification required the applicant to affirm that the “Borrower will use all
the proceeds of this Loan solely as working capital to alleviate economic injury. . .”. The Borrower also
certified that no fees were paid to any representative in connection with applying for a loan, other than

those reported on the loan application.

10. Any funds issued under the EIDL are issued directly by the SBA. EIDL fund

INDICTMENT 2


10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Case 2:25-cr-00191-DJC Document1 Filed 08/14/25 Page 3 of 7

applications are received in cloud-based platforms. The location of the server through which the EIDL
application is submitted is based on the date the application was processed by SBA and the application
number. |

11. The maximum loan amount for EIDL loans fluctuated over time. In April 2020, the
maximum loan amount for an EIDL was $150,000. In September 2021, the maximum loan amount
increased to $2 million. As the maximum loan amount increased, applicants could request an already-
existing EIDL loan be modified to a higher loan amount. A request for a modification of an EIDL loan
was submitted using the SBA’s cloud-based platform. Ifthe SBA approved a request to modify a loan,
new loan documents, including an amended loan authorization and agreement, were generated for the
applicant’s review and signature. The new loan documents required the applicant to make the same
affirmative certifications as were required in an initial EIDL application.

SCHEME TO DEFRAUD

12. | Between in or about April 2020 and in or about May 2023 in the County of Sacramento,
State and Eastern District of California, and elsewhere, FURSOV knowingly and with the intent to
defraud, devised, intended to devise, participated in, and executed, a material scheme and artifice to
defraud the SBA of money and property; and to obtain money and property from the SBA by means of
materially false and fraudulent pretenses, representations, and promises. |

13. The purpose of the scheme and artifice to defraud was to obtain money in the form of an
EIDL loan from the SBA. Specifically, FURSOV applied for and received an EIDL loan modification
for over $1 million on behalf of his company, Fresh Air Comfort LLC, with the intent to defraud, steal,
and convert proceeds of the loan for his personal use and without the intent to use all the proceeds for .

their authorized purpose.

MANNER AND MEANS

14. Onor about April 15, 2020, FURSOV submitted an EIDL application to the SBA on
behalf of Fresh Air Comfort LLC. That application was processed, approved, and funds were disbursed.

on or about June 18, 2020.
15.. In or about December 2021, FURSOV learned that the EIDL program rules had changed

to allow for loan modifications of significantly higher amounts.

INDICTMENT


10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Case 2:25-cr-00191-DJC Document1 Filed 08/14/25 Page 4of7

16. Onor about January 4, 2022, FURSOV began the process of applying for a modification
of the EIDL loan he originally applied for in April 2020.

17. As apart of that modification process, Fursov received new loan documents, including an
amended loan authorization and agreement. On or about January 20, 2022, FURSOV signed the
amended loan authorization and agreement he received, and by doing so, certified that he would use the
funds solely for working capital and affirmed that all statements in his entire loan modification
application were true and correct. .

18.  Insigning the amended loan authorization and agreement, FURSOV signed and agreed to
the following statements, knowing that he did not have the intent expressed and that the facts were
untrue:

a) That he would use the proceeds of the loan solely as working capital to alleviate
economic injury;

b) That no fees were paid, directly or indirectly, to any representative for services
provided, or to be provided, in connection with applying for or closing the loan; and

c) That all representations in the entire loan application, including supplementary
submissions for the modification, were true. | |

19. The above statements were untrue, as FURSOV intended to convert at least a portion of
the funds for his personal use. Further, FURSOV made the affirmative certifications despite knowing
that he intended to pay an individual for assisting him with obtaining the loan.

20. On or about January 20, 2022, the SBA approved FURSOV’s loan modification
application. .

21. On or about January 25, 2022, the SBA funded FURSOV’s modified loan.

22. Between November 21, 2022, and May 2023, the SBA attempted to contact FURSOV
regarding repayment of the modified loan. FURSOV avoided all contact and interaction with employees
from the SBA following the funding of the modified loan.

WIRE TRANSFER

23. On or about January 26, 2022, in the State and Eastern District of California and

elsewhere, for the purpose of executing the aforementioned scheme and artifice to defraud, and

INDICTMENT


10
in
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Case 2:25-cr-00191-DJC Document1 Filed 08/14/25. Page 5of7

attempting to do so, FURSOV did knowingly cause to be transmitted by means of wire communication
in interstate commerce, certain writings, signs, signals, and sounds, to wit: a wire transfer of $1,004,600
from the SBA into the Fresh Air Comfort LLC business checking account ending in 4297.

All in violation of Title 18, United States Code, Sections 2 and 1343.

FORFEITURE ALLEGATION: [18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c) — Criminal
Forfeiture] -

1. Upon conviction of the offense alleged in this Indictment, defendant OLEG
GREGORVICH FURSOV shall forfeit to the United States pursuant to 18 U.S.C. § 981(a)(1)(C) and 28
U.S.C. § 2461(c), all property, real and personal, which constitutes or is derived from proceeds traceable
to such violation, including but not limited to the following:

a. A sum of money equal to the total amount of proceeds traceable to such offense,
for which defendant is convicted.

2. If any property subject to forfeiture, as a result of the offense alleged in this Indictment,
for which defendant is convicted:

a. camnot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third party;

C. has been placed beyond the jurisdiction of the court;

d. | has been substantially diminished in value; or

e. has been commingled with other property which cannot be divided without
difficulty; |

it is the intent of the United States, pursuant to 28 U.S.C. § 2461(c), incorporating 21 U.S.C. § 853(p), to

seek forfeiture of any other property of defendant, up to the value of the property subject to forfeiture.

A TRUE BILL.

/s/ Signature on file w/AUSA

Lar. (sar. a

ERIC GRANT
United States Attorney

INDICTMENT


Case 2:25-cr-00191-DJC Document1 Filed 08/14/25 Page 6 of 7

UNITED STATES DISTRICT COURT
Eastern District of California
Criminal Division

THE UNITED STATES OF AMERICA

VS.

OLEG GREGORVICH FURSOV

INDICTMENT

VIOLATION(S): 18 U.S.C. § 1343; 18 U.S.C. § 981(a)(1)(C); 28 U.S.C. § 2461(c)

A true bill /s/ Signature on file w/AUSA

Detention Without Bail - Bail to be Determined at Initial Appearance in Federal Court

Bail, $

hot
GPO 863 525

Case 2:25-cr-00191-DJC Document1 Filed 08/14/25 Page 7 of 7

United States v. Oleg Gregorvich Fursov
Penalties for Indictment

VIOLATION: 18 U.S.C. § 1343 — Wire Fraud

PENALTIES: Maximum of 20 years in prison;
Fine of up to $250,000 or twice the gross gains or loss; and
Supervised release of 3 years

SPECIAL ASSESSMENT: $100 (mandatory)

FORFEITURE ALLEGATION:

VIOLATION: 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c) — Criminal Forfeiture

PENALTIES: As stated in the charging document

File and source

File

gov.uscourts.caed.469684.1.0.pdf

Size

1,554,511 bytes

SHA-256

4bca7021dd0d1360577849487627a9f48d7138ff830560538b737ff495387e6a

Our copy

gov.uscourts.caed.469684.1.0.pdf

Original

archive.org