Criminal Complaint and Affidavit — U.S. v. Manukyan

Record facts

U.S. District Court, Central District of California · No. 2:20-mj-03710-DUTY · Doc. 1 · 2020-08-10 · Docket on CourtListener

Full text

Case 2:20-mj-03710-DUTY

Document 1

Filed 08/10/20

$2 5HY &ULPLQDO&RPSODLQW 5HYE\86$2RQ 

Page 1 of 21 Page ID #:1

‫ ܆‬2ULJLQDO‫'܆‬XSOLFDWH2ULJLQDO

81,7('67$7(6',675,&7&2857

LODGED
CLERK, U.S. DISTRICT COURT



IRUWKH

'0

08/10/2020

CENTRAL DISTRICT OF CALIFORNIA

&HQWUDO'LVWULFWRI&DOLIRUQLD

BY: ___________________ DEPUTY

AP

8QLWHG6WDWHVRI$PHULFD
Y
$50$10$18.<$1

&DVH1RPM

'HIHQGDQW V 

&5,0,1$/&203/$,17%<7(/(3+21(
2527+(55(/,$%/((/(&7521,&0($16
,WKHFRPSODLQDQWLQWKLVFDVHVWDWHWKDWWKHIROORZLQJLVWUXHWRWKHEHVWRIP\NQRZOHGJHDQGEHOLHI
%HJLQQLQJLQRUEHIRUHDQGFRQWLQXLQJWKURXJK-XO\LQWKHFRXQW\RI/RV$QJHOHVLQWKH&HQWUDO
'LVWULFWRI&DOLIRUQLDWKHGHIHQGDQW V YLRODWHGWKHIROORZLQJVWDWXWHVDVGHVFULEHGLQWKHDWWDFKPHQW
Code Sections

Offense Description

86&††$

%DQN)UDXG$JJUDYDWHG,GHQWLW\
7KHIW

7KLVFULPLQDOFRPSODLQWLVEDVHGRQWKHVHIDFWV
Please see attached affidavit.
_ &RQWLQXHGRQWKHDWWDFKHGVKHHW

/s Alfredo Rossi
Complainant’s signature

$OIUHGR5RVVL6SHFLDO$JHQW
Printed name and title

$WWHVWHGWRE\WKHDSSOLFDQWLQDFFRUGDQFHZLWKWKHUHTXLUHPHQWVRI)HG5&ULP3E\WHOHSKRQH
'DWH

$XJXVW
Judge’s signature

&LW\DQGVWDWH /RV$QJHOHV&DOLIRUQLD

+RQ.DUHQ/6WHYHQVRQ860DJLVWUDWH-XGJH
Printed name and title


Case 2:20-mj-03710-DUTY

Document 1

Filed 08/10/20

Page 2 of 21 Page ID #:2

&RPSODLQW$WWDFKPHQW

&RXQW2QH 86&† 

%HJLQQLQJEHIRUHDQGFRQWLQXLQJWKURXJK-XO\LQ/RV$QJHOHV&RXQW\
ZLWKLQWKH&HQWUDO'LVWULFWRI&DOLIRUQLDDQGHOVHZKHUHGHIHQGDQW$50$10$18.<$1
DFWLQJZLWKWKHLQWHQWWRGHIUDXGNQRZLQJO\H[HFXWHGDQGDWWHPSWHGWRH[HFXWHDVFKHPHWR
GHIUDXG%DQNRI$PHULFDDIHGHUDOO\LQVXUHGILQDQFLDOLQVWLWXWLRQDVWRPDWHULDOPDWWHUVDQGWR
REWDLQPRQH\VDQGIXQGVRZQHGE\DQGLQWKHFXVWRG\DQGFRQWURORI%DQNRI$PHULFDE\PHDQV
RIPDWHULDOIDOVHDQGIUDXGXOHQWSUHWHQVHVUHSUHVHQWDWLRQVDQGSURPLVHVDQGWKHFRQFHDOPHQWRI
PDWHULDOIDFWV7RH[HFXWHWKHIUDXGXOHQWVFKHPHGHIHQGDQWDSSOLHGIRUDQGUHFHLYHG
JRYHUQPHQWXQHPSOR\PHQWEHQHILWV²DVERWKRWKHULQGLYLGXDOVDQGDVEXVLQHVVHV²XVLQJIDOVH
LQIRUPDWLRQ'HIHQGDQWXVHG%DQNRI$PHULFDLVVXHGGHELWFDUGVLVVXHGLQWKHQDPHVRIYLFWLPV
RILGHQWLW\WKHIWWRZLWKGUDZDVFDVKIURP$70VWKHXQHPSOR\PHQWEHQHILWVLVVXHGWRWKRVH
SHUVRQV'HIHQGDQWDOVRIDOVHO\WROG%DQNRI$PHULFDWKDWKLVVKHOOEXVLQHVVHV$UJR*OREDO
,QFDQG([SUHVV:LULQJHPSOR\HGVFRUHVRIZRUNHUVLQRUGHUWRUHFHLYHWKURXJKWKDWILQDQFLDO
LQVWLWXWLRQPLOOLRQLQ3D\FKHFN3URWHFWLRQ3URJUDPVORDQV

&RXQW7ZR 86&†$ 

%HJLQQLQJEHIRUHDQGFRQWLQXLQJWKURXJK-XO\LQ/RV$QJHOHV&RXQW\
ZLWKLQWKH&HQWUDO'LVWULFWRI&DOLIRUQLDDQGHOVHZKHUHGHIHQGDQW$50$10$18.<$1
NQRZLQJO\WUDQVIHUUHGSRVVHVVHGDQGXVHGZLWKRXWODZIXODXWKRULW\DPHDQVRILGHQWLILFDWLRQ
RIDQRWKHUSHUVRQGXULQJDQGLQUHODWLRQWRDIHORQ\YLRODWLRQRI7LWOH8QLWHG6WDWHV&RGH
6HFWLRQ%DQN)UDXGDVFKDUJHGLQ&RXQW2QHNQRZLQJWKDWWKHPHDQVRILGHQWLILFDWLRQ
EHORQJHGWRDQRWKHUDFWXDOSHUVRQ


Case 2:20-mj-03710-DUTY

Document 1

1
2
3

Page 3 of 21 Page ID #:3

AFFIDAVIT
I, Alfredo Rossi, being duly sworn, declare and state as
follows:

4
5

Filed 08/10/20

I.
1.

PURPOSE OF AFFIDAVIT

This affidavit is made in support of a criminal complaint

6

and arrest warrant against Arman MANUKYAN (“MANUKYAN”) for

7

violations of Title 18, United States Code, §§ 1344 and 1028A (Bank

8

Fraud and Aggravated Identity Theft).

9

2.

The facts set forth in this affidavit are based upon my

10

personal observations, my training and experience, and information

11

obtained from various law enforcement personnel and witnesses.

12

affidavit is intended to show merely that there is sufficient

13

probable cause for the requested complaint and does not purport to

14

set forth all of my knowledge of or investigation into this matter.

15

Unless specifically indicated otherwise, all conversations and

16

statements described in this affidavit are related in substance and

17

in part only.

18
19

This

II. BACKGROUND OF SPECIAL AGENT ALFREDO ROSSI
3.

I am a Special Agent with Homeland Security Investigations

20

(“HSI”) and have been so employed since June 2019. I am currently

21

assigned to the High Intensity Financial Crimes Area (“HIFCA”) group,

22

where I investigate matters concerning bank fraud, wire fraud,

23

identity theft, money laundering, and other illegal financial

24

transactions.

25

4.

Prior to becoming a Special Agent with HSI, I was employed

26

as Special Agent with the United States Secret Service (“USSS”) from

27

June 2016 until June 2019, where I was responsible for the

28

investigation of various types of theft and fraud, including the


Case 2:20-mj-03710-DUTY

Document 1

Filed 08/10/20

Page 4 of 21 Page ID #:4

1

manufacturing of counterfeit and fraudulent identification documents,

2

and the investigation of financial crimes (such as access device

3

crimes, credit card fraud, check fraud, and schemes to conceal and

4

launder the proceeds of such crimes).

5

5.

To become an HSI Special Agent, I completed 9 months of

6

training at the Federal Law Enforcement Training Center in Brunswick,

7

Georgia.

8

have participated in several investigations related to alien

9

smuggling, narcotics smuggling, weapons trafficking, organized

10

criminal activity, child exploitation, and financial crimes. I have

11

participated in various aspects of criminal investigations, including

12

bank records analysis, telephone records analysis, electronic

13

surveillance, physical surveillance, search warrants, arrests, and

14

reviewing evidence from digital devices.

15

law enforcement agents regarding their experience in criminal

16

investigations, interviewed defendants, confidential informants, and

17

witnesses who had personal knowledge regarding the methods used to

18

commit various types of criminal offenses.

19

6.

During my employment as an HSI and USSS Special Agent, I

I have also spoken to many

Any facts or circumstances that are cited in this affidavit

20

are familiar to me through my direct participation in this

21

investigation, discussions with other law enforcement personnel

22

involved in this investigation, and/or my review of investigative

23

reports generated by other law enforcement personnel.

24

is made for the sole purpose of demonstrating probable cause for the

25

issuance of the requested search warrant and does not purport to set

26

forth all of my knowledge of or investigation into this matter.

27

Unless specifically indicated otherwise, all conversations and

28
2

This affidavit


Case 2:20-mj-03710-DUTY

Document 1

Filed 08/10/20

Page 5 of 21 Page ID #:5

1

statements described in this affidavit are related in substance and

2

in part only.

3
4

III. SUMMARY OF PROBABLE CAUSE
7.

In or about June 2020, MANUKYAN submitted two applications

5

for loans to Bank of America (“BofA”) on behalf of two shell entities

6

registered to MANUKYAN – Argo Global Inc. (“Argo Global”), and

7

Express Wiring -- through the Paycheck Protection Program (“PPP”)

8

established by the Coronavirus Aid, Relief, and Economic Security Act

9

for a total loanable amount of $1.7 million.

10

Global loan and denied the Express Wiring one, and as a result,

11

MANUKYAN received a total of $867,187 in funds. In the application

12

process, MANUKYAN attached fabricated tax documentation and made

13

false representations about the operational status of the companies,

14

and how the loan proceeds would be spent. Shortly after receiving the

15

funds in a business account in Argo Global’s name, MANUKYAN

16

transferred most of the balance to an external account for which he

17

is the sole signator as well as to another BofA personal account for

18

which MANUKYAN is also the sole signator.

19
20

BofA approved the Argo

IV. PREVIOUS GPS AND BANK ACCOUNT SEIZURE WARRANTS
8.

Based on an earlier affidavit, on July 7, 2020, the

21

Honorable John E. McDermott, United States Magistrate Judge, issued a

22

GPS tracking affidavit for a cellular telephone number used by ARMAN

23

MANUKYAN, as well as a second number reported by ARMAN MANUKYAN which

24

he does not appear to use, along with a seizure warrant for three of

25

ARMAN MANUKYAN’s bank accounts.

26

to locate MANUKYAN’s residence, and subsequently obtained and

27

executed federal search warrants there, as described in more detail

28

below.

Through the GPS warrant, I was able

3


Case 2:20-mj-03710-DUTY

1
2

Document 1

V.
9.

Filed 08/10/20

Page 6 of 21 Page ID #:6

STATEMENT OF PROBABLE CAUSE

Based on my review of investigative reports and notes, bank

3

statements, witness statements, my discussions with other law

4

enforcement officers working on this investigation, and other

5

evidence, I learned the following information:

6

A.

7

10. The Coronavirus Aid, Relief, and Economic Security

8

(“CARES”) Act is a federal law enacted around March 2020 and was

9

designed to provide emergency financial assistance to the millions of

10

Americans who are suffering the economic effects caused by the COVID-

11

19 pandemic. One source of relief provided by the CARES Act was the

12

authorization of up to $349 billion in forgivable loans to small

13

businesses for job retention and certain other expenses, through a

14

program referred to as the Paycheck Protection Program (“PPP”).

15

Around April 2020, Congress authorized over $300 billion in

16

additional PPP funding.

17

The Paycheck Protection Program

11. In order to obtain a PPP loan, a qualifying business must

18

submit a PPP loan application, which is signed by an authorized

19

representative of the business. The PPP loan application requires the

20

business (through its authorized representative) to acknowledge the

21

program rules and make certain affirmative certifications in order to

22

be eligible to obtain the PPP loan. One such certification requires

23

the applicant (through its authorized representative) to affirm that

24

“[t]he [PPP loan] funds will be used to retain workers and maintain

25

payroll or make mortgage payments, lease payments, and utility

26

payments; I understand that if the funds are used for unauthorized

27

purposes, the federal government may pursue criminal fraud charges.”

28

In the PPP loan application, the small business (through its
4


Case 2:20-mj-03710-DUTY

Document 1

Filed 08/10/20

Page 7 of 21 Page ID #:7

1

authorized representative) must state, among other things, its: (a)

2

average monthly payroll expenses; and (b) number of employees. These

3

figures are used to calculate the amount of money the small business

4

is eligible to receive under the PPP. In addition, businesses

5

applying for a PPP loan must provide documentation showing their

6

payroll expenses.

7

12. A business PPP loan application is received and processed,

8

in the first instance, by a participating financial institution, then

9

transmitted, for further review, to the Small Business Administration

10

(“SBA”) to assess the applicant’s eligibility. If a PPP loan

11

application is approved, the participating financial institution

12

funds the PPP loan using its own monies.

13

13. PPP loan proceeds must be used by the business on certain

14

permissible expenses -- payroll costs, interest on mortgages, rent,

15

and utilities. The PPP allows the interest and principal on the PPP

16

loan to be entirely forgiven if the business spends the loan proceeds

17

on these expense items within a designated period of time (usually

18

eight weeks of receiving the proceeds) and uses at least 75% of the

19

PPP loan proceeds on payroll expenses.

20

B.

MANUKYAN Submitted Fabricated Tax Documents for His Shell
Business Argo Global to BofA for a PPP Loan

21
14. From reviewing loan documents provided by BofA and the SBA,
22
I learned that in or around June 2020, MANUKYAN submitted two
23
applications for PPP loans to BofA which were consequently received
24
by the SBA, as follows:
25
a.

First, MANUKYAN applied for a loan in the name of Argo

26
Global, claiming that Argo Global was a sewing business which
27
reported an average monthly payroll expenses of $346,875 and a total
28
5


Case 2:20-mj-03710-DUTY

Document 1

Filed 08/10/20

Page 8 of 21 Page ID #:8

1

of 73 employees. The application listed MANUKYAN as the principal

2

with a home address of 209 E Palmer Ave Apt 214, Glendale.

3

learned from MANUKYAN’s immigration file, however, that he told

4

immigration authorities that he did not live at that address, but

5

rather his ex-wife and son did.)

6

address for Argo Global as 433 Camden Dr 6th floor, Beverly Hills,

7

California.

8

a commercial mail receiving agency (“CMRA”), or virtual office. As

9

proof of Argo Global payroll expenses, MANUKYAN provided an Internal

10

Revenue Service (“IRS”) Form 940 - Employer's Annual Federal

11

Unemployment (FUTA) dated on April 08 2020, and IRS Form 941 -

12

Employer’s Quarterly Federal Tax dated on January 12, 2020,

13

purporting to show wages and taxes for Argo Global for tax year 2019

14

in the amount of $4,162,500. These IRS documents were both submitted

15

to BofA unsigned. Additionally, the underwriting packet did not

16

include a list of employees or associates employed by Argo Global.

17

b.

(I

The loan application listed the

As described later, this address actually corresponds to

Second, MANUKYAN applied for a loan in the name of

18

Express Wiring, listing MANUKYAN as the principal and listing

19

MANUKYAN’S ADDRESS in Glendale as the loan mailing address. This PPP

20

loan application was sent to BofA few days after the Argo Global

21

application and was submitted for an amount of $884,748. The SBA

22

rejected this application indicating that this loan had been

23

submitted either after the cutoff date of June 22, 2020 or the

24

government allocated funds for the PPP had run out.

25

15. I have reviewed additional representations MANUKYAN made

26

and submitted with the Argo Global loan application package (and

27

which were required by the SBA). Among other things, MANUKYAN

28

certified the following:
6


Case 2:20-mj-03710-DUTY

1

a.

Document 1

Filed 08/10/20

Page 9 of 21 Page ID #:9

MANUKYAN certified that Argo Global was last

2

incorporated with the California Secretary of State on December 10,

3

2019 and “had employees for whom the applicant paid salaries and

4

payroll taxes or paid independent contractors.”

5

b.

MANUKYAN certified that “All SBA loan proceeds will

6

be used only for business-related purposes as specified in the loan

7

application and consistent with the Paycheck Protection Program

8

Rule.”

9

c.

MANUKYAN again certified that “the funds will be used

10

to retain workers and maintain payroll or make mortgage interest

11

payments, lease payments, and utility payments.”

12

Argo Global Inc. Appears to Be a Shell Business

13

16. On or about July 1, 2020 I conducted a search of Argo

14

Global on open source search engines such as google as well as

15

business networking apps such as Yelp and did not observe any

16

information related to any sewing business matching the identifiers

17

provided by MANUKYAN.

18

There Is No Record of the Tax Payments Argo Global Claims

19

17. On or about July 2, 2020 I spoke with Special Agent (“SA”)

20

Rob Bravo with the Treasury Inspector General for Tax Administration

21

(“TIGTA”) regarding IRS Forms 940 and IRS Forms 941 that were

22

submitted by MANUKYAN as part of the loan application process to

23

represent the authenticity of the business Argo Global. SA Bravo

24

stated that no documentation regarding Argo Global could be found

25

across IRS databases generally, and that he could find no record that

26

the aforementioned Form 940 and Form 941 were ever actually filed

27

with the IRS in particular.

On July 7, 2020, he told me that no tax

28
7


Case 2:20-mj-03710-DUTY

Document 1

Filed 08/10/20

Page 10 of 21 Page ID #:10

1

documents had ever been filed for Argo Global Inc., or for MANUKYAN’s

2

other purported business, Express Wiring.

3

Express Wiring Also Appears to Be a Shell Business

4

18. On or about July 5, 2020 I conducted a search of Express

5

Wiring on open source search engines such as google as well as

6

business networking apps such as Yelp and did not observe any

7

information related to any business matching the identifiers provided

8

by MANUKYAN.

9

C.

BofA Funded the Argo Global Loan Based on the False
Information Provided by MANUKYAN

10
19. According to bank records, on or about June 3, 2020, BofA
11
funded the Argo Global PPP loan, wiring the approved funds to BofA
12
business checking account 325117015294 held in the name of Argo
13
Global Inc., with MANUKYAN as the sole person with signature
14
authority over the account (“MANUKYAN’s Argo Account”), for a total
15
of approximately $867,187.

On or about July 1, 2020, I reviewed the

16
account statements and signature card for Bank of America account
17
5294 (MANUKYAN’s Argo Account) and learned the following:
18
a.

MANUKYAN’s Argo Account was opened in the name of

19
Argo Global by MANUKYAN on or about January 28, 2020 at a BofA branch
20
located at 7255 Woodman Ave, Van Nuys, California.
21
b.

Before the SBA PPP loan disbursement on June 3, 2020,

22
MANUKYAN’s Argo Account had a strange pattern of activity:

there

23
were biweekly large cash deposits ranging from $1,500 to $21,977,
24
typically followed by similar-sized checks being written against the
25
account to MANUKYAN.

As a consequence, the balance remained low.

In

26
my training and experience, this pattern is indicative of money
27
laundering; criminals who are trying to make an account for a shell
28
8


Case 2:20-mj-03710-DUTY

Document 1

Filed 08/10/20

Page 11 of 21 Page ID #:11

1

business appear active will often make offsetting transactions to it

2

using funds and other accounts they control.

3

records did not show activity consistent with a sewing business.

4

did not see any purchases at fabric or craft stores.

5

to what appeared to be credit accounts held with “Infiniti” car

6

manufacturer, and to other financial institutions that referenced

7

MANUKYAN’s name.

8

for a legitimate business operating in sewing and craft to be

9

receiving large amounts of cash into a newly opened business account.

10

Also based on my training and experience, a legitimate business would

11

not receive large cash payments during the covid-19 pandemic while

12

also applying for government relief to pay for employee wages and

13

unemployment.

14

D.

My review of the bank
I

I saw payments

Based on my training and experience it is uncommon

MANUKYAN rapidly transferred $100k of SBA funds out of
MANUKYAN’s Argo Account into MANUKYUAN’S BOTW ACCOUNT

15
20. On or about June 4, 2020, one day after the $867,187 PPP
16
funds were disbursed into MANUKYAN’s Argo Account, MANUKYAN
17
transferred $48,000 into BofA account 325090924800 (“MANUKYAN’S BOA
18
ACCOUNT”), followed by a second transfer of $62,000 on or about June
19
5, 2020, also from MANUKYAN’s Argo Account into a personal checking
20
accounts, MANUKYAN’S BOA ACCOUNT.
21
21. On or about July 6, 2020, I reviewed the account statements
22
and signature card for Bank of America account 4800 and learned that
23
MANUKYAN’S BOA ACCOUNT was opened in the name of MANUKYAN on or about
24
August 28, 2017 at a BofA branch located at 203 N Glendale Ave,
25
Glendale, California.
26
27
28
9


Case 2:20-mj-03710-DUTY

1

E.

Document 1

Filed 08/10/20

Page 12 of 21 Page ID #:12

MANUKYAN Wires Most of the SBA Loan Out of MANUKYAN’s Argo
Account into MANUKYUAN’S BOTW ACCOUNT

2
22. On or about June 17, 2020, MANUKYAN wired $475,000 of the
3
PPP loan proceeds out of MANUKYAN’s Argo Account to Bank of the West
4
account 053651949 (“MANUKYAN’S BOTW ACCOUNT”), followed by a second
5
wire for $212,000 on June 18, 2020, to the same account.
6
23. On or about July 1, 2020, I reviewed the account statements
7
and signature card for MANUKYAN’S BOTW ACCOUNT and learned the
8
following:
9
a.

MANUKYAN’S BOTW ACCOUNT was opened in the name of

10
MA&CO by MANUKYAN on or about May 22, 2018 at a Bank of the West
11
branch in Glendale, CA.
12
b.

MANUKYAN listed phone number 857-505-8149 (MANUKYAN’S

13
TELEPHONE) as his personal cellphone number.
14
c.

From the day the account was opened on or about May

15
22, 2018 with an initial starting deposit of $100, through April
16
2020, MANUKYAN’S BOTW ACCOUNT was only used four times for one ATM
17
cash withdrawal of $50, one ATM cash withdrawal of $20, one debit
18
card purchase in the amount of $9.84 at a Rite Aid store in Van Nuys,
19
California, and one debit card purchase in the amount of $9.91 at a
20
Rite Aid store in Glendale, California.

MANUKYAN’S BOTW ACCOUNT was

21
then used again in June 2020 for the two wires of SBA PPP funds for a
22
total of $687,000 from ARGO’s BOA ACCOUNT into MANUKYAN’S BOTW
23
ACCOUNT.

MANUKYAN’S BOTW ACCOUNT also received two checks from

24
MANUKYAN’s Argo Account in June 2020 for a total of $44,900.
25
MANUKYAN Cannot Explain the Purpose of a $200,000 Wire to APMEX
26
24. According to bank records, on June 24, 2020, MANUKYAN went
27
to a BOTW branch in Glendale, CA to wire $200,000 from MANUKYAN’S
28
10


Case 2:20-mj-03710-DUTY

Document 1

Filed 08/10/20

Page 13 of 21 Page ID #:13

1

BOTW ACCOUNT to an account in the name of “APMEX”.

2

web search, APMEX is a dealer in precious metals such as gold bars.

3

In my training and experience, those trying to launder substantial

4

sums often purchase precious metals because they are untraceable.)

5

The teller handling the transaction asked MANUKYAN the reason for the

6

large wire, and MANUKYAN replied that his accountant instructed him

7

to wire the funds out. Approximately 10 minutes after the completion

8

of the wire documentation for APMEX, MANUKYAN returned to the

9

Glendale branch and said he wanted to cancel the wire to “APMEX,” and

10

instead asked to wire the $200,000 to his personal savings account at

11

the Los Angeles Federal Credit Union (“MANUKYAN’S LAFCU ACCOUNT”),

12

however he did not have his account number, so the wire was not

13

completed.

14

(According to a

An Hour Later, MANUKYAN Went to a Different Branch to Wire the
$200,000 to His Personal Account Instead

15
16
17
18
19
20
21
22
23
24
25
26
27
28

25. That same day, approximately an hour after the original
attempted wire, MANUKYAN went to a different BOTW branch, this one in
Burbank, to wire the $200,000 he tried to wire at the Glendale BOTW
branch earlier in the day, and this time was able to complete the
wire to his personal savings account at the Los Angeles Federal
Credit Union, number 10000007507320 (MANUKYAN’S LAFCU ACCOUNT).

But

on or about June 25, 2020, the wire to the Los Angeles Federal Credit
Union was rejected, and the $200,000 funds were returned to
MANUKYAN’S BOTW ACCOUNT. BOTW declared the account activity
suspicious and froze MANUKYAN’S BOTW ACCOUNT. On the same day, BOTW
contacted HSI for assistance with the investigation.
MANUKYAN Claims He Was Going to Use the $200,000 to Start a New
Limousine Business, Contradicting His Certification on the PPP
Application
11


Case 2:20-mj-03710-DUTY

Document 1

Filed 08/10/20

Page 14 of 21 Page ID #:14

1

26. On or about June 26, 2020, MANUKYAN was contacted by a BOTW

2

bank investigator at phone number 857-505-8149 (MANUKYAN’S TELEPHONE)

3

and was asked to explain the nature of the funds and reason behind

4

the wires. MANUKYAN stated that his accountant told him to move

5

$200,000 to his savings account and that he was just following his

6

accountant’s instructions. Additionally, MANUKYAN stated that he was

7

in urgent need of the funds since he was planning on starting a new

8

limousine business and needed to place vehicle orders on Amazon.

9

MANUKYAN also stated that he had customers already lined up and that

10

the freeze would force him to terminate business with BOTW.

11

27. Based on my knowledge and experience, Amazon does not allow

12

the sale of vehicles on their online market and only allows users to

13

research vehicle’s prices, shop for car accessories and upload

14

reviews. Also based on my training and experience investigating

15

fraud, I know that fraudsters often use high-pressure tactics to

16

influence others to give them money, expeditiously, such as through

17

threats to terminate a business relationship, like MANUKYAN did on

18

the call with the BOTW bank investigator.

19

MANUKYAN Transferred Fraud Proceeds from MANUKYAN’s Argo Account to

20

MANUKYAN’S BOTW ACCOUNT and MANUKYAN’S LAFCU ACCOUNT

21

28. From reviewing Bank of America documents for MANUKYAN’s

22

Argo Account, I learned that a few days after the PPP SBA loan funds

23

were deposited into that account, MANUKYAN rapidly withdrew the funds

24

in various ways.

25

drawn against MANUKYAN’s Argo Account.

26

to MANUKYAN, and negotiated at other financial institutions MANUKYAN

27

had accounts opened with.

28

through the following SEIZABLE ACCOUNTS:

Starting on June 5, 2020, multiple checks were
The checks were made payable

MANUKYAN negotiated the following checks

12


Case 2:20-mj-03710-DUTY

1

a.

2

BOTW ACCOUNT;

3

b.

4

c.

Page 15 of 21 Page ID #:15

A check dated June 05, 2020 for $6,200 at MANUKYAN’S

A check dated June 05, 2020 for $9,600 at MANUKYAN’S

A check dated June 11, 2020 for $14,700 at MANUKYAN’S

LAFCU ACCOUNT; and

7

d.

8

BOTW ACCOUNT.

9

Filed 08/10/20

LAFCU ACCOUNT;

5
6

Document 1

A check dated June 12, 2020 for $38,700 at MANUKYAN’S

29. Based on my training and experience, I know that all of the

10

financial institutions mentioned in this affidavit are federally

11

insured.

12

F.

Argo Global Inc.’s Current Address Is a Virtual Office/Mail
Drop

13
30. On or about June 30, 2020 I conducted surveillance at 433 N
14
Camden Drive, Beverly Hills, California – an address that according
15
to the California Articles of Incorporation is associated with Argo
16
Global - and learned the following:
17
a.

The building is managed by a company called ESDI which

18
leases virtual offices to several tenants. On or about July 1, 2020,
19
ESDI took over the management of the building from the previous
20
landlord, Barrister Executive Suites, Inc.
21
b.

ESDI President Massy Fanzine explained to me that

22
after the recent change of management, some of the older tenants did
23
not renew their leases and elected to stay with Barrister Executive
24
Suites, relocating at their new address located at 9440 S Santa
25
Monica Blvd Suite 301, Beverly Hills, California. President Fanzine
26
stated that Argo Global was not one of their tenants and that it
27
likely moved over with Barrister Executive Suites.
28
13


Case 2:20-mj-03710-DUTY

Document 1

Filed 08/10/20

Page 16 of 21 Page ID #:16

1

31. Also on June 30, 2020 I conducted surveillance at 9440 S Santa

2

Monica Blvd Suite 301, Beverly Hills, CA and learned the following:

3

a.

Barrister Executive Suites recently moved to this

4

address and appeared to be still undergoing the transition from the

5

older location. An administrator with Barrister Executive Suites

6

stated that Argo Global had been a tenant with Barrister Executive

7

Suites for less than a year and that the only service they provided

8

to Argo Global was holding their mail. Additionally, the Barrister

9

Executive Suites administrator stated that Argo Global never had an

10

actual office space and that no employees from Argo Global had ever

11

worked at the 433 N Camden Drive address or the 9440 S Santa Monica

12

Blvd address.

13

G.

Argo Global Inc.’s Original Address Was 7855 HAZELTINE
AVENUE

14
32. On or about June 26, 2020, I reviewed the articles of
15
incorporation for Argo Global Inc. filed on or about January 30, 2018
16
with the California Secretary of State. This document lists MANUKYAN
17
as the initial agent for service of process of this business located
18
at 7855 HAZELTINE AVENUE (the official address of MANUKYAN’S
19
RESIDENCE).
20
H.
21

Argo Global Inc.’s Address of Record with the IRS is 7855
HAZELTINE AVENUE

22

33. On or about July 15, 2020 I learned from SA Bravo with TIGTA

23

that a review of the IRS Integrated Data Retrieval System (IDRS)

24

showed that the address of record associated with the Employer

25

Identification Number (EIN) for Argo Global Inc. is 7855 HAZELTINE

26

AVENUE.

27
28
14


Case 2:20-mj-03710-DUTY

1

I.

Document 1

Filed 08/10/20

Page 17 of 21 Page ID #:17

MANUKYAN resides at the 7855/7857 HAZELTINE (MANUKYAN’S
RESIDENCE)

2
34. On July 15, 2020, I reviewed the GPS pings for MANUKYAN’S
3
TELEPHONE which have been provided by T-Mobile at intervals of
4
fifteen minutes since on or about July 13, 2020 and learned the
5
following:
6
a.

the GPS pings for MANUKYAN’S TELEPHONE often

7
correspond to geographical coordinates located within a few miles of
8
the 7855/7857 HAZELTINE, PANORAMA CITY, which is within the radius of
9
uncertainty for the pings.

That is, while the pings are not located

10
at MANUKYAN’S RESIDENCE, they are consistent with the expected
11
coordinates if MANUKYAN’S TELEPHONE were located at MANUKYAN’S
12
RESIDENCE.
13
35. On July 15, 2020, I conducted surveillance in the vicinity of
14
the GPS pings and observed the following:
15
a.

I saw MANUKYAN (identified by his driver’s license

16
photograph and bank surveillance photographs) exiting the lot of
17
MANUKYAN’S RESIDENCE and entering MANUKYAN’s VEHICLE, which was
18
parked on HAZELTINE AVENUE across the street from MANUKYAN’S
19
RESIDENCE. On or about July 15, 2020, I reviewed the California Law
20
Enforcement Telecommunication System database and found that
21
MANUKYAN’s VEHICLE, bearing California license plate 8NAW574, was a
22
Toyota Camry 2018 last registered to MANUKYAN at a previous address.
23
b.

I saw a white Buick SUV leaving the driveway of

24
MANUKYAN’S RESIDENCE bearing CA license plate 8JJL281. On or about
25
July 15, 2020, I reviewed the California Law Enforcement
26
Telecommunication System database and found that the vehicle bearing
27
California license plate 8JJL281 was a Buick 2019 registered to
28
15


Case 2:20-mj-03710-DUTY

Document 1

Filed 08/10/20

Page 18 of 21 Page ID #:18

1

MANUKYAN’s ex-wife, Hasmik Zakoyan at 621 Myrtle St, Glendale,

2

California.

3

J.

MANUKYAN Withdrew Cash at ATMs Using Debit Cards in Other
Persons’ Names on July 15, 2020

4
36. Continuing on July 15, 2020, HSI Special Agents followed
5
MANUKYAN, who left MANUKYAN’S RESIDENCE driving MANUKYAN’s VEHICLE,
6
and observed him stopping at four Bank of America ATMs at about the
7
following times and at the following locations:
8
a.

At 10:01 – at a Bank of America ATM located at 7255

9
Woodman Ava, Yan Nuys, California;
10
b.

At 10:46 – at a Bank of America ATM located at 9012

11
Sepulveda Blvd, North Hills, California;
12
c.

At 10:56 at a Bank of America ATM located at 8720

13
Balboa Blvd, Northridge, California
14
d.

At 11:10 at a Bank of America ATM located at 17650

15
Saticoy St, Reseda, California;
16
37. On or about July 16, 2020 I spoke to Bank of America
17
Investigator Christopher Thompson and learned that MANUKYAN conducted
18
four ATM withdrawals using the following Employment Development
19
Department (EDD) benefit cards in the name of individuals other than
20
MANUKYAN to withdraw approximately $1,000 per card at each
21
aforementioned ATM:
22
a.

EDD Bank of America Debit Card account 4427 4341 8564

23
5189 held in the name of ANASTASIA ISAENKO registered at 7855
24
HAZELTINE;
25
b.

EDD Bank of America Debit Card account 4427 4341 8627

26
0243 held in the name of EKATERINA RYABOVA registered at 7855
27
HAZELTINE;
28
16


Case 2:20-mj-03710-DUTY

1

c.

Document 1

Filed 08/10/20

Page 19 of 21 Page ID #:19

EDD Bank of America Debit Card account 4427 4341 9406

2

6997 held in the name of JOVOKHIR TOPILDIEV registered at 7857

3

HAZELTINE;

4

d.

EDD Bank of America Debit Card account 4427 4341 9463

5

1691 held in the name of AXYNYA KURBATOVA registered at 444

6

Devonshire lane, Glendale, California.

7

K.

HSI executes a search warrant at MANUKYAN’S RESIDENCE and
retrieves additional EDD Bank of America Debit Cards

8
38. On July 17, 2020, the Honorable Steve Kim, United States
9
Magistrate Judge, issued a search warrant for 7855 AND 7857 HAZELTINE
10
AVENUE, PANORAMA CITY which was executed by agents on July 22, 2020.
11
During the search of MANUKYAN’s personal belongings the following
12
additional EDD benefit cards were seized by HSI:
13
a.

EDD Bank of America Debit Card account 4427 4341 9398

14
5437 held in the name of DAVRON MAGAMETOV registered at 7857
15
HAZELTINE;
16
b.

EDD Bank of America Debit Card account 4427 4341 9002

17
7480 held in the name of PINKNEY FORD registered at 6636 Fulton Ave,
18
Van Nuys, California;
19
c.

EDD Bank of America Debit Card account 4427 4341 6689

20
5449 held in the name of ARMAN MANUKYAN;
21
L.
22

MANUKYAN Claimed He Found on the Street EDD Cards Recovered
from His Room, But Falsely Insisted He Had Never Used Them

23

39. On July 22, 2020, MANUKYAN told me he was collecting

24

unemployment benefits using EDD Bank of America Debit Card account

25

4427 4341 6689 5449 held in is name.

26

other two cards found in his room held in the name of DAVRON

27

MAGAMETOV and PINKNEY FORD, MANUKYAN stated that he had found these

28

two cards in the streets and consequently decided to keep them in his
17

When I asked him about the


Case 2:20-mj-03710-DUTY

Document 1

Filed 08/10/20

Page 20 of 21 Page ID #:20

1

room. He insisted, however, that he had never used them.

2

confronted about the ATM withdrawals of EDD Bank of America Debit

3

Cards in the names of other individuals as observed by agents during

4

the surveillance on July 15, 2020, MANUKYAN paused for a few seconds

5

and replied that he wished to talk to an attorney before answering

6

any further questions.

7

M.

When

MANUKYAN’s Landlord Confirmed that the Unemployment
Recipients Identified by EDD Never Lived at that Residence

8
40. Continuing on July 22, 2020, I spoke to the landlord and
9
owner of the 7855 AND 7857 HAZELTINE AVENUE, PANORAMA CITY, Edgar
10
Zakoyan, about the high number of unemployment applications filed
11
with the EDD utilizing 7855 AND 7857 HAZELTINE AVENUE, PANORAMA CITY
12
as the address of record, and showed him a list of the following
13
account holders: “Isaenko Anastasia”, “Mocanu Tatiana”, “Ryabova
14
Ekaterina”, “Topildiev Jovokhir”, “Yakutina Darya”, and “Magametov
15
Davron”.

Zakoyan verified that none of these names identified by EDD

16
as beneficiary for unemployment benefits had ever lived at that
17
address.
18
N.

MANUKYAN is Fleeing to France

19
41. On or about August 7, 2020 I spoke to the landlord and
20
owner of MANUKYAN’S RESIDENCE, Edgar Zakoyan, who told me that he was
21
worried for MANUKYAN since he had not seen him or heard from him for
22
a few days. Zakoyan stated that MANUKYAN’s parents had reached out to
23
him asking about MANUKYAN’s whereabouts as they also were not able to
24
get a hold of him. Zakoyan also stated that MANUKYAN’s vehicle was
25
still parked in front of the residence and that the keys to the house
26
and MANUKYAN’s vehicle were left inside of MANUKYAN’s room unsecured.
27
28
18


Case 2:20-mj-03710-DUTY

1

42.

Document 1

Filed 08/10/20

Page 21 of 21 Page ID #:21

On August 9, 2020, I received notification from the

2

National Targeting Center (“NTC”) that MANUKYAN had boarded Air

3

France flight 179 from Mexico City, Mexico inbound to Paris, France

4

with a final destination of Minsk, Belarus.

5
6

VI.
43.

CONCLUSION

Based on the foregoing, there is probable cause to believe

7

MANUKYAN violated Title 18, United States Code, Sections 1344 and

8

1028A (Bank Fraud and Aggravated Identity Theft).

9
10
11

Attested to by the applicant in accordance
with the requirements of Fed. R. Crim. P. 4.1
by telephone on this ____
WK day of August,
2020.

12
13
14
15

UNITED STATES MAGISTRATE JUDGE

16
17
18
19
20
21
22
23
24
25
26
27
28
19

File and source

File

gov.uscourts.cacd.791269.1.0.pdf

Size

253,645 bytes

SHA-256

e1ec519c6e468997e35a43ae14ce582de24a9c51eac4ec18a35064cda6b279d9

Our copy

gov.uscourts.cacd.791269.1.0.pdf

Original

PACER (login required)