Court filing

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

Summary

Criminal complaint and supporting affidavit filed August 10, 2020 as Document 1 in United States v. Arman Manukyan, No. 2:20-mj-03710-DUTY, in the U.S. District Court for the Central District of California, sworn by Homeland Security Investigations Special Agent Alfredo Rossi. It charges bank fraud and aggravated identity theft under Title 18, United States Code, §§ 1344 and 1028A. The affidavit states Manukyan applied to Bank of America for PPP loans for shell entities Argo Global Inc. and Express Wiring with fabricated tax documents, claiming Argo Global had 73 employees, and received $867,187 for Argo Global. It states he transferred most of the funds to accounts he controlled, and that on August 9, 2020 he boarded a flight from Mexico City to Paris. These are allegations.

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Filed August 10, 2020 in U.S. v. Manukyan; one of 2 filings from this case.

Record facts

Court	U.S. District Court, Central District of California
Filed	2020-08-10

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“Criminal Complaint and Affidavit — U.S. v. Manukyan.” U.S. District Court, Central District of California, No. 2:20-mj-03710-DUTY, Doc. 1, filed 2020-08-10. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/us-v-manukyan/2020-08-10-criminal-complaint-affidavit/, SHA-256 e1ec519c6e468997e35a43ae14ce582de24a9c51eac4ec18a35064cda6b279d9.

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AO 91 (Rev. 11/11) Criminal Complaint (Rev. by USAO on 3/12/20)
܆Original ܆ Duplicate Original

UNITED STATES DISTRICT COURT

for the

Central District of California

United States of America

ARMAN MANUKYAN,

Defendant(s)

Case No.

CRIMINAL COMPLAINT BY TELEPHONE
OR OTHER RELIABLE ELECTRONIC MEANS

I, the complainant in this case, state that the following is true to the best of my knowledge and belief.

Beginning in or before 2020, and continuing through July, 2020, in the county of Los Angeles in the Central

District of California, the defendant(s) violated the following statutes as described in the attachment:

Code Sections
Offense Description

18 U.S.C. §§ 1344, 1028A
Bank Fraud, Aggravated Identity
Theft

This criminal complaint is based on these facts:

Please see attached affidavit.

_ Continued on the attached sheet.

/s Alfredo Rossi
Complainant’s signature

Alfredo Rossi, Special Agent
Printed name and title
Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone.

Date:
Judge’s signature

City and state: Los Angeles, California
Hon. Karen L. Stevenson, U.S. Magistrate Judge
Printed name and title

2:20-mj-03710

08/10/2020

August 10, 2020

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CLERK, U.S. DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

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Case 2:20-mj-03710-DUTY Document 1 Filed 08/10/20 Page 1 of 21 Page ID #:1
Complaint Attachment

Count One (18 U.S.C. § 1349)

Beginning before 2020, and continuing through July, 2020, in Los Angeles County,
within the Central District of California, and elsewhere, defendant ARMAN MANUKYAN,
acting with the intent to defraud, knowingly executed and attempted to execute a scheme to
defraud Bank of America, a federally-insured financial institution, as to material matters, and to
obtain moneys and funds owned by and in the custody and control of Bank of America by means
of material false and fraudulent pretenses, representations, and promises, and the concealment of
material facts. To execute the fraudulent scheme, defendant applied for and received
government unemployment benefits—as both other individuals and as businesses—using false
information. Defendant used Bank of America-issued debit cards issued in the names of victims
of identity theft to withdraw as cash from ATMs the unemployment benefits issued to those
persons. Defendant also falsely told Bank of America that his shell businesses, Argo Global,
Inc., and Express Wiring, employed scores of workers in order to receive through that financial
institution $1.7 million in Paycheck Protection Programs loans.

Count Two (18 U.S.C. § 1028A)

Beginning before 2020, and continuing through July, 2020, in Los Angeles County,
within the Central District of California, and elsewhere, defendant ARMAN MANUKYAN
knowingly transferred, possessed, and used, without lawful authority, a means of identification
of another person during and in relation to a felony violation of Title 18, United States Code,
Section 1344, Bank Fraud, as charged in Count One, knowing that the means of identification
belonged to another actual person.

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AFFIDAVIT

I, Alfredo Rossi, being duly sworn, declare and state as

follows:

I.
PURPOSE OF AFFIDAVIT

1.
This affidavit is made in support of a criminal complaint

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

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

Fraud and Aggravated Identity Theft).

2.
The facts set forth in this affidavit are based upon my

personal observations, my training and experience, and information

obtained from various law enforcement personnel and witnesses. This

affidavit is intended to show merely that there is sufficient

probable cause for the requested complaint and does not purport to

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

Unless specifically indicated otherwise, all conversations and

statements described in this affidavit are related in substance and

in part only.

II.
BACKGROUND OF SPECIAL AGENT ALFREDO ROSSI

3.
I am a Special Agent with Homeland Security Investigations

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

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

where I investigate matters concerning bank fraud, wire fraud,

identity theft, money laundering, and other illegal financial

transactions.

4.
Prior to becoming a Special Agent with HSI, I was employed

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

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

investigation of various types of theft and fraud, including the

Case 2:20-mj-03710-DUTY Document 1 Filed 08/10/20 Page 3 of 21 Page ID #:3
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manufacturing of counterfeit and fraudulent identification documents,

and the investigation of financial crimes (such as access device

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

launder the proceeds of such crimes).

5.
To become an HSI Special Agent, I completed 9 months of

training at the Federal Law Enforcement Training Center in Brunswick,

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

have participated in several investigations related to alien

smuggling, narcotics smuggling, weapons trafficking, organized

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

participated in various aspects of criminal investigations, including

bank records analysis, telephone records analysis, electronic

surveillance, physical surveillance, search warrants, arrests, and

reviewing evidence from digital devices. I have also spoken to many

law enforcement agents regarding their experience in criminal

investigations, interviewed defendants, confidential informants, and

witnesses who had personal knowledge regarding the methods used to

commit various types of criminal offenses.

6.
Any facts or circumstances that are cited in this affidavit

are familiar to me through my direct participation in this

investigation, discussions with other law enforcement personnel

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

reports generated by other law enforcement personnel. This affidavit

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

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

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

Unless specifically indicated otherwise, all conversations and

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statements described in this affidavit are related in substance and

in part only.

III. SUMMARY OF PROBABLE CAUSE

7.
In or about June 2020, MANUKYAN submitted two applications

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

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

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

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

for a total loanable amount of $1.7 million. BofA approved the Argo

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

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

process, MANUKYAN attached fabricated tax documentation and made

false representations about the operational status of the companies,

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

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

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

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

which MANUKYAN is also the sole signator.

IV.
PREVIOUS GPS AND BANK ACCOUNT SEIZURE WARRANTS

8.
Based on an earlier affidavit, on July 7, 2020, the

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

GPS tracking affidavit for a cellular telephone number used by ARMAN

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

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

ARMAN MANUKYAN’s bank accounts. Through the GPS warrant, I was able

to locate MANUKYAN’s residence, and subsequently obtained and

executed federal search warrants there, as described in more detail

below.

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V.
STATEMENT OF PROBABLE CAUSE

9.
Based on my review of investigative reports and notes, bank

statements, witness statements, my discussions with other law

enforcement officers working on this investigation, and other

evidence, I learned the following information:

A.
The Paycheck Protection Program

10.
The Coronavirus Aid, Relief, and Economic Security

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

designed to provide emergency financial assistance to the millions of

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

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

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

businesses for job retention and certain other expenses, through a

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

Around April 2020, Congress authorized over $300 billion in

additional PPP funding.

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

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

representative of the business. The PPP loan application requires the

business (through its authorized representative) to acknowledge the

program rules and make certain affirmative certifications in order to

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

the applicant (through its authorized representative) to affirm that

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

payroll or make mortgage payments, lease payments, and utility

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

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

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

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

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

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

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

applying for a PPP loan must provide documentation showing their

payroll expenses.

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

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

transmitted, for further review, to the Small Business Administration

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

application is approved, the participating financial institution

funds the PPP loan using its own monies.

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

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

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

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

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

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

PPP loan proceeds on payroll expenses.

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

14.
From reviewing loan documents provided by BofA and the SBA,

I learned that in or around June 2020, MANUKYAN submitted two

applications for PPP loans to BofA which were consequently received

by the SBA, as follows:

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

Global, claiming that Argo Global was a sewing business which

reported an average monthly payroll expenses of $346,875 and a total

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of 73 employees. The application listed MANUKYAN as the principal

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

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

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

rather his ex-wife and son did.) The loan application listed the

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

California. As described later, this address actually corresponds to

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

proof of Argo Global payroll expenses, MANUKYAN provided an Internal

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

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

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

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

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

to BofA unsigned. Additionally, the underwriting packet did not

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

b.
Second, MANUKYAN applied for a loan in the name of

Express Wiring, listing MANUKYAN as the principal and listing

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

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

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

rejected this application indicating that this loan had been

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

government allocated funds for the PPP had run out.

15.
I have reviewed additional representations MANUKYAN made

and submitted with the Argo Global loan application package (and

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

certified the following:

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a.
MANUKYAN certified that Argo Global was last

incorporated with the California Secretary of State on December 10,

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

payroll taxes or paid independent contractors.”

b.
MANUKYAN certified that “All SBA loan proceeds will

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

application and consistent with the Paycheck Protection Program

Rule.”

c.
MANUKYAN again certified that “the funds will be used

to retain workers and maintain payroll or make mortgage interest

payments, lease payments, and utility payments.”

Argo Global Inc. Appears to Be a Shell Business

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

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

business networking apps such as Yelp and did not observe any

information related to any sewing business matching the identifiers

provided by MANUKYAN.

There Is No Record of the Tax Payments Argo Global Claims

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

Rob Bravo with the Treasury Inspector General for Tax Administration

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

submitted by MANUKYAN as part of the loan application process to

represent the authenticity of the business Argo Global. SA Bravo

stated that no documentation regarding Argo Global could be found

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

the aforementioned Form 940 and Form 941 were ever actually filed

with the IRS in particular. On July 7, 2020, he told me that no tax

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

other purported business, Express Wiring.

Express Wiring Also Appears to Be a Shell Business

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

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

business networking apps such as Yelp and did not observe any

information related to any business matching the identifiers provided

by MANUKYAN.

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

19.
According to bank records, on or about June 3, 2020, BofA

funded the Argo Global PPP loan, wiring the approved funds to BofA

business checking account 325117015294 held in the name of Argo

Global Inc., with MANUKYAN as the sole person with signature

authority over the account (“MANUKYAN’s Argo Account”), for a total

of approximately $867,187. On or about July 1, 2020, I reviewed the

account statements and signature card for Bank of America account

5294 (MANUKYAN’s Argo Account) and learned the following:

a.
MANUKYAN’s Argo Account was opened in the name of

Argo Global by MANUKYAN on or about January 28, 2020 at a BofA branch

located at 7255 Woodman Ave, Van Nuys, California.

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

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

were biweekly large cash deposits ranging from $1,500 to $21,977,

typically followed by similar-sized checks being written against the

account to MANUKYAN. As a consequence, the balance remained low. In

my training and experience, this pattern is indicative of money

laundering; criminals who are trying to make an account for a shell

Case 2:20-mj-03710-DUTY Document 1 Filed 08/10/20 Page 10 of 21 Page ID #:10
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business appear active will often make offsetting transactions to it

using funds and other accounts they control. My review of the bank

records did not show activity consistent with a sewing business. I

did not see any purchases at fabric or craft stores. I saw payments

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

manufacturer, and to other financial institutions that referenced

MANUKYAN’s name. Based on my training and experience it is uncommon

for a legitimate business operating in sewing and craft to be

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

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

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

also applying for government relief to pay for employee wages and

unemployment.

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

20.
On or about June 4, 2020, one day after the $867,187 PPP

funds were disbursed into MANUKYAN’s Argo Account, MANUKYAN

transferred $48,000 into BofA account 325090924800 (“MANUKYAN’S BOA

ACCOUNT”), followed by a second transfer of $62,000 on or about June

5, 2020, also from MANUKYAN’s Argo Account into a personal checking

accounts, MANUKYAN’S BOA ACCOUNT.

21.
On or about July 6, 2020, I reviewed the account statements

and signature card for Bank of America account 4800 and learned that

MANUKYAN’S BOA ACCOUNT was opened in the name of MANUKYAN on or about

August 28, 2017 at a BofA branch located at 203 N Glendale Ave,

Glendale, California.

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

22.
On or about June 17, 2020, MANUKYAN wired $475,000 of the

PPP loan proceeds out of MANUKYAN’s Argo Account to Bank of the West

account 053651949 (“MANUKYAN’S BOTW ACCOUNT”), followed by a second

wire for $212,000 on June 18, 2020, to the same account.

23.
On or about July 1, 2020, I reviewed the account statements

and signature card for MANUKYAN’S BOTW ACCOUNT and learned the

following:

a.
MANUKYAN’S BOTW ACCOUNT was opened in the name of

MA&CO by MANUKYAN on or about May 22, 2018 at a Bank of the West

branch in Glendale, CA.

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

TELEPHONE) as his personal cellphone number.

c.
From the day the account was opened on or about May

22, 2018 with an initial starting deposit of $100, through April

2020, MANUKYAN’S BOTW ACCOUNT was only used four times for one ATM

cash withdrawal of $50, one ATM cash withdrawal of $20, one debit

card purchase in the amount of $9.84 at a Rite Aid store in Van Nuys,

California, and one debit card purchase in the amount of $9.91 at a

Rite Aid store in Glendale, California. MANUKYAN’S BOTW ACCOUNT was

then used again in June 2020 for the two wires of SBA PPP funds for a

total of $687,000 from ARGO’s BOA ACCOUNT into MANUKYAN’S BOTW

ACCOUNT. MANUKYAN’S BOTW ACCOUNT also received two checks from

MANUKYAN’s Argo Account in June 2020 for a total of $44,900.

MANUKYAN Cannot Explain the Purpose of a $200,000 Wire to APMEX

24.
According to bank records, on June 24, 2020, MANUKYAN went

to a BOTW branch in Glendale, CA to wire $200,000 from MANUKYAN’S

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

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

In my training and experience, those trying to launder substantial

sums often purchase precious metals because they are untraceable.)

The teller handling the transaction asked MANUKYAN the reason for the

large wire, and MANUKYAN replied that his accountant instructed him

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

of the wire documentation for APMEX, MANUKYAN returned to the

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

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

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

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

completed.

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

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

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

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

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

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

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

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

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

limousine business and needed to place vehicle orders on Amazon.

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

the freeze would force him to terminate business with BOTW.

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

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

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

reviews. Also based on my training and experience investigating

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

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

threats to terminate a business relationship, like MANUKYAN did on

the call with the BOTW bank investigator.

MANUKYAN Transferred Fraud Proceeds from MANUKYAN’s Argo Account to

MANUKYAN’S BOTW ACCOUNT and MANUKYAN’S LAFCU ACCOUNT

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

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

were deposited into that account, MANUKYAN rapidly withdrew the funds

in various ways. Starting on June 5, 2020, multiple checks were

drawn against MANUKYAN’s Argo Account. The checks were made payable

to MANUKYAN, and negotiated at other financial institutions MANUKYAN

had accounts opened with. MANUKYAN negotiated the following checks

through the following SEIZABLE ACCOUNTS:

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

BOTW ACCOUNT;

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

LAFCU ACCOUNT;

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

LAFCU ACCOUNT; and

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

BOTW ACCOUNT.

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

financial institutions mentioned in this affidavit are federally

insured.

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

30.
On or about June 30, 2020 I conducted surveillance at 433 N

Camden Drive, Beverly Hills, California – an address that according

to the California Articles of Incorporation is associated with Argo

Global - and learned the following:

a.
The building is managed by a company called ESDI which

leases virtual offices to several tenants. On or about July 1, 2020,

ESDI took over the management of the building from the previous

landlord, Barrister Executive Suites, Inc.

b.
ESDI President Massy Fanzine explained to me that

after the recent change of management, some of the older tenants did

not renew their leases and elected to stay with Barrister Executive

Suites, relocating at their new address located at 9440 S Santa

Monica Blvd Suite 301, Beverly Hills, California. President Fanzine

stated that Argo Global was not one of their tenants and that it

likely moved over with Barrister Executive Suites.

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

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

a.
Barrister Executive Suites recently moved to this

address and appeared to be still undergoing the transition from the

older location. An administrator with Barrister Executive Suites

stated that Argo Global had been a tenant with Barrister Executive

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

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

Executive Suites administrator stated that Argo Global never had an

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

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

Blvd address.

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

32.
On or about June 26, 2020, I reviewed the articles of

incorporation for Argo Global Inc. filed on or about January 30, 2018

with the California Secretary of State. This document lists MANUKYAN

as the initial agent for service of process of this business located

at 7855 HAZELTINE AVENUE (the official address of MANUKYAN’S

RESIDENCE).

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

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

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

showed that the address of record associated with the Employer

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

AVENUE.

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15

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

34.
On July 15, 2020, I reviewed the GPS pings for MANUKYAN’S

TELEPHONE which have been provided by T-Mobile at intervals of

fifteen minutes since on or about July 13, 2020 and learned the

following:

a.
the GPS pings for MANUKYAN’S TELEPHONE often

correspond to geographical coordinates located within a few miles of

the 7855/7857 HAZELTINE, PANORAMA CITY, which is within the radius of

uncertainty for the pings. That is, while the pings are not located

at MANUKYAN’S RESIDENCE, they are consistent with the expected

coordinates if MANUKYAN’S TELEPHONE were located at MANUKYAN’S

RESIDENCE.

35.
On July 15, 2020, I conducted surveillance in the vicinity of

the GPS pings and observed the following:

a.
I saw MANUKYAN (identified by his driver’s license

photograph and bank surveillance photographs) exiting the lot of

MANUKYAN’S RESIDENCE and entering MANUKYAN’s VEHICLE, which was

parked on HAZELTINE AVENUE across the street from MANUKYAN’S

RESIDENCE. On or about July 15, 2020, I reviewed the California Law

Enforcement Telecommunication System database and found that

MANUKYAN’s VEHICLE, bearing California license plate 8NAW574, was a

Toyota Camry 2018 last registered to MANUKYAN at a previous address.

b.
I saw a white Buick SUV leaving the driveway of

MANUKYAN’S RESIDENCE bearing CA license plate 8JJL281. On or about

July 15, 2020, I reviewed the California Law Enforcement

Telecommunication System database and found that the vehicle bearing

California license plate 8JJL281 was a Buick 2019 registered to

Case 2:20-mj-03710-DUTY Document 1 Filed 08/10/20 Page 17 of 21 Page ID #:17
16

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

California.

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

36.
Continuing on July 15, 2020, HSI Special Agents followed

MANUKYAN, who left MANUKYAN’S RESIDENCE driving MANUKYAN’s VEHICLE,

and observed him stopping at four Bank of America ATMs at about the

following times and at the following locations:

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

Woodman Ava, Yan Nuys, California;

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

Sepulveda Blvd, North Hills, California;

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

Balboa Blvd, Northridge, California

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

Saticoy St, Reseda, California;

37.
On or about July 16, 2020 I spoke to Bank of America

Investigator Christopher Thompson and learned that MANUKYAN conducted

four ATM withdrawals using the following Employment Development

Department (EDD) benefit cards in the name of individuals other than

MANUKYAN to withdraw approximately $1,000 per card at each

aforementioned ATM:

a.
EDD Bank of America Debit Card account 4427 4341 8564

5189 held in the name of ANASTASIA ISAENKO registered at 7855

HAZELTINE;

b.
EDD Bank of America Debit Card account 4427 4341 8627

0243 held in the name of EKATERINA RYABOVA registered at 7855

HAZELTINE;

Case 2:20-mj-03710-DUTY Document 1 Filed 08/10/20 Page 18 of 21 Page ID #:18
17

c.
EDD Bank of America Debit Card account 4427 4341 9406

6997 held in the name of JOVOKHIR TOPILDIEV registered at 7857

HAZELTINE;

d.
EDD Bank of America Debit Card account 4427 4341 9463

1691 held in the name of AXYNYA KURBATOVA registered at 444

Devonshire lane, Glendale, California.

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

38.
On July 17, 2020, the Honorable Steve Kim, United States

Magistrate Judge, issued a search warrant for 7855 AND 7857 HAZELTINE

AVENUE, PANORAMA CITY which was executed by agents on July 22, 2020.

During the search of MANUKYAN’s personal belongings the following

additional EDD benefit cards were seized by HSI:

a.
EDD Bank of America Debit Card account 4427 4341 9398

5437 held in the name of DAVRON MAGAMETOV registered at 7857

HAZELTINE;

b.
EDD Bank of America Debit Card account 4427 4341 9002

7480 held in the name of PINKNEY FORD registered at 6636 Fulton Ave,

Van Nuys, California;

c.
EDD Bank of America Debit Card account 4427 4341 6689

5449 held in the name of ARMAN MANUKYAN;

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

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

unemployment benefits using EDD Bank of America Debit Card account

4427 4341 6689 5449 held in is name. When I asked him about the

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

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

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

Case 2:20-mj-03710-DUTY Document 1 Filed 08/10/20 Page 19 of 21 Page ID #:19
18

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

confronted about the ATM withdrawals of EDD Bank of America Debit

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

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

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

any further questions.

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

40.
Continuing on July 22, 2020, I spoke to the landlord and

owner of the 7855 AND 7857 HAZELTINE AVENUE, PANORAMA CITY, Edgar

Zakoyan, about the high number of unemployment applications filed

with the EDD utilizing 7855 AND 7857 HAZELTINE AVENUE, PANORAMA CITY

as the address of record, and showed him a list of the following

account holders: “Isaenko Anastasia”, “Mocanu Tatiana”, “Ryabova

Ekaterina”, “Topildiev Jovokhir”, “Yakutina Darya”, and “Magametov

Davron”. Zakoyan verified that none of these names identified by EDD

as beneficiary for unemployment benefits had ever lived at that

address.

N.
MANUKYAN is Fleeing to France

41.
On or about August 7, 2020 I spoke to the landlord and

owner of MANUKYAN’S RESIDENCE, Edgar Zakoyan, who told me that he was

worried for MANUKYAN since he had not seen him or heard from him for

a few days. Zakoyan stated that MANUKYAN’s parents had reached out to

him asking about MANUKYAN’s whereabouts as they also were not able to

get a hold of him. Zakoyan also stated that MANUKYAN’s vehicle was

still parked in front of the residence and that the keys to the house

and MANUKYAN’s vehicle were left inside of MANUKYAN’s room unsecured.

Case 2:20-mj-03710-DUTY Document 1 Filed 08/10/20 Page 20 of 21 Page ID #:20
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42.
On August 9, 2020, I received notification from the

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

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

with a final destination of Minsk, Belarus.

VI.
CONCLUSION

43.
Based on the foregoing, there is probable cause to believe

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

1028A (Bank Fraud and Aggravated Identity Theft).

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

UNITED STATES MAGISTRATE JUDGE

10th

ITED STATES MAGISTRATE JUDGE

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

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