United States Of America v. Vahe Margaryan
- Date
- 2020-03-12
Summary
A criminal complaint in United States v. Vahe Margaryan, et al., Case No. 2:25-MJ-03132-DUTY, in the U.S. District Court for the Central District of California, filed May 23, 2025 as Document 1 in Case 2:25-cr-00458-AB. It charges Margaryan and other named defendants with offenses between May 2, 2019 and January 31, 2025 under 18 U.S.C. § 286, 18 U.S.C. § 287, 18 U.S.C. § 1343, 18 U.S.C. § 1344, 18 U.S.C. § 1956(h), 18 U.S.C. § 1956(a)(1) and 18 U.S.C. § 1957. The affidavit of Eric Ley, a Special Agent of the SBA Office of Inspector General, attested by telephone before Magistrate Judge Patricia Donahue, alleges that the defendants used shell companies and bank accounts to obtain PPP, EIDL and SBA Preferred Lender Program loans, for a total loss of more than $20,000,000. It also supports arrest warrants and search warrants. The filing runs 145 pages.
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Case 2:25-cr-00458-AB Document1 Filed 05/23/25 Page1of145 Page ID #:92
AO 91 (Rev. 11/11) Criminal Complaint (Rev. by USAO on 3/12/20) CL) Original O Duplicate Original
cur Coos coer | UNITED STATES DISTRICT COURT cn EO coun
05/23/2025
5/22/2025 for the
CENTRAL DISTRICT OF CALIFORNIA
BY: I Vv DEPUTY
CENTRAL DISTRICT OF CALIFORNIA . . . .
BY: MMC DEPUTY Central District of California
United States of America
V.
VAHE MARGARYAN,
aka “William McGrayan,”
SARKIS SARKISYAN,
aka “Samuel Shaw,”
AKSEL MARKARYAN,
aka “Axel Mark,”
ASHOT BEJANYAN,
aka “Alex Benjamin,”
JACK AYDINIAN,
aka “Jack Aydi,”
TARON MUSAYELYAN,
aka “Teyron Musaleyan,”
HOVANNES HOVANNISYAN,
aka “John Harvard,”
MERY BABAYAN,
aka “Mery Diamondz,”
ANAHIT SAHAKYAN,
FELIX PARKER,
RUDIK YENGIBARYAN,
aka “Samuel Stavros,”
YOHAN VACHYAN,
aka “John Vachyan,”
KHACHATUR NIKOGHOSYAN, and
BORIS SAHAKYAN,
Case No. 2:25-MJ-03132-DUTY
Defendants.
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.
On or about the dates of between May 2, 2019 and January 31, 2025, in the county of Los Angeles in the
Central District of California, and elsewhere, the defendants violated:
AUSAs: Mark Aveis (x4477), Gregg Marmaro (x8500)
Case 2:25-cr-00458-AB Documenti1 Filed 05/23/25 Page2of145 Page ID #:93
Code Section Offense Description
18 U.S.C. § 286 Conspiracy to Defraud Government with Respect
to Claims
18 U.S.C. § 287 False, Fictitious or Fraudulent Claims
18 U.S.C. § 1343 Wire Fraud
18 U.S.C. § 1344 Bank Fraud
18 U.S.C. § 1956(h) Money Laundering Conspiracy
18 U.S.C. § 1956(a)(1) Laundering of Monetary Instruments
18 U.S.C. § 1957 Engaging in Monetary Transactions in Property
Derived from Specified Unlawful Activity
This criminal complaint is based on these facts:
Please see attached affidavit.
Continued on the attached sheet.
/s/ Eric Ley, Special Agent
Complainant’s signature
Eric Ley, Special Agent, Office of Inspector
General, U.S. Small Business Administration
Printed name and title
Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone.
Date: May 23, 2025 Alinta Lanakwe.
Judge’s signature
City and state: Los Angeles, California Hon. Patricia Donahue, U.S. Magistrate Judge
Printed name and title
AUSAs: Mark Aveis (x4477), Gregg Marmaro (x8500)
Case 2:25-cr-00458-AB Document 1 Filed 05/23/25 Page 3 of 145 Page ID #:94
Contents
I. INTRODUCTION..........................................3
II. PURPOSE OF AFFIDAVIT..................................4
III. SUMMARY OF PROBABLE CAUSE.............................8
IV. PROBABLE CAUSE.......................................14
A. The Paycheck Protection Program.................14
B. The Economic Injury Disaster Loan Program.......16
C. PPPL Forgiveness................................18
D. SBA’s Preferred Lender Program..................19
E. Interview of F.N................................20
F. Interview of A.M................................26
G. SUBJECTS MCGRAYAN, SHAW, and MARK: Wire Fraud,
Bank Fraud, and Money Laundering re “Dynamic” PLP
Loan............................................29
H. SUBJECTS MCGRAYAN, MARK, and MUSAYELYAN: Wire
Fraud, Bank Fraud, and Money Laundering RE “GDI”
PLP Loan........................................40
I. SUBJECTS MCGRAYAN, HARVARD, and DIAMONDZ: Wire
Fraud, Bank Fraud, and Money Laundering re “OAS”
PLP Loan........................................45
J. SUBJECTS MCGRAYAN, BENJAMIN, AND AYDI: Attempted
Wire Fraud and Bank Fraud re “Alex Titan
Solutions” PLP Loan.............................50
K. SUBJECTS MCGRAYAN, ANAHIT, AND PARKER: Wire
Fraud, Bank Fraud, and Money Laundering re
“Canmar” PLP Loan...............................56
L. SUBJECTS MCGRAYAN and STAVROS: Attempted Wire
Fraud and Bank Fraud re “Stavros Auto Group” PLP
Loan............................................61
M. SUBJECTS MCGRAYAN and MUSAYELYAN: False Claim,
Wire Fraud, and Money Laundering re GUM EIDL....64
N. SUBJECT MUSAYELYAN: False Claim, Wire Fraud, and
Money Laundering re Personal EIDL...............67
O. SUBJECT VACHYAN: False Claim, Wire fraud, Bank
Fraud (PPPL only),and Money Laundering re “Art
Case 2:25-cr-00458-AB Document 1 Filed 05/23/25 Page 4 of 145 Page ID #:95
Mart” PPP and EIDL..............................71
P. SUBJECT NIKOGOSYAN: False Claim, Wire Fraud, and
Money Laundering re “CM” EIDL...................75
Q. SUBJECT BORIS: False Claim, Wire Fraud, Bank
Fraud, and Money Laundering re “CP Mobile
Mechanics” PPPL.................................77
R. SUBJECT DIAMONDZ: False Claim, Wire Fraud, and
Money Laundering re “American Best Filter” EIDL.82
V. ADDITIONAL PROBABLE CAUSE IN SUPPORT OF REQUEST FOR
ISSUANCE OF SEARCH WARRANTS..........................88
A. MCGRAYAN Resides and Does Business at the SUBJECT
PREMISES........................................88
B. Training and Experience Regarding the Offense
Conduct.........................................90
VI. TRAINING AND EXPERIENCE ON DIGITAL DEVICES...........91
VII. CONCLUSION...........................................94
2
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AFFIDAVIT
I, Eric Ley, being duly sworn, declare and state as
follows:
I. INTRODUCTION
1. I have been a federal agent for more than 12 years.
Since May 2021, I have been a Special Agent of the U.S. Small
Business Administration (“SBA”), Office of Inspector General
(“SBA-OIG”). Before that, I was a Special Agent with the United
States Secret Service for eight years.
2. Since graduating from the Criminal Investigator
Training Program conducted at the Federal Law Enforcement
Training Center, I have over ten years of experience
investigating various criminal offenses including bank fraud,
wire fraud, and money laundering. As such, I have interviewed
hundreds of witnesses and targets, participated in the execution
of numerous search and arrest warrants relating to financial
crimes, and worked with federal prosecutors to prepare
investigations for prosecution.
3. For the past four years, I have focused on
investigating crimes associated with pandemic stimulus funding,
sometimes referred to as Covid-19 fraud, and on fraud against
the SBA’s Preferred Lending Program. From reviewing dozens of
pandemic stimulus loan files and documents associated with those
files, such as subpoenaed bank records and public records, I
have become familiar with the processing and vetting of
applications under the Paycheck Protection and Economic Injury
Disaster Loan programs, among other pandemic-related funding
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programs. From reviewing numerous and similar loan files and
documents associated with those files, I have also become
familiar with the processing and vetting of applications under
SBA-guaranteed lending programs.
4. Through my investigations, my training and experience,
and discussions with other law enforcement personnel, I have
become familiar with the tactics and methods employed by those
who conduct wire and bank fraud schemes using fraudulent loan
statements and fabricated documents, money laundering, and
identity theft, among other federal offenses. These methods
include, but are not limited to, the use of wireless
communications technology, such as encrypted messaging platforms
such as “WhatsApp;” the creation or purchase of corporate
“shells,” i.e., corporations that have been formed through the
filing of articles of incorporation but conduct no business and
are used solely to create the appearance of legitimacy;
fabricating bank statements or other business documents to
satisfy lender underwriting requirements to qualify for loans;
and moving funds through multiple accounts to promote and
conceal fraud.
II. PURPOSE OF AFFIDAVIT
5. This affidavit is made in support of a criminal
complaint against, and request for issuance of arrest warrants
for, the following individuals (also referred to individually at
times as “SUBJECT,” or collectively, “SUBJECTS”) for violations
of 18 U.S.C. §§ 286/287 (conspiracy to defraud the government
with respect to claims/make false claims), 1343 (wire fraud),
4
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1344 (bank fraud), 1956(h) (money laundering conspiracy),
1956(a)(1) et seq. (money laundering), 1957 (engaging in
monetary transactions in property derived from specified
unlawful activity), and/or 31 U.S.C. §§ 5313, 5324
(structuring), as more fully described below:
VAHE MARGARYAN, AKA WILLIAM MCGRAYAN (“MCGRAYAN”);
SARKIS SARKISYAN, AKA SAMUEL SHAW (“SHAW”);
AKSEL MARKARYAN, AKA AXEL MARK (“MARK”);
ASHOT BEJANYAN, AKA ALEX BENJAMIN (“BENJAMIN”);
JACK AYDINIAN, AKA JACK AYDI (“AYDI”);
TARON MUSAYELYAN, AKA TEYRON MUSEYELYAN (“MUSAYELYAN”);
HOVANNES HOVANNISYAN, AKA JOHN HARVARD (“HARVARD”);
MERY BABAYAN, AKA MERY DIAMONDZ (“DIAMONDZ”);
ANAHIT SAHAKYAN (“ANAHIT”);
FELIX PARKER (“PARKER”);
RUDIK YENGIBARYAN, AKA SAMUEL STAVROS (“STAVROS”);
YOHAN VACHYAN, AKA JOHAN VACHYAN, AKA JOHN VACHYAN
(“VACHYAN”);
KHACHATUR NIKOGHOSYAN (“NIKOGHOSYAN”); and
BORIS SAHAKYAN (“BORIS”).
6. This affidavit is also made in support of an
application for search warrants for the following:
a. The person of MCGRAYAN, as more fully described
in Attachment A-1 (the “SUBJECT PERSON”); and
b. 6450 Olcott Street, Tujunga, CA 91042-2852
(“SUBJECT PREMISES”), as more fully described in Attachment A-2.
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7. As described more fully below, I respectfully submit
there is probable cause to believe the requested search warrants
will yield evidence of violations of 18 U.S.C. §§ 286/287
(conspiracy to commit, and making, false claims to the
government), 1343 (wire fraud), 1344 (bank fraud), 1956(h)
(money laundering conspiracy), 1956(a)(1) et seq. (money
laundering), 1957 (engaging in monetary transactions in property
derived from specified unlawful activity), and/or 31 U.S.C. §§
5313, 5324 (structuring) (collectively, the “SUBJECT OFFENSES”)
that were committed by MCGRAYAN and others, known and unknown.
8. The facts set forth in this affidavit are based on my
personal observations; my training and experience; witness
interviews that I have conducted; reports that I have read of
interviews conducted by other law enforcement agents; my review
of documents obtained from third parties, either by way of
subpoena or voluntary submission, such as bank or business
records; my review of publicly-filed documents such as corporate
filings; Internet searches for open source information;
financial analyses or financial records summaries prepared by a
SBA analyst who told me that she reviewed and prepared such
analyses and summaries from bank and other financial records
obtained in this investigation, and whom I believe to be
qualified to make such analyses and summaries from having worked
with her for several years and having reviewed her work product
in other matters; and my review of documents created or amassed
by the SBA in connection with providing funding for the various
loans and grants more fully described below. Accordingly,
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absent mention below of specific attribution from any of the
above-summarized evidence, I have, solely for clarity, generally
omitted attribution for a specific fact or statement.
9. Whenever I refer herein to a bank, I mean a financial
institution whose deposits were insured by the Federal Deposit
Insurance Corporation. Whenever I refer herein to bank records,
I have done so by identifying each account by an abbreviation
for the bank followed by the account’s last four digits, e.g.,
“JPMC 1234.” Whenever I refer to the substance or content of
such accounts, such reference is based on my review of the
records of the account(s), including bank statements, signature
card/account application documents, canceled checks, offset and
credits, and other records provided by each bank pursuant to a
grand jury subpoena. Similarly, unless stated otherwise,
whenever I refer to records of or relating to the SBA, I am
referring to SBA records that I have reviewed as accessible to
me in my capacity as a Special Agent of the SBA-OIG.
10. My description of the offense conduct below is based
on my review of the above-summarized evidence and is provided
solely for the purpose of establishing probable cause to believe
that one or more of the above-stated offenses were committed by
the SUBJECTS. Accordingly, I have not described all of the
evidence that I have reviewed during the course of this
investigation and my omission of evidence or mention of other
subjects or targets of this investigation should be considered
with that limitation.
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11. Unless stated otherwise, all conversations and
statements described in this affidavit are related in substance
and/or in part only; all dates are “on or about” or
approximations; all amounts are rounded or close approximations;
and the words “on or about” and “approximately” are omitted for
clarity.
12. Unless otherwise stated, based on my review of the
evidence gathered in this case, I believe that all electronic
communications, e.g., email or online transmission of
information (e.g., a loan application) and transfers of funds
between SUBJECTS’ accounts as well as the transmission of
proceeds of loans or grants were by means of interstate wire
transmission in furtherance of wire fraud. 1
III. SUMMARY OF PROBABLE CAUSE
13. I have probable cause to believe that the SUBJECTS
committed the SUBJECT OFFENSES by creating, purchasing, or using
corporations for use in name only, i.e., as “shells;” opening or
directing others to open multiple bank accounts in the names of
those shells; submitting and directing others to submit
fraudulent applications, related documents, and fake documents
to obtain loans; and then laundering and directing others to
launder the proceeds of those loans through various bank
1 The following information is provided by the AUSA:
In August 2022, the statute of limitations for any criminal
charge alleging that a borrower engaged in fraud with respect to
PPPs or EIDLs was extended from five to ten years. 15 U.S.C.
§ 636(b)(16).
8
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accounts for personal use, for a total loss of more than
$20,000,000.
14. Evidence obtained in this case shows, as more fully
described below, that SUBJECTS, acting at MCGRAYAN’s direction,
posed as “owners” of shells; opened shell accounts by providing
their genuine identification and signing account-opening
documents; signed documents associated with obtaining bank and
pandemic stimulus loans; participated in filing tax returns that
were plainly fraudulent; and received, as fees for
participating, cash or transfers from shell accounts or other
sources, and that they did so knowingly and with the intent to
defraud and launder money. I therefore have probable cause to
believe, as more fully described below, that such SUBJECTS
knowingly participated in the below-described fraudulent scheme
and laundered money to further it. Accordingly, arrest warrants
are sought against such SUBJECTS as MCGRAYAN’s co-schemers
and/or co-conspirators.
15. Some of the fraudulently obtained loans were funded
by more than $1 trillion in taxpayer-based, Congressional
appropriations to get the country through the Covid-19 pandemic.
Other loans were made by banks under an SBA-guaranteed program
to provide individuals or small businesses the opportunity to
borrow money to buy or obtain working capital for small
businesses where such individuals or small businesses might not
otherwise have access to capital.
16. More specifically, the offense conduct involved the
following:
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a. MCGRAYAN and others, known and unknown, met
individuals who, with few exceptions, were older and of Armenian
or South Caucasus regional descent, at social or spiritual
events. MCGRAYAN and others, known and unknown, convinced such
SUBJECTS to become titular owners of newly formed or dormant
corporations that were, at most, a “shell” or placeholder for
future use. MCGRAYAN advised such SUBJECTS that owning a shell
was legitimate and done to legitimately obtain loans.
b. The names of the shells were consistent in their
vagueness, which lent them some apparent legitimacy, such as
“Global 6 Solutions,” “Global Ultimate Management,” “Mass
Exclusive LLC,” or “Optimal Business Solutions.” Several such
entities purported to conduct information technology services,
such as “Dynamic Delivery Install” or “Dynamic IT.” Others
appeared to be engaged in some sort of automotive business, such
as “CP Mobile Mechanic,” “Mobile Auto Repair,” or “CM General
Auto Electric Supply.” Still others appeared to be in the art
or printing field, such as “Art Mart” or “Zart Art Printing.”
No matter the shell’s name, the SUBJECTS whose names were
associated with shell ownership had no intent to conduct
business and had no significant, if any, history of similar
business ownership or experience.
c. At MCGRAYAN’S direction, such SUBJECTS opened
bank accounts in the names of the shells (“shell accounts”);
granted MCGRAYAN and other co-schemers permission to access and
to transact business on the shell accounts by providing their
personal identifying information and passcodes and facilitating
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remote access to computers (including computers provided by
MCGRAYAN) via software programs such as “Any Desk;” and provided
blank checks to MCGRAYAN and wrote checks on the shell accounts
to other accounts or payees. MCGRAYAN advised such SUBJECTS –
as the titular “owners” of shell corporations and the
signatories of shell accounts – that the sole purpose of their
corporate ownership and the shell accounts was to assist
MCGRAYAN in legitimately obtaining loans but the evidence shows
that the sole purpose was, instead, to fraudulently obtain and
launder proceeds of fraudulently obtained loans.
d. Another common feature of the offense conduct was
that MCGRAYAN directed such SUBJECTS to sign federal income tax
returns for their respective shells, not to report legitimate
income, but to fraudulently support loan applications on behalf
of their shells because the lenders relied on tax returns as
part of the underwriting decision. I know from my training and
experience that individuals commonly submit fake tax returns to
lenders to fraudulently obtain loans. Here, however, MCGRAYAN
and such SUBJECTS went a step further. The evidence shows that
the prospective lenders would investigate whether the shells had
actually filed tax returns with the IRS as opposed to simply
providing lenders with copies of what the SUBJECTS represented
were the shells’ genuine tax returns. Based on my training and
experience, I have observed that many lenders have evolved from
earlier underwriting practices to where they actually obtain an
applicant’s (e.g., a shell’s) tax returns directly from the IRS.
Thus, to lend further legitimacy to what I believe were fake
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returns, MCGRAYAN paid a tax preparer, in cash, to prepare
returns for such SUBJECTS’ shells that falsely reported not only
substantial income but substantial income tax due. The evidence
further shows that MCGRAYAN assuaged any concern on the part of
a SUBJECT in whose shell’s name a loan was sought by stating
that the financial information on the return was accurate and
that he (MCGRAYAN) would ensure that any taxes would be paid.
e. MCGRAYAN and such SUBJECTS further, and commonly,
attempted to create the appearance of the shells’ legitimacy
with other fraudulent documents that were provided to lenders in
connection with loan underwriting. For example, I have probable
cause to believe that MCGRAYAN and SUBJECTS signed standard form
“purchase agreements” that purported to memorialize the purchase
of businesses that were, in fact, simply shells with no value;
created fake websites and resumes; fraudulently claimed prior
employment; doctored bank statements; and concocted office
leases or obtained cheap office space leases, again solely to
fraudulently create the appearance that the shells were going
concerns.
f. Finally, ill-gotten loan proceeds were routinely
laundered back and forth through shell accounts in a process
called “layering.” For example, loan proceeds were initially
deposited into an account for the applicant/shell. MCGRAYAN
then directed the SUBJECT who was the signatory on the account
to deposit checks from other shells into that shell account.
MCGRAYAN then remotely accessed that shell’s bank account and
transferred funds to other shell accounts; directed the account
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holder to give him the checkbook for that shell’s account; or
directed the account holder to purchase cashier’s checks for
deposit into another shell account. This was done for multiple
reasons. First, transfers into and out of shell accounts were
conducted to make it appear that the shell account had genuine
business activity. Transfers to individuals were kept at a
minimum; most transfers were in the name of, again, shell
entities whose names, again, seemed legitimate. Next, transfers
from other shell entities to a shell/applicant’s account that
appeared to show legitimate business activity were done to
satisfy a loan condition that a SUBJECT had sufficient
downpayment or equivalent funds to buy another (fake) business.
Next, SUBJECTS used those same accounts to conceal the ill-
gotten loan proceeds. And there were literally thousands of
laundered transactions, including many in amounts of just under
$10,000, evidencing structuring to avoid Bank Secrecy Act
reporting requirements. 2 The SUBJECTS ultimately used the
2 The following legal authority was provided by the AUSA:
Federal law requires banks and other financial institutions
to file reports with the Secretary of the Treasury whenever they
are involved in a cash transaction or exchange of currency that
exceeds $10,000. “A person who willfully violates this law is
subject to criminal penalties.” 31 U.S.C. §§ 5313, 5324; 31 CFR
§ 103.22(a),(b)(2006 Ed.); Ratzlaf v. United States, 510 U.S.
135, 136 (1994); see also, United States v. Turner, 400 F.3d
491, 497 (7th Cir. 2005)(in case charging conspiracy to launder
money, “we know that certain types of transactions may be
indicative of a design to conceal. These include transactions
surrounded in unusual secrecy, structured transactions,
depositing ill-gotten funds into another’s bank accounts, using
third parties to conceal the real owner, or engaging in unusual
financial moves which culminate in a transaction.”).
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proceeds for personal uses or for purposes plainly not
authorized by the terms of the loans. 3
IV. PROBABLE CAUSE
A. The Paycheck Protection Program
17. The Coronavirus Aid, Relief, and Economic Security
(“CARES”) Act was a federal law enacted in or about March 2020
that was designed to provide emergency financial assistance to
Americans suffering economic harm as a result of the COVID-19
pandemic. One form of assistance provided by the CARES Act was
the authorization of United States taxpayer funds in the form of
loans to small businesses for job retention and certain other
expenses, through a program referred to as the Paycheck
Protection Program (“PPP; loans under that program are sometimes
referred to herein as a “PPPL” or “PPPLs”). PPPL proceeds were
required to be used by the applicant business to pay certain
expenses such as payroll costs, interest on mortgages, rent, and
utilities.
3 The following legal authority was provided by the AUSA:
Joinder of criminal defendants is appropriate if they “are
alleged to have participated in the same act or transaction, or
in the same series of acts or transactions, constituting an
offense or offenses.” Fed. R. Crim. P. 8(b); see also Zafiro v.
United States, 506 U.S. 534, 537 (1993) (“There is a preference
in the federal system for joint trials of defendants who are
indicted together.”). Trying codefendants together is “the
rule, rather than the exception ... especially in conspiracy
cases.” See, e.g., United States v. Barnes, 979 F.3d 283, 316
(5th Cir. 2020). If defendants are tried together, the court
can give the jury instructions to consider each count, and the
evidence pertaining to it, as to each defendant. “A jury is
presumed to follow [the court's] instructions.” Weeks v.
Angelone, 528 U.S. 225, 234 (2000).
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18. In order to obtain a PPPL, a qualifying business was
required, among other things, to submit a PPPL application that
required the applicant business (through its authorized
representative) to acknowledge PPP program rules and make
certain affirmative certifications that the applicant business
would comply with all such rules to be eligible to obtain a
PPPL. Such certifications required, among other things, that
the applicant affirm that “[PPP] funds will be used to retain
workers and maintain payroll or make mortgage interest payments,
lease payments, and utility payments,” and that the “loan
proceeds will be used only for business-related purposes as
specified in the [PPPL application]” and consistent with PPP
rules. The authorized representative of the applicant was also
required to certify that “the information provided in th[e] PPP
application and the information provided in all supporting
documents and forms is true and accurate in material respects,”
and that “I understand that if the funds are knowingly used for
unauthorized purposes, the federal government may hold me
legally liable, such as for charges of fraud.”
19. A PPPL applicant’s representative was also required
to state, among other things, the applicant’s average monthly
payroll expenses and number of its employees. These figures
were used to calculate the amount of money that the business was
eligible to receive under the PPP. In addition, the applicant’s
representative was required to provide documentation showing its
payroll expenses and such other documentation as the SBA or the
lender requested.
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20. A PPPL application and supporting documents were
submitted online through a portal and processed by a
participating lender. The applicant’s representative confirmed
his/her true identity through a variety of means including
providing personal identifying information, uploading a copy of
that person’s driver’s license and/or Social Security card,
and/or executing loan documents via a document authentication
platform such as DocuSign. If a PPPL application was approved,
the participating lender would fund the PPPL using its own funds
and would wire-transfer those funds to a bank account designated
by the applicant. By wire-transferring the loan proceeds to
that designated account, the lender, the SBA and, ultimately,
law enforcement would have yet another way to ensure that the
application was sought by the stated applicant through his/her
duly acting representative and that the applicant received and
used those funds in accordance with PPP rules.
21. If PPP lending criteria were followed by the lender,
the SBA, in turn, guaranteed the borrower’s repayment in the
event of that borrower’s default.
B. The Economic Injury Disaster Loan Program
22. In addition to the PPP, the CARES Act authorized
taxpayer funds under the Economic Injury Disaster Loan program
(individually, an “EIDL,” or, collectively, “EIDLs”). The EIDL
program provided low-interest funding to small businesses,
renters, and homeowners affected by the COVID-19 pandemic.
23. In order to obtain an EIDL, a qualifying business was
required to submit an application to the SBA, typically through
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an online portal, and provide information about its operations,
such as the nature of the applicant’s business (e.g.,
“agriculture”), the number of employees, and gross revenues for
the 12-month period preceding the Covid-19 pandemic. Like
PPPLs, EIDL applicants were required to certify that all
information in the application as provided by the applicant or
on behalf of the applicant by their authorized representative
was true and correct.
24. An EIDL “Loan Authorization and Agreement” (“LA&A”)
was executed by the applicant’s authorized representative as a
condition of receipt of EIDL proceeds. The LA&A required that
the applicant would use the EIDL proceeds only for purposes
stated in EIDL rules, such as for employee payroll expenses,
employee sick leave, and business obligations and expenses such
as business debts, rent, and mortgage payments. EIDL funds
could not be used other than for those purposes, including that
such funds could not be deposited or held for future business
operations, used to capitalize a new business or for business
start-up expenses, or used for purposes not associated with the
operation of a going concern.
25. The amount of an EIDL was determined, in part, by the
applicant’s representations in the EIDL application about the
nature of the applicant’s business and the applicant’s
statements about employees and revenue. Any funds paid under an
EIDL were issued directly by the SBA from CARES Act
appropriations by Congress.
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26. If the EIDL applicant also obtained a PPPL, EIDL
proceeds could not be used for the same purpose as the PPP loan
proceeds.
27. PPP and EIDL applicants were also obligated to
provide true and correct information in response to requests by
PPP lenders or the SBA as part of the PPPL and EIDL vetting
process, such as requests to clarify business ownership and
requests to provide genuine payroll tax documents such as IRS
Forms 940, 941, or W3 “Transmittal of Wage and Tax Statements.”
C. PPPL Forgiveness
28. Under certain circumstances, PPP borrowers were
entitled to forgiveness of their PPP obligations. As a
condition of forgiveness, borrowers were required to complete a
“PPP Loan Forgiveness Application” on which their authorized
representative represented and certified that the borrower had
complied with all PPP rules “including the rules related to . .
. eligible uses of PPP loan proceeds[]” and that “[t]he
information provided in th[e forgiveness application was] true
and correct in all material respects.” The forgiveness
application warned that ”knowingly making a false statement to
obtain forgiveness was a federal crime, punishable by
imprisonment and/or a fine.”
29. I know from my training and experience, and from
evidence gathered in this case, that PPP lenders and the SBA
relied on an applicant’s truthfulness in statements made on
applications and related documents, and on the genuineness of
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documents submitted by applicants in support of applications, to
determine whether to approve PPPLs or EIDLs.
D. SBA’s Preferred Lender Program
30. Both before, throughout, and after the Covid-19
pandemic, the SBA offered loans to finance the purchase or
start-up of, or for working capital for, small businesses
through a program known as Preferred Lender Program (“PLP”).
Such loans (herein individually referred to as a “PLP,” or
collectively as “PLPs”) were offered to small businesses or
individuals seeking to buy or improve small businesses who might
not be eligible for business loans through normal lending
channels.
31. PLPs were administered by financial institutions or
other lenders that conducted underwriting or due diligence,
including, for example, site visits, requesting an applicant’s
financial statements, obtaining federal income tax returns from
the IRS, verifying proof of good faith downpayments or deposits,
independently evaluating businesses to be acquired, evaluating
the seller’s accounts receivable, and reviewing leases for
business space. A PLP lender that complied with SBA
underwriting guidelines was eligible for an SBA guarantee of a
substantial part of the loan in the event of a borrower’s
default.
32. I know from my training and experience that PLP
lenders and the SBA relied on the parties’ truthfulness in
statements made on PLP applications and in related documents, or
provided through escrow holders or business brokers, and on the
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genuineness of documents submitted in support of applications,
to determine whether to approve PLPs.
E. Interview of F.N.
33. On May 2, 2025, I interviewed F.N. F.N. told me the
following, among other things:
a. He recognized MCGRAYAN from a photograph that I
showed him. (The photograph came from a genuine copy of
MCGRAYAN’s driver’s license.)
b. F.N. is a musician. He met MCGRAYAN in 2016 at
social events where F.N. performed. F.N. befriended MCGRAYAN
and was ultimately hired by MCGRAYAN to perform music at
MCGRAYAN’s house. F.N. was impressed by MCGRAYAN because
MCGRAYAN seemed reliable and resourceful. MCGRAYAN called F.N.,
“brother” and said that he (MCGRAYAN) was an attorney. 4
c. Near the end of 2018 or in early 2019, F.N. was
blinded by a reaction to medication. MCGRAYAN visited him and
appeared empathetic. MCGRAYAN told F.N. that he (MCGRAYAN)
would help F.N. recover by starting a business to sell guitar
lessons online, something that F.N. had wanted to do.
4 I searched the California State Bar’s license lookup
site and found no record that MCGRAYAN was a member of the
California Bar. I did query law enforcement databases for
records of individuals who sought fingerprinting and found an
entry that MCGRAYAN was fingerprinted on May 29, 2019, as part
of his application for a State Bar license but that as of July
21, 2022, he was “no longer interested.” I also conducted an
open source/Internet search and found no result that MCGRAYAN is
or was a member of the bar of any other state. I did see online
a “LinkedIn” page for MCGRAYAN that stated that MCGRAYAN
graduated from Southwestern Law School in 2015 and then was
enrolled in an L.L.M. program in banking and securities law
offered by the University of Southern California.
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d. MCGRAYAN then told F.N. that he started a
business for F.N. called “Music E Solutions” but did so without
F.N.’s knowledge or permission. F.N. did not conduct any
business activity with Music E Solutions and, around May 2019,
F.N. spoke to MCGRAYAN who suggested that the company named be
changed to “Mobile Auto Repair, Inc.” (“MARI”). F.N. asked
MCGRAYAN if that was legal and MCGRAYAN said that it was.
MCGRAYAN then directed F.N. to go to a location in downtown Los
Angeles to register MARI in F.N.’s name. F.N. did so. (I know
from reviewing California Secretary of State records that on May
2, 2019, a Statement of Information (“SOI”) was filed that
reflected that F.N. became MARI’s sole officer and director. I
also know from reviewing California Secretary of State records
that MARI was incorporated in June 2017 and that it was
suspended due to the failure to file a SOI until F.N. filed an
SOI in May 2019. I believe, based on my training and experience
that the history of MARI’s incorporation is consistent with that
of forming a “shell” corporation for later sale or use.)
e. F.N. knew nothing about being a mechanic and did
not intend to operate MARI as a mechanic or any other business.
f. Around the same time (May 2019), MCGRAYAN
directed F.N. to open multiple bank accounts in the name of MARI
with F.N. as the sole signatory. F.N. thought doing so was
suspicious and questioned MCGRAYAN why he should do so and
whether it was legal. MCGRAYAN said that it was necessary to
help qualify for loans and that it was legal. MCGRAYAN rebuffed
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F.N.’s inquiry by questioning F.N.’s loyalty to MCGRAYAN, saying
things like “brother, it’s ok” or words to that effect.
g. MCGRAYAN also told F.N. that money from some
unnamed “business in New York” would be deposited into the MARI
accounts. MCGRAYAN told F.N. to give MCGRAYAN access to the
accounts by providing MCGRAYAN with F.N.’s driver’s license and
Social Security numbers, date of birth, and accounts passcodes.
MCGRAYAN also told F.N. to give MCGRAYAN and “the New York guys”
remote access to F.N.’s computer. F.N. provided the government
an excerpt of a WhatsApp chat, more fully discussed below, in
which MCGRAYAN told F.N. to use “Any Desk” for remote access.
(I learned from an open source/Internet search that “Any Desk”
is a software application that allows remote access of a
computer.)
h. MCGRAYAN directed F.N. to deposit checks into the
MARI accounts. F.N. received checks by mail and, as MCGRAYAN
had directed him, F.N. took pictures of those checks, sent those
images to MCGRAYAN, and deposited the checks into one of the
MARI accounts.
i. At MCGRAYAN’s direction, F.N. brought blank
checks for one or more of the MARI accounts to MCGRAYAN at
MCGRAYAN’s house.
j. At MCGRAYAN’s direction, F.N. withdrew funds from
one or more of the MARI accounts and used those funds to buy
cashier’s checks in amounts as directed by MCGRAYAN. F.N.
recalled buying cashier’s checks from Bank of the West. (I know
from reviewing records from Bank of the West that F.N. bought
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cashier’s checks of $175,000 (11/24/2021), $141,910
(12/16/2021), $308,000 (12/17/2021), $485,010 (1/20/2022), and
$518,151 (5/12/2022).) MCGRAYAN directed F.N. to deposit the
cashier’s checks into a MARI account and then divide those
amounts into smaller checks and move them to other accounts.
k. F.N. personally appeared at branches of the banks
to open the MARI accounts at MCGRAYAN’s direction. In each
case, F.N. presented bank employees with F.N.’s genuine
identification documents and signed signature cards and account
opening documents. (I know from reviewing the signature cards
and bank records that there were five MARI accounts and that
each was opened and maintained at a bank branch located in Los
Angeles County.)
l. F.N. estimated that, at MCGRAYAN’s direction,
F.N. signed dozens, if not hundreds, of checks to move money
between not only the MARI accounts but accounts in the names of
what he believed were fake corporations like MARI. F.N.
estimated that he signed numerous other documents at MCGRAYAN’s
direction and saw other documents that he did not sign but that
had his signature that had been “cut and pasted.”
m. MCGRAYAN largely communicated with F.N. over the
“WhatsApp” messaging platform. (I know from my training and
experience that “WhatsApp” is an end-to-end encrypted messaging
platform that is commonly used to conduct criminal activity.)
Below are excerpts from a WhatsApp exchange between F.N. and
MCGRAYAN that F.N. provided that show MCGRAYAN’s direction to
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F.N. to permit MCGRAYAN’s 24-7 access to F.N.’s computer and
MCGRAYAN’s “frustrati[on]” with F.N.:
n. There were three other individuals on MCGRAYAN’s
team that came to meet F.N. to deliver documents or to obtain
F.N.’s signature on them. On one occasion, a member of the team
delivered to F.N. a completed federal income tax return for MARI
that had F.N.’s name on the return and required his signature.
F.N. reviewed the return and saw entries that he had no idea
about or whether the information was correct. F.N. noticed that
the return indicated that MARI had a large amount of tax due.
F.N. was concerned about being responsible for the taxes and
spoke to MCGRAYAN. MCGRAYAN told him “don’t worry, we will
24
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handle the tax payments” or words to that effect. F.N. later
learned that no taxes were ever paid. 5
o. MCGRAYAN directed messaged F.N. over WhatsApp to
deposit checks into specific accounts; MCGRAYAN attached images
of those checks and emailed those checks to F.N. (See above for
an example.)
p. MCGRAYAN directed F.N. to participate in seeking
loans, including bank loans and PPPLs and EIDLs. F.N. was
suspicious about the legitimacy of doing so, but MCGRAYAN told
him not to worry because MCGRAYAN would make sure that the loans
were repaid. (I know from reviewing the evidence in this case
that there was at least one loan of $250,000 by JPMorgan Chase
to MARI whose payments were made from what I believe to be
laundered proceeds; a PPP loan for $24,345; and nearly $1.5
million in EIDL and EIDL modifications.)
q. MCGRAYAN directed F.N. to make calls to help get
loans approved.
r. MCGRAYAN directed F.N. to conduct the foregoing
activities over WhatsApp for several years.
s. F.N. became increasingly afraid of MCGRAYAN as
MCGRAYAN’s tone became more belligerent when F.N. questioned
MCGRAYAN about whether what they were doing was legal. MCGRAYAN
told F.N. that they had a “blood pact, and that you don’t want
to fuck with me or the New York guys.”
5 A law enforcement database query revealed that MCGRAYAN
in July 2020 was fingerprinted in connection with applying to be
a licensed tax preparer.
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t. F.N. believed that MCGRAYAN was “scary and
unhinged.” He was at MCGRAYAN’s house in 2022 and saw MCGRAYAN
pull out a gun 6 and baseball bat and approach a man who had just
arrived in a car. F.N. saw MCGRAYAN approach the man and saw
MCGRAYAN wield the bat and heard MCGRAYAN scream at the man.
MCGRAYAN said that he called the FBI on the man. MCGRAYAN
several times over the years of their dealings told him, “don’t
fuck with us.” MCGRAYAN told F.N. that MCGRAYAN grew up with
gangs in Armenia and was a semi-professional boxer.
u. F.N. moved to Japan in or about March 2025, in
part out of concern for his safety for having been involved with
MCGRAYAN that was triggered by receiving a target letter. (I
served F.N. with a target letter regarding this investigation in
February 2025.)
F. Interview of A.M.
34. I interviewed A.M., who told me the following, among
other things:
a. He is a tax preparer.
b. He met MCGRAYAN socially around 2021 and told
MCGRAYAN that he was starting a tax preparation business.
c. MCGRAYAN started referring clients to him around
that same time. MCGRAYAN told him that the clients needed tax
returns prepared to help qualify for loans.
6 A law enforcement database query shows that MCGRAYAN was
fingerprinted on September 24, 2024, in connection with his
application to the Pasadena Police Department for a concealed
firearm carry permit.
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d. A.M. received several client referrals from
MCGRAYAN (collectively, the “MCGRAYAN Clients”). A.M.
identified by name the several MCGRAYAN Clients including
(SUBJECTS) SHAW, MARK, BENJAMIN, AYDI, VACHYAN, NIKOGHOSYAN,
HARVARD, ANAHIT, STAVROS, DIAMONDZ, and BORIS.
e. A.M. prepared tax returns on behalf of the
MCGRAYAN Clients for their respective business entities based on
scant financial statements or information that each client
provided either in a face-to-face meeting with A.M. or by email.
A.M. thought the financial statements were “odd” but clients
told him that the financial statements were prepared “overseas.”
A.M. produced several email examples of requests to prepare tax
returns for MCGRAYAN Clients, to which financial statements were
attached, including the following:
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f. As shown by the example above, A.M. was hired to
prepare multiple years’ tax returns for a client’s purported
business entity (here, a shell) where at least some of the
returns were untimely. Thus, it was typically, if not always,
the case that the returns were prepared and signed on the same
day for multiple years.
g. A.M. verified the identity of each of the
MCGRAYAN Clients by meeting each of them face-to-face when they
signed each return or by obtaining from each such client copies
of their photo identification so that he could then have each
such client sign each return using the DocuSign online
authentication platform.
h. Each MCGRAYAN Client signed the return(s) without
objection or question, including when A.M., as he typically did,
told the MCGRAYAN Client, “you owe a lot of taxes” and also
explained to each of them the consequences of failing to pay
such taxes.
i. MCGRAYAN directed A.M. to e-file each such
return.
j. MCGRAYAN, not the clients, paid A.M., in cash, to
prepare each return.
k. A.M. was happy to get the referrals from MCGRAYAN
because he (A.M.) was just starting his tax return preparation
business.
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G. SUBJECTS MCGRAYAN, SHAW, and MARK: Wire Fraud, Bank
Fraud, and Money Laundering re “Dynamic” PLP Loan
35. In June 2023, SHAW 7 applied to Grasshopper Bank (“GB”)
for a $2,830,000 PLP loan to purchase “Dynamic Delivery Install,
Inc” from MARK (the “Dynamic PLP”). In summary, I have probable
cause to believe that MCGRAYAN, SHAW, and MARK schemed to
defraud GB by making false statements and submitting phony
documents, including fraudulently concealing SHAW’s criminal
history, lying about prior employment, and providing fake bank
statements and fake federal income tax returns. The Dynamic PLP
was approved and its proceeds disbursed to a shell account whose
signatory was MARK who, in turn, laundered the proceeds through
other shell accounts and structured cash withdrawals to further
conceal the fraudulent use of loan proceeds.
36. I reviewed the Dynamic PLP loan file provided by GB
and learned the following:
a. On a standard “SBA 7(a) Borrower Information
Form” that I am familiar with from examining numerous PLP loan
files, SHAW was identified as the “100%” owner of the purchaser,
“Dynamic IT Solutions, Inc.”
b. A June 2023 “business purchase agreement”
identified “Dynamic IT Solutions, Inc.” as the buyer and
“Dynamic Delivery Install Inc.,” as the seller. MCGRAYAN was
7 I have concurrently applied for an arrest warrant on a
complaint affidavit alleging that SHAW and others to whom he is
related or engaged in business fraudulently sought pandemic
stimulus funds by submitting phony documents and then misusing
those funds. I hereby incorporate that complaint affidavit
(attached here as Exhibit A) as further probable cause to
believe that SHAW committed the offense conduct described
herein.
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identified as the broker through his business, “Exceed
Companies.” I have seen these standard form “business purchase
agreements” in the other PLP loan transactions described below
that I believe to be similarly fraudulent. Each such
transaction also identified the same escrow company, “Escrow 1,”
and the same escrow officer, “Escrow Officer 1.”
37. The files for the Dynamic PLP identified SHAW as the
buyer’s representative based on an image of SHAW’s genuine
driver’s license that matched SHAW’s driver’s license and
referenced SHAW’s residence address at the same address shown on
his driver’s license. I know from my training and experience
that PLP lenders require documentary proof of parties’
identities in the form of photos of driver’s licenses, Social
Security cards, or passports.
38. On April 3, 2023, as part of GB’s due diligence, SHAW
signed a “personal resume” in which he identified himself as
SHAW, with his true date of birth, Social Security Number, and
driver’s license. SHAW checked the box, “no,” in answer to the
question, “have you ever been charged with and/or arrested for
any criminal offense other than a motor vehicle violation? This
includes offenses which have been dismissed, discharged or not
prosecuted.” I obtained copies of SHAW’s driver’s licenses
under both his given name, “Sarkis Sarkisyan,” and SHAW,
depicted here:
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39. I know from law enforcement databases that SHAW, under
his birth name, “Sarkis Sarkisyan,” was convicted of felonies in
the State of California in 2011. 8 I know from my training and
experience in investigating PPP, EIDL, PLP, and other SBA-
related loan fraud cases that lenders deem borrower’s criminal
histories material to evaluating whether to approve loans.
40. SHAW also listed on the same document his “business
experience” as including prior employment by “Oncore Inc.,”
“from 2012 to 2020” as “IT Specialist – Handling Technical
Support on Daily Basis.” I interviewed H.A. in connection with
visiting Oncore Inc. at the same address that SHAW had given.
(H.A. was not present but I spoke to him over the phone on a
call placed to him by an Oncore employee at my request.) H.A.
said that he was a co-owner of Oncore Inc. and that Oncore Inc.
employed IT specialists and dispatchers. H.A. said that neither
Sarkis Sarkisyan or SHAW were ever employed by Oncore Inc. and
that H.A. did not know SHAW. I know from my training and
experience in investigating this and similar cases that an
8 In 2011, SHAW was convicted in Santa Clara Superior
Court, case no. B1151803, of unauthorized access to computers
(Cal.Pen.C. sec. 502(c)(1)), theft of credit card information
(Cal.Pen.C. sec. 484e), counterfeiting credit cards (Cal.Pen.C.
sec. 484i), and conspiracy (Cal.Pen.C. sec. 182).
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applicant’s statement about prior employment, especially a claim
of prior employment in a field relevant to the application, is
considered material to evaluating whether to approve a loan. I
also know from reviewing evidence gathered in this investigation
that it was common for SUBJECTS to claim to own “IT”
(information technology) companies or to engage in “IT” work,
including making claims that their IT companies hired offshore
contractors where, based on the totality of the evidence, I
believe such claims were false.
41. I know that PLP lenders typically required that
borrowers provide proof of funds for deposits to show that
borrowers had “skin in the game,” similar to where lenders
require that applicants for home mortgages put up downpayments.
The required deposits were typically quite large, such as more
than $400,000 in cash for a $3 million loan. I also know that
such funds must be “seasoned,” meaning that such funds had to be
in the account for a reasonable time before a loan application
was submitted to mitigate the lenders’ risk that such funds were
borrowed or not otherwise based on the borrower’s legitimate
financial activity.
42. GB received four months of purported bank statements
to prove that SHAW had seasoned funds sufficient to pay the
deposit of $465,000 as required under the Dynamic PLP business
purchase agreement. The bank statements that SHAW provided to
GB depicted a JPMC account ending in 3038 (the “JPMC 3038”) in
SHAW’s name at the same address shown on his driver’s license.
I know from reviewing genuine statements that SHAW opened that
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account on January 6, 2023 by providing his true Social Security
number, driver’s license number, and date of birth, and that he
gave that same address as his residence address.
43. I believe that the JPMC 3038 statements that were
provided as proof of SHAW’s deposit funds were fake (the “SHAW
Statement(s)”). The SHAW Statements started with January 2023
and went through May 2023. For example, the first such SHAW
Statement, for January 24 through February 21, 2023, indicated a
beginning balance of $802,959.56. However, I compared that
statement for the same period to the genuine statement that I
obtained from JPMC for JPMC 3038. The genuine statement’s
beginning balance was $2,959.56, or $800,000 less than the
beginning balance shown on the SHAW Statement. Based on my
training and experience, I believe that the SHAW Statement was
“photoshopped” or otherwise altered through the use of software
like Adobe Photoshop. 9 The ending balance for the same period on
the SHAW Statement was $858,421.36, or approximately $800,000
more than the true ending balance for the same period on genuine
statement, $86,421.91. The SHAW Statements for the three months
9 I know from my training and experience that fraudsters
use Adobe Photoshop or similar programs, some of which are
available online for free, to create phony bank or business
documents. The process is, unfortunately, quite simple: the
fraudster scans a genuine document, say a bank statement, to
create a digital file. The program then digitizes the
characters in the document, thus enabling the characters to be
manipulated or changed. The fraudster then edits the document
to his or her liking and saves the fake in “pdf” format. The
fraudster would not email the fake “pdf” version because the
“properties” feature could be used to reveal the manipulation.
Thus, the fraudster would instead print the fake version and
forward that printed version or save that printed version
(neither of which would have incriminating “creation date” or
similar metadata) to the lender.
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thereafter reflected the false balance and ultimately, but
falsely, showed seasoned downpayment funds available to close
the deal. Here are images of the first SHAW Statement and the
genuine statement (the SHAW Statement is on the left; the
genuine statement is on the right):
44. I also found it to be common practice that PLP
lenders required that borrowers provide federal income tax
returns as part of loan underwriting. The loan file for the
Dynamic PLP contained what purported to be Form 1040 federal
income tax returns for SHAW for calendar years 2020, 2021, and
2022. Each return contained the name of the same preparer,
A.M., who, as stated above, identified SHAW as one of many
MCGRAYAN Clients for whom he prepared business entity returns
solely to qualify for loans (as opposed to needing to file their
returns to comply with income tax laws). I have probable cause
to believe, based on the totality of the evidence, including
F.N.’s statement, that SHAW, like all other participants in the
fraudulent PLPs discussed herein, signed and caused the returns
34
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to be filed knowing that the returns were fraudulent and
obtained solely to qualify for PLPs, and that each such SUBJECT
well knew that they were participating in a fraudulent scheme
for that reason alone, notwithstanding that any such SUBJECT may
have been told by MCGRAYAN that signing such returns, or doing
any other act to accomplish something that was false or
fraudulent, was otherwise “legitimate” or “legal.” 10
45. Each of the tax returns provided to GB was prepared
by A.M. on the same day, February 14, 2023; thus, the 2020 and
2021 returns were untimely and, therefore, I have further
probable cause to believe that the returns had been prepared to
support SHAW’s loan application as opposed to reporting genuine
financial activity.
46. A.M. further stated that he prepared the tax returns
for his clients solely on the basis of information provided by
the client and that he verified the identity of his clients
during face-to-face meetings or requested and received via email
a photocopy of their driver’s license and Social Security card.
A.M. said that his clients either signed their returns in his
presence or via the “DocuSign” signature authentication
platform.
47. On each of the tax returns that were provided to GB,
SHAW represented that he earned hundreds of thousands of dollars
10Based on SHAW’s offense conduct described in the
concurrently submitted complaint affidavit describing SHAW’s
fraud in connection with seeking a PPP for a different phony
shell, “Prime Funding” (see Exhibit A), I also have probable
cause to believe that SHAW well knew that the returns were
fraudulent and had them prepared with the intent to defraud GB.
35
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annually as an “IT Specialist.” He reported owing approximately
$165,000 in federal income taxes in total for those tax years
(2020-2022). Based on my investigation, I found nothing to
indicate that SHAW paid any such income tax. I also noted that,
despite stating that he was employed by Oncore Inc. for 2012-
2020, he never reported any compensation from Oncore Inc.
48. I also found to be common practice that PLP lenders
obtained “transcripts” from the IRS to confirm that loan
applicants actually filed the returns that they provided to the
lenders. (In some cases, the lenders obtained such returns from
the IRS.) I know from my training and experience that IRS
transcripts are summaries of IRS filings that include, for
example, the tax year for a return, the date the return was
filed, the adjusted gross income and tax due and payable per the
return, and penalties or interest assessed for late-filed
returns.
49. The Dynamic PLP loan file contained IRS transcripts
that I believe to be genuine. The transcripts showed that each
of the above-described returns was untimely; that each was
actually submitted to the IRS on the same day; that the 2020 and
2021 returns were assessed a late filing penalty; and that each
return reported substantial tax due and owing, collectively
approximately $165,000, not including penalties or interest. I
have learned in the course of this investigation that a common
feature of the fraudulent scheme was different from other fraud
schemes where perpetrators simply provided unfiled income tax
returns to lenders for underwriting. Here, perpetrators
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actually filed tax returns with the IRS but the returns
contained false information, including huge income numbers and
large taxes due and owing. Based on the evidence gathered in
this investigation, I believe that the SUBJECTS who signed or
caused to be filed such returns – late, through the same
preparer, solely to obtain loans, claiming large income and
large tax due and owing, but paying no taxes – did so solely to
create the appearance of substantial income and the ability to
repay their loans, and all solely to satisfy lender underwriting
criteria.
50. GB approved the Dynamic PLP loan application. A
closing statement in the Dynamic PLP loan file identified Escrow
Officer 1 as the escrow officer. I know from this investigation
that Escrow Officer 1 was the same escrow officer at Escrow 1
for several fraudulent PLP loans, some of which are described
herein.
51. Based on my review of the Dynamic PLP loan file and
bank statements obtained via subpoena, I know that the
$2,748,546 in net loan proceeds were wired from GB to an Escrow
1 account at City National Bank in Los Angeles on June 13, 2023.
Together with the $465,000 deposit, Escrow 1 disbursed those
proceeds, in relevant part, as follows: (1) a check for
commissions to MCGRAYAN for $62,000, and (2) a check to the
purported seller, Dynamic Delivery Install, Inc. (MARK’s shell
company), for $3,021,606.
52. The Dynamic PLP proceeds check for $3,021,606 was
mailed to an address that I know from law enforcement databases
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to be MARK’s residence address. I obtained from JPMC via
subpoena, and reviewed, records for an account ending in 0835
(the “JPMC 0835”) and learned the following:
a. The proceeds check for $3,021,606 was deposited
on June 14, 2023 into the JPMC 0835:
b. MARK opened the JPMC 0835 under the name of
Dynamic Delivery Install, Inc. on June 30, 2020, by presenting
his true Social Security number and identifying himself as
“president.” I compared MARK’s signature on the signature card
for the 0835 account with his California driver’s license and
believe they were signed by one and the same person:
c. The balance in JPMC 0835 before the deposit of
the Dynamic PLP proceeds check was $44,769.26, a small balance
compared to the PLP proceeds check of more than $3 million, thus
making it easy to trace the use of those proceeds:
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d. As shown on the above-depicted “checking
summary,” there were 40 electronic withdrawals totaling $768,057
from the JPMC 0835, substantially all of which came from the
Dynamic PLP loan proceeds check. The same bank statement showed
that those withdrawals occurred over only three days and all to
shells whose owners, and the sole signatories on the shells’
bank accounts, were SUBJECTS BENJAMIN (“Arms of Olympus”),
HARVARD (“Olympus Axv Solutions”), PARKER (“Mass Exclusive”),
NIKOGHOSYAN (“CM General Auto Electric Supplies”), and STAVROS
(“Hawk Fleet”): 11
53. The JPMC 0835 bank statements further showed online
transfers totaling $50,000 to SHAW’s shell, Prime, that he used
to fraudulently obtain a PPP loan as more fully described in
Exhibit A.
11One such “online payment” on June 29, 2023 was to “Alpha
Omega Solutions LLC” for $10,280.95. I know from my
investigation that Alpha Omega Solutions LLC was a shell whose
account signatory was ARSEN TERZIAN, aka Steven Terzaki.
TERZIAN is a SUBJECT in the concurrently submitted complaint and
affidavit against SUBJECT SHAW. (See Exhibit A).
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54. Within approximately four weeks, substantially all of
the Dynamic PLP loan proceeds (more than $2.7 million) were
transferred out via online transfers to the same shells that I
have repeatedly noticed in this case were used to “layer”
fraudulently obtained loan proceeds.
55. Finally, bank records from the JPMC 0835 show that,
between July 3 and 31, 2023, MARK signed bank withdrawal slips
(the signature on the slips matched that of his driver’s license
and the signature card for the JPMC 0835) for nine separate cash
withdrawals of $4,500. I also know from my training and
experience that breaking up cash withdrawals in this way is
consistent with structuring to avoid reporting cash activity to
the IRS. I therefore have probable cause to believe, based on
the totality of the evidence regarding the Dynamic PLP
transaction and others described below, that these withdrawals
represented MARK’s personal cut of fraudulently obtained and
laundered proceeds.
H. SUBJECTS MCGRAYAN, MARK, and MUSAYELYAN: Wire Fraud,
Bank Fraud, and Money Laundering RE “GDI” PLP Loan
56. I reviewed a PLP loan file from First Internet Bank
of Indiana (“FIBI”) involving SUBJECTS MGGRAYAN, MARK, and
MUSAYELYAN. I learned the following that indicated that
MCGRAYAN, MARK, and MUSAYELYAN committed wire fraud and money
laundering in substantially the same manner as with the Dynamic
PLP, described above:
a. A November 2023 standard form “Business Purchase
Agreement” for MARK’s purported business, “Global Dynamic IT”
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(“GDI”), to buy MUSAYELYAN’s’ purported business, “Global
Ultimate Management” (“GUM”), for $3,650,000. The agreement
stated that the purchase price was to be paid by a $550,000 cash
deposit and a PLP for $3,100,000 (“the GDI PLP”).
b. Like the Dynamic PLP deal between SHAW and MARK,
MCGRAYAN was the broker who stood to receive a commission of
tens of thousands of dollars.
c. MARK’s identity as the authorized representative
of GDI was established by, at least: (1) a photocopy of the
genuine driver’s license for MARK as requested by FIBI; (2) a
“non-identity affidavit” with MARK’s true date of birth, Social
Security number, and residence address that contained what
appeared to be a live ink signature above what appears to be a
notary jurat and signature of a notary who authenticated MARK’s
signature; (3) a “personal financial statement” that identified
MARK by what I have verified by law enforcement databases and
other loan documents to be his then personal residence; (4) a
“beneficial ownership” statement that contained not only a
substantially identical live ink signature that matched that of
MARK’s driver’s license but also contained his true date of
birth, driver’s license number, and Social Security number; and
(5) a “personal eligibility questionnaire” that contained not
only a substantially identical live ink signature that matched
that of MARK’s driver’s license but also contained his true date
of birth, driver’s license number, Social Security number, and
an electronic “DocuSign” signature for “Axle MARK” next to his
live ink signature.
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d. A “management resume,” bearing MARK’s true date
of birth, Social Security number, personal residence address,
and a live ink signature of MARK that matched that of the other,
above-described GUM PLP loan documents and also bore the
DocuSign signature of MARK, stated that MARK worked for “Oncore,
Inc.” from 2012 to 2017 as “IT manager” to “handl[e] technical
support on daily basis.” As mentioned above, I spoke to H.A.,
who identified himself as a co-owner of Oncore Inc. He told me
that MARK was employed by Oncore Inc. for about a year, not as
an “IT Specialist” but as a “dispatcher.” A “resume” that SHAW
had provided in connection with the Dynamic PLP, described
above, similarly misrepresented that SHAW had the identical
position at Oncore Inc. (“IT Specialist – Handling Technical
Support on Daily Basis”) and, as described above, an Oncore Inc.
representative told me that SHAW never worked at Oncore Inc.
e. MARK’s “management resume” also claimed his work
experience as “president” of Dynamic Delivery Install, Inc. from
2017 to 2023. I know from reviewing a duly subpoenaed loan file
from the Federal National Mortgage Association that, in June
2019, MARK applied for a loan to buy his personal residence (the
same residence that he later identified on numerous loan and
related documents in this investigation). On his loan
application, MARK stated that, as of June 2019, he had been
employed as a “load salesman” for six years at $2,197/month. He
mentioned nothing about Dynamic Delivery Install, Inc., or his
purported work in “IT.” Thus, as stated above, I have probable
cause to believe that Dynamic Delivery Install, Inc. was a shell
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that was created or at least used for the sole purpose of
supporting the fraudulent application for the Dynamic PLP loan.
f. I also know from my training and experience that
FIBI, like other PLP lenders, required that a PLP borrower, here
GDI, submit proof of seasoned good faith deposit funds. Similar
to how SHAW submitted fake bank statements to qualify for the
Dynamic PLP, discussed above, so too MARK submitted fake bank
statements to fraudulently obtain loan approval. From reviewing
the FIBI loan file, I learned that:
i. The file contained a purported bank
statement for a JPMC account ending in 1343 (the “JPMC 1343”) in
the name of MARK at the same residence address that MARK
provided on other loan documents (the “MARK Statement”).
ii. For the period of September 1 through 29,
2023, the MARK Statement showed a beginning balance of
$805,002.02.
iii. I obtained genuine records for the 1343
Account from JPMC via subpoena. I compared those genuine
records to the Mark Statement (for the same period (September 1
through 29, 2023)) and learned that the beginning balance on the
genuine statement was actually $5,002.02, or $800,000 less than
the MARK Statement. The Mark Statement (i.e., the fabricated
statement is on the left, below, and the genuine statement is on
the right):
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iv. I also noticed that the inflated number
(appx. $800,000) on the MARK Statement was substantially
identical to the inflated number on SHAW’s fake bank statements
that he had provided in connection with fraudulently seeking the
Dynamic PLP loan, described above, in which MARK was the sole
owner of the purported (but fake) seller.
g. FIBI, like GB, required tax returns from the
seller to establish that the seller, GUM, had genuine revenue to
support its valuation for the purpose of justifying the purchase
price in the purchase agreement. I reviewed GUM’s tax returns
that, like the Dynamic PLP, were prepared by A.M. A.M. had told
me that MCGRAYAN referred several clients to him to prepare tax
returns for the purpose of the clients’ (or their “entities”)
applications for loans. A.M. recalled preparing the GUM
returns. These returns described millions in revenue and, over
the period of three tax years, whose returns were prepared at
the same time, and were untimely as to at least the first two
years, reported over a hundred thousand dollars in tax due and
owing. Based on A.M.’s and F.N.’s statements, and the totality
of the evidence gathered in this investigation, I have probable
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cause to believe that GUM’s tax returns were fraudulent and
submitted solely to defraud FIBI.
h. The GDI PLP was funded on February 23, 2024. Net
loan proceeds of $3,497,426 were disbursed by check no. 150376
payable to “Global Ultimate Management” and mailed to 6615
Hazeltine Avenue, Unit 103, Van Nuys, CA 91405, an address that
I know from law enforcement databases was at that time
MUSAYELYAN’s personal residence.
I. SUBJECTS MCGRAYAN, HARVARD, and DIAMONDZ: Wire Fraud,
Bank Fraud, and Money Laundering re “OAS” PLP Loan
57. I reviewed records from Byline Bank and learned the
following:
a. A May 2021 purchase agreement described “John
Harvard, Olympus AXV Solutions, Inc.” (“OAS”) as the purchaser
of the assets of “American Best Filter, Inc.” for $2,600,000. I
believe that SUBJECT HARVARD signed this agreement because the
signature bearing his name matched that of his genuine driver’s
license and his notarized signature on other documents
associated with this transaction.
b. The seller’s signature line identified the seller
as “Mery Diamondz D/B/A American Best Filter, Inc” (“ABF”) who
signed the agreement on May 17, 2021. The signature appeared to
be a live ink signature of SUBJECT DIAMONDZ whose signature I
recognized as matching that of DIAMONDZ’s genuine driver’s
license and multiple bank account signature cards bearing her
signature and identifying her by her true date of birth, Social
Security number, and driver’s license number.
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c. The transaction was, like substantially all of
the fraudulent PLPs in this investigation, brokered by MCGRAYAN
who stood to receive a commission of several thousand dollars.
d. HARVARD represented that OAS intended to purchase
the assets of ABF to “expand its operations” and that OAS was
presently engaged in “provid[ing] commercial/ residential/
industrial water filtration and water softener systems,
primarily in the Los Angeles area.” Consistent with the
totality of the evidence gathered in this investigation, I
believe OAS was merely a shell that was neither engaged in any
such business nor did it intend to expand any business into the
stated subject area or any other.
e. The loan file contained an office lease agreement
dated November 1, 2021, for $500/month “to terminate on October
31, 2026.” Based on my observation of other leases for similar,
small spaces, made at or close to applying for PLPs, I believe
that the lease was fake and made with the intent to defraud
Byline Bank. No less, the lease did not identify OAS as the
occupant; the occupant, identified in several places on the
lease, including just above what appeared to be HARVARD’s
genuine, live ink signature, was “American Olympus Solutions,
Inc.,” what I believe to be yet another shell held by HARVARD.
58. In April 2025, I visited and photographed the
building area where HARVARD claimed that OAS operated and saw no
references to OAS’s occupancy. I believe that was consistent
with fraudulent statements and documents submitted to obtain the
PLP as well as with documents in the Byline Bank file that
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stated that the entire amount of the loan that was guaranteed by
the SBA ($1,739,589) loan was “charged off” in part because a
“Site Visit conducted on 12/19/2023 during “regular” business
hours indicated the business was not open, doors locked, and no
lights were on.”
59. The purchase agreement for the OAS PLP stated that
ABF did business at 345 W. Foothill Blvd., Suite 5, Glendora,
CA. The Byline file contained a copy of a lease agreement for
that space that stated that ABF had taken tenancy in November
2021 (the same month that OAS had purportedly signed its lease
for its space). I spoke to R.N., who told me that her father,
P.N. had owned the building at that time and that he died of
Alzheimer’s disease in June 2021, or several months before the
lease was signed that bore his signature. R.N. reviewed the
lease and told me that the lease was fake because her father did
not, and could not, due to his death, sign the lease. R.N. said
that she was familiar with the tenants in the building and knew
nothing about ABF.
60. In April 2025, I photographed the outside of the
office space that was identified in the fake lease as ABF’s
office. The image that I took, below, depicted “American Best
Filter, Inc.” on the left window and “Canmar Promo Corp, Inc.”
Each was a shell and each lease was fake. (Canmar Promo Corp,
Inc. is the subject of another fraudulent PLP, described below.)
Furthermore, neither space seemed consistent with that of the
operation of businesses that claimed millions in income by for
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selling water filtration equipment (ABF) or offering vague
“marketing” services (Canmar).
61. The Byline Bank file also contained what appeared to
be a genuine notarized, live ink signature of HARVARD on
November 2021 in support of a guarantee of OAS’s PLP obligation.
I have probable cause to believe, based on that and the totality
of the evidence described herein, that HARVARD knowingly
participated in the scheme to defraud Byline Bank.
62. Records for Bank of America account ending in 3882
(the “BofA 3882”) show the following:
a. The signature card/account opening application
was signed on May 12, 2020 at an Encino branch of Bank of
America. The signature card indicated that the account holder
signed the signature card before a Bank of America employee on
that same date. The signature matches that of DIAMONDZ’s
driver’s license. Based on F.N.’s statement and the totality of
the evidence in this case, I have probable cause to believe that
DIAMONDZ actually signed this signature card (and that of
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several other cards for accounts that she opened around the same
time) at MCGRAYAN’s direction, knowing that doing so was to
obtain loans that, at the least, were suspicious if not
fraudulent.
b. The proceeds of the OAS PLP, $2,139,941, were
deposited to the BofA 3882 on November 12, 2021. The prior,
existing balance was $64,250.
c. Approximately $2 million, in the form of six
checks, ranging from $205,000 to $450,501, was withdrawn from
the BofA 3882 within three days of the deposit of the PLP
proceeds. Five checks were written to “American Best Filter,
Inc.” and one was written to “Mery Diamondz.” Each bore a
signature that matched that of DIAMONDZ’s driver’s license and
the signature card for the 3882 Account. The printing on the
checks did not appear to match that of DIAMONDZ on at least one
other check that bore DIAMONDZ’s signature. Based on F.N.’s
statement and the totality of the evidence that I have reviewed
in this investigation, I believe that MCGRAYAN, or someone
acting at his direction, wrote out each such check and either
directed DIAMONDZ to sign each check or obtained pre-signed
checks from DIAMONDZ.
d. One of the checks, for $450,501, was deposited
into a Wells Fargo account in the name of “American Best Filter,
Inc.” and ending in 7536 (the “WF 7536”). I reviewed WF 7536
records and learned from the signature card/account application
that the WF 7536 was opened by DIAMONDZ seven days before the
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BofA 3882, as her signature, date of birth, Social Security
number, and driver’s license matched that of DIAMONDZ.
e. I further reviewed the account statements for the
WF 7536 over approximately six months to trace the flow of the
$450,501 check that had come through the BofA 3882 from the
proceeds of the OAS PLP and learned that just under $75,000 was
transferred (in two payments, one for $25,000 and the other for
$49,800), online, to “Zart Art Printing,” and $49,805 to “CP
Mobile Mechanic, Inc.,” also online, and each a shell whose
accounts were opened around the same time, and in manner
consistent with, that of the shell accounts opened by F.N. and
DIAMONDZ to obtain loans.
f. In August 2022, and continuing monthly thereafter
for approximately 12 months, the WF 7536 was used to layer
funds, i.e., launder funds received from and, commonly in the
same billing cycle, paid to, the same shells whose accounts were
repeatedly used to layer funds.
63. A.M. told me that he met DIAMONDZ, for whom he
prepared ABF tax returns, who signed the returns and told him
that she that she was in the water filter business.
J. SUBJECTS MCGRAYAN, BENJAMIN, AND AYDI: Attempted Wire
Fraud and Bank Fraud re “Alex Titan Solutions” PLP
Loan
64. I have probable cause to believe that MCGRAYAN,
BENJAMIN, and AYDI attempted to commit wire fraud and bank fraud
against First Citizens Bank in North Carolina (“FCBNC”) by
making false statements and submitting fraudulent documents to
seek a $3 million PLP. The PLP was denied.
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65. I obtained from FCBNC a loan file for a PLP for
borrower “Alex Titan Solutions, Inc.,” and learned the
following:
a. In January 2025, FCBNC received online an
application for a PLP for $3 million for “Alex Titan Solutions,
Inc.,” acting through its owner, BENJAMIN, to buy the assets of
“Titan Solutions, Inc.,” acting through its owner, AYDI. The
purchase price included $2.6 million for the seller’s assets and
$275,000 for working capital. The seller’s stated current
accounts receivable were $197,000. BENJAMIN’s true name, date
of birth, and then-residence address in connection appear on the
PLP application.
b. The purchase agreement was dated October 14,
2024, brokered and signed by MCGRAYAN, and the escrow was
handled by Escrow Officer 1 at Escrow 1.
c. The file contained a 2023 IRS Form 1120 corporate
tax return for “Titan Solutions, Inc.” dated May 6, 2024,
bearing a signature purportedly of AYDI, and reporting $2.8
million in revenue, $817,783 in taxable income, and more than
$50,000 tax due and owing. Although I did not further
investigate this return because there was substantial, other
evidence that this loan was fraudulent, I have probable cause to
believe that the return was, in fact, fraudulent as it was
consistent with the other fraudulent returns described herein.
d. The loan file contained a copy of a lease for
AYDI’s business to be sold for $3 million, a small office space
on Green street in Pasadena (the “Green Street Office”). The
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Green Street Office lease was written in June 2024, for one year
at monthly rent of $638.
66. I interviewed T.T. who told me the following:
a. She is a realtor in the Pasadena area who
advertises heavily in the Armenian community.
b. She received a call around early June 2024 from
an individual seeking to rent a small office in Pasadena. She
assembled five or so listings, including one for the Green
Street Office, and emailed them to the caller whose named she
could not recall. T.T. arranged to meet the caller at one of
the listings and to then caravan to the others.
c. She met two individuals at the first of the
listings. She claimed that she could not identify either of
them. She showed them the Green Street Office and they selected
it because it was the cheapest rent.
d. T.T. obtained a lease application from the
lessor of the Green Street Office and forwarded that to the
email address that she received from one of the individuals whom
she met during the caravan/showings. T.T. said she received a
commission for her work, in an amount she could not recall, and
that she values her reputation in the community of largely
Armenian clients. I showed T.T. a picture of AYDI. T.T.
claimed that she could not recall meeting him.
e. Other than meeting the two individuals at the
Green Street Office to show them that space (and four others
during that same time), T.T. communicated with the prospective
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tenant(s) by email. T.T. received from one of the two
individuals the following:
i. An “Application” for the Green Street
Office in the name of AYDI with AYDI’s true Social Security
number, date of birth, and driver’s license, contained a
signature at the bottom of the application in the same printing
and writing instrument (what appeared to be a “sharpie” or
similar instrument) that matched that of AYDI’s driver’s
license. I therefore have probable cause to believe that AYDI
executed the lease application and will refer to it as such.
ii. AYDI stated in the Application that he was
the “president” of “Titan Solutions,” the name of the business
to purportedly be sold. He gave its business address as the
same as his stated residence address, an apartment in Valley
Village, CA. AYDI claimed that he had earned a monthly salary
from Titan Solutions, since December 2018, of $16,000.
iii. AYDI also emailed with the lease application
several other documents including purported financial statements
for Titan Solutions. One such purported financial statement was
an income statement for Titan Solutions that I believe to be
fabricated, using Quickbooks or one of many open source
programs, based on my review of numerous other, similar, and
bogus financial statements gathered in this investigation.
iv. AYDI also emailed “Articles of
Incorporation” for “Titan Solutions Inc.” in California, dated
September 2018. There was no reference to AYDI or anyone
associated with this investigation. The corporate agent for
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service of process was “Registered Agents Inc.” Based on my
training and experience and the evidence gathered in this case,
I believe that these corporate articles were obtained or
purchased by MCGRAYAN and held as a shell for future use to
fraudulently obtain loans.
v. AYDI also emailed a “Statement of
Information” (“SOI”) for “Titan Solutions” dated April 22, 2024,
that identified AYDI as the sole officer and director from the
same residence address that AYDI stated in the lease application
for the Green Street Office, and that was e-signed by AYDI. I
know based on my training and experience that, under California
law, a corporation must file an SOI within 90 days of
incorporation and then annually, and that failure to file SOIs
may result in suspension. I reviewed records of the California
Secretary of State and learned that no SOI was filed for Titan
Solutions until April 22, 2024, and that it was suspended until
April 2023. Based on this information, F.N.’s statements, and
on the totality of the evidence described herein, I have
probable cause to believe that MCGRAYAN directed AYDI to sign
and/or submit this SOI to “revive” the otherwise dormant Titan
Solutions shell to create the appearance that it was a
legitimate business solely for the purpose of fraudulently
obtaining the PLP.
f. ADYI also emailed T.T. copies of JPMC bank
statements for an account in the name of Titan Solutions Inc.
ending in 0153 (the “JPMC 0153”), apparently to show that Titan
Solutions was a going concern with legitimate income. I
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reviewed records for that account and learned that the JPMC 0153
was not used for legitimate business activity but, instead, like
the other shell accounts described herein, for money laundering:
i. ADYI opened that account on May 11, 2023,
using his true name, Social Security Number, and residence
address (the same address he used on the Green Street Office
lease application). The first deposit was a $100 cash and a
check from one of the numerous shell entities, opened by SUBJECT
VACHYAN in the name of “Art Mart” for $9,670.99, an amount that,
based on my training and experience and the evidence gathered in
this case, was evidence of intent to structure and layer ill-
gotten gains. 12
ii. Between its opening in May 2023, and when
AYDI provided JPMC 0153 statements to E.L., the Green Street
Office landlord’s representative, the account was used solely to
launder money in a nearly identical manner to that of numerous
other accounts opened by SUBJECTS by receiving the deposit of
checks from shells and then withdrawing and sending those same
funds to those same and other similar shells’ accounts in the
names of other SUBJECTS.
67. I interviewed A.S. who told me that she is a loan
officer at FCBNC and is familiar with the Titan PLP loan file.
A.S. told me that FCBNC ordered a site visit of the Green Street
Office as part of loan underwriting and that she told BENJAMIN
that he needed to be present during the site inspection. A.S.
12The offense conduct involving VACHYAN and his shell,
“Art Mart,” is discussed below.
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told me that BENJAMIN told her that Titan Solutions did not
occupy the space because it was being “fumigated.”
68. I interviewed E.L. who told me the following:
a. He is the representative for the owner of the
building for the Green Street Office.
b. He negotiated the lease for the Green Street
Office regarding Titan Solutions.
c. The tenant never actually moved into the space.
d. (Contrary to what BENJAMIN told A.S., the loan
underwriter), the space was never fumigated.
K. SUBJECTS MCGRAYAN, ANAHIT, AND PARKER: Wire Fraud,
Bank Fraud, and Money Laundering re “Canmar” PLP Loan
69. I reviewed a PLP loan file from Ameris Bank
(“Ameris”) and have probable cause to believe that MCGRAYAN,
ANAHIT, and PARKER committed wire fraud and bank fraud by making
fraudulent statements and submitting fraudulent documents to
qualify for more than $2 million in PLP funding, and then
laundered the proceeds through shell accounts.
70. I reviewed the Ameris loan file and learned the
following:
a. A January 2023 asset purchase agreement purported
to show that ANAHIT’s corporation, Canmar Promo Corp (“Canmar”),
agreed to buy the assets of PARKER’s purported company, “Mass
Exclusive,” for $2,905,000, in the form of a $750,000 cash
downpayment and a $2,155,000 loan. MCGRAYAN was the broker and
the escrow was handled by Escrow Company 1 and Escrow Officer 1.
MCGRAYAN stood to receive a 1% “referral fee” of $22,500
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according to the escrow instructions and an invoice that
MCGRAYAN’s business sent to the lender, but I have probable
cause to believe that MCGRAYAN received millions through the
laundering of the loan proceeds via shell accounts.
b. A “management resume” was submitted to Ameris for
ANAHIT as part of the underwriting process. The resume stated
that ANAHIT, a late ‘60’s woman of Armenian descent, had managed
Canmar as a promotional and apparel business since 2015. The
resume also stated that ANAHIT had worked for “So Cal
Promotions” in Yorba Linda from 2007 to 2015 as a “promotions
manager.” I conducted an online search of So Cal Promotions and
found it to be a genuine promotional and apparel business in
Yorba Linda. https://www.socalpromotions.com/. In April 2025,
I spoke to J.S., who told me that he is the owner of So Cal
Promotions in Yorba Linda. He stated that he remembers the
names of every employee from 2007 to 2015 and, when told that
ANAHIT had listed So Cal Promotions on her resume, J.S. said he
had “never heard of her” and “she’s pulling your leg.”
c. Escrow instructions allocated the purchase price
as follows: “Furniture, Fixtures & Equipment - $125,000.00,”
“Goodwill - $580,000.00,” and “Covenant Not to Compete -
$2,200,000.00.” I know from my training and experience that the
value placed on a “covenant not to compete” is oftentimes
considered equivalent to the claimed asset value of a service
business for purposes of underwriting a loan to buy a service
business. Based on the totality of the evidence relating to
this transaction and that of the other PLP transactions
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described herein, I have probable cause to believe that these
figures were entirely made up with the intent to defraud because
Mass Exclusive was yet another valueless shell.
71. Ameris required that Canmar have a minimum 10-year
office lease. The lender’s “closing checklist” showed that
Canmar had to provide a copy of that ten-year building lease and
that Canmar subordinate its interest in that lease space as
collateral for the PLP. I showed R.N. a copy of the lease for
Canmar’s office space that was provided to Ameris. The lease
bore ANAHIT’s signature that matched that of her driver’s
license. As stated above, R.N. told me that her father, P.N.,
had owned the building but had died in June 2021 of Alzheimer’s
disease. R.N. told me that she is familiar with P.N.’s
signature and that, having reviewed the lease, R.N. determined
that P.N.’s signature was forged, as was P.N.’s signature on the
“subordination” agreement, because P.N. had died in 2021, two
years before both documents were purportedly executed in 2023.
72. Ameris’s “vetting memo” contained a detailed
spreadsheet that evaluated Canmar’s creditworthiness based on
its federal income tax returns. Copies of Canmar’s returns for
calendar years 2020 and 2021 were included in the loan file and,
according to the “closing checklist,” they were provided on
behalf of the borrower. IRS transcripts that appear to be
genuine were also included in the loan file. I reviewed those
documents and made these observations:
a. The transcripts showed that the tax returns were
not timely filed. The 2020 tax return was filed on May 16,
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2022, or just before the Canmar PLP loan was sought. The 2021
tax return was filed on February 13, 2023, or during the loan
underwriting process (actually, just a few weeks before the loan
was approved and funded).
b. Each return was prepared by A.M. As stated
above, A.M. stated that he received numerous client referrals
from MCGRAYAN to prepare tax returns to support loans. A.M.
identified ANAHIT as one such client. A.M. said that he
verified ANAHIT’s identity by obtaining from her a photocopy of
her driver’s license and Social Security card in connection with
using the Docusign authentication platform. A.M. provided
copies of those identity documents to me and I confirmed via law
enforcement databases that they were genuine and for ANAHIT.
c. A.M. also provided a copy of this email order to
prepare Canmar’s tax return:
73. Ameris’s records included a wire transfer memo
showing that loan proceeds of $2,242,761 were wired from the
closing agent (a law firm in Boca Raton, FL) to City National
Bank in Los Angeles FBO Escrow Company 1 on March 14, 2023. On
March 15, 2023, Escrow Company 1 wrote and mailed a check for
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the Canmar PLP proceeds. I traced that check to a Wells Fargo
account ending in 0655 (the “WF 0655”) and learned the
following:
a. The Canmar PLP proceeds check was deposited into
the WF 0655 on March 16, 2023.
b. The WF 0655 was opened on June 10, 2020, or
around the same time that numerous other shell accounts were
opened by other SUBJECTS at, based on the totality of the
evidence in this case, at the direction of MCGRAYAN for the sole
purpose of fraudulently facilitating loans.
c. The signature card/account application stated
that PARKER was the “owner with control of the entity” of Mass
Exclusive, further stated his true date of birth, Social
Security number, and driver’s license, and further indicated
that PARKER’s identity at the time of opening the account was
determined upon the bank employee’s review of PARKER’s Social
Security card and driver’s license. I compared the signature on
that card to that of PARKER’s driver’s license and believe that
they were signed by one and the same person. Again, I have
probable cause to believe that PARKER personally opened this
account at MCGRAYAN’s direction, knowing or having the strong
suspicion that the account was to be used solely to fraudulently
obtain loans.
d. The activity in the WF 0655 was entirely
consistent with the money laundering “layering” activity in the
numerous other accounts described in this affidavit, including
showing transfers from that account in amounts consistent with
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the transfers by and between shells’ accounts and then deposits
from the same shells, as shown in these excerpts from the March
2023 WF 0655 statement:
74. Substantially all of the Canmar PLP proceeds were
transferred out of the WF 0655 to other shells’ accounts within
less than 60 days with several interspersed $1,000 ATM cash
withdrawals that I have probable cause to believe were, in whole
or in part, ANAHIT’s cut of the fraudulent proceeds.
L. SUBJECTS MCGRAYAN and STAVROS: Attempted Wire Fraud
and Bank Fraud re “Stavros Auto Group” PLP Loan
75. I have probable cause to believe that MCGRAYAN and
STAVROS attempted to obtain nearly $3 million in PLP funds by
using fabricated bank statements that were substantially similar
to the fabricated bank statements submitted for the Dynamic PLP
and GDI PLP frauds, described above.
76. I reviewed a loan file from First Internet Bank of
Indiana (“FIBI”) and learned the following:
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a. In June 2024 FIBI received a written inquiry to
make a PLP on behalf of “Stavros Auto Group Inc.” for $2,855,000
to purchase a business to be designated. The loan was not
ultimately funded.
b. An individual identified as STAVROS signed and e-
signed FIBI’s “personal eligibility questionnaire” that required
that he provide and certify personal identifying information.
The document had STAVROS’s true Social Security number and date
of birth. His live-ink signature matched that of his genuine
driver’s license. FIBI’s file also contained a color photocopy
of STAVROS’s “Passport Card,” with his photo that matched that
on his driver’s license, which I verified through law
enforcement data basis to be genuine. I will, therefore,
hereafter refer to STAVROS as the borrower.
c. STAVROS represented to FIBI that he currently
operated “Stavros Auto Group Inc.” under the fictitious business
name of “Tru Sight Auto Group” at 17425 Chatsworth St., Suite
102-B, Granada Hills, CA 91344. 13
d. To satisfy FIBI’s inquiry that STAVROS show
seasoned funds for the $345,000 cash “injection” (i.e.,
downpayment), STAVROS sent FIBI a photocopy of a statement for a
US Bank account ending in 1844 (the “USB 1844”) for the period
of July 13 through August 13, 2024. The statement identified
the account holder as “Samuel Stavros” at 17425 Chatsworth St.,
13I know from my investigation that this address has been
fraudulently used by Arsen Terzian, aka Steven Terzaki, whose
offense conduct is described in the concurrently submitted
complaint and affidavit for a warrant for his arrest. (See
Exhibit A.)
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Suite 102#B, Granada Hills, CA,” account ending in 1844 (the
“USB 1844”). The statement showed a beginning balance of
$48,954 and a deposit of $490,000 on August 13, 2024.
e. I obtained genuine bank statements from US Bank
for the USB 1844. I learned the following:
i. STAVROS opened the account on August 17,
2020, using is true Social Security number and date of birth.
His signature matches that of his driver’s license. The account
was opened around the same time as that of several other shells
(or, in this case and in F.N.’s case, individually but,
similarly, at the direction of MCGRAYAN).
ii. For the same period (July 13 through August
13, 2024), the genuine statement showed a deposit on August 13
for “90,000,” (the genuine statement did not have a “dollar”
sign directly in front of that number). The statement that had
been provided to FIBI in support of the PLP request showed a
deposit on the same date of “490,000,” evidencing that a
fabricated statement had been provided to FIBI. The fabricated
statement (on the left) and the genuine statement (on the right)
are compared below:
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M. SUBJECTS MCGRAYAN and MUSAYELYAN: False Claim, Wire
Fraud, and Money Laundering re GUM EIDL
77. I have probable cause to believe that MCGRAYAN and
MUSAYELYAN schemed to defraud the SBA through fraudulent
representations and fraudulent documents to obtain an EIDL on
behalf of MUSAYELYAN’s shell, GUM, the same shell that was three
years later involved in the GDI PLP fraud, and then laundered
the proceeds in an identical manner.
78. I reviewed SBA files for the GUM EIDL and learned the
following:
a. On March 30, 2020, within a week of the
nationwide Covid-19 lockdown, a EIDL application for $139,000
was submitted for GUM.
b. Like substantially all of the hundreds of EIDL
files I have reviewed, the application was submitted via SBA’s
online portal. The application identified MUSAYELYAN as the
applicant’s contact and stated that he was GUM’s “CEO,” that GUM
was engaged in “retail” business activity, and that MUSAYELYAN
was GUM’s “100%” owner. The application further provided
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MUSAYELYAN’s true date of birth, Social Security number, and the
same residence address to which the GUM PLP loan proceeds were
mailed years later, as described above.
c. The EIDL application claimed that GUM was
established in 2008, that its 2019 gross revenues were $845,000,
and that the EIDL proceeds should be wire-transferred to a JPMC
account ending in 8927 (the “JPMC 8927”).
d. A person who identified himself as MUSAYLEYAN
signed the standard form Loan Authorization and Agreement
(“LA&A”) via the DocuSign online authentication platform on May
30, 2020, in which he represented that GUM would, in pertinent
part, “use all the proceeds of this [l]oan solely as working
capital to alleviate economic injury caused by disaster
occurring in the month of January 31, 2020[.]”
e. I obtained from JPMC via subpoena, and reviewed,
genuine records for the JPMC 8927 and learned the following:
i. The GUM EIDL proceeds ($138,900, net of
fees) were deposited into that account on June 8, 2020, as shown
by this excerpt from a genuine account statement:
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f. The beginning balance for that period (May 30 to
June 20, 2020), shown above, was $17,633. The balance beyond
the deposit of the EIDL proceeds substantially consisted of
deposits of electronic checks from a variety of the same shells
that I have observed were the payors and payees of hundreds of
instances of money laundering “layering” throughout this case.
Below is a sampling of the deposited checks from shells:
g. Many of the deposits were in odd amounts within
$1,000 or so, or less, of $10,000, indicating, based on my
training and experience, that the parties to the transactions
broke up the deposits to avoid reporting the transactions to the
IRS.
h. Consistent with the numerous other money
laundering/layering transactions described in this affidavit,
substantially all of the EIDL proceeds were laundered by online
withdrawal transfers to accounts in the names of other shells,
as shown by an excerpt of the JPMC 8927 statement for the period
in which the EIDL proceeds were deposited:
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79. None of the transfers either into or out of this
account, both before credit for the EIDL proceeds or after, were
consistent with the required use “solely as working capital to
alleviate economic injury caused by disaster occurring in the
month of January 31, 2020[.]”
N. SUBJECT MUSAYELYAN: False Claim, Wire Fraud, and Money
Laundering re Personal EIDL
80. On June 30, 2020, an EIDL application for $150,000
was submitted for MUSAYELYAN doing business as “Global Ultimate
Systems” (the “GUS EIDL”). The application was submitted via
SBA’s online portal. The application identified MUSAYELYAN as
the applicant’s contact by his phone number at the same
residence address for MUSAYELYAN for the GUM EIDL, described
above. The application further stated that GUS was a sole
proprietorship of MUSAYELYAN, that GUS was established in 2018,
and that its 2019 gross revenues were $1,258,900.
81. The GUS EIDL was funded on July 2020 for $149,900
(net of $100 fees). I reviewed US Bank records for an account
ending in 4221 (the “USB 4221”) and learned the following:
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a. MUSAYELYAN was the sole signatory and
electronically opened the account September 2018.
b. The EIDL proceeds were deposited into the USB
4221 Account on July 27, 2020. The preceding balance was
$11,723.
c. Approximately $120,000 in checks were written
against the USB 4221 Account within 60 days of the EIDL deposit,
including nearly $80,000 within less than 30 days, many in odd
amounts just under $10,000. These checks were, as I have
observed in several other accounts as part of this
investigation, consistent with the intent to structure. Other
deposits were substantially de minimus and not consistent with
regular business income.
82. I know from my training and experience that EIDL
borrowers frequently sought EIDL modifications to obtain more
money related to the same business and based on the initial EIDL
application’s representations. While initial EIDLs were
approved primarily on the basis of information stated by the
borrower or borrower’s authorized representative, the SBA
required that EIDL modification applicants provide more
information and documentation to support their applications.
Such documents commonly included government-issued
identification documents and documents to verify income or
financial condition such as genuine federal income tax returns.
83. In October 2021, an application was submitted to
increase (modify) the GUS EIDL by $788,800. The SBA file for
the modification contained the following:
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a. Images of a driver’s license and passport for
MUSAYELYAN that I matched those identifiers in law enforcement
databases.
b. An SBA Form 413 “Personal Financial Statement”
that I am familiar with and I know was commonly required by SBA
for borrowers seeking EIDL modifications. Above the signature
that matched that of MUSAYELYAN’s driver’s license and passport,
and which stated his true Social Security number, the statement
claimed MUSAYELYAN’s annual salary was $229,434.
84. The Loan Agreement & Authorization (“LA&A”) for the
EIDL modification that was signed electronically by “Taron
MUSAYEYLAN” on January 5, 2022.
85. I know that the standard form “Rapid Finance
Application” for EIDLs includes a “Note” section that
chronologically logs activities by SBA representative, date, and
time status or progress of vetting an EIDL. The “Note” for the
GUS EIDL contained chronological entries for contacts between
the SBA and a person claiming to be MUSAYELYAN that indicated
that the SBA, as part of EIDL underwriting, emailed MUSAYELYAN
at the email account identified on the EIDL application a
request that he provide his 2018 and 2019 tax returns and that,
days later, the SBA received 2018 and 2019 tax returns in the
name of MUSAYELYAN.
86. The SBA’s file included what appeared to be
unsigned, “self-prepared” 2018 and 2019 calendar year federal
income tax returns for MUSAYELYAN, bearing MUSAYEYLAN’s true
Social Security number and residence address. Each return
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stated that MUSAYELYAN was engaged in “IT Consulting” under the
fictitious business name of GUS (as opposed to under a corporate
name), with his principal place of business as his true
residence, and that his gross receipts were $1,284,942 for 2019.
The return reported $70,841 in tax due and owing.
87. IRS transcripts show that MUSAYELYAN’s 2018 and 2019
tax returns that SBA received were filed in late 2021 and that
no income taxes were actually paid. Based on my training and
experience, and review of evidence gathered in this
investigation including that the MUSAYELYAN tax returns appear
to have been prepared in two days and solely because the SBA
required them for an EIDL modification, I believe that these
returns were false.
88. The GUS EIDL application identified a Wells Fargo
bank account ending in 2739 (the “WF 2739”) to receive the EIDL
modification proceeds. I reviewed records for the WF 2739 and
learned, among other things, that out of those proceeds $400,000
was transferred in days to a Wells Fargo account ending in 2532
in the name of “Taron Musayelyan DBA Global Ultimate
Management.” I reviewed the signature card for that account and
learned that MUSAYELYAN had opened that account with his genuine
Social Security number and date of birth, in a manner consistent
with that of the other SUBJECTS who opened shell accounts at
MCGRAYAN’s direction and solely to facilitate fraudulent loans
whose proceeds were laundered and not used as represented.
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O. SUBJECT VACHYAN: False Claim, Wire fraud, Bank Fraud
(PPPL only),and Money Laundering re “Art Mart” PPP and
EIDL
89. I have probable cause to believe that VACHYAN schemed
to defraud the SBA and a lender by making fraudulent statements
and submitting fraudulent documents to obtain a PPPL and EIDL
for a fake art dealer/shell called “Art Mart, Inc.” (“Art
Mart”). The proceeds of these fraudulently obtained loans were
deposited into an account controlled by VACHYAN and disbursed in
a manner consistent with that of the other shell accounts, thus
supporting probable cause to believe that VACHYAN fraudulently
participating in seeking the loans to launder their proceeds
instead of for legitimate business purposes.
90. The address for Art Mart that was provided on PPPL
and EIDL applications, discussed below, and on bank statements,
was 352 W Chevy Chase Dr Apt C, Glendale, CA 91204. I searched
online for a description of that property, and conducted a site
visit there, and observed that the property is a small, multi-
unit apartment building in a residential area. I saw nothing in
the nature of a “retail store [] that [according to the Internet
description at www.mapquest.com/us/california/art-mart-inc-
427506994, as of April 25, 2025] specializes in offering a wide
selection of art supplies and materials[.]”
91. SBA files and records that I reviewed from US Bank
show that, on June 5, 2020, an application was submitted for a
$494,677 PPPL in the name of “Art Mart, Inc. (”Art Mart”).
Twelve days later, an application was submitted for an EIDL in
the same name.
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92. The applications identified the same owner, VACHYAN,
and had the same address and the same contact information. The
PPPL application and promissory note that were submitted to
lender US Bank were e-signed by “Johan Vachyan” on June 9, 2020.
93. The PPPL application claimed that Art Mart was an
“art dealer” with “payroll” of 35 employees. The EIDL claimed
that Art Mart had 35 employees and 2019 gross revenue of $3.9
million.
94. The EIDL application designated a US Bank account
ending in 0638 (the “USB 0638”) to receive a wire transfer of
EIDL proceeds. I received and reviewed records of US Bank
obtained by subpoena and saw a signature card/account
application dated September 24, 2017, that identified VACHYAN as
the sole signatory and showed a signature that matches that of
his driver’s license. I also compared that signature card and,
in particular, VACHYAN’s signature on it, to two other US Bank
signature cards for US Bank accounts (the “USB 2692” and the
“USB 3955”) whose records were provided by US Bank along with
those of the 0638 Account. The USB 2692 signature card was for
a personal account for VACHYAN and his wife (whose identity and
marriage to VACHYAN I have verified from law enforcement
databases), opened in 2016, and identified VACHYAN by his true
date of birth and Social Security number and stated that he was
employed by “G&H Medical Transportation.” The signature card
for the USB 3955 identified VACHYAN as the “sole proprietor” of
“Mart Art and Antiques” and identified VACHYAN by his true
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Social Security number. The signatures on all three signature
cards appear to be written by one and the same person: VACHYAN.
95. I obtained EDD records and learned that Art Mart had
a single employee for a single quarter within the time period
stated in the EIDL and PPPL applications. I also obtained a
response from the IRS to a Fact of Filing request and learned
that Art Mart had never filed IRS Forms 941 or 940 to report
wages and taxes withheld for employees.
96. The PPPL application was approved and its proceeds,
$494,677, were deposited into the USB 0638 Account on June 9,
2020. I reviewed the USB 0638 records to trace the use of PPP
proceeds and learned the following:
a. There were numerous checks bearing a signature
that matched that of VACHYAN’s driver’s license and the
signature card for the account. None of the checks was
consistent with that of paying for payroll of 35 employees as
represented on the Art Mart EIDL, as described above.
b. Instead, the numerous checks were in the
thousands, with no evidence of deduction for withholding or
payment of payroll taxes, including checks dated June 10 and 11,
2020, for $17,100 and $16,900, respectively, to H.G.; June 12
and 13, 2020 for $17,800 and $21,000, respectively, to I.T.
(whom I have determined to be a neighbor of SHAW and to whom
SHAW wrote checks to be laundered from fraudulent loan
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proceeds 14); June 10, 2020, for $29,310 to “Swift Vending LLC,” a
purported entity that I believe was a shell; June 13 and 14,
2020, for $9,768 and $9,600, respectively, to A.M. and A.K.,
amounts that, as described above, are consistent with
structuring; and June 24, 2020, for $19,600 to SHAW, about whom
I have found no evidence that he was either an artist whose
works were marketed by Art Mart or that he was employed by Art
Mart.
97. I reviewed federal income tax returns obtained from
L.F. by subpoena. L.F. was a tax preparer who provided copies
of the returns that he prepared for numerous shells identified
in this affidavit, including Art Mart. I specifically reviewed
the Art Mart federal income tax return for calendar year 2019
that L.F. provided and observed that the return reported gross
income of $85,226 for 2019. The return also reported nothing
for the cost of labor (i.e., payroll).
98. In August 2021, a PPP forgiveness application was
submitted under the electronic signature of VACHYAN. The
forgiveness application stated that Art Mart paid 35 employees
from the time of the deposit of the PPPL proceeds to October 31,
2020, and that Art Mart had 38 employees as of August 2021 for
$856,451 “payroll and non-payroll costs.” As stated above,
there does not appear to be any legitimate evidence (e.g., EDD
SHAW’s related offense conduct is described in the
14
concurrently submitted complaint and affidavit against SHAW and
others for fraud in connection with pandemic stimulus
applications.
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or IRS records) for payroll expenses that were claimed in the
forgiveness application. 15
P. SUBJECT NIKOGOSYAN: False Claim, Wire Fraud, and Money
Laundering re “CM” EIDL
99. I have probable cause to believe that NIKOGOSYAN
knowingly participated in obtaining and then laundering the
proceeds of more than $2 million in EIDL funding by, among other
things, submitting phony tax returns prepared solely to obtain
funds for a shell called “CM General Auto Electric Supplies,
Inc.” (“CM”).
100. On March 30, 2020, days after the Covid-19 lockdown
commenced, an EIDL application was submitted online on behalf of
CM. NIKOGOSYAN was identified as CM’s sole owner, including by
his then true (per law enforcement databases) residence address,
correct Social Security number, and date of birth. The
application stated that CM was opened in 2012, had “1” employee,
and that its 2019 gross revenue was $929,000.
101. In connection with evaluating CM’s EIDL, SBA sought
and received an email in May 2020 from an individual who
identified himself as NIKOGOSYAN and provided what I believe,
from law enforcement databases, was a copy of his Permanent
Resident (“Green”) card. Law enforcement databases that I have
15Because I have probable cause to believe that MCGRAYAN
and VACHYAN defrauded USB and the SBA by way of fraudulent
statements, I have not discussed the use of proceeds. I
reviewed the bank statements showing the use and tracing of
those proceeds and have probable cause to believe, as I have
discussed several times herein, that those accounts show misuse
and laundering of those proceeds.
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checked have no record that NIKOGOSYAN reported that his Green
card was lost, stolen, or misused.
102. In early 2022, NIKOGOSYAN requested an EIDL
modification on behalf of CM, to increase its EIDL by more than
$1.5 million. The “Note” section on the EIDL modification
application indicated that the process lasted several months, in
part based on the time taken to respond to the SBA’s request for
documents to support the modification request.
103. Among other requests as reflected in the EIDL
application “note” section, the SBA requested and received
copies of NIKOGOSYAN’s driver’s license and Social Security
card, both of which I believe, based on my review of law
enforcement databases, were genuine.
104. The SBA further requested that CM submit tax returns
including for the calendar year 2021. I reviewed a copy of that
return that was submitted on behalf of CM and noted the
following:
a. The return was prepared by A.M.
b. A.M. dated the return “03-09-2023.” I know from
interviewing A.M. that he said that his custom and practice was
that he dated returns the same date that he completed them and
the client signed them. Thus, this return was untimely.
c. Moreover, as A.M. had said that his MCGRAYAN
Clients included NIKOGOSYAN, this return, like all others, was
prepared at MCGRAYAN’s and NIKOGOSYAN’s request solely to
support a loan application.
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105. A.M. had also provided documents in connection with
his interview. Those documents included photocopies of
NIKOGOSYAN’s driver’s license and Social Security card because,
as A.M. stated, he needed to verify the identity of his clients
if they intended to sign their returns via DocuSign. The 2021
CM return in the SBA file, described above, bears NIKOGOSYAN’s
DocuSigned signature. Those documents also included 2018 and
2019 CM tax returns that each bore NIKOGOSYAN’s live ink
signature. Copies of those returns were also provided to the
SBA in connection with vetting a CM EIDL modification. A.M.
confirmed that NIKOGOSYAN signed those returns in A.M.’s
presence along with standard IRS Forms 8879 that directed A.M.
to e-file those return. The 2018 and 2019 returns were
similarly untimely and, I believe, prepared solely to
fraudulently facilitate an EIDL modification. Each of those
returns, along with the 2021 returns, reported millions in
revenue and tens of thousands in taxes due and owing. According
to the IRS transcripts for those returns, found in the SBA file,
no taxes were paid.
Q. SUBJECT BORIS: False Claim, Wire Fraud, Bank Fraud,
and Money Laundering re “CP Mobile Mechanics” PPPL
106. I have probable cause to believe that BORIS
fraudulently schemed to obtain a $2 million PPPL and then
laundered those funds to conceal the fraud.
107. I reviewed SBA records and learned the following:
a. On March 30, 2020 an EIDL was applied for in the
name of “CP Mobile Mechanics Inc.” (“CPMM”). The application
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identified BORIS by his true date of birth and Social Security
number and as CPMM’s “CEO” and “100%” owner.
b. The EIDL application stated that CPMM’s gross
revenue for 2019 was $1,275,000.
c. The EIDL application identified a Bank of America
account ending in 3396 (the “BofA 3396”) for deposit of the EIDL
proceeds.
d. The EIDL “note” section shows an entry on May 19,
2020, that an individual on behalf of CPMM spoke to an SBA
representative. The individual verified that the EIDL
application was valid. The SBA representative advised that the
individual needed to provide a copy of his “US Permanent
Resident” card. I reviewed a U.S. “Permanent Resident” card in
the SBA records for this EIDL and I believe it to be genuine and
for BORIS.
e. That same day, an individual who identified
himself as BORIS electronically signed a standard EIDL LA&A on
behalf of CPMM and certified that CPMM would “use all the
proceeds of this [EIDL] solely as working capital to alleviate
economic injury caused by the [Covid-19 pandemic] occurring in
the month of January 31, 2020[.]”
f. On May 20, 2020, the day after SBA confirmed
BORIS’s identity via his Permanent Resident card, SBA wired
$143,900 to the BofA 3396.
g. I reviewed Bank of America records for the BofA
3396 and learned the following:
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i. The proceeds of the CPMM EIDL described
above were deposited into the BofA 3396 on May 20, 2020.
ii. Within about 60 days, substantially all of
the EIDL proceeds were withdrawn via checks payable to several
of the same shells described in this affidavit. I noted no
payments to automobile parts suppliers, for equipment,
utilities, or to individuals that appeared to be associated with
real mechanic work.
108. Sometime after CPMM obtained the initial EIDL
funding, CPMM sought two EIDL modifications that increased the
total amount of CPMM’s EIDL to just under $2 million:
a. On August 4,2021, an LA&A was e-signed by “Boris
Sahakyan” to increase the initial EIDL to $500,000. A net check
in the amount of $356,000 was wired to the BofA 3396 on August
16, 2021.
b. On October 27,2021, an LA&A was e-signed by
“Boris Sahakyan” to increase the EIDL to $1,970,000. A net
check in the amount of $1,470,800 was wired to the BofA 3396
Account on November 3, 2021.
c. As a condition to receiving the EIDL modification
funds, CPMM was required, among other things, to authorize SBA
to verify that CPMM had, in fact, filed federal income tax
returns. IRS transcripts that the SBA obtained showed that CPMM
untimely filed its 2019 calendar year federal income tax return
(on March 4, 2021). Based on my training and experience, and
the evidence gathered in this case, I have probable cause to
believe that the untimely filed return was filed solely to
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fraudulent obtain EIDL funding and not to comply with income tax
laws.
109. I obtained from JPMorgan Chase Bank, and reviewed,
records for a “second draw” PPP obtained by CPMM, and records
for an account ending in 8509 in the name of “CP Mobile
Mechanic, Inc.” (the “JPMC 8509”), and learned the following:
a. On March 24, 2021, an application was submitted
to JPMC for a “second draw” PPP on behalf of CPMM. I know that
a “second” or later draw PPP was similar to an EIDL modification
as later draws are provided to the same entity upon newly
established need. A “first draw” PPP had been authorized in
summer 2020 by Celtic Bank for a $23,437.50 PPP based on an
application e-signed by “Boris Sahakyan” as “president” of CPMM.
b. The “second draw” application was also e-signed
by “Boris Sahakyan” and sought $1,087,525 for “payroll costs”
for “35” employees. The application stated that CPMM had
$435,010 in monthly payroll costs as of February 4, 2021.
c. JPMC required that second draw PPP applicants
submit copies of their filed federal income tax returns. CPMM’s
2019 calendar year federal income tax return submitted to JPMC
reported 2019 calendar year gross revenue as $7,252,000 or about
five times the gross revenue that CPMM had reported to the IRS
on which the second EIDL modification was based, as described
above. To be clear, I believe there is probable cause to
believe both returns were fraudulent because the returns were
obtained solely to fraudulently facilitate loans.
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d. The JPMC 8509 into which the PPPL second draw
funds were deposited was opened on May 6, 2019, or about five
days after BORIS assumed the CPMM corporate shell and at a time
consistent with when other shell accounts were opened as
described herein.
e. The signature card/account application identified
BORIS by his true driver’s license and Social Security numbers
and bore what I believe was a live ink date and signature that
was consistent with that of BORIS’s signature on his driver’s
license.
f. Proceeds for the second draw PPP were deposited
into the JPMC 8509 on March 26, 2021. The prior balance was
$151,605, so I have traced the use of the proceeds on a “first-
in, first-out” basis that assumed that the prior balance was
from legitimate sources. There were three deposits that, based
on the totality of the evidence described in this affidavit, I
believe were deposited with the intent to be laundered. Namely,
there were three checks from shell “American Best Filter, Inc”
from an account whose signatory was SUBJECT DIAMONDZ (for
$9,000, $8,956, and $7,850) just days apart and clearly evidence
of intent to structure as well as to money launder, as shown by
these excerpts from those account records:
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g. Nonetheless, even by crediting those funds as
legitimate, substantially all of the PPPL second draw proceeds
were spent in approximately 60 days by withdrawals in the form
of checks or online transfers to the same bogus shell entities
as well as to SUBJECT MUSAYELYAN in the form of two $50,000 wire
transfers to SUBJECT MUSAYELYAN in Armenia notated as “software
technology expenses,” as shown by this excerpt from those
account records:
110. Finally, EDD records showed only “no record” for any
payroll paid by or for employees of either CPMM or BORIS for the
time period covered by the PPPL draws.
R. SUBJECT DIAMONDZ: False Claim, Wire Fraud, and Money
Laundering re “American Best Filter” EIDL
111. In addition to DIAMONDZ’s offense conduct relating
to the OAS PLP, described above, I have probable cause to
believe that DIAMONDZ schemed to commit wire fraud using the
same common plan for the other fraudulent activity described
herein, namely, by opening multiple bank accounts knowing that
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such accounts would be used to obtain loans and that such
accounts would be manipulated by others, by participating in
submitting fraudulent statements and documents to obtain an
EIDL, and then by laundering fraud proceeds through her multiple
accounts.
112. I reviewed SBA records and learned the following:
a. On June 16, 2020, an EIDL application was
submitted online on behalf of “American Best Filter, Inc.”
(“ABF”), approximately three years before ABF (and DIAMONDZ)
were associated with the fraudulent PLP transaction described
above. The application identified ABF’s “business phone” as
matching that on a JPMC account signature card for the first of
multiple bank accounts that DIAMONDZ had just opened (as more
fully described below). The EIDL application also provided the
same business address for ABF on each of the signature cards for
those bank accounts (and that matched that of DIAMONDZ’s
residence address on her driver’s license).
b. The application stated that DIAMONDZ took over
ownership of ABF on “1/1/2019,” that there was “1” employee for
this “retail” business, and that ABF’s 2019 gross revenue was
“$1,321,365.” Based on the totality of the evidence that I have
reviewed in this case, including ABF’s bank records, discussed
below, and the file regarding the ABF PLP, discussed above, I
believe that the gross revenue figure provided on the EIDL
application was fraudulent and that ABF was simply a shell
designed to defraud and launder money.
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c. The LA&A and EIDL promissory note were e-signed
by “Mery Diamondz” on June 24, 2020. The LA&A, like all others
during this time period, required that “[b]orrower will use all
the proceeds of this Loan solely as working capital to alleviate
economic injury caused by disaster occurring in the month of
January 31, 2020[.]”
d. SBA approved the ABF EIDL and funded it in the
amount of $149,900 on June 24, 2020. The proceeds were wire-
transferred to a JPMC account ending in 0831 (the “JPMC 0831”).
I reviewed the records for that account and learned that:
i. from the time of its opening (March 2020) to
the date of the EIDL proceeds’ deposit, the account was used,
like all other shells, to move money between shells based on the
timing, means of deposit, and other substantial similarities in
the accounts’ transactions;
ii. substantially all of the ABF EIDL proceeds
were transferred out for laundering through other shell
accounts, and
iii. none of the EIDL proceeds was used as
represented or intended, i.e., for “working capital” for ABF.
113. I reviewed bank records that show that DIAMONDZ
began her participation in the above-described fraudulent scheme
in substantially the same manner as other shell “owners,” by
opening multiple bank accounts at about the same time in the
name of her shell, ABF:
a. On March 23, 2020, less than two weeks after the
Covid-19 lockdown commenced, DIAMONDZ opened JPMC account ending
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in 0831 in the name of ABF (“JPMC 0831”). The signature card
stated ABF’s EIN as 84-3484169, which I know from reviewing an
EIN origination schedule provided to me by a co-case agent, was
obtained between May 13, 2019, and March 20, 2020, listed
DIAMONDZ’s then residence (per her driver’s license) as ABF’s
business address, identified DIAMONDZ as ABF’s “president,” and
contained her true Social Security number and a signature that I
believe matches that of her genuine driver’s license.
b. The next day, DIAMONDZ opened Bank of the West
account ending in 2534 at a branch in Encino, also in the name
of ABF, at the same address she had provided the day before to
JPMC at a bank branch also located in Encino, by providing her
true date of birth, and Social Security and driver’s license
numbers, and with a signature that I believe matches that of
both her driver’s license and the JPMC signature card, above.
c. On May 5, 2020, DIAMONDZ opened Wells Fargo
account ending in 7536 in the name of ABF (the “WF 7536”), using
the same address, identifying herself as the “owner with control
of the entity,” claiming $100k as ABF’s “annual gross sales”
from “administrative, support, waste management and remediation
services” and “water filtering and clean up,” by providing her
true date of birth, Social Security number, and driver’s license
number; and with a signature that I believe matches that of the
other signature cards, above, and her driver’s license.
d. On May 12, 2020, DIAMONDZ signed a signature card
for a personal Bank of America account ending in 1383 in her
alias name, DIAMONDZ, and also stating her given name, Mery
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Babayan, by providing her true Social Security number. The
signature card appeared to be an update as the records for the
same account contained multiple signature cards dating back to
the opening of the account in 2015. One such update was dated
February 23, 2017, contained her signature that I believe
matches that of all other signature cards, discussed above, and
stated that her identity was confirmed by “US DRIVER LICENSE
W/PHOTO.”
e. On July 24, 2020, DIAMONDZ opened BBVA (later
owned by PNC) bank account ending in 4277 in the name of ABF.
The signature card contains the same EIN but no personal
identifying information for DIAMONDZ. It does contain a
signature which I believe matches that of all other signature
cards and her driver’s license, discussed above.
f. Each of these accounts was used to moved shell
account funds like the other shell accounts described herein.
For example, the initial deposits into the WF 7536 consisted of
two “Edeposit(s)” in amounts that I believe were consistent with
that from shell accounts, as shown by this excerpt of the May
2020 WF 7536 statement:
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114. My belief is supported not only by the totality of
evidence of similar activity in other shell accounts, some of
which is described above, but by the use of the WF 7536 account
the very next month to launder funds to those same shell
entities, as shown the following excerpt of the June 2020 WF
7536 statement, and because the account went substantially
dormant the next month (July 2020):
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V. ADDITIONAL PROBABLE CAUSE IN SUPPORT OF REQUEST FOR ISSUANCE
OF SEARCH WARRANTS
A. MCGRAYAN Resides and Does Business at the SUBJECT
PREMISES
115. Queries in law enforcement databases revealed that
MCGRAYAN resides at the SUBJECT PREMISES, including that his
driver’s license identifies the SUBJECT PREMISES as MCGRAYAN’s
residence. On April 29, 2025, I conducted surveillance of the
SUBJECT PREMISES and saw a Lexus parked in the driveway of the
SUBJECT PREMISES within approximately 15 feet of the front door
of that residence. IRS-CI SA Geff Clark told me that he
conducted surveillance of the SUBJECT PREMISES on April 28,
2025, and saw the same Lexus at the same location and noted its
California license, no. 9LEV135. A query of that license number
in law enforcement databases revealed that the vehicle is
registered to MCGRAYAN at the SUBJECT PREMISES.
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116. I reviewed a March 12, 2025 Statement of Information
that was submitted online to the California Secretary of State
that identified MCGRAYAN as the CEO of Exceed Companies whose
“principal” and “mailing” address was the SUBJECT PREMISES.
117. I reviewed an SBA application for a disaster loan
that was submitted on January 10, 2025, for benefits related to
the Los Angeles county fires under the name of Exceed Companies
LLC and e-signed by “William Mcgrayan.” The e-signature was
verified by the Docusign authentication platform as that of
MCGRAYAN. I used an open-source IP address lookup and
geolocator platform to determine the location of the IP address
on the Docusigned SBA application. The location was identified
as “Tujunga canyon” whose geo-coordinates approximate those of
the SUBJECT PREMISES. The application listed the SUBJECT
PREMISES as MCGRAYAN’s mailing address. The application also
listed two phone numbers, which I know from searching law
enforcement databases are cellular (mobile) phone numbers: (818)
730-7570 and (818) 570-9030. Open sources show that the latter
number was subscribed to by “Annie Mcgrayan” and was the office
number for Exceed Companies, which I know from public records
was the LLC owned by MCGRAYAN and that was involved in the
fraudulent PLP transactions described above. Open sources show
that the former number is for Annie Mcgrayan, aka Ani Ghazaryan,
whom I know from law enforcement databases to be related to
MCGRAYAN and who also resides at the SUBJECT PREMISES.
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B. Training and Experience Regarding the Offense Conduct
118. Based on my training and experience, and information
obtained from other law enforcement personnel who investigate 18
U.S.C. §§ 286/287 (conspiracy to defraud the government with
respect to claims/make false claims), 1343 (wire fraud), 1344
(bank fraud), 1956(h) (money laundering conspiracy), 1956(a)(1)
et seq. (money laundering), 1957 (engaging in monetary
transactions in property derived from specified unlawful
activity), and/or 31 U.S.C. §§ 5313, 5324 (structuring), I know
the following:
a. Individuals involved in committing such offenses
must keep evidence of their crimes, such as accounts used in the
scheme, simply to keep the scheme going. Much of this evidence
is now stored on digital devices such as computers and
smartphones.
b. Generally, perpetrators of fraud schemes maintain
the evidence described above where it is close at hand and safe,
such as in their residences, automobiles, and, especially with
smartphones, on their person. My training and experience is
further informed by the statements of F.N., some of which are
described above, including that F.N. went to the SUBJECT
PREMISES to deliver blank shell account checks to MCGRAYAN.
c. Members of a fraud conspiracies or schemes must
communicate with one another out of necessity. Commonly this is
done by text, email, telephone, or specialty communication
application, often an encrypted one such as WhatsApp, as
specifically discussed above, and most often by smartphone.
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Members of the scheme commonly carry their smartphones, which
include the contact information for their co-schemers, on or
near their persons, such as in their cars or residences.
VI. TRAINING AND EXPERIENCE ON DIGITAL DEVICES 16
116. Based on my training, experience, and information
from those involved in the forensic examination of digital
devices, I know that the electronic evidence, inter alia,
described below, is often retrievable from digital devices.
117. Forensic methods may uncover electronic files or
remnants of such files months or even years after the files have
been downloaded, deleted, or viewed via the Internet. Normally,
when a person deletes a file on a computer, the data contained
in the file does not disappear; rather, the data remain on the
hard drive until overwritten by new data, which may only occur
after a long period of time. Similarly, files viewed on the
Internet are often automatically downloaded into a temporary
directory or cache that are only overwritten as they are
replaced with more recently downloaded or viewed content and may
also be recoverable months or years later.
118. Digital devices often contain electronic evidence
related to a crime, the device’s user, or the existence of
As used herein, the term “digital device” includes any
16
electronic system or device capable of storing or processing
data in digital form, including central processing units;
desktop, laptop, notebook, and tablet computers; personal
digital assistants; wireless communication devices, such as
paging devices, mobile telephones, and smart phones; digital
cameras; gaming consoles; peripheral input/output devices, such
as keyboards, printers, scanners, monitors, and drives; related
communications devices, such as modems, routers, cables, and
connections; storage media; and security devices.
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evidence in other locations, such as, how the device has been
used, what it has been used for, who has used it, and who has
been responsible for creating or maintaining records, documents,
programs, applications, and materials on the device. That
evidence is often stored in logs and other artifacts that are
not kept in places where the user stores files, and in places
where the user may be unaware of them. For example, recoverable
data can include evidence of deleted or edited files; recently
used tasks and processes; online nicknames and passwords in the
form of configuration data stored by browser, e-mail, and chat
programs; attachment of other devices; times the device was in
use; and file creation dates and sequence.
119. The absence of data on a digital device may be
evidence of how the device was used, what it was used for, and
who used it. For example, showing the absence of certain
software on a device may be necessary to rebut a claim that the
device was being controlled remotely by such software.
120. Digital device users can also attempt to conceal
data by using encryption, steganography, or by using misleading
filenames and extensions. Digital devices may also contain
“booby traps” that destroy or alter data if certain procedures
are not scrupulously followed. Law enforcement continuously
develops and acquires new methods of decryption, even for
devices or data that cannot currently be decrypted.
121. Based on my training, experience, and information
from those involved in the forensic examination of digital
devices, I know that it is not always possible to search devices
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for data during a search of the premises for a number of
reasons, including the following:
122. Digital data are particularly vulnerable to
inadvertent or intentional modification or destruction. Thus,
often a controlled environment with specially trained personnel
may be necessary to maintain the integrity of and to conduct a
complete and accurate analysis of data on digital devices, which
may take substantial time, particularly as to the categories of
electronic evidence referenced above. Also, there are now so
many types of digital devices and programs that it is difficult
to bring to a search site all of the specialized manuals,
equipment, and personnel that may be required.
123. Digital devices capable of storing multiple
gigabytes are now commonplace. As an example of the amount of
data this equates to, one gigabyte can store close to 19,000
average file size (300kb) Word documents, or 614 photos with an
average size of 1.5MB.
124. This search warrant requests authorization to use
the biometric unlock features of a device, based on the
following, which I know from my training, experience, and review
of publicly available materials:
125. Users may enable a biometric unlock function on some
digital devices. To use this function, a user generally
displays a physical feature, such as a fingerprint, face, or
eye, and the device will automatically unlock if that physical
feature matches one the user has stored on the device. To
unlock a device enabled with a fingerprint unlock function, a
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user places one or more of the user’s fingers on a device’s
fingerprint scanner for approximately one second. To unlock a
device enabled with a facial, retina, or iris recognition
function, the user holds the device in front of the user’s face
with the user’s eyes open for approximately one second.
126. In some circumstances, a biometric unlock function
will not unlock a device even if enabled, such as when a device
has been restarted or inactive, has not been unlocked for a
certain period of time (often 48 hours or less), or after a
certain number of unsuccessful unlock attempts. Thus, the
opportunity to use a biometric unlock function even on an
enabled device may exist for only a short time. I do not know
the passcodes of the devices likely to be found in the search.
127. Thus, the warrant I am applying for would permit law
enforcement personnel to, with respect to any device that
appears to have a biometric sensor and falls within the scope of
the warrant: (1) depress MCGRAYAN’s thumb and/or fingers on the
device(s); and (2) hold the device(s) in front of MCGRAYAN’s
face with his eyes open to activate the facial-, iris-, and/or
retina-recognition feature.
128. Other than what has been described herein, to my
knowledge, the United States has not attempted to obtain this
data by other means.
VII. CONCLUSION
119. For all the reasons described above, there is
probable cause to believe that VAHE MARGARYAN, AKA WILLIAM
MCGRAYAN; SARKIS SARKISYAN, AKA SAMUEL SHAW; AKSEL MARKARYAN,
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AKA AXEL MARK; ASHOT BEJANYAN, AKA ALEX BENJAMIN; JACK AYDINIAN,
AKA JACK AYDI; TARON MUSAYELYAN, AKA TEYRON MUSEYELYAN; HOVANNES
HOVANNISYAN, AKA JOHN HARVARD; MERY BABAYAN, AKA MERY DIAMONDZ;
ANAHIT SAHAKYAN; FELIX PARKER; RUDIK YENGIBARYAN, AKA SAMUEL
STAVROS, YOHAN VACHYAN, AKA JOHAN VACHYAN, AKA JOHN VACHYAN,
KHACHATUR NIKOGHOSYAN, AND BORIS SAHAKYAN committed violations
of 18 U.S.C. §§ 286/287 (conspiracy to defraud the government
with respect to claims/make false claims), 1343 (wire fraud),
1344 (bank fraud), 1956(h) (money laundering conspiracy),
1956(a) (1) et seg. (money laundering), 1957 (engaging in
monetary transactions in property derived from specified
unlawful activity), and/or 31 U.S.C. §§ 5313, 5324 (structuring)
and that evidence of such violations, as described above and in
Attachment B of this affidavit, will be found in a search of the
SUBJECT PERSON and SUBJECT PREMISES, as further described above
and in Attachments A-1 and A-2 of this affidavit.
Attested to by the applicant in
accordance with the requirements
of Fed. R. Crim. P. 4.1
by telephone on this 23rd day of
May, 2025.
HONORABLE PATRICIA DONAHUE
UNITED STATES MAGISTRATE JUDGE
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ATTACHMENT A (SARKISYAN et al Affidavit)
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Contents
I. INTRODUCTION..........................................3
II. PURPOSE OF AFFIDAVIT..................................4
III. SUMMARY OF PROBABLE CAUSE.............................7
IV. PROBABLE CAUSE........................................7
A. The Paycheck Protection Program..................7
B. The Economic Injury Disaster Loan Program........9
C. PPPL Forgiveness................................11
D. Restaurant Revitalization Fund Grants...........12
E. SUBJECT SHAW: Wire Fraud, Bank Fraud, and Money
Laundering re “Prime” PPPL......................13
1. SHAW’s Background..........................13
2. Offense Conduct re “Prime” PPPL............15
3. Wire Fraud re Prime’s PPPL Forgiveness
Application................................19
F. SUBJECT MIKHAELYAN: Wire Fraud, Bank Fraud, and
Money Laundering re “Cornwall” PPPL.............20
G. SUBJECT MIKHAELYAN: Wire Fraud and False Claim re
Cornwall EIDL...................................24
H. SUBJECTS MIKHAELYAN and YEMENEJIAN: Wire Fraud,
False Claim, and Money Laundering re “Nairi” RRF
................................................25
I. MIKHAELYAN: Wire Fraud and False Claim re “Rest”
EIDL Modification...............................28
J. SUBJECT YEMENEJIAN: Wire Fraud and False Claim re
“Tiny Tots” EIDL................................30
K. SUBJECT TERZYAN: Wire Fraud, False Claim, and
Money Laundering re “Grub House” EIDL and EIDL
Modification....................................34
L. SUBJECT TERZYAN: Wire Fraud, False Claim, and
Money Laundering re “Grub House” RRF............37
M. SUBJECT MARIANNA: Wire Fraud, False Claim, and
Money Laundering re “Rustwood” EIDL.............42
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N. SUBJECT MARIANNA: Wire Fraud and False Claim re
Personal EIDL...................................45
V. CONCLUSION...........................................47
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AFFIDAVIT
I, Eric Ley, being duly sworn, declare and state as
follows:
I. INTRODUCTION
1. I have been a federal agent for more than 12 years.
Since May 2021, I have been a Special Agent of the U.S. Small
Business Administration (“SBA”), Office of Inspector General
(“SBA-OIG”). Before that, I was a Special Agent with the United
States Secret Service for eight years.
2. Since graduating from the Criminal Investigator
Training Program conducted at the Federal Law Enforcement
Training Center, I have over ten years of experience
investigating various criminal offenses including bank fraud,
wire fraud, and money laundering. As such, I have interviewed
hundreds of witnesses and targets, participated in the execution
of numerous search and arrest warrants relating to financial
crimes, and worked with federal prosecutors to prepare
investigations for prosecution.
3. For the past four years, I have focused on
investigating crimes associated with SBA-related loan and
guarantee programs including pandemic stimulus funding,
sometimes referred to as Covid-19 fraud. From reviewing dozens
of pandemic stimulus loan files and documents associated with
those files such as subpoenaed bank records and public records,
I have become familiar with the processing and vetting of
applications under the Paycheck Protection and Economic Injury
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Disaster Loan programs, among other pandemic-related funding
programs.
4. Through my investigations, my training and experience,
and discussions with other law enforcement personnel, I have
become familiar with the tactics and methods employed by those
who conduct wire fraud schemes using fraudulent loan statements
and fabricated documents, money laundering, and identity theft,
among other federal offenses. These methods include, but are
not limited to, the use of wireless communications technology,
such as encrypted messaging platforms such as “WhatsApp;” the
creation or purchase of corporate “shells,” i.e., corporations
that have been formed through the filing of articles of
incorporation but conduct no business and are used solely to
create the appearance of legitimacy; fabricating bank statements
or other business documents to satisfy lender underwriting
requirements to qualify for loans; and moving funds through
multiple accounts to promote and conceal fraud.
II. PURPOSE OF AFFIDAVIT
5. This affidavit is made in support of a criminal
complaint against, and request for issuance of arrest warrants
for, the following individuals (also, where context requires, by
“SUBJECT [NAME],” or collectively, the “SUBJECTS”), for
violations of 18 U.S.C. §§ 286/287 (conspiracy to defraud the
government with respect to claims/make false claims), 1343 (wire
fraud), 1344 (bank fraud), 1956(h) (money laundering
conspiracy), 1956(a)(1) et seq. (money laundering), 1957
(engaging in monetary transactions in property derived from
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specified unlawful activity), and/or 31 U.S.C. §§ 5313, 5324
(structuring) (collectively, the “Subject Offenses”) as more
fully described below:
SARKIS SARKISYAN, AKA SAMUEL SHAW (“SHAW”);
MIKHAEL MIKHAELYAN (“MIKHAELYAN”);
ARSEN TERZYAN, AKA STEVEN TERZAKI (“TERZYAN”);
SARKIS YEMENEJIAN (“YEMENEJIAN”); and
MARIANNA SARKISYAN (“MARIANNA”).
6. The facts set forth in this affidavit are based on my
personal observations; my training and experience; witness
interviews that I have conducted; reports that I have read of
interviews conducted by other law enforcement agents; my review
of documents obtained from third parties, either by way of
subpoena or voluntary submission, such as bank or business
records; my review of publicly-filed documents such as corporate
filings; Internet searches for open source information;
financial analyses or financial records summaries prepared by a
SBA analyst who told me that she reviewed and prepared such
analyses and summaries from bank and other financial records
obtained in this investigation, and whom I believe to be
qualified to make such analyses and summaries from having worked
with her for several years and having reviewed her work product
in other matters; and my review of documents created or amassed
by the SBA in connection with providing funding for the various
loans and grants more fully described below. Accordingly,
absent mention below of specific attribution from any of the
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above-summarized evidence, I have, solely for clarity, generally
omitted attribution for a specific fact.
7. Whenever I refer herein to a bank, I mean a financial
institution whose deposits were insured by the Federal Deposit
Insurance Corporation. Whenever I refer herein to bank records,
I have done so by identifying each account by an abbreviation
for the bank followed by the account’s last four digits, e.g.,
“JPMC 1234.” Whenever I refer to the substance or content of
such accounts, such reference is based on my review of the
records of the account(s), including bank statements, signature
card/account application documents, canceled checks, offset and
credits, and other records provided by each bank pursuant to a
grand jury subpoena. Similarly, unless stated otherwise,
whenever I refer to records of or relating to the SBA, I am
referring to SBA records that I have reviewed as accessible to
me in my capacity as a Special Agent of the SBA-OIG.
8. My description of the offense conduct below is based
on my review of the above-summarized evidence and is provided
solely for the purpose of establishing probable cause to believe
that one or more of the above-stated offenses were committed by
the SUBJECTS. Accordingly, I have not described all of the
evidence that I have reviewed during the course of this
investigation and my omission of evidence or mention of other
subjects or targets of this investigation should be considered
in that light.
9. Unless stated otherwise, all conversations and
statements described in this affidavit are related in substance
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and/or in part only; all dates are “on or about” or
approximations; all amounts are rounded or close approximations;
and the words “on or about” and “approximately” are omitted for
clarity.
III. SUMMARY OF PROBABLE CAUSE
10. I have probable cause to believe that the SUBJECTS
committed the Subject Offenses by creating, purchasing, or using
corporations for use in name only, i.e., as “shells”; opening
and assisting others in opening one or more bank accounts in the
names of those shells; submitting and assisting others to submit
fraudulent applications to obtain millions of dollars in
pandemic stimulus funding; creating and submitting fake
documents in support of those fraudulent applications; and
laundering and directing others to launder the proceeds of such
funding through multiple bank accounts for, ultimately, personal
use.
IV. PROBABLE CAUSE
A. The Paycheck Protection Program
11. The Coronavirus Aid, Relief, and Economic Security
(“CARES”) Act was a federal law enacted in or about March 2020
that was designed to provide emergency financial assistance to
Americans suffering economic harm as a result of the COVID-19
pandemic. One form of assistance provided by the CARES Act was
the authorization of United States taxpayer funds in the form of
loans to small businesses for job retention and certain other
expenses, through a program referred to as the Paycheck
Protection Program (“PPP;” loans under that program are
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sometimes referred to herein as a “PPPL” or “PPPLs”). PPPL
proceeds were required to be used by the applicant business to
pay certain expenses such as payroll costs, interest on
mortgages, rent, and utilities.
12. In order to obtain a PPPL, a qualifying business was
required, among other things, to submit a PPPL application that
required the applicant business (through its authorized
representative) to acknowledge PPP program rules and make
certain affirmative certifications that the applicant business
would comply with all such rules to be eligible to obtain a
PPPL. Such certifications required, among other things, that
the applicant affirm that “[PPP] funds will be used to retain
workers and maintain payroll or make mortgage interest payments,
lease payments, and utility payments,” and that the “loan
proceeds will be used only for business-related purposes as
specified in the [PPPL application]” and consistent with PPP
rules. The authorized representative of the applicant was also
required to certify that “the information provided in th[e] PPP
application and the information provided in all supporting
documents and forms is true and accurate in material respects,”
and that “I understand that if the funds are knowingly used for
unauthorized purposes, the federal government may hold me
legally liable, such as for charges of fraud.”
13. A PPPL applicant’s representative was also required
to state, among other things, the applicant’s average monthly
payroll expenses and number of its employees. These figures
were used to calculate the amount of money that the business was
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eligible to receive under the PPP. In addition, the applicant’s
representative was required to provide documentation showing its
payroll expenses and such other documentation as the SBA or the
lender requested.
14. A PPPL application and supporting documents were
submitted online through a portal and processed by a
participating lender. The applicant’s representative confirmed
his/her true identity through a variety of means including
providing personal identifying information, uploading a copy of
that person’s driver’s license and/or Social Security card,
and/or executing loan documents via a document authentication
platform such as DocuSign. If a PPPL application was approved,
the participating lender would fund the PPPL using its own funds
and would wire-transfer those funds to a bank account designated
by the applicant. By wire-transferring the loan proceeds to
that designated account, the lender, the SBA and, ultimately,
law enforcement would have yet another way to ensure that the
application was sought by the stated applicant through his/her
duly acting representative and that the applicant received and
used those funds in accordance with PPP rules.
15. If PPP lending criteria were followed by the lender,
the SBA, in turn, guaranteed the borrower’s repayment in the
event of that borrower’s default.
B. The Economic Injury Disaster Loan Program
16. In addition to the PPP, the CARES Act authorized
taxpayer funds under the Economic Injury Disaster Loan program
(individually, an “EIDL,” or collectively, “EIDLs”). The EIDL
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program provided low-interest funding to small businesses,
renters, and homeowners affected by the COVID-19 pandemic.
17. In order to obtain an EIDL, a qualifying business was
required to submit an application to the SBA, typically through
an online portal, and provide information about its operations,
such as the nature of the applicant’s business, e.g.,
“agriculture,” the number of employees, and gross revenues for
the 12-month period preceding the Covid-19 pandemic. Like
PPPLs, EIDL applicants were required to certify that all
information in the application as provided by the applicant or
on behalf of the applicant by their authorized representative
was true and correct.
18. An EIDL “Loan Authorization and Agreement” (“LA&A”)
was executed by the applicant’s authorized representative as a
condition of receipt of EIDL proceeds that stated that. The
LA&A required that the applicant use the EIDL proceeds only for
purposes stated in EIDL rules, such as for employee payroll
expenses, employee sick leave, and business obligations and
expenses such as business debts, rent, and mortgage payments.
EIDL funds could not be used other than for those purposes,
including that such funds could not be deposited or held for
future business operations, used to capitalize a new business or
for business start-up expenses, or used for purposes not
associated with the operation of a going concern.
19. The amount of an EIDL was determined, in part, by the
applicant’s representations in the EIDL application about the
nature of the applicant’s business and the applicant’s
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statements about employees, and revenue. Any funds paid under
an EIDL were issued directly by the SBA from CARES Act
appropriations by Congress.
20. If the EIDL applicant also obtained a PPPL, EIDL
proceeds could not be used for the same purpose as the PPP loan
proceeds.
21. PPP and EIDL applicants were also obligated to
provide true and correct information in response to requests by
PPP lenders or the SBA as part of the PPPL and EIDL vetting
process, such as requests to clarify business ownership and
requests to provide genuine payroll tax documents such as IRS
Forms 940, 941, or W3 “Transmittal of Wage and Tax Statements.”
C. PPPL Forgiveness
22. Under certain circumstances, PPPL borrowers were
entitled to forgiveness of their PPP obligations. As a
condition of forgiveness, borrowers were required to complete a
“PPP Loan Forgiveness Application” on which their authorized
representative represented and certified that the borrower had
complied with all PPP rules “including the rules related to . .
. eligible uses of PPP loan proceeds[]” and that “[t]he
information provided in th[e forgiveness application was] true
and correct in all material respects.” The forgiveness
application warned that ”knowingly making a false statement to
obtain forgiveness was a federal crime, punishable by
imprisonment and/or a fine.”
23. I know from my training and experience, and from
evidence gathered in this case, that PPPL lenders and the SBA
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relied on an applicant’s truthfulness in statements made on
applications and related documents, and on the genuineness of
documents submitted by applicants in support of applications, to
determine whether to approve PPPLs or EIDLs.
D. Restaurant Revitalization Fund Grants
24. In March 2021, the American Rescue Plan Act became
law and established the Restaurant Revitalization Fund (“RRF”)
for which Congress appropriated $28.6 billion for the SBA to
award emergency assistance to qualifying businesses that served
food or drink, essentially restaurants. Entitlement was
substantially based on pandemic-caused revenue loss. The RRF
was a conditional grant program, meaning that RRF recipients
were not required to repay the funds so long as those funds were
used for specific expenses and by a certain deadline.
25. RRF applicants submitted personal and business
information, typically through an online SBA portal, in support
of each RRF application. Among other things, applicants were
required to list all owners of 20% or more of the business. The
listing for each owner required the owner’s Employer
Identification Number (“EIN”), Social Security number, or
“Individual Taxpayer Identification Number.”
26. The SBA prioritized RRF awards to small businesses at
least 51% owned and controlled by women, veterans, and/or the
socially and economically disadvantaged.
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27. RRF recipients were required to certify that they
would use RRF proceeds for normal business operations such as
for payroll costs, health care, business mortgages or rent.
Recipients were then required to submit a “post-award report” in
which they certified that their RRF proceeds were used in
compliance with the program.
E. SUBJECT SHAW: Wire Fraud, Bank Fraud, and Money
Laundering re “Prime” PPPL
1. SHAW’s Background
28. In 2011, SHAW, under his given name Sarkis
Gareginovich Sarkisyan, was convicted in Santa Clara Superior
Court, case no. B1151803, of unauthorized access to computers
(Cal.Pen.C. sec. 502(c)(1)), theft of credit card information
(Cal.Pen.C. sec. 484e), counterfeiting credit cards (Cal.Pen.C.
sec. 484i), and conspiracy (Cal.Pen.C. sec. 182). In 2023, SHAW
changed his name from Sarkis Gareginovich Sarkisyan to Samuel
SHAW. Genuine images of SHAW’S prior and latest driver’s
license are below:
29. SHAW is the brother-in-law of SUBJECTS MIKHAELYAN and
TERZYAN.
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30. SHAW has fraudulently claimed that he is the victim
of identity theft by lying about his income and employment to
obtain credit, failing to pay such debt, and then years later
claiming the debts were not his. I reviewed documents provided
by BMW Financial Services (“BMW”), and spoke with Homeland
Security Investigations analyst Michael Reid, and learned the
following:
a. In 2014, SHAW financed the purchase of a new BMW,
in connection with which he provided his true Social Security
number and listed his true residence address (the same address
that, as more fully discussed below, he provided in connection
with several fraudulent loan applications). He claimed an
annual salary of $876,000 as an employee of “Nairi Restaurant”
(a business for which, as more fully discussed below, SHAW’s
brother-in-law, MIKAELYAN, and another SUBJECT, YEMENEJIAN,
fraudulently obtained an RRF and by which SHAW was never
employed). I know from other documents in this case, also more
fully discussed below, that SHAW during that same time period
(2012 to 2020) fraudulently claimed that he was an “IT
Specialist.”
b. SHAW paid loan installments on the BMW loan for
approximately five years from a bank account that he controlled.
c. In 2018, SHAW submitted a report under penalty of
perjury to the Federal Trade Commission that he was the victim
of identity theft with respect to the BMW loan and other debts.
d. SHAW then sent a letter to Equifax (a credit
reporting agency) in which he claimed that he was the victim of
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identity theft relating to credit accounts (e.g., Macy’s and
Bloomingdale’s). Attached to SHAW’s letter to Equifax was what
appeared to be a Long Beach Police Department (“LBPD”) report
that indicated that SHAW had reported his identity theft to
LBPD. The report indicated that SHAW provided to LBPD the same
purportedly misused credit accounts, including BMW (an account
on which SHAW had paid installments for several years before
claiming that his identity was stolen).
e. HSI Analyst Reid told me that he provided LBPD a
copy of the purported LBPD report that SHAW had sent to Equifax.
An LBPD employee responded that the purported report that SHAW
had sent to Equifax was fake as the LBPD number on the purported
report did not match the genuine report number in LBPD’s files
and that the purported report appeared to have been altered.
2. Offense Conduct re “Prime” PPPL
31. Prime Funding, Inc. (“Prime”) was incorporated in
2018 and, in January 2021, its business address was updated in
California corporation records to 7011 Liberty Drive, Van Nuys,
CA (the “Liberty Address”), an address that I know from SHAW’s
driver’s license and other sources to be SHAW’s personal
residence at all times relevant to this affidavit.
32. Three months later, in April 2021, an application was
submitted online for a PPPL on behalf of Prime. The application
identified SHAW as Prime’s authorized representative and
contained SHAW’s driver’s license, Social Security number, and
the Liberty Address. The stated reason for the PPPL was to
cover Prime’s payroll costs for 57 employees at an average
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monthly payroll of $314,583. The applicant submitted what
appeared to be genuine Internal Revenue Service (“IRS”) Forms
941 (quarterly payroll tax returns) that identified the Liberty
Address as Prime’s business address.
33. I reviewed a response from the IRS pursuant to a law
enforcement “Fact of Filing” request that is commonly used in
these investigations to determine if IRS-related documents were
actually filed with the IRS. I learned that none of the Forms
941 submitted on behalf of Prime in connection with the PPPL was
actually filed with the IRS.
34. I also know from my training and experience that the
California Employment Development Department (“EDD”) maintains
records of wages paid to employees. I reviewed EDD records for
Prime and learned that Prime had never reported the payment of
any wages.
35. The applicant for the Prime PPPL also provided as
part of the PPP underwriting process what purported to be
payroll reports prepared by a third-party payroll processor
called “Paylocity,” an entity that I know to be similar to
payroll processor ADP. The reports listed 56 names of
individuals who were purportedly employed by Prime with titles
like “customer service,” “sales,” or “admin.” I received
information from Paylocity that Paylocity never did any payroll
work for Prime and that the reports were fake. Below is an
image of one such report, showing gross wages of $1,539,526,
that was submitted by the applicant for the Prime PPP:
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36. The applicant for the Prime PPPL designated a
JPMorgan Chase Bank (“JPMC”) account ending in 6026 (the “JPMC
6026”) to receive the proceeds of Prime’s PPPL. I know that
PPPL, EIDL, and RRF applicants were required to designate a bank
account to which funds would be wire-transferred to the
applicant.
37. An individual identifying himself as SHAW
electronically, via the DocuSign authentication platform,
acknowledged and then electronically transmitted to the lender,
JPMorgan Chase, a standard form PPPL certification that stated,
among other things, that PPPL proceeds would solely be used by
Prime to retain employees and for certain of its business
expenses.
38. Prime’s PPPL was approved and funded by JPMorgan
Chase in April 2021, for $786,457, with a wire transfer in that
amount. I reviewed bank records for JPMC 6026 that showed the
wire-transfer deposit of the Prime PPPL proceeds, and learned
the following:
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a. The balance in the JPMC 6026 was $173 before the
PPP proceeds were deposited.
b. SHAW was the sole signatory on the 6026 Account.
The signature card/account application identified SHAW by his
true name, Social Security number, and date of birth. His
signature matched that of his driver’ license.
c. Within six weeks of the deposit, substantially
all of the Prime PPPL proceeds were withdrawn or transferred out
of the account.
d. SHAW made more than $50,000 in cash withdrawals
from the JPMC 6026 following the PPPL proceeds deposit,
including four such withdrawals just under $10,000. Based on my
training and experience, I believe that those transactions
indicated that transactions were structured to ensure that the
bank did not submit Currency Transaction Reports to the U.S.
Treasury Department. 1
e. There were no payments to any payroll company for
Prime, nor were there any checks or transfers to any of the
1 The following legal authority was provided by the AUSA:
Federal law requires banks and other financial institutions
to file reports with the Secretary of the Treasury whenever they
are involved in a cash transaction or exchange of currency that
exceeds $10,000. “A person who willfully violates this law is
subject to criminal penalties.” 31 U.S.C. §§ 5313, 5324; 31 CFR
§ 103.22(a),(b)(2006 Ed.); Ratzlaf v. United States, 510 U.S.
135, 136 (1994); see also, United States v. Turner, 400 F.3d
491, 497 (7th Cir. 2005)(in case charging conspiracy to launder
money, “we know that certain types of transactions may be
indicative of a design to conceal. These include transactions
surrounded in unusual secrecy, structured transactions,
depositing ill-gotten funds into another’s bank accounts, using
third parties to conceal the real owner, or engaging in unusual
financial moves which culminate in a transaction.”).
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names of purported Prime employees listed on the “Paylocity”
reports.
f. Out of PPPL proceeds, SHAW wrote a $49,569 check
(the signature on the check matches that of SHAW’s driver’s
license) to “Humboldt Wholesale, Inc.,” which, on further
investigation, appeared to be a supplier of items to cultivate
marijuana. See, e.g., https://www.dnb.com/business-
directory/company-
profiles.humboldt_wholesale_inc.cd260285658c4f8a89458e6c479d928e
.html.
g. Out of the Prime PPPL proceeds in the JPMC 6026,
SHAW also made large online payments to individuals whom I
identified as friends or neighbors of SHAW’s father and who were
not identified on either the fake Paylocity or EDD records as
associated with or employed by Prime:
April 29, 2021 – June 8, 2021 - $90,000.00 to E.T.
May 24, 2021 – June 9, 2021 - $17,468.00 to T.T.
May 24, 2021 – June 9, 2021 - $17,532.00 to A.T.
3. Wire Fraud re Prime’s PPPL Forgiveness
Application
39. In June 2022, an application was submitted online to
forgive Prime’s PPPL. “Sarkis G. Sarkisyan” (whose name matches
that on SHAW’s previous driver’s license, depicted above) was
identified as the “primary contact” on the forgiveness
application and the Liberty Address was provided as Prime’s
“business address.” The forgiveness application was
electronically signed by “Sarkis Sarkisyan” as Prime’s
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“authorized representative.” Based on this evidence and the
evidence that shows that SHAW controlled and misused the Prime
PPPL proceeds, described above, I have probable cause to believe
that SHAW submitted this forgiveness application and will refer
to that application as such.
40. SHAW was required to certify that the Prime PPPL
proceeds were “used to pay business costs that are eligible for
forgiveness,” such as payroll costs to retain employees. SHAW
stated that Prime’s payroll costs were $1,539,526.58, an amount
that matched that of the payroll costs on the phony Paylocity
payroll report submitted to support the PPPL, as described
above.
41. Again, in reviewing bank records showing the wire
transfer of the Prime PPPL proceeds to the JPMC 6026, I did not
see any withdrawals or transfers that appeared to be for Prime’s
payroll.
F. SUBJECT MIKHAELYAN: Wire Fraud, Bank Fraud, and Money
Laundering re “Cornwall” PPPL
42. On May 20, 2020, an application for a PPPL was
submitted on behalf of the “Cornwall Group, Inc.” (“Cornwall”).
43. Public records show that MIKAELYAN was Cornwall’s
sole officer and director, and at various times in public
records its stated business was “management” or “water
restoration.”
44. Contrary to the above-described public records,
Cornwall’s PPPL application stated that Cornwall was a
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“miscellaneous store retailer,” had 81 employees, and had an
average monthly payroll of $357,541.
45. The applicant also submitted various documents in
support of the application, including, similar to SHAW’s PPPL
application for Prime, an IRS Form 941. Here, that form
reported that Cornwall had paid wages in the first quarter of
2020 in excess of $1 million.
46. I submitted an IRS Fact of Filing request for
Cornwall and from that response confirmed that no such form was
actually submitted to the IRS.
47. The applicant also submitted a payroll report
purportedly from Paylocity, the same payroll company whose
payroll report SHAW had fabricated. The report listed purported
Cornwall employees and their wages. I learned from EDD that EDD
has no record of the purported employees and from Paylocity that
it had no records for Cornwall.
48. An individual identifying himself as MIKHAELYAN
electronically, via the DocuSign authentication platform,
acknowledged and then electronically transmitted to the lender,
Bank of America, a standard form PPPL certification that stated,
among other things, that PPPL proceeds would solely be used by
Cornwall to retain employees and for certain of its business
expenses.
49. Bank of America approved the Cornwall PPPL
application and funded the loan of $893,852 in May 2020. I
reviewed records from Bank of America for a Bank of America
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account ending in 7587 (the “BofA 7587”) into which the Cornwall
PPP proceeds were deposited. I learned the following:
a. An individual identifying himself as MIKHAELYAN
opened the BofA 7587 in 2017. The signature card/account
application identified MIKHAELYAN by his true date of birth and
genuine Social Security and driver’s license numbers.
b. MIKHAELYAN was the sole signatory on the BofA
7587. The signature on the signature card matches that of
MIKHAELYAN on his genuine driver’s license.
c. The balance just before the deposit of the
Cornwall PPP loan proceeds was de minimus.
d. Substantially all of the Cornwall PPPL proceeds
were withdrawn in the form of checks within about a week of the
proceeds’ deposit, including a $40,000 check to the Los Angeles
Rams. The signatures on that check (and each check) matched
that of MIKHAELYAN’s driver’s license:
50. In August 2021, an application was submitted for
forgiveness of the entire Cornwall PPPL. The application
electronically certified, in a manner similar to the initial
PPPL certification, that Cornwall had 82 employees at the time
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of the forgiveness application and that the PPPL proceeds were
used for Cornwall’s business expenses including 60% for payroll.
51. I also saw a check within the BofA 7587 records, that
I believe bore MIKHAELYAN’s genuine signature, for $479,000.
The check bore the notation “PPP payroll” (the “PPP Payroll
Check”):
52. The balance in the BofA 7587 at the time of the PPP
Payroll Check consisted substantially of unspent Cornwall PPPL
loan proceeds. I traced the deposit of the PPP Payroll Check to
a different Cornwall account, at HSBC bank (the “HSBC Account”).
I reviewed records of that account and learned that the HSBC
Account was opened three months before the date that the
Cornwall PPPL application was submitted. The signature
card/account application identified the sole signatory as
MIKHAELYAN, by his true personal identifying information. I
also learned from reviewing bank statements for the HSBC Account
that there were no checks or withdrawals to any person named as
a Cornwall employee on the Paylocity report, nor were there any
payments to Paylocity or other transfers consistent with paying
wages or compensation to others at least for the operation of a
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“miscellaneous store retailer” as MIKHAELYAN had represented on
the Cornwall PPPL application.
G. SUBJECT MIKHAELYAN: Wire Fraud and False Claim re
Cornwall EIDL
53. On July 14, 2020, an EIDL application was submitted
to SBA for a $150,000 EIDL on behalf of Cornwall. The standard
form application identified MIKHAELYAN as the contact person,
giving his correct address, and stating that Cornwall had 2019
calendar year revenue of $478,000 (nearly the same number as the
PPP Payroll Check that MIKHAELYAN had signed a few weeks
earlier); had two employees (compared to 82 as MIKHAELYAN had
stated on the Cornwall PPP application only two months earlier);
and had zero revenue for 2020 (compared to over $1 million as
stated on the Form 941 for the first quarter of 2020 that
MIKHAELYAN had submitted in support of the Cornwall PPPL
application).
54. A person who identified himself as MIKAELYAN signed
the standard form Loan Authorization and Agreement (“LA&A”) via
the DocuSign online authentication platform in which he
represented that Cornwall would, in pertinent part, “use all the
proceeds of this [l]oan solely as working capital to alleviate
economic injury caused by disaster occurring in the month of
January 31, 2020[.]”
55. On the basis of the applicant’s representations,
above, the EIDL was approved and its proceeds ($149,900, net of
fees) wire-transferred to the HSBC Account. MIKHAELYAN promptly
signed checks to spend-down substantially all of those proceeds,
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including checks to MIKHAELYAN’s sister, SUBJECT MARIANNA
SARKISYAN and to others not identified on the Paylocity report
as “employees” of Cornwall.
H. SUBJECTS MIKHAELYAN and YEMENEJIAN: Wire Fraud, False
Claim, and Money Laundering re “Nairi” RRF
56. In May 2021, an application for an RRF for a
restaurant called “Nairi Meat & Deli” in Hollywood, CA (“Nairi”
and the “Nairi RRF”) was submitted to the SBA. The email
contact on the application was “mikaelyanmike@gmail.com.”
57. RRFs were offered to support the restaurant industry
by providing funding to offset significant pandemic-related
revenue loss. RRFs had specific requirements to ensure
equitable distribution to small business concerns owned by
women, veterans, and socially and economically disadvantaged
applicants.
58. The Nairi RRF application identified L.D., a woman,
as the president and 100 percent owner. I interviewed L.D. She
told me that she did not own Nairi at the time of the RRF
application and that she gave up ownership to MIKHAELYAN and her
ex-husband, YEMENEJIAN, in the early 2000’s. L.D. also stated
that she could not recall whether she or MIKHAELYAN submitted
the Nairi RRF application, but in any event that she gave
MIKHAELYAN permission to do so. MIKHAELYAN was previously
identified as Nairi’s sole owner on an EIDL application.
59. In further support of the Nairi RRF, the applicant
submitted a 2019 federal income tax return for Nairi that,
according to IRS transcripts that I reviewed, was filed
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approximately two weeks before the RRF application was
submitted, thus indicating that the return was untimely (i.e.,
it should have been filed in 2020) and prepared to facilitate
the Nairi RRF as opposed to reporting financial activity to
comply with tax laws.
60. The SBA approved the Nairi RRF and in May 2021 wire-
transferred the RRF grant proceeds of $1,905,824 to a JPMC
account ending in 5870 (the “JPMC 5870”). I reviewed records
for the JPMC 5870 and learned the following:
a. L.D. was removed as a signatory before the RRF
was sought, and MIKHAELYAN was replaced as the sole signatory.
b. Within about two weeks after the Nairi RRF
proceeds were deposited into the JPMC 5870, YEMENEJIAN, who was
not a signatory on the account, wrote 16 checks to MIKHAELYAN
(and confirmed as such during an interview), each in the amount
of $4,567.50, totaling $73,072. 2 I know from my training and
experience that individuals frequently transact in amounts below
$10,000 for fear of drawing suspicion for structuring. The
detail of those checks is as follows:
Date of Check Amount Payee
March 15, 2020 $9,135 Mikael Mikaelyan
March 31, 2020 $9,135 Mikael Mikaelyan
April 3, 2020 $4,567.50 Mikael Mikaelyan
April 10, 2020 $4,567.50 Mikael Mikaelyan
April 17, 2020 $4,567.50 Mikael Mikaelyan
April 24, 2020 $4,567.50 Mikael Mikaelyan
2 The bank still honored the checks, even though signed by a
non-signatory.
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c. L.D.’s ex-husband, SUBJECT YEMENEJIAN, wrote
numerous checks on the account, again even though he was not a
signatory, including to “Express Restoration.” I know from
reviewing evidence in this case that “Express Restoration” was a
purported corporation – likely just a shell – whose president
was identified on public records as MIKHAELYAN.
d. YEMENEJIAN also wrote a $36,504 check to
“Humboldt Wholesale,” the same entity that SHAW paid out of PPPL
funds and that I believe from open sources to be a marijuana
cultivation supply business. I have found no information that
Nairi was a marijuana dispensary in addition to being a
restaurant.
e. L.D. also told me that she was remodeling her
residence during the time that the Nairi RRF proceeds were
received and that a check signed by YEMENEJIAN out of those
proceeds, to Bank of America for $104,044, was to pay off a
secured loan that she had obtained for home improvements that
had nothing to do with Nairi’s operation.
f. All told, YEMENEJIAN signed over 150 checks
totaling more than $1.2 million out of the RRF proceeds to a
variety of payees, some of which appeared to be shells or, at
least, not restaurant suppliers or Nairi employees according to
EDD records and the absence of related IRS records.
61. The SBA required that all RRF recipients submit
annually a “post award report” in which the RRF recipient’s
representative was required to certify that the RRF funds had
been used as required, i.e., for restaurant-related expenses.
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62. I reviewed a post-award report for Nairi that was
submitted via email from the same email account that identified
on the Nairi RRF application: “mikhaelyanmike@gmail.com.” The
report certified that all RRF proceeds were used for permissible
business-related expenses. The post-award report did not
mention or separately itemize the $73,072 payments to
MIKHAELYAN, the $104,044 payment to pay off L.D.’s loan from
Bank of America, or the $36,504 payment to the marijuana
cultivation supply business.
63. In June 2024, during this investigation and shortly
after I first spoke to L.D., MIKHAELYAN called me. He told me
that he owned Nairi and that he wanted to participate in an
interview that I had scheduled with L.D. I told MIKHAELYAN that
he could not participate in the interview of L.D. but that I
would separately interview him. He stated that he should be
present during L.D.’s interview because they “were family.” He
then stated that he only “managed the operations” of Nairi and
would not answer when I asked if he “owned” Nairi. He repeated
that he was “in charge” of operations and added that YEMENEJIAN
was also involved in running Nairi.
I. MIKHAELYAN: Wire Fraud and False Claim re “Rest” EIDL
Modification
64. In May 2020, an EIDL application for $150,000 was
submitted online on behalf of Rest Assured Restoration (“Rest”).
The EIDL application showed MIKHAELYAN’s true name, date of
birth, and email address that matched that of the RRF
application and related RRF documents. The applicant stated
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that Rest was in the “personal services” industry, had 18
employees, and had gross revenues for calendar year 2019 of
$754,000.
65. Per records that I obtained from EDD, Rest had no
employees and no filings at all.
66. Per an IRS Fact of Filing request, the IRS had no
records of payroll tax returns for Rest.
67. The Rest EIDL was approved and its proceeds were
deposited into an account whose sole signatory was MIKHAELYAN.
68. In late 2021, the SBA received an application to
modify the Rest EIDL by increasing the loan by $350,000. The
Rest EIDL file “notes” section (that I know contained summaries
of communications between borrowers and SBA loan officers,
including requests for additional financial information)
reflected that MIKAELYAN was advised that he needed to provide
genuine federal income tax returns for Rest for calendar years
2019 and 2020 to justify the modification and to authorize the
SBA to confirm that such returns were filed with the IRS.
69. I reviewed in the Rest EIDL file what appeared to be
Rest calendar year 2019 and 2020 federal income tax returns
signed by MIKHAELYAN and IRS transcripts that reflected the
filing of such returns. The transcripts showed that the returns
had not been timely filed but, instead, were filed together in
December 2021, just before the Rest EIDL modification request
was made. The transcripts reflected that Rest had gross income
for each year of more than $1 million and that Rest owed tens of
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thousands of dollars in income taxes. No taxes were actually
paid. 3
70. The SBA ultimately denied the Rest EIDL modification
request by concluding that Rest had filed its income tax returns
solely to qualify for the EIDL modification rather than to
reflect genuine financial activity.
J. SUBJECT YEMENEJIAN: Wire Fraud and False Claim re
“Tiny Tots” EIDL
71. In August 2020, an application was submitted online
for an EIDL for Tiny Tots Childcare, Inc. (“Tiny Tots”) for
$150,000. The applicant described Tiny Tots as providing
“educational services” and “daycare” since its “start date” of
January 1, 2019.
72. An individual identified as YEMENEJIAN electronically
signed an EIDL LA&A for the Tiny Tots EIDL on August 7, 2020, in
which the applicant promised to “use all the proceeds of this
Loan solely as working capital to alleviate economic injury
caused by disaster occurring in the month of January 31,
2020[.]” Thus, by the terms of the LA&A, TTCI had to be in
existence “in the month of January [], 2020.”
73. The Tiny Tots EIDL was funded and, based on my review
of SBA records relating to this EIDL, its proceeds were wire-
3 As more fully described in the concurrently submitted
request for issuance of arrest and search warrants for SUBJECT
MCGRAYAN, et al., I have probable cause to believe that SUBJECTS
submitted fraudulent tax returns to obtain loans in a somewhat
creative manner where the returns fraudulently reported
substantial income and tax due in order to create the appearance
of legitimacy. No tax was ever paid.
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transferred into California Credit Union Account ending in 8996
(the “CCU 8996”).
74. I reviewed records for the CCU 8996 and learned the
following:
a. The signature card/account application identified
YEMENEJIAN as Tiny Tot’s authorized representative and provided
his true name, date of birth, and driver’s license number. The
account was opened with $200 on August 5, 2020, or one day
before the Tiny Tots EIDL application was submitted to the SBA.
b. YEMENEJIAN was identified on the signature
card/account application as the CEO and 100% owner of Tiny Tots.
I recognized the signature on the signature card/account
application as matching that of YEMENEJIAN’s driver’s license, a
copy of which was also included in the CCU records.
c. CCU records also contained a “Statement of
Information” (“SOI”) for “Tiny Tots Childcare, Inc.,” filed with
the California Secretary of State on July 31, 2020, or five days
before the CCU 8996 was opened. The SOI, which I confirmed had,
in fact, been publicly filed, identified YEMENEJIAN as the sole
officer and director of Tiny Tots at the same address for Tiny
Tots that YEMENEJIAN had given when he opened the CCU 8996.
d. CCU 8996 records show that the Tiny Tots EIDL
proceeds of $149,900 (net of fees) were deposited into that
account on August 10, 2020. The prior balance was $200, an
amount credited to the account when it was opened days earlier.
There was no other deposit activity.
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e. As more fully described below, none of the EIDL
proceeds was used “solely as working capital to alleviate
economic injury caused by disaster occurring in the month of
January 31, 2020” because, as described below, Tiny Tots never
opened.
75. An application for an EIDL modification for Tiny Tots
was later sought to obtain another $349,900. In connection with
that application, as required and requested by SBA to underwrite
the EIDL, the applicant provided a 2019 federal income tax
return for Tiny Tots that indicated it had been prepared by C.H.
I interviewed C.H., who told me the following:
a. He is a tax preparer.
b. He prepared the Tiny Tots return that I saw in
the SBA’s Tiny Tots EIDL modification file.
c. YEMENEJIAN came to C.H.’s office and presented a
small piece of paper with line items for purported business
income and expenses for Tiny Tots. YEMENEJIAN directed C.H. to
prepare Tiny Tots’s 2019 federal income tax return using that
information.
d. YEMENEJIAN did not provide any other information
to C.H. for the preparation of the return.
e. C.H.’s practice was to prepare returns for
clients based on information provided by clients. C.H. did not
personally verify or audit any such information. C.H. would
simply instruct clients, including by providing cover letters
for returns, that the returns that he prepared for clients based
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on client’s information were simply, in essence, as reliable and
accurate as that information.
f. YEMENEJIAN signed Tiny Tots’s 2019 federal income
tax return in C.H.’s presence.
76. I reviewed that return and learned that, among other
things, YEMENEJIAN reported that Tiny Tots had gross revenue
from operations for calendar year 2019 of $356,640. Based on my
training and experience, and review of the totality of the
evidence gathered in this investigation, I have probable cause
to believe that YEMENEJIAN submitted made up numbers to C.H.
with the intent that C.H. prepare a false income tax return to
fraudulently facilitate obtaining this EIDL.
77. I served a grand jury subpoena on YEMENEJIAN as Tiny
Tots’s custodian of records and agent for service of process.
Through counsel, YEMENEJIAN produced a building lease in
response to the subpoena’s request for that and other records.
I reviewed the lease and learned the following that the lease
was executed on August 30, 2018. The lessor was identified as
S.B.
78. I interviewed S.B. and learned the following:
a. S.B. told me that he was the lessor for the
subject property and that he met YEMENEJIAN to negotiate the
lease on behalf of Tiny Tots.
b. S.B. stated that the lease with Tiny Tots never
took effect because the City of Los Angeles refused to issue
Tiny Tots a permit to operate.
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c. S.B. gave me a copy of the lease from his
(S.B.’s) files. The lease was similar to the copy that
YEMENEJIAN had produced pursuant to the grand jury subpoena.
However, S.B. also produced an “amendment” to the lease that
YEMENEJIAN had not produced. The “amendment” was dated June
2019 and signed by S.B. and by YEMENEJIAN (his signature plainly
matched that of known exemplars). The “amendment” stated that
it related to the lease “between [S.B.’s business] and Sarkis
Yemenejian dated August 30, 2018,” and that “lessee and lessor
her[e]by agree to cancel such lease[.]” The “amendment” also
stated that YEMENEJIAN’s previously paid security deposit of
$30,472 was to be repaid, at YEMENEJIAN’s direction, to L.D.
(YEMENJIAN’s ex-wife).
79. I reviewed the CCU 8996 records and confirmed that
YEMENEJIAN had written S.B.’s company a deposit check of $30,472
out of proceeds of the Tiny Tots EIDL.
80. Based on my review of the TTCI EIDL records provided
by SBA, I learned that YEMENEJIAN paid nothing toward repayment
of the Tiny Tots EIDL and concealed from the SBA that Tiny Tots
never operated.
K. SUBJECT TERZYAN: Wire Fraud, False Claim, and Money
Laundering re “Grub House” EIDL and EIDL Modification
81. In January 2021, an application was submitted to SBA
for a $150,000 EIDL on behalf of “Grub House, Inc.” (“Grub
House” or the “Grub House EIDL”). TERZYAN 4 was identified on the
4 In 2016, TERZYAN was convicted in this district of
conspiracy to possess 15 or more unauthorized access devices, in
(footnote cont’d on next page)
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Grub House EIDL application by his true name, Social Security
number, and driver’s license number.
82. The application claimed that Grub House’s revenue for
the 12 months preceding January 31, 2020, was $433,441.
83. In March 2021, an individual identified as “Arsen
Terzyan owner/officer” e-signed the standard form EIDL “Loan
Authorization and Agreement” (“LA&A”) on behalf of Grub House.
Like that of substantially all other EIDL LA&As, the signer
promised that “[b]orrower will use all the proceeds of this Loan
solely as working capital to alleviate economic injury caused by
disaster occurring in the month of January 31, 2020 and
continuing thereafter[.]”
84. The Grub House EIDL application also identified a
JPMC account ending in 3502 (the “JPMC 3502”) as the bank
account into which EIDL proceeds should be wire-transferred.
85. On April 2, 2021, the Grub House EIDL proceeds of
$149,900 (net of fees) were wire transferred from the SBA to the
JPMC 3502. I reviewed records for the JPMC 3502 and learned the
following:
a. The account was opened in October 2019.
b. The signature card/account application showed
that an individual identified as TERZYAN opened the account by
providing his true name and genuine Social Security and driver’s
license numbers. The signature on the signature card/account
application matched that of TERZYAN’s driver’s license.
violation of 18 U.S.C. section 1029(b)(2) and sentenced to three
years in prison. United States v. Nazar Daniyelyan, et al., CR
15-621-GW.
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c. The balance in the account before the deposit of
the Grub House EIDL proceeds was $1,361.
86. Substantially all of the Grub House EIDL proceeds
were spent in 30 days as the balance in the JPMC 3502 at the end
of the statement period for the deposit (approximately April
2021) was $524.
87. I traced the use of the Grub House EIDL proceeds. I
saw 17 checks totaling $102,070, each bearing a signature of
TERZYAN that matched that of his driver’s license, in amounts
consistent with structuring. None appeared consistent with use
as working capital to alleviate damage caused by the Covid-19
pandemic, and at least one such payment was to TERZYAN’s sister-
in-law, SUBJECT MARIANNA:
Date Range Amount Payee
April 2, 2021 $8,500.00 Terzyan Personal Account
April 2, 2021 $9,892.00 Terzyan Personal Account
April 1 – April 3, 2021 $50,000 No Limit Cargo
April 6 – April 9, 2021 $17,700.00 A Gi
April 7, 2021 $9,150.00 Home Energy Rating
April 7, 2021 $9,150.00 Hers Raters
April 14, 2021 $14,000.00 Marianna Sarkisyan
88. In April 2021, an application was made for a
modification to the Grub House EIDL to increase the total EIDL
to $500,000.
89. I know from my training and experience that the SBA
at that time commonly required that applicants submit tax
returns and/or provide the SBA with permission (via an IRS Form
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4506-T) to obtain directly from the IRS transcripts for the
applicant as well as the applicant’s tax returns.
90. The Grub House EIDL file contained an IRS Form 4506-T
bearing the electronic signature of TERZYAN.
91. I reviewed the transcripts that the SBA obtained for
federal income tax returns for the calendar years 2018 and 2019.
The transcripts showed that Grub House’s income tax returns for
those years were untimely, submitted on the same day in February
2021, and prepared by the same tax preparer, L.F., whom I know
from the evidence in this case was identified as the tax
preparer for several other targets including SHAW and
MIKHAELYAN.
92. The chronological activity section on the EIDL
application (“note” section) indicated that the SBA declined the
EIDL modification because Grub House’s tax returns were obtained
to qualify for the EIDL modification as opposed to submitted to
report genuine financial activity.
L. SUBJECT TERZYAN: Wire Fraud, False Claim, and Money
Laundering re “Grub House” RRF
93. In May 2021, an application was submitted to the SBA
for an RRF on behalf of Grub House, Inc. (“Grub House” and the
“Grub House RRF”). The “100%” owner was identified as TERZYAN,
and provided his residence address at 16719 Lahey St., Granada
Hills, CA, as Grub House’s business address.
94. I recently listened to a recording between a creditor
and TERZYAN that was made as part of that creditor’s
underwriting for a loan to TERZYAN. During that recording,
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TERZYAN identified himself by providing the last four digits of
his (true) Social Security number that matched that on the Grub
House RRF application and the EIDLs described above. He also
gave as his residence address and phone number the same
residence address and phone number shown on the Grub House RRF
application. I therefore believe that TERZYAN made the
representations on and submitted the Grub House RRF application
and will refer to that application as such.
95. TERZYAN claimed on the Grub House RRF that Grub
House’s 2019 calendar year gross receipts were $1,423,441 and
that he expected to report $463,792 for gross receipts for Grub
House for 2020.
96. On the January 2021 EIDL application for Grub House
that TERZYAN submitted, as described above, TERZYAN claimed that
Grub House’s “Actual 2019 gross revenue” was exactly one million
dollars less than the amount now claimed on the Grub House RRF
application, or $423,441.
97. On the Grub House RRF application, TERZYAN identified
the JPMC 3502 as the business bank account into which proceeds
of the RRF should be wire-transferred (the same account into
which the Grub House EIDL proceeds were transferred).
98. TERZYAN represented on the Grub House RRF application
that RRF proceeds would be used solely for Grub House’s business
expenses such as payroll costs, rent, utilities, food and
beverage purchases, construction of outdoor seating, supplies,
and other operating expenses.
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99. TERZYAN further represented on that same application
that Grub House was at least 51 percent owned and controlled by
“[a] socially and economically disadvantaged individual[].”
100. On May 28, 2021, having approved the Grub House RRF
application, the SBA wire-transferred proceeds of $1,864,830 to
the JPMC 3502.
101. I reviewed records for the JPMC 3502 and learned the
following:
a. As stated above, I believe that TERZYAN opened
and controlled that account.
b. The balance in the account was $524 before the
RRF proceeds were credited on May 28, 2021. As described above,
substantially all of the deposits to the account from April 2,
2021, to the date of deposit of the RRF proceeds came from the
Grub House EIDL proceeds.
c. Substantially all of the Grub House RRF proceeds
were paid out within about three months of the deposit of the
RRF proceeds. Below is a chart that shows the date ranges,
amounts, and payees for the first six weeks of activity in the
JPMC 3502 following the RRF proceeds deposit, totaling
approximately $1.2 million:
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Date Range Amount(s) Payee
June 4 – August 6, 2021 $286,084.00 Humboldt Wholesale (Hydroponics)
June 8 – June 9, 2021 $219,804.79 Hawthorn Hydroponics
May 28 – December 31, 2021 $160,000.00 Arsen Terzyan’s Personal Account
July 13, 2021 $40,000.00 Ikon Development (Koko Polosajian)
July 13, 2021 $60,000.00 Standard Home Lending (K
P )
July 21, 2021 $50,000.00 M L J
July 22 – August 11, 2021 $50,000.00 Pre-Packaging and Moving Service
July 13, 2021 $50,000.00 Aykem, LLC
August 4, 2021 $50,000.00 Woodland Shane Matthew
June 21 – July 19, 2021 $14,000.00 Maria Sarkisyan
July 16, 2021 $13,671.31 Macy’s
July 15, 2021 $3,145.00 Express Restoration (Mikael Mikaelyan)
d. The first two line items refer to payments to
what I believe were marijuana cultivation supply businesses, one
of which (Humboldt Wholesale) was the same such business to
which SUBJECT SHAW paid out of PPPL proceeds as described above.
SUBJECT MARIANNA received $14,000.
102. RRF recipients were required to certify that RRF
proceeds were used in compliance with RRF rules. Such
compliance was required via a “post-award report.”
103. Acknowledging on the post-award report that “[a]ny
false statement or misrepresentation to SBA may result in
criminal, civil or administrative sanctions including, but not
limited to: 1) fines and imprisonment[,]” an individual
identified as TERZYAN electronically signed and submitted that
report in December 2021 and represented that all of the Grub
House RRF proceeds were used for Grub House business expenses,
as follows:
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Amount Eligible Categories
$ 317,204.00 Payroll (including paid sick leave)
$ 94,563.00 Rent / Mortgage
$ 31,202.00 Utilities
$ 87,750.00 Debt Service
$ 45,673.00 Construction of Outdoor Seating
$ 16,185.00 Maintenance
$ 16,831.00 Supplies
$ 928,686.00 Food and Beverage (including raw materials)
$ 48,874.00 Covered Supplier Costs
$ 277,862.04 Business Operating Expenses
$ 1,864,830.04 TOTAL
104. EDD records show that Grub House’s payroll
commenced during the third quarter of 2019 and that it
maintained five employees through the first quarter of 2020.
Grub House maintained one employee from Q2 2020 to Q4 2020.
There was no EDD record of payroll during calendar year 2021.
Grub House’s EDD account ceased on March 31, 2022.
105. Based on my review of the JPMC 3502, I have probable
cause to believe that TERZIAN at least fraudulently misused and
misrepresented on the RRF post-award report payments of $317,204
as payroll expenses, if not in excess of $600,000 more to
marijuana cultivation suppliers that he fraudulently
mischaracterized as other purported business-related expenses.
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M. SUBJECT MARIANNA: Wire Fraud, False Claim, and Money
Laundering re “Rustwood” EIDL
106. On May 30, 2020, an EIDL was submitted on behalf of
a shell called “Rustwood Enterprises, Inc.” (“Rustwood”) for
$150,000. MARIANNA was identified as the contact person by her
true name, Social Security number, date of birth, and residence
address (the same address as SHAW). The application identified
MARIANNA as the owner of Rustwood and stated that Rustwood had
2019 calendar year gross revenue of $1.6 million and 14
employees. The application identified a California Credit Union
(“CCU”) account ending in 7905 (the “CCU 7905”) as the account
to which the EIDL proceeds should be wire-transferred/deposited.
107. EDD records and IRS Fact of Filing information
showed that Rustwood did not have any employees for the period
covered by the EIDL application.
108. On May 30, 2020, an individual identified as
MARIANNA electronically signed the LA&A and, like that of
substantially all other EIDL LA&As, the signer promised that
“[b]orrower will use all the proceeds of this Loan solely as
working capital to alleviate economic injury caused by disaster
occurring in the month of January 31, 2020 and continuing
thereafter[.]”
109. I reviewed the records for CCU 7905 and learned the
following:
a. The signature card/account application was signed
on April 1, 2020, or about two months before the Rustwood EIDL
was sought. It contained MARIANNA’s true name, Social Security
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number, and driver’s license number, each of which matched that
on the Rustwood EIDL application. 5 I compared the signature on
the signature card with that of MARIANNA’s driver’s license and
believe the signatures were written by one and the same person:
MARIANNA. The signature card stated that Rustwood was involved
in “landscape design.”
b. There was minimal activity in the CCU 7905 for
the months of April and May 2020, such as a transfer from
another account in the name of MARIANNA for $500 to open the
account and a withdrawal at a Walgreen’s store in Van Nuys
(which I know was in the vicinity of MARIANNA’s residence). For
May 2020, there were approximately $300 in what appeared to be
personal expenses (e.g., “Tigranakert Meat Marke[t]” in Van
Nuys).
c. The EIDL proceeds of $149,900 (less $100 fees)
were deposited on June 29, 2020, followed by the deposit of an
EIDL advance of $10,000 on July 7, 2020. (I know from my
training and experience that the SBA commonly paid EIDL
applicants an advance of $1,000 for every claimed employee, up
to $10,000, to hold them over until EIDL proceeds were paid;
this situation was slightly different as the advance was paid
after the proceeds.)
d. There was no significant activity in the account
until October, when approximately $100,000 – substantially, if
5 The signature card contained MARIANNA’s prior residence
address that MARIANNA verified in mid-2021 in connection with
seeking an increase/modification of the Rustwood EIDL, as
discussed below.
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not solely, EIDL proceeds – was withdrawn in the form of checks
or electronic transfers. Below is a summary of the payments
that show use of the EIDL proceeds, none of which is consistent
with the operation of a “landscape design” business or with
payment of payroll:
Date Range Amount(s) Payees
October 1 – October 3, 2020 $46,495.00 Express Restoration (Mikael Mikaelyan)
October 6, 2020 $18,500.00 M K
October 16 – December 16, 2020 $26,565.00 A G
October 19, 2020 $17,860.00 Macy’s Online Payment
November 4, 2020 $15,122.00 Ranchito Investments
November 25, 2020 $3,190.00 Body Design Rejuvenation
December 4, 2020 $5,800.0 Cornwall Group (Mikael Mikaelyan)
December 4 – January 6, 2021 $22,634.00 Toluca Commercial, Inc.
December 5, 2020 $15,000.00 American Mobile Power Solution
December 11, 2020 $7,000.00 Maria Sarkisyan
December 17, 2020 $17,901.60 First Bank
January 4, 2021 $49,200.00 Best Tudor
110. In April 2021, MARIANNA applied for a modification
to increase the Rustwood EIDL to $500,000. The SBA “note”
summary for this application described a detailed conversation
between an SBA representative and MARIANNA, the relevant parts
of which are summarized as follows:
a. The representative (identified as the “LO” (loan
officer)) stated that the LO “called and spoke w/Marianna
Sarkisyan @ 818-747-5007.” That was the same number that was
provided on the Rustwood EIDL in 2020.
b. The LO “asked applicant PII questions to verify
information from the initial EIDL, including “date business
established, verified home & business address, verified business
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entity—stated C corp-business Agriculture.” I know from my
training and experience that SBA loan officers commonly verified
applicant’s personal identifying information from EIDL
applications in connection with vetting modification requests.
c. The LO also verified MARIANNA’s identity by
confirming that MARIANNA had received a bankruptcy discharge in
August 2019 and previously lived at the same address that
MARIANNA had provided when she opened the CCU 7906.
d. In response to the LO’s question about why the
EIDL application stated $1.6 million in gross revenue for 2019
“versus the 2019 [$570,338 in gross revenue] reported on [a tax
transcript that was provided pursuant to a tax information
release form signed by MARIANNA],” MARIANNA explained the more
than $1 million discrepancy by stating that “she completed the
[EIDL] application without her tax accountant.”
e. The LO explained that the variance was too great
to approve the modification and that “applicant stated she
understood.”
N. SUBJECT MARIANNA: Wire Fraud and False Claim re
Personal EIDL
111. SBA records show that, on July 13, 2020, fewer than
two months after MARIANNA applied for the Rustwood EIDL, an
online application was submitted for a $150,000 EIDL for
“Marianna Sarkisyan” as a “Sole-Proprietorship” (the “MARIANNA
EIDL”). The MARIANNA EIDL application contained not only
MARIANNA’s true name but her true Social Security number and the
same residence address she had provided when she applied for the
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Rustwood EIDL in May 2020. The application claimed that
MARIANNA was in the business of “property management/realty” and
also stated that MARIANNA’s “gross revenues for the twelve
months prior to [] January 31, 2020” was $357,000,” but
mentioned nothing about her association with, or any income
derived from, Rustwood. The MARIANNA EIDL application
identified a California Credit Union account ending in 0956 (the
“CCU 0956”) to which EIDL proceeds should be wire-transferred.
112. The MARIANNA EIDL was approved and funded in the
amount of $150,000 in August 2020. In July 2021, an application
was submitted online to modify the MARIANNA EIDL by increasing
it to $500,000 (a net increase of $350,000). An LA&A for this
modification was e-signed by “Marianna Sarkisyan” on July 26,
2021 and, similar to other EIDL requirements at that time, the
applicant agreed that “[applicant] will use all the proceeds of
this Loan solely as working capital to alleviate economic injury
caused by disaster occurring in the month of January 31, 2020
and continuing thereafter[.]”
113. I reviewed records of the CCU 0956 and learned the
following:
a. The account was opened in 2013. The signature
card/account application identified the account holder as
MARIANNA based on her true date of birth, Social Security
number, and driver’s license number. The signature on the card
matches that of her driver’s license and the numerous checks on
accounts associated with her that I have seen during this
investigation.
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b. The proceeds of the MARIANNA EIDL modification
were deposited into the CCU 0956 on July 30, 2021.
Cc. The beginning balance in that account (as of July
1, 2021) was $8,234. For the several months preceding that
date, the account appeared to be largely used for personal
expenses (e.g., substantial Amazon and Postmates payments,
recurrent $1,820 Chase Auto Lease payments).
d. The bulk of the EIDL proceeds were used for a
variety of expenses not associated with “working capital” for a
business including the same substantial Amazon payments,
recurrent Chase Auto Lease payments, $8,298 in Aeroflot plane
tickets, $55,000 to Rustwood, $15,000 to Pacific BMW, $4,862 to
Louis Vuitton, $24,000 to Mercedes Benz of Beverly Hills, and
$2,090 to Monolo Blahnik Intl London (high-end shoes).
V. CONCLUSION
114. For all the reasons described above, there is
probable cause to believe that SARKIS SARKISYAN, AKA SAMUEL
SHAW; MIKHAEL MIKHABLYAN; ARSEN TERZYAN, AKA STEVEN TERZAKI; and
MARIANNA SARKISYAN committed the Subject Offenses.
Attested to by the applicant in
accordance with the requirements
of Fed. R. Crim. P. 4.1
by telephone on this 23rd day of
May, 2025.
HONORABLE PATRICIA DONAHUE
UNITED STATES MAGISTRATE JUDGE
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