Criminal Complaint and Affidavit — U.S. v. Samvel Grigoryan and Hayk Martirosyan (C.D. Cal.)

Summary

A criminal complaint with an attached affidavit, filed September 8, 2023 as Document 1 in Case 2:23-cr-00468, in the U.S. District Court for the Central District of California. The complaint names Samvel Grigoryan and Hayk Martirosyan and cites 18 U.S.C. §§ 371, 1960 (Conspiracy to Operate an Unlicensed Money Transmitting Business); it is signed /s/ Austin Anderson, FBI Special Agent. The affidavit states that Grigoryan, with the assistance of Martirosyan, is known to operate an unlicensed money service business named "Coinexchange.am" offering cash-for-cryptocurrency exchange. It states that an FBI confidential human source gave more than $140,000 in U.S. currency in exchange for cryptocurrency in August and September 2023. It also supports search warrant applications.

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“Criminal Complaint and Affidavit — U.S. v. Samvel Grigoryan and Hayk Martirosyan (C.D. Cal.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-2-23-cr-00468-dkt-1-c-d-cal-6f4bad27af/, SHA-256 86fe5ed3500b786d6eb233c470090d16d23de92fecf1d939553abf62bea40395.

Full text

Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 1 of 34 Page ID #:1
AO 91 (Rev. 11/11) Criminal Complaint (Rev. by USAO on 3/12/20) ‫ ܆‬Original ‫ ܆‬Duplicate Original

UNITED STATES DISTRICT COURT LODGED
CLERK, U.S. DISTRICT COURT

for the 9/8/2023
CENTRAL DISTRICT OF CALIFORNIA
JB
BY: ____________BB______ DEPUTY

Central District of California

United States of America 9/8/23
nne
v.

SAMVEL GRIGORYAN, and Case No. 2:23-mj-04608-DUTY
HAYK MARTIROSYAN,

Defendant(s)

CRIMINAL COMPLAINT BY TELEPHONE
OR OTHER RELIABLE ELECTRONIC MEANS

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

Beginning on or about a date unknown and continuing to on or about September 8, 2023, in the county of Los

Angeles in the Central District of California, the defendant(s) violated:

Code Section Offense Description

18 U.S.C. §§ 371, 1960 Conspiracy to Operate an Unlicensed Money Transmitting Business

This criminal complaint is based on these facts:

Please see attached affidavit.

_ Continued on the attached sheet.

/s/ Austin Anderson
Complainant’s signature

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

Date: Septembe 8, 2023
Judge’s signature

City and state: Los Angeles, California Hon. Maria A. Audero, U.S. Magistrate Judge
Printed name and title

AUSA: J. Mark Childs x2433
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 2 of 34 Page ID #:2

AFFIDAVIT

I, Austin Anderson, being duly sworn, declare and state as

follows:

I. PURPOSE OF AFFIDAVIT

1. This affidavit is made in support of a criminal

complaint and arrest warrant against Samvel GRIGORYAN

(“GRIGORYAN”) and Hayk MARTIROSYAN (“MARTIROSYAN”) for violation

of 18 U.S.C. §§ 371, 1960 (Conspiracy to Operate an Unlicensed

Money Transmitting Business) (the “SUBJECT OFFENSES”).

2. In addition, this affidavit is made in support of

applications to search the following:

a. The person of GRIGORYAN, as described more fully

in Attachment A-1;

b. The person of MARTIROSYAN, as described more

fully in attachment A-2;

c. 1041 Elm Avenue, in Glendale, California, as

described more fully in Attachment A-3 (“SUBJECT PREMISES 1”);

d. 416 West Wilson Avenue, in Glendale, California,

as described more fully in Attachment A-4 (“SUBJECT PREMISES

2”)(collectively, SUBJECT PREMISES 1 and SUBJECT PREMISES 2 are

referred to herein as “SUBJECT PREMISES”).

e. A white Mercedes-Benz sedan bearing California

license plate “8YBF750”, with a vehicle identification number

(“VIN”) W1K6G7GB8MA041973, as described more fully in Attachment

A-5 (“SUBJECT VEHICLE 1”).

f. A black Mercedes-Benz sedan bearing California

license plate “LIMO8”, with VIN W1KEG2BB8PF014575, as described
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 3 of 34 Page ID #:3

more fully in Attachment A-6 (“SUBJECT VEHICLE 2”)(collectively,

SUBJECT VEHICLE 1 and SUBJECT VEHICLE 2 are referred to herein

as “SUBJECT VEHICLES”).

3. The requested search warrants seek authorization to

seize evidence, fruits, or instrumentalities of violations of 18

U.S.C. § 1960 (Operating an Unlicensed Money Transmitting

Business) and 18 U.S.C. §§ 371, 1960 (Conspiracy to Operate an

Unlicensed Money Transmitting Business) (the “SUBJECT

OFFENSES”), as described more fully in Attachment B.

Attachments A-1 through A-6 and B are incorporated herein by

reference.1

4. The facts set forth in this affidavit are based upon

my personal observations, my training and experience, and

information obtained from various law enforcement personnel and

witnesses, as well as my conversations and analysis with more

experienced agents and officers who are familiar with money

laundering. This affidavit is intended to show merely that

there is sufficient probable cause for the requested arrest

warrants and search warrants and does not purport to set forth

all of my knowledge of or investigation into this matter.

Unless specifically indicated otherwise, all conversations and

1 The descriptions of the GRIGORYAN, MARTIROSYAN, SUBJECT
PREMISES and the SUBJECT VEHICLES contained herein and in A-1
through A-6 are based on my own observations while conducting
surveillance, my discussions with other officers and/or agents
who conducted surveillance in this case, my review of reports
about surveillance in this case, open source data base searches,
records from government sources (e.g., CA DMV and Department of
Homeland Security) and information provided by others during
this investigation.
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 4 of 34 Page ID #:4

statements described in this affidavit are related in substance

and in part only.

II. BACKGROUND OF SPECIAL AGENT AUSTIN ANDERSON

5. I am a Special Agent (“SA”) with the Federal Bureau of

Investigation (“FBI”), and have been so employed since August

2021. As a requirement for employment as an FBI Special Agent,

I successfully completed the New Agent Basic Field Training

Course located at the FBI Training Academy in Quantico,

Virginia. As a function of my assignment, I have received both

formal and informal training from the FBI and other institutions

regarding computer technology, financial investigations,

cryptocurrency, and organized crime. I received Bachelor of

Science Degrees in Accounting and Finance from the University of

Utah. Before joining the FBI, I was employed as a staff

accountant from October 2019 to May 2021.

6. As a Special Agent with the FBI, my job duties include

the investigation of organized crime groups using advanced

technology to conduct large scale computer-enabled and computer-

facilitated crime, including violations of the SUBJECT OFFENSES.

7. I have conducted and participated in several criminal

investigations for violations of federal and state laws

including, but not limited to, financial crimes, computer-based

financial crimes, money laundering, fraud and other organized

criminal activity. I have prepared, executed, and assisted in

numerous search and arrest warrants. I have also conducted and

participated in criminal and administrative interviews of

witnesses and suspects. I am familiar with the formal methods
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 5 of 34 Page ID #:5

of money laundering investigations, including, but not limited

to, electronic surveillance, visual surveillance, general

questioning of witnesses, search warrants, confidential

informants, and analysis of financial records.

III. SUMMARY OF PROBABLE CAUSE

8. Samvel GRIGORYAN, with the assistance of co-

conspirator Hayk MARTIROSYAN, is known to operate an unlicensed

money service business named “Coinexchange.am”, which provides

cash-for-cryptocurrency exchange services in the Los Angeles

area. Because this business is not registered with the United

States Treasury Financial Crimes Enforcement Network (“FinCEN”),

discussed below, and does not comply with the mandatory

reporting requirements for money service businesses, it attracts

customers interested in evading federal anti-money laundering

(“AML”) regulations, such as Know Your Customer (“KYC”) identity

verification, and obfuscating the movement of funds by

preserving the anonymity of the transacting parties.2 Over three

separate occasions in August and September 2023, an FBI
confidential human source (“CHS”) gave GRIGORYAN and MARTIROSYAN

more than $140,000 in U.S. currency in exchange for

cryptocurrency. Neither GRIGORYAN nor MARTIROSYAN ever asked

the CHS for identification and never reported the transactions

to FinCEN as required.

FinCEN is a bureau within the U.S. Treasury Department.
2
The mission of FinCEN, among other things, is to safeguard the
financial system from illicit use, combat money laundering and
its related crimes including terrorism, and promote national
security through the strategic use of financial authorities and
the collection, analysis, and dissemination of financial
intelligence.
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 6 of 34 Page ID #:6

9. To date, no licensed business or corporation has been

discovered relating to either GRIGORYAN or MARTIROSYAN.

According to a FinCEN database, no currency transaction reports

were ever filed pertaining to the transactions conducted by

GRIGORYAN and the CHS. As explained below, neither GRIGORYAN

nor MARTIROSYAN are licensed or registered as money services

businesses with FinCEN, as required by federal statute,

discussed herein. As such, based on this investigation

discussed below, GRIGORYAN, along with the assistance of

MARTIROSYAN, is running an unlicensed money transmitting service

in violation of 18 U.S.C. § 1960.

10. There is probable cause to believe that evidence of

the Subject Offenses will be located in the SUBJECT PREMISES and

the SUBJECT VEHICLES. Investigating agents have observed on

multiple occasions, as set forth below, GRIGORYAN and

MARTIROSYAN utilizing the SUBJECT VEHICLES in activities

directly related to exchange transactions, to include holding

meetings about the cash-for-cryptocurrency scheme with a client

and counting cash inside the SUBJECT VEHICLES. As discussed

below, agents have also observed cash being taken directly from

a cash-for-cryptocurrency transaction to each of the SUBJECT

PREMISES.

IV. BACKGROUND ON VIRTUAL CURRENCY

11. Virtual currency (also known as cryptocurrency or

digital currency) is generally defined as an electronic-sourced

unit of value that can be used as a substitute for fiat currency

(i.e., currency created and regulated by a government). Virtual
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currency exists entirely on the Internet and is not stored in

any physical form. Virtual currency is not issued by any

government, bank, or company and is instead generated and

controlled through computer software operating on a

decentralized peer-to-peer network. Virtual currency is not

illegal in the United States and may be used for legitimate

financial transactions. However, virtual currency is often used

for conducting illegal transactions, such as the sale of

controlled substances or the laundering or concealment of funds.

12. Bitcoin is a type of virtual currency. Bitcoin

payments are recorded on a public ledger that is maintained by

peer-to-peer verification, and is thus not maintained by a

single administrator or entity. Individuals can acquire

Bitcoins either by “mining” or by purchasing Bitcoins from other

individuals. An individual can “mine” for Bitcoins by allowing

his/her computing power to verify and record the Bitcoin

payments into a public ledger. Individuals are rewarded for

this by being given newly created Bitcoins.

13. An individual can send and receive Bitcoins through

peer-to-peer transactions or by using a third-party broker.

Such transactions can be done on any type of computer, including

laptop computers and smart phones.

14. Bitcoins are stored in digital “wallets.” A digital

wallet essentially stores the access code that allows an

individual to conduct Bitcoin transactions on the public ledger.

To access Bitcoins on the public ledger, an individual must use

a public address (or “public key”) and a private address (or
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 8 of 34 Page ID #:8

“private key”). The public address can be analogized to an

account number while the private key is like the password to

access that account.

15. Individuals who possess cryptocurrency as a result of

illicit activity often need to convert it to fiat (government-

backed) currency. Such purchases and sales are often

facilitated by peer-to-peer Bitcoin exchangers who are not

registered with the federal or a state government and who

advertise their services on websites designed to facilitate such

transactions. These unregistered exchangers often charge a

higher transaction fee than legitimate, registered virtual

currency exchangers. This higher fee is essentially a premium

that the unregistered exchangers charge in return for not filing

reports on the exchanges pursuant to the Bank Secrecy Act, such

as Currency Transaction Reports and Suspicious Activity Reports,

as discussed below.3

16. All Bitcoin transactions are recorded on a public

ledger known as the “Blockchain,” stored on the peer-to-peer

network on which the Bitcoin system operates. The Blockchain

serves to prevent a user from spending the same Bitcoins more

than once. However, the Blockchain only reflects the movement

of funds between anonymous Bitcoin addresses and, therefore,

3 The Bank Secrecy Act (“BSA”), 31 U.S.C. Section 5311 et
seq, establishes program, recordkeeping and reporting
requirements for money transmitting businesses, national banks,
federal savings associations, federal branches and agencies of
foreign banks. The BSA was amended to incorporate the
provisions of the USA PATRIOT Act which requires financial
institutions to adopt a customer identification program as part
of its BSA compliance program.
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 9 of 34 Page ID #:9

cannot by itself be used to determine the identities of the

persons involved in the transactions. Only if one knows the

identities associated with each wallet involved in a set of

transactions is it possible to meaningfully trace funds through

the system.

17. Bitcoin is one example of a virtual currency; other

digital currencies, such as Tether (“USDT”), Tron, Etherium, and

Monero also exist. The technology underlying these currencies

are similar, though some of these currencies provide more

privacy and anonymity to the users.

18. Exchangers and users of cryptocurrencies store and

transact their cryptocurrency in a number of ways, as wallet

software can be housed in a variety of forms, including on a

tangible, external device (“hardware wallet”), downloaded on a

PC or laptop (“desktop wallet”), with an Internet-based cloud

storage provider (“online wallet”), as a mobile application on a

smartphone or tablet (“mobile wallet”), printed public and

private keys (“paper wallet”), and as an online account

associated with a cryptocurrency exchange. Because these

desktop, mobile, and online wallets are electronic in nature,

they can be located on mobile devices (e.g., smart phones or

tablets) or at websites that users can access via a computer,

smart phone, or any device that can search the Internet.

Moreover, hardware wallets are located on some type of external

or removable media device, such as a USB thumb drive or other

commercially available device designed to store cryptocurrency

(e.g. Trezor, Keepkey, or Nano Ledger). In addition, paper
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 10 of 34 Page ID #:10

wallets contain an address and a QR code4 with the public and

private key embedded in the code. Paper wallet keys are not

stored digitally. Wallets can also be backed up into, for

example, paper printouts, USB drives, or CDs, and accessed

through a “recovery seed” (random words strung together in a

phrase) or a complex password. Additional security safeguards

for cryptocurrency wallets can include two-factor authorization

(such as a password and a phrase). I also know that individuals

possessing cryptocurrencies often have safeguards in place to

ensure that their cryptocurrencies become further secured in the

event that their assets become potentially vulnerable to seizure

and/or unauthorized transfer.

19. Some companies offer cryptocurrency wallet services

which allow users to download a digital wallet application onto

their smart phone or other digital device. A user typically

accesses the wallet application by inputting a user-generated

PIN code or password. Users can store, receive, and transfer

cryptocurrencies via the application; however, many of these

companies do not store or otherwise have access to their users’

funds or the private keys that are necessary to access users’

wallet applications. Rather, the private keys are stored on the

device on which the wallet application is installed (or any

digital or physical backup private key that the user creates).

As a result, these companies generally cannot assist in seizing

or otherwise restraining their users’ cryptocurrency.

4 A QR code is a matrix barcode that is a machine-readable
optical label.
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 11 of 34 Page ID #:11

Nevertheless, law enforcement could seize cryptocurrency from

the user’s wallet directly, such as by accessing the user’s

smart phone, accessing the wallet application, and transferring

the cryptocurrency therein to a law enforcement-controlled

wallet. Alternatively, where law enforcement has obtained the

recovery seed for a wallet (see above), law enforcement may be

able to use the recovery seed phrase to recover or reconstitute

the wallet on a different digital device and subsequently

transfer cryptocurrencies held within the new wallet to a law

enforcement-controlled wallet.

V. BACKGROUND REGARDING REGULATIONS GOVERNING VIRTUAL CURRENCY
MONEY TRANSMITTAL

20. Based on my training and experience as well as

information provided by others, I am aware of the following:

a. The Bank Secrecy Act (“BSA”) is codified at 31

U.S.C. §§ 5313-5326. These laws were enacted by Congress to

combat the use of financial institutions to launder the proceeds

of crime. Title 31 U.S.C. § 310 establishes FinCEN as a bureau

within the U.S. Treasury Department, and describes FinCEN's

powers and duties to, among other things, to enforce compliance

with the BSA.

b. The definition of a financial institution under

the statute, 31 U.S.C. § 5312(a)(2)(R), includes “a licensed

sender of money or any other person who engages as a business in

the transmission of funds[.]” Under the relevant federal

regulations, financial institutions are also defined as “money

servicing businesses,” (“MSBs”) which include “money
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 12 of 34 Page ID #:12

transmitters.” See 31 C.F.R. § 1010.100(t)(3) (defining

“financial institution” as a “money servicing business”); 31

C.F.R. § 1010.100(ff)(5) (defining money transmitters as money

services businesses).

c. In 2013, FinCEN issued guidance that a money

transmitter can include an individual who offers exchange

services between virtual currency5 and fiat currency. See

Application of FinCEN's Regulations to Persons Administering,

Exchanging, or Using Virtual Currencies, FIN-2013-G001, issued

March 18, 2013 (the “FinCEN Guidance”). This guidance was

reaffirmed in May 2019. The FinCEN Guidance articulated that

those who are money transmitters because they offer exchange

services between virtual currency and fiat currency are also

MSBs and must comply with the applicable portions of the BSA,

some of which are described below.

d. Financial institutions, including MSBs and money

transmitters, are required to report each deposit, withdrawal,

exchange of currency, or other payment or transfer involving

more than $10,000 in currency. See 31 C.F.R. §§ 1022.300,

1022.310, 1022.311, and 1022.312 (cross-referencing 31 C.F.R. §§

1010.300, 1010.310, and 1010.311, and 1010.312); see also 31

U.S.C. § 5313(a). These reports are referred to as Currency

Transaction Reports (“CTRs”). A “transaction” for purpose of

filing a CTR includes “multiple currency transactions . . . if

the financial institution has knowledge that they are by or on

behalf of any person and result in either cash in or cash out

5 A brief background on virtual currency is described above.
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 13 of 34 Page ID #:13

totaling more than $10,000 during any one business day.” 31

C.F.R. § 1010.313. CTRs must be filed within 15 days following

the day on which the reportable transactions occurred. See 31

C.F.R. § 1010.306(a)(1). Financial institutions must verify and

record the name and address of the individual who conducted the

reportable transactions, and must accurately record the

identity, social security number, or taxpayer identification

number of any person or entity on whose behalf the reportable

transaction was conducted. See 31 C.F.R. § 1010.312. CTRs are

filed with FinCEN and are made available to law enforcement. It

is a federal crime under Title 31 for an MSB or money

transmitter to fail to file a CTR. See 31 U.S.C. §§ 5313(a) and

5322.

e. In addition to being required to file CTRs,

certain MSBs, including money transmitters, are required to file

suspicious activity reports (“SARs”). See 31 C.F.R. §§ 1022.320

(stating at sub-section (a)(1) that money transmitters are a

type of MSB required to file SARs). SARs must be filed on
transactions aggregating to at least $2,000 in value and the MSB

knows or has reason to suspect: (1) the funds are derived from

illegal activity or are intended to hide or disguise funds or

assets derived from illegal activity to violate or evade any

federal law or regulation; (2) the transaction is designed to

evade the Title 31 reporting requirements; (3) the transaction

services no apparent business or lawful purpose, and there is no

other reasonable explanation for the transaction; and (4) the

transaction involves use of the money transmitter to facilitate
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 14 of 34 Page ID #:14

criminal activity. See 31 C.F.R. §§ 1022.320(a)(2)(i)-(iv).

MSBs are required to file a SAR within 30 calendar days after

the date of the initial detection of the underlying facts that

warrant the filing of a SAR. See 31 C.F.R. §§ 1022.320(b)(3).

Lastly, MSBs are required to maintain supporting documentation

for the SAR for a period of five years from the date of filing

the SAR. See 31 C.F.R. §§ 1022.320(c). It is a federal crime

under Title 31 for a money transmitter to fail to file a SAR.

See 31 U.S.C. §§ 5318(g) and 5322.

f. Financial institutions, including MSBs and money

transmitters, are required to create and maintain effective

anti-money laundering compliance programs. See 31 U.S.C. §

5318(h)(1); see also 31 C.F.R. § 1010.210. The program must

have written policies, procedures, and controls governing the

verification of customer identification, the filing of reports

such as CTRs, the creation and retention of records, responses

to law enforcement requests, and other compliance with BSA

requirements. The anti-money laundering compliance program must

have a compliance officer who is responsible for assuring that

the business complies with all BSA requirements. It is a

federal crime under Title 31 for an MSB or money transmitter to

fail to maintain an effective anti-money laundering compliance

program. See 31 U.S.C. §§ 5318(h)(1) and 5322.

g. Any person who owns or controls an MSB is

responsible for registering, and periodically re-registering,

the business with FinCEN. See, 31 U.S.C. § 5330(a); see also 31

C.F.R. § 1022.380. Registration must be done on or before the
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end of the 180-day period beginning on the day following the

date the business was established. See, 31 C.F.R.

§ 1022.380(b)(3). A money transmitting business that fails to

U.S.C. § 1960. Specifically, § 1960 makes criminally liable

anyone who “knowingly conducts, controls, manages, supervises,

directs, or owns all or part of an unlicensed money transmitting

business.” That includes, under 18 U.S.C. § 1960(b)(1)(B), a

business that “fails to comply with the money transmitting

business registration requirements under section 5330 of title

31, United States Code, or regulations prescribed under such

section[.]”6

6 Unlicensed money remitting is prohibited by statute at
18 U.S.C. § 1960, which provides:
(a)Whoever knowingly conducts, controls, manages,
supervises, directs, or owns all or part of an unlicensed money
transmitting business, shall be fined in accordance with this
title or imprisoned not more than 5 years, or both.
The statute includes the following:
(1)the term “unlicensed money transmitting business” means
a money transmitting business which affects interstate or
foreign commerce in any manner or degree and—
(A)is operated without an appropriate money transmitting
license in a State where such operation is punishable as a
misdemeanor or a felony under State law, whether or not the
defendant knew that the operation was required to be licensed or
that the operation was so punishable;
(B)fails to comply with the money transmitting business
registration requirements under section 5330 of title 31, United
States Code, or regulations prescribed under such section; or
(C)otherwise involves the transportation or transmission of
funds that are known to the defendant to have been derived from
a criminal offense or are intended to be used to promote or
support unlawful activity;
(2)the term “money transmitting” includes transferring
funds on behalf of the public by any and all means including but
(footnote cont’d on next page)
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 16 of 34 Page ID #:16

h. Additionally, even if a money transmitter is

registered with FinCEN, 18 U.S.C. § 1960(b)(1)(C) also

criminalizes money transmitting businesses that “involve . . .

the transportation or transmission of funds that are known to

the defendant to have been derived from a criminal offense or

are intended to be used to promote or support unlawful

activity.”

21. In the scheme described below, GRIGORYAN and

MARTIROSYAN are engaged in unlicensed money transmitting

business, in that they are exchanging cryptocurrency for funds

in the form of United States currency, charging a fee as a

percentage of the amount of the transfer. Neither GRIGORYAN or

MARTIROSYAN are licensed or registered as money services

businesses with FinCEN, as required by federal statute.

VI. STATEMENT OF PROBABLE CAUSE

22. The Federal Bureau of Investigation (“FBI”), Drug

Enforcement Administration (“DEA”), Internal Revenue Service

(“IRS”), United States Postal Inspection Service (“USPIS”),

Homeland Security Investigations (“HSI”), and other law

enforcement agencies are investigating the money laundering

operation (“MLO”) associated with Samvel GRIGORYAN and Hayk

MARTIROSYAN, which – as an organization - engages in cash-for-

cryptocurrency monetary exchanges utilizing the business name

“coinexchange.am”.

not limited to transfers within this country or to locations
abroad by wire, check, draft, facsimile, or courier; . . . .
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 17 of 34 Page ID #:17

A. Identification of GRIGORYAN and MARTIROSYAN

23. In or about December 2021, GRIGORYAN, a citizen of

Armenia, attempted to cross the United States border from Mexico

into San Ysidro, California using a false American passport.

Upon being denied entry into the United States, GRIGORYAN and

his family claimed asylum from Armenia to U.S. immigration

officials and were subsequently paroled into the United States.

Upon entry, GRIGORYAN provided immigration authorities with

SUBJECT PREMISES 2 as his contact address.

24. In or about March 2023, Hayk MARTIROSYAN, a citizen of

Armenia, crossed the San Ysidro port of entry into the United

States, claimed asylum from Armenia to U.S. immigration

officials, and was paroled into the United States. MARTIROSYAN

also provided SUBJECT PREMISES 2 as his contact address.

B. Identification of Coinexchange.am

25. GRIGORYAN, MARTIROSYAN and co-conspirators, known and

unknown to the investigation, are associated with an established

Armenian website offering the exchange of fiat currency (e.g.,

United States currency) for cryptocurrency. The website URL is

“CoinExchange.AM”, and is available to read in Armenian,

English, and Russian. The home page states the “company has been

trading in cryptocurrencies since 2014.” Additionally, the home

page of the site states the business operates “offices abroad

Los Angeles Dubai: Iran: Georgia [sic].” The phone number +374

96 14 44 44 (“Subject Phone Number”) is listed on the top right

of the website. It is listed three times along the banner,
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 18 of 34 Page ID #:18

adjacent to icons for the Apple phone, Viber, and WhatsApp

applications.

a. I conducted additional open source research on

the social media platforms, including, Instagram and Tik Tok,

and found social media accounts advertising cryptocurrency

exchange services under the name “coinexchange.am”. Both pages

on Instagram and Tik Tok displayed videos promoting

cryptocurrency exchange services, one of which displayed a

billboard in what appeared to be a train station with the

company website on it, “Coinexchange.am”. Both the Instagram and

Tik Tok accounts listed the Subject Phone Number as contact

information in the bio section. Furthermore, on the Instagram

account which contained the advertisement for coinexchange.am,

the first post was published in August 2020.

C. Coinexchange.am not licensed with FinCEN

26. To date, no licensed business or corporation has been

discovered relating to either GRIGORYAN or MARTIROSYAN, or to

the SUBJECT PREMISES. According to a FinCEN transaction report

database, no currency transaction reports were ever filed

pertaining to the below transactions. Additionally, I queried

the FinCEN Money Service Business (“MSB”) database7 in or about

September 2023 which yielded negative results for GIRGORYAN,

MARTIROSYAN, and coinexchange.am.

7 The FinCEN MSB database allows users to query a list of
licensed MSB’s using individual names, Doing Business As (“DBA”)
names, or addresses, among other criteria for the purpose of
determining whether or not said criteria are related to any
licensed MSBs.
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 19 of 34 Page ID #:19

D. August 24, 2023 CHS Exchange

27. On August 21, 2023, at the direction of FBI Special

Agents, an FBI Confidential Human Source (“CHS”)8 contacted the

Subject Phone Number listed on coinexchange.am via WhatsApp

messages and voice chat, and spoke to an individual later

identified as GRIGORYAN. This communication was preserved and

recorded, and I have reviewed it and it contains GRIGORYAN’s

voice as I am familiar with it as a result of this

investigation. The recorded communications between GRIGORYAN

and CHS were conducted in the English language (CHS does not

speak Armenian). During the initial conversation on August 21,

2023, CHS informed GRIGORYAN that CHS found GRIGORYAN’s contact

information on the Coinexchange.am Instagram page. During this

conversation, CHS inquired if GRIGORYAN could conduct a cash for

cryptocurrency exchange, specifically, U.S. currency for Bitcoin

(“BTC”). During this first recorded conversation, GRIGORYAN

agreed to an exchange of $40,000 U.S. currency for BTC, plus a

5% commission rate, and requested to meet CHS in Glendale, CA,

on Thursday August 24, 2023.9

8 The CHS recently pleaded guilty to a violation of 21
U.S.C. § 841(a)(1) (Distribution of Methamphetamine) and is
cooperating with the government in the interest of obtaining
sentencing consideration. The CHS does not have any other prior
convictions. Agents have corroborated the information provided
by the CHS to the extent possible and believe the CHS to be
credible to the extent the CHS’s information is corroborated.
Additionally, the CHS has received occasional meals purchased by
the FBI during meetings between handling agents and the CHS.
9 After this initial interaction between CHS and GRIGORYAN,
I later viewed the WhatsApp messages between them and preserved
the communications.
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 20 of 34 Page ID #:20

28. During the morning of August 24, 2023, GRIGORYAN

communicated to CHS via WhatsApp text messages that the cash for

BTC exchange would take place that day at 1 p.m. in the vicinity

of Pelanconi Park, located in Glendale, California.

29. On August 24, 2023, investigators with DEA and FBI

established surveillance at Pelanconi Park, located in Glendale,

per GRIGORYAN’s instructions, in anticipation of the meeting

between GRIGORYAN and CHS. Prior to the meeting, investigators

provided CHS with $42,000 in U.S. currency contained in a brown

plastic bag. Investigators outfitted CHS with an audio

recording device and a transmitter so that investigators could

listen to the communications between CHS and GRIGORYAN real-time

as they were occurring. I heard the transmitted conversations

real-time on August 24, 2023 and I have read the transcript of

this meeting. On August 24, 2023, at approximately 1:20 pm,

investigators observed the initial meet and introduction between

the CHS, GRIGORYAN, and another unknown male (UM #1) in front of

(outside of) Pelanconi Park.

30. At approximately 1:27 pm, in front of Pelanconi Park,

CHS, who was carrying the bag of cash, and GRIGORYAN entered

SUBJECT VEHICLE 1. UM #1 did not enter SUBJECT VEHICLE 1 and

remained outside of the park, smoking a cigarette.

a. During the recorded meeting on August 24, 2023,

CHS gave the $42,000 in U.S. currency to GRIGORYAN, who counted

the cash in SUBJECT VEHICLE 1. GRIGORYAN told CHS that he would

send the BTC to CHS. Shortly thereafter, the FBI controlled

Bitcoin wallet furnished to the CHS received approximately
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 21 of 34 Page ID #:21

1.5329 Bitcoin (BTC) in exchange for the $40,000 USD. At the

time, 1.5329 BTC was worth, approximately, $40,000 USD. The

remaining $2,000 USD provided to GRIGORYAN was a 5% transaction

fee.

b. During this meeting, GRIGORYAN made comments that

demonstrated he regularly conducted cash-for-cryptocurrency

transactions. For instance, GRIGORYAN showed CHS his cell phone

which displayed a cryptocurrency application that detailed a

series of recent transactions GRIGORYAN had conducted with his

cryptocurrency wallet. According to the CHS, GRIGORYAN had

conducted several cryptocurrency transactions totaling between

$40,000 and $300,000 within the previous two days, the

implication being that GRIGORYAN has a ready supply of

cryptocurrency to exchange for high-volumes of USD. GRIGORYAN

stated that he conducted cryptocurrency transactions around the

world, to include the United States, Russia, and Europe.

GRIGORYAN stated he had recently conducted four cryptocurrency

transactions that totaled one million USD.

c. When GRIGORYAN asked about the nature of CHS’s

business, CHS stated “I’ll tell you next time.” CHS indicated

their business was buying something from China to bring to the

United States. GRIGORYAN stated that he had “more friends who

want dollar in China”, and implied that he was interested in

conducting additional business with CHS in the future.

GRIGORYAN also advised CHS to use the cryptocurrency United
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 22 of 34 Page ID #:22

States Dollar Tether (USDT) instead of BTC as it was more

convenient for transferring money overseas.10

d. Upon completing the cash for cryptocurrency

exchange, GRIGORYAN indicated the CHS had good reason to trust

him, as exchanging was his business and how he provided for his

children. GRIGORYAN stated “Trust me, don’t worry . . . it’s my

business. I have kids, you understand? … If I lie, I can’t help

. . .” Based on the context of the entire conversation,

GRIGORYAN was attempting to gain CHS’s trust for future

cryptocurrency transaction by inferring to CHS that

cryptocurrency transactions are GRIGOYAN’s main source of

revenue.

e. At approximately 1:30 pm, the investigative team

observed GRIGORYAN handing the aforementioned brown plastic bag

containing $42,000 from inside SUBJECT VEHICLE 1 to UM #1, who

took the bag and entered a white Kia sedan, CA license plate

9CBX945 (white Kia), registered at SUBJECT PREMISES 2.11 UM #1

drove away alone from Pelanconi Park in the white Kia and,

10Based on my training and experience, USDT is often used
in illicit transactions as it is widely considered less volatile
than other cryptocurrencies. As such, it can be a preferred
method of transferring cryptocurrency funds that would otherwise
be difficult to execute, such as transactions across borders or
transactions that would typically be subject to anti-money
laundering regulations.
11Per records from the CA Department of Motor Vehicles (“CA
DMV”), SUBJECT VEHICLE 1 is registered to Lessee Dealmakers
Group Inc./Aram Markaryan at location 6627 Colbath Ave, Van Nuys
CA 91405. Per records from the CA DMV, SUBJECT VEHICLE 2 is
registered to Arpine Dadrian or Tigran Petrosyan, address 1229
Viola Avenue 7, Glendale, CA. Per records from CA DMV, the
White Kia sedan is registered to Galina Zargaryan (believed to
be GRIGORYAN's mother), at address 416 W. Wilson Avenue, Apt D,
Glendale CA (SUBJECT PREMESIS 2).
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 23 of 34 Page ID #:23

approximately, five minutes later was observed by a law

enforcement agent pulling into the driveway at SUBJECT PREMISES

1. During this same time period, GRIGORYAN and CHS walked into

Pelanconi Park.

f. At approximately 1:35 pm, SUBJECT VEHICLE 2 was

observed leaving the driveway of SUBJECT PREMISES 1, and a few

minutes later SUBJECT VEHICLE 2 arrived at Pelanconi Park with

UM #1 driving and MARTIROSYAN travelling as a passenger in the

vehicle. Thereafter, law enforcement agents observed

MARTIROSYAN and UM #1 exit SUBJECT VEHICLE 2 at Pelanconi Park,

near GRIGORYAN and CHS, who were still in the park.

g. At approximately, 1:40 pm, law enforcement agents

observed MARTIROSYAN, GRIGORYAN, CHS and UM #1 all meet-up in

Pelanconi Park.

h. During the recorded meeting on August 24, 2023,

CHS asked GRIGORYAN if he was available to conduct another cash

for BTC exchange in the coming weeks, to which GRIGORYAN replied

“For next time, uh, bro, for next time. Uh, You give all this

brother or my, another brother. . . You give him, uh, dollar. I

send. . . Okay, you give him dollar, he go. I send it. It’s

okay for you, we can work.”

i. During the meeting between MARTIROSYAN,

GRIGORYAN, CHS and UM #1, in Pelanconi Park, GRIGORYAN

introduced MARTIROSYAN as his “brother” to the CHS, and

indicated to CHS that CHS would be working with MARTIROSYAN in

future cash-for-cryptocurrency deals. GRIGORYAN indicated,

however, that CHS should continue to contact GRIGORYAN at the
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 24 of 34 Page ID #:24

Subject Phone Number in order set up the logistics in advance.

GRIGORYAN stated “my another brother now come. You see him face.

Okay? . . . For next time . . . You give him, if I . . . can’t

see you, you see him”, referring to MARTIROSYAN. GRIGORYAN also

indicated he had an office in Armenia and that he was well-known

in the Armenian cryptocurrency exchange market, saying, “I have

office in my country. . . every people who . . . selling or

buying crypto know who I am.”

31. At approximately 1:50 pm, the meeting between CHS,

GRIGORYAN, MARTIROSYAN, and UM #1 concluded. CHS departed the

meeting location and the rest of participants left.

Approximately two minutes later, SUBJECT VEHICLE 2, with

MARTIROSYAN and UM#1 in the vehicle, was observed by a law

enforcement agent arriving at SUBJECT PREMISES 1.

32. At approximately 2:55 pm, surveillance units observed

SUBJECT VEHICLE 1 in the alleyway behind SUBJECT PREMISES 2.

GRIGORYAN then exited the vehicle and walked into the unit

closest to the alley at SUBJECT PREMISES 2.

E. August 28, 2023 CHS Exchange

33. On August 28, 2023, CHS contacted GRIGORYAN over a

WhatsApp communication and arranged for another cash-for-crypto

transaction. During this communication, according to the CHS,

GRIGORYAN agreed to provide CHS with $60,000 worth of

cryptocurrency in exchange for $60,000 USD currency with an

additional transaction fee of 5% to be paid to GRIGORYAN, for a

total amount of $63,000. According to CHS, during these

communications, GRIGORIAN agreed with CHS to do the cash-for-
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 25 of 34 Page ID #:25

crypto transaction at 2:00 pm at Pelanconi park in Glendale,

California.

a. Prior to the meeting between GRIGORYAN and CHS,

FBI agents equipped the CHS with an audio recording device and

transmitter, and counted the $63,000 USD before it was provided

to the CHS.

34. At approximately 2:00 pm, law enforcement agents

observed SUBJECT VEHICLE 2 arrive at Pelanconi Park.

Surveillance units observed MARTIROSYAN and GRIGORYAN exit the

vehicle. Shortly thereafter, CHS arrived at Pelanconi Park and

met with MARTIROSYAN and GRIGORYAN. CHS, MARTIROSYAN and

GRIGORYAN then entered SUBJECT VEHICLE 2. CHS was seen entering

SUBJECT VEHICLE 2 holding a white pastry box containing the

$63,000 previously provided to the CHS by agents. The cash was

then counted in the car and the transaction commenced.

a. During this meeting CHS stated to MARTIROSYAN and

GRIGORYAN, in summary, that the cash provided for the exchange

was derived from proceeds of illicit drug transactions, which

MARTIROSYAN and GRIGORYAN acknowledged during the transaction.

At one point, after CHS described the drug dealing business,

GRIGORYAN, in the presence of MARTIROSYAN and the CHS, asked

“Your people, uh . . . ship here drugs?”, to which the CHS

replied “No, no, not here. Mexico.” Later, in the conversation,

CHS stated “so Mexico, they-they know how to make it ‘cause

right now, you can’t do anything. It’s just the chemical, but

in Mexico, they make it into a pill and then the pill, they send

over here. And then, once they send it, right, it’s completely
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 26 of 34 Page ID #:26

. . . people buy it just like that. One deal, it’s over. I get

a whole bunch of cash and then, we have to send more money to

China to buy the chemicals there.” Subsequently, GRIGORYAN and

MARTIROSYAN conversed in a foreign language (likely, Armenian),

after which GRIGORYAN said to the CHS “Everything is good.”12

b. At the conclusion of the transaction, the FBI

controlled Bitcoin wallet furnished to the CHS received

approximately 2.307 Bitcoin (the approximate value of $60,000

USD, at the time) in exchange for the $60,000 cash.

c. Once the transaction was completed, CHS exited

SUBJECT VEHICLE 2 empty-handed. Shortly thereafter, MARTIROSYAN

and GRIGORYAN departed the area in SUBJECT VEHICLE 2. A law

enforcement surveillance team followed SUBJECT VEHICLE 2, which

was last observed in the vicinity of SUBJECT PREMISES 2.

F. September 6, 2023 CHS Exchange

35. On September 4, 2023, CHS contacted GRIGORYAN over a

WhatsApp communication and arranged for another cash-for-crypto

transaction. During these communications (text messaging was

preserved), GRIGORYAN agreed to conduct a cash-for-crypto

exchange in the amount of $40,000 to be executed on September 6,

2023, plus a fee of 5% to GRIGORYAN, for total amount of

$42,000. GRIGORYAN agreed to conduct the cash-for-crypto on

September 6, 2023 in Pelanconi Park in Glendale, California.

12At the conclusion of this discussion, CHS stated to
GERGORIAN and MARTIROSYAN, “I mean, you know my business, I mean
I-I don’t wanna scare you, you know what I mean”, to which
GRIGORYAN replied, “I’m more scared than you.”
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 27 of 34 Page ID #:27

36. Prior to the September 6, 2023 meeting, investigating

agents supplied CHS with a brown paper bag containing $42,000 in

cash and equipped the CHS with an audio recording device and a

transmitter. The investigative team conducted surveillance of

the meeting location in the park as well as SUBJECT PREMISES 1

and 2.

37. At approximately 2:00 pm, SUBJECT VEHICLE 2 was

observed departing SUBJECT PREMISES 1. At approximately 2:04

pm, SUBJECT VEHICLE 2, arrived at Pelanconi Park in Glendale.

MARTIROSYAN was observed exiting the vehicle and walked to the

park. MARTIROSYAN and GRIGORYAN met near a staircase near the

baseball fields. MARTIROSYAN and GRIGORYAN subsequently walked

to the east side of the park and met with CHS.

38. At approximately 2:06 pm, agents conducting

surveillance observed, in the park, CHS hand the bag containing

the $42,000 cash to MARTIROSYAN, who then walked back to SUBJECT

VEHICLE 2 and departed the park.

a. The investigative team, utilizing aerial
surveillance, observed MARTIROSYAN drive SUBJECT VEHICLE 2

directly to SUBJECT PREMISES 1. SUBJECT VEHICLE 2 arrived at

SUBJECT PREMISES 1 at approximately 2:12 pm. Upon arrival at

SUBJECT PREMISES 1, MARTIROSYAN exited SUBJECT VEHICLE 2 and

walked between the buildings in the rear of SUBJECT PREMISES 1,

toward the entrance to the detached unit, as described in

Attachment A-3. After approximately six (6) minutes,

MARTIROSYAN was observed walking out of the space between the
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 28 of 34 Page ID #:28

two buildings of SUBJECT PREMISES 1 and entered SUBJECT VEHICLE

39. Meanwhile, after MARTIROYSAN departed the park, CHS

and GRIGORYAN finished conducting the transaction in the park,

in which GRIGORYAN charged 5% commission on an exchange of

$40,000 cash for USDT cryptocurrency.

a. At the conclusion of the transaction, the FBI

controlled USDT wallet furnished to the CHS received

approximately 39,850 USDT in exchange for the $40,000 cash,

roughly the value of 39,850 USDT at the time.

b. During the meeting, GRIGORYAN stated that all

further business would likely be handled by MARTIROSYAN as

GRIGORYAN planned to leave United States and return to Armenia

on either September 10 or 12, 2023.

40. Based on conversations with an HSI agent, once an

individual with a pending asylum status departs the United

States, that individual would not typically be granted entry

into the United States upon their return.

VII. TRAINING AND EXPERIENCE REGARDING EVIDENCE ASSOCIATED WITH
MONEY LAUNDERING AND VIRTUAL CURRENCY

106. I know from my training and experience that unlicensed

money transmitters, engaged in exchanging virtual currency for

cash, and money launderers in general, also keep records of

finances of their customers, including logs of transactions of

money provided to them and money provided in exchange, and in

some cases, the commission or fee earned for the transaction.

Particularly in cases where these individuals engage in peer-to-
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 29 of 34 Page ID #:29

peer transactions (i.e., transactions on a customer-to-customer

basis), exchangers and launderers keep records, either digitally

or manually, of the volume of exchanges they have conducted.

These exchangers may also retain information regarding their

Bitcoin wallets, the Bitcoin wallets of their customers/clients,

and other information regarding Bitcoin accounts. (This would

apply to other virtual currencies as well.)

107. Individuals involved in virtual currency, including

those who launder funds by using virtual currency, use a variety

of digital devices, such as phones and computers. These

individuals also use multiple digital devices in order to

maintain anonymity and to compartmentalize communication, or use

encrypted forms of communication in speaking with criminal

associates. These digital devices are frequently carried on the

person themselves.

68. Also, based on my experience and training and

knowledge of virtual currency and money laundering, I am aware

that unlicensed money transmitters also store wealth in other

forms, such as gift cards (also known as cash cards), precious

metals, or casino chips. Because launderers prefer to stay

outside of the regulated banking and financial system (to avoid

detection), these forms of wealth are other mediums to exchange

and/or store money.

69. Money launderers who deal with significant amounts of

cash and/or other illicit contraband also have more than one

location where they store such contraband or records of

contraband. I believe the SUBJECT PREMISES 1 and 2 are such
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 30 of 34 Page ID #:30

locations based on funds from CHS transactions being taken

directly to both locations.

VIII. TRAINING AND EXPERIENCE ON DIGITAL DEVICES13

70. Based on my training, experience, and information from

those involved in the forensic examination of digital devices, I

know that the following electronic evidence, inter alia, is

often retrievable from digital devices:

a. 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.

b. Digital devices often contain electronic evidence

related to a crime, the device’s user, or the existence of

evidence in other locations, such as, how the device has been

13As used herein, the term “digital device” includes any
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.
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 31 of 34 Page ID #:31

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.

c. 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.

d. 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.

71. 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 for data
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 32 of 34 Page ID #:32

during a search of the premises for a number of reasons,

including the following:

a. 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.

b. 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.

72. The 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:

a. 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
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 33 of 34 Page ID #:33

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.

b. 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.

c. 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 GRIGORYAN’s and MARTIROSYAN’s thumb

and/or fingers on the device(s); and (2) hold the device(s) in

front of GRIGORYAN’s and MARTIROSYAN’s faces with his or her

eyes open to activate the facial-, iris-, and/or retina-

recognition feature.

d. Other than what has been described herein, to my

knowledge, the United States has not attempted to obtain this

data by other means.

IX. CONCLUSION

73. For all of the reasons described above, there is

probable cause to believe that GRIGORYAN and MARTIROSYAN have
Case 2:23-cr-00468-TJH Document 1 Filed 09/08/23 Page 34 of 34 Page ID #:34

committed a violation of 18 U.S.C. §§ 371, 1960 (Conspiracy to

Operate an Unlicensed Money Transmitting Business) and there is

probable cause to believe that GRIGORYAN has committed a

violation of 18 U.S.C. § 1960 (Operating an Unlicensed Money

Transmitting Business).

74. In addition, for all the reasons described above,

there is probable cause to believe that the items listed in

Attachment B, which constitute evidence, fruits, and

instrumentalities of violations of the SUBJECT OFFENSES, will be

found in a search of GRIGORYAN and MARTIROSYAN, and at SUBJECT

PREMISES 1 and SUBJECT PREMISES 2, as well as in SUBJECT VEHICLE

1 and SUBJECT VEHICLE 2, as described in Attachments A-1 through

A-6.

Attested to by the applicant in
accordance with the requirements
of Fed. R. Crim. P. 4.1 by
8th day of
telephone on this ____
September, 2023.

THE HONORABLE MARIA A. AUDERO
UNITED STATES MAGISTRATE JUDGE

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