Indictment — United States v. Vahe Margaryan et al., Central District of California (Document 155)

Summary

A grand jury indictment in United States v. Vahe Margaryan, aka "William McGrayan," Sarkis Sarkisyan, aka "Samuel Shaw," and Aksel Markaryan, aka "Axel Mark," CR 2:25-CR-00458-AB, in the United States District Court for the Central District of California, filed June 10, 2025 as Document 155. Counts One through Twenty-Five charge bank fraud under 18 U.S.C. § 1344(2), alleging that from about June 2020 through about January 2025 the defendants used shell companies and fabricated financial statements, resumes and tax returns to obtain SBA-guaranteed Preferred Lender Program loans. Further counts charge money laundering conspiracy under 18 U.S.C. § 1956(h) and transactional money laundering. Later counts charge Sarkisyan with wire fraud over a PPP loan of $786,457 to Prime Funding, Inc. and its forgiveness application.

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UNITED STATES OF AMERICA,
Plaintiff,
Vv.

VAHE MARGARYAN,

aka “William McGrayan,
SARKIS SARKISYAN,

aka “Samuel Shaw,” and
AKSEL MARKARYAN,

aka “Axel Mark,”

Defendants.

The Grand Jury charges:

A. INTRODUCTORY ALLEGATIONS

Hase 2:25-cr-00458-CV Document 155 Filed 06/10/25 Page1lof19 PageID mop

FILED

CLERK, U.S. DISTRICT COURT

6/10/2025

CENTRAL DISTRICT OF CALIFORNIA
BY: MMC

DEPUTY

UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA

January 2025 Grand Jury

CR 2:25-CR-00458-AB

INDICTMENT

[18 U.S.C. § 1344(2

Bank

Fraud; 18 U.S.C. § 1956(h):

Money Laundering Conspiracy;

18 U.5.C. § 1957:
Transactional Money
Laundering]

COUNTS ONE THROUGH TWENTY-FIVE

[18 U.S.C. §§ 1344(2), 2]

At times relevant to this Indictment:
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‘i Defendants VAHE MARGARYAN, also known as (“aka”)
“William McGrayan” (MCGRAYAN), SARKIS SARKISYAN, aka “Samuel
Shaw” (SARKISYAN), and AKSEL MARKARYAN, aka “Axel Mark”
(MARKARYAN), were residents of Los Angeles County, California.

2. Grasshopper Bank (“GB”), First Internet Bank of
Indiana, Byline Bank, First Citizens Bank of North Carolina,
Ameris Bank, and JPMorgan Chase Bank (“JPMC”) were financial
institutions, the deposits of which were insured by the Federal
Deposit Insurance Corporation.

3. The United States Small Business Administration
(“SBA”) guaranteed certain loans vetted and originated by
financial institutions pursuant to the SBA’s “Preferred Lender
Program” (“PLP”). PLP loans were offered to small businesses or
individuals, seeking to buy or improve small businesses, who
might not be eligible for loans through normal lending channels.

4. Dynamic Delivery Install, Inc. (“DDI”); American Best
Filter, Inc. (“ABF”); Olympus AXV Solutions, Inc. (“OAS”);
Canmar Promo Corp (“CPC”); Dynamic IT Solutions, Inc. (“DIS”);
Mass Exclusive LLC; Prime Funding, Inc. (“Prime”); Arms of
Olympus LLC (“AOO”); Alpha Omega Solutions LLC (“AOS”); Hawk
Fleet LLC (“Hawk Fleet”); Global Dynamic IT (“GDI”); Global
Ultimate Management (“GUM”); Stavros Auto Group, Inc.
(“Stavros”); Alex Titan Solutions, Inc. (“ATS”); and Titan
Solutions, Inc. (“Titan”) were among the group of shell
companies that defendant MCGRAYAN and others known and unknown

to the Grand Jury created and caused to be created.
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Bs THE SCHEME TO DEFRAUD

te Beginning on a date unknown, but at least in or about
June 2020, and continuing through at least in or about January
2025, in Los Angeles County, within the Central District of
California, and elsewhere, defendants MCGRAYAN, SARKISYAN, and
MARKARYAN, together with others known and unknown to the Grand
Jury, each aiding and abetting each other, knowingly and with
intent to defraud, executed and attempted to execute a scheme to
obtain money, funds, credits, assets, and other property owned
by and in the custody and control of financial institutions by
means of material false and fraudulent pretenses,
representations, and promises.

6. The scheme to defraud operated, in substance, as
follows:

a. Defendants SARKISYAN and MARKARYAN, and others at
defendant MCGRAYAN’s direction posed as owners and operators of
newly formed or dormant business entities that, in fact, were
merely shells that conducted no business activity. They did so,
knowing they had no intention to actually conduct business
through these shell companies.

b. Defendants SARKISYAN and MARKARYAN, and others at
defendant MCGRAYAN’s direction opened bank accounts in the names
of such shells, including, for example, a JPMorgan Chase Bank
account ending in 0835 (“JPMC 0835”) in the name of DDI opened
by defendant MARKARYAN at defendant MCGRAYAN’s direction. At
defendant MCGRAYAN’s direction, defendants SARKISYAN and

MARKARYAN and others who opened these accounts gave defendant
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MCGRAYAN and other co-schemers permission to access and transact
business using the accounts, including by providing passcodes
and blank checks and by facilitating remote computer access via
software programs.

CG. In order to fraudulently induce financial
institutions to make PLP loans to the shell companies and to
believe that the shell companies would use the loan proceeds to
purchase legitimate and ongoing business concerns, defendants
MCGRAYAN, SARKISYAN, and MARKARYAN, and others at defendant
MCGRAYAN’s direction, made false statements and fabricated and
provided fabricated documents in connection with applications
for PLP loans for those shell companies, including an
application for a $2.83 million PLP loan from GB to DDI. Such
false statements and fabricated documents included fabricated
bank and financial statements, phony resumes that described
purported extensive work histories or other qualifications, and
fraudulent federal income tax returns that defendants MCGRAYAN,
SARKISYAN, and MARKARYAN and others at defendant MCGRAYAN’s
direction would file and cause to be filed.

a. As defendants MCGRAYAN, SARKISYAN, and MARKARYAN
knew and intended, the financial institutions would rely on
these false statements and fabricated documents in funding PLP
loans for the shell companies.

e. Defendants MCGRAYAN, SARKISYAN, and MARKARYAN
used and caused the use of such PLP loan proceeds, obtained from
the fraud on the financial institutions, for personal use and to

create the appearance of cash flow for other shell companies to
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support further fraudulent applications for PLP funds.
Additionally, in order to conceal the disposition of the PLP
loan proceeds and the fact that they were used for purposes not
authorized by the loans’ terms, defendants MCGRAYAN, SARKISYAN,
and MARKARYAN, and others at defendant MCGRAYAN’s direction
regularly layered funds, i.e., transferred the proceeds of
fraudulently obtained PLP loans and other fraudulently obtained
funds into and out of the shell company accounts, including by
depositing checks and transferring funds from one shell company
to another.

Cre THE EXECUTIONS OF THE SCHEME

7. On or about the following dates, within the Central
District of California and elsewhere, the defendants named below
committed and willfully caused others to commit the following
acts, each of which constituted an execution or attempted

execution of the fraudulent scheme:

COUNT DATE DEFENDANT (S) | ACT

ONE 5/17/2021 |MCGRAYAN Submission to Byline Bank
of Business Purchase
Agreement and Joint Escrow
Instructions purporting to
show that OAS was
purchasing the assets of
ABF for $2.6 million, in
support of PLP loan for OAS

TWO 11/1/2021 |MCGRAYAN Submission to Byline Bank
of fraudulent lease for
office space located at 345
W. Foothill Blvd., Suite 5,
Glendora, CA, in support of
PLP loan for OAS
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Gase 2:25-cr-00458-CV Document 155

Filed 06/10/25

COUNT

DATE

DEFENDANT (S)

ACT

THREE

11/12/2021

MCGRAYAN

Wire transfer of $2,139,941
proceeds of PLP loan for
OAS to Bank of America
account ending in 3882

FOUR

2/14/2023

MCGRAYAN
SARKISYAN

Submission to GB of
fraudulent federal income
tax returns for defendant
SARKISYAN for calendar
years 2020 and 2021 in
support of PLP loan for DIS

FIVE

3/7/2023

MCGRAYAN

Submission to Ameris Bank
of Business Purchase
Agreement and Joint Escrow
Instructions purporting to
show that CPC was
purchasing Mass Exclusive
LLC for $2.9 million in
support of PLP loan for CPC

SIX

3/7/2023

MCGRAYAN

Submission to Ameris Bank
of Internal Revenue Service
(“IRS”) Form 4506-T
permitting Ameris Bank to
obtain copy of calendar
years 2020 and 2021 IRS
Form 1120 tax returns for
CPC that (falsely) reported
revenue and tax due and
owing, in support of PLP
loan for CPC

SEVEN

3/14/2023

MCGRAYAN

Wire transfer of loan
proceeds for PLP loan for
CPC of $2,242,761 to Escrow
Company 1

EIGHT

4/3/2023

MCGRAYAN
SARKISYAN
MARKARYAN

Submission to GB of
fraudulent resume for
defendant SARKISYAN in
support of PLP loan for DIS

Page 6o0f19 Page ID #:341
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COUNT DATE DEFENDANT (S) | ACT
NINE 6/8/2023 MCGRAYAN Submission to GB of
SARKISYAN Business Purchase Agreement
MARKARYAN and Joint Escrow
Instructions purporting to
show that defendant
SARKISYAN, on behalf of
DIS, was purchasing DDI
from defendant MARKARYAN
for $3.1 million in support
of PLP loan for DIS
TEN 6/13/2023 | MCGRAYAN Wire transfer of loan
SARKISYAN proceeds of $2,748,546.18
MARKARYAN from PLP loan for DIS from
GB to Escrow Company 1
ELEVEN 6/14/2023 | MCGRAYAN Deposit of check from
SARKISYAN Escrow Company 1 to JPMC
MARKARYAN 0835 for $3,021, 606.38
comprising loan proceeds
from PLP loan for DIS from
GB
TWELVE 6/28/2023 | MCGRAYAN Online transfer of $25,000
SARKISYAN from JPMC 0835 to Prime
MARKARYAN
THIRTEEN | 6/28/2023 | MCGRAYAN Online transfer of
SARKISYAN $13,680.99 from JPMC 0835
MARKARYAN to AOO
FOURTEEN | 6/29/2023 | MCGRAYAN Online transfer of
SARKISYAN $10,280.95 from JPMC 0835
MARKARYAN to AOS
FIFTEEN 6/29/2023 | MCGRAYAN Online transfer of
SARKISYAN $13,580.75 from JPMC 0835
MARKARYAN to Hawk Fleet
SIXTEEN 11/1/2023 | MCGRAYAN Submission to First
MARKARYAN Internet Bank of Indiana
of Business Purchase
Agreement and Joint Escrow
Instructions purporting to
show that defendant
MARKARYAN, on behalf of
GDI, was purchasing GUM for
$3.65 million in support of
PLP loan for GDI

Page 7 of 19 Page ID #:342
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ase 2:25-cr-00458-CV Document 155

Filed 06/10/25

COUNT

DATE

DEFENDANT (S)

ACT

SEVENTEEN

11/1/2023

MCGRAYAN
MARKARYAN

Submission to First
Internet Bank of Indiana of
fraudulent resume for
defendant MARKARYAN in
support of PLP loan for GDI

EIGHTEEN

2/23/2024

MCGRAYAN
MARKARYAN

Submission to First
Internet Bank of Indiana of
fabricated bank statements
for defendant MARKARYAN for
JPMC account ending in 1343
in support of PLP loan for
GDI

NINETEEN

2/23/2024

MCGRAYAN
MARKARYAN

Wire transfer of $3,497,426
in loan proceeds from PLP
loan for GDI from First
Internet Bank of Indiana to
Escrow Company 1

TWENTY

8/29/2024

MCGRAYAN

Online request to First
Internet Bank of Indiana
for PLP loan of $2,855,000
for Stavros to purchase a
business to be designated

ONE

8/29/2024

MCGRAYAN

Submission to First
Internet Bank of Indiana of
fabricated bank statement
for Stavros USBank account
ending in 1844 in support
of PLP loan for Stavros

TWO

10/14/2024

MCGRAYAN

Submission to First
Citizens Bank of North
Carolina of Business
Purchase Agreement and
Joint Escrow Instructions
purporting to show that ATS
was purchasing Titan for $3
million in support of PLP
loan for ATS

TWENTY-
THREE

1/15/2025

MCGRAYAN

Submission to First
Citizens Bank of North
Carolina of fraudulent
“Alex Titan Solutions, Inc.
Business Plan 2024” in
support of PLP loan for ATS

Page 8 of 19 Page ID #:343
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Gase 2:25-cr-00458-CV Document 155

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COUNT DATE DEFENDANT (S) | ACT

TWENTY- 1/15/2025 | MCGRAYAN Submission to First

FOUR Citizens Bank of North
Carolina of fraudulent
“Arms of Olympus Accounts
Receivable Aging Report as
of October 31, 2024” in
support of PLP loan for AOS

TWENTY— 1/15/2025 | MCGRAYAN Submission to First

FIVE Citizens Bank of North

Carolina of IRS Form 4506-T
permitting First Citizens
Bank of North Carolina to
obtain copy of calendar
year 2024 IRS Form 1120 tax
return for Titan that
(falsely) reported $2.8
million in revenue and more
than $50,000 in tax due and
owing, in support of PLP
loan for ATS

Page 90f19 Page ID #:344
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Case 2:25-cr-00458-CV Document155_ Filed 06/10/25 Page10of19 Page ID
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COUNT TWENTY-SIX
[18 U.S.C. § 1956(h)]
8. The Grand Jury realleges paragraphs 1 through 4 and 6
through 7 of this Indictment here.

A. THE OBJECT OF THE CONSPIRACY

oF Beginning no later than in or about June 2020, and
continuing through at least in or about January 2025, in Los
Angeles County, within the Central District of California, and
elsewhere, defendants MCGRAYAN, SARKISYAN, and MARKARYAN
conspired with each other and others known and unknown to the
Grand Jury, to knowingly and intentionally conduct financial
transactions, knowing that the property involved in the
financial transactions represented the proceeds of some form of
unlawful activity, and which property was, in fact, the proceeds
of specified unlawful activity, namely, bank fraud, in violation
of Title 18, United States Code, Section 1344(2), with the
intent to conceal and disguise the nature, location, source,
ownership, and control of the proceeds.

B. . MANNER AND MEANS OF THE CONSPIRACY

10. The object of the conspiracy was carried out, and to
be carried out, in substance, in the manner described in
paragraphs 1 through 4 and 6 of this Indictment.

or OVERT ACTS

11. On or about the following dates, in furtherance of
the conspiracy and to accomplish its object, defendants
MCGRAYAN, SARKISYAN, and MARKARYAN, together with others known

and unknown to the Grand Jury, committed and willfully caused
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#:346

others to commit the following overt acts, among others, within
the Central District of California, and elsewhere:

Overt Act No. 1: Deposit of GB PLP proceeds check from

Escrow Company 1 to JPMC 0835 on June 14, 2023.

Overt Act No. 2: Online wire transfer of $43,000 to

Express Water Damage Restoration on June 27, 2023.

Overt Act No. 3: Online wire transfer of $120,000 to As

Management Inc on June 28, 2023.

Overt Act No. 4: Online payment of $13,690.99 to

Thunkked Out, Inc on June 28, 2023.

Overt Act No. 5: Online payment of $12,950.99 to Art

Mart, Inc. on June 28, 2023.

Overt Act No. 6: Online payment of $10,280.95 to AOS.

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COUNTS TWENTY-SEVEN THROUGH THIRTY-TWO
[18 U.S.C. §§ 1957(a), 2]

12. The Grand Jury realleges paragraphs 1 through 4, 6
through 7, and 11 of this Indictment here.

TS ss On or about the dates set forth below, in Los Angeles
County, within the Central District of California, and
elsewhere, defendants MCGRAYAN, SARKISYAN, and MARKARYAN,
knowing that the funds involved represented the proceeds of some
form of unlawful activity, each aiding and abetting the others,
engaged in and willfully caused others to engage in the
following monetary transactions in criminally derived property
of a value greater than $10,000, which property, in fact, was
derived from specified unlawful activity, namely, bank fraud, in
violation of Title 18, United States Code, Section 1344(2), "I

charged in Counts One through Twenty-Five of this Indictment:

COUNT DATE DEFENDANT (S) MONETARY TRANSACTION
TWENTY- | 11/4/2021 MCGRAYAN Check no. 1014 for
SEVEN $55,000 to Exceed

Companies from ABF Bank
of America account
ending in 3882,
comprising proceeds of
PLP loan for OAS

TWENTY- | 11/12/2021 | MCGRAYAN Check no. 1015 for

EIGHT $300,600 to ABF from ABF
Bank of America account
ending in 3882,
comprising proceeds of
PLP loan for OAS

TWENTY- | 11/12/2021 | MCGRAYAN Check no. 1017 for

NINE $450,500.99 to ABF from
ABF Bank of America
account ending in 3882,
comprising proceeds of
PLP loan for OAS

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Page 13 of 19 Page ID

COUNT DATE DEFENDANT (S) MONETARY TRANSACTION

THIRTY | 6/28/2023 | MCGRAYAN Online wire transfer of
SARKISYAN $25,000 from JPMC 0835
MARKARYAN to Prime

THIRTY- | 6/28/2023 | MCGRAYAN Online transfer of

ONE SARKISYAN $13,680.99 from JPMC
MARKARYAN 0835 to AOO

THIRTY- | 6/29/2023 | MCGRAYAN Online transfer of

TWO SARKISYAN $10,280.95 from JPMC
MARKARYAN 0835 to AOS

THIRTY- | 6/29/2023 | MCGRAYAN Online transfer of

THREE SARKISYAN $13,580.75 from JPMC
MARKARYAN 0835 to Hawk Fleet

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COUNTS THIRTY-FOUR THROUGH THIRTY-FIVE
[18 U.S.C. §§ 1343, 2]
14. The Grand Jury realleges paragraphs 1 through 2, 4,
and 6(a) through 6(b) of this Indictment here.

A. INTRODUCTORY ALLEGATIONS

At times relevant to this Indictment:

15. 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”). PPP loan proceeds were required to
be used by the applicant business to pay certain expenses such
as payroll costs, interest on mortgages, rent, and utilities.

16. In order to obtain a PPP loan, a qualifying business
was required, among other things, to submit an 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 PPP
loan. 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
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proceeds will be used only for business-related purposes as
specified in the [PPP loan 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.”

17. A PPP loan 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.

18. A PPP loan 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 PPP loan application was

approved, the participating lender would fund the PPP loan using

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#:351

its own funds and would wire-transfer those funds to a bank
account designated by the applicant.

19 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.

20. Under certain circumstances, PPP borrowers were
entitled to forgiveness of their PPP obligations. Asa
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.”

B. THE SCHEME TO DEFRAUD

A. Beginning in or about April 2021, and continuing
through at least in or about June 2022, in Los Angeles County,
within the Central District of California, and elsewhere,
defendant SARKISYAN, together with others known and unknown to
the Grand Jury, each aiding and abetting the other, knowingly
and with the intent to defraud, devised, participated in, and
executed a scheme to defraud JPMC and the SBA as to material
matters, and to obtain money and property from JPMC and the SBA,

namely, a PPP loan for Prime and forgiveness of that PPP loan,
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by means of material false and fraudulent pretenses,
representations, and promises.

Ze The scheme to defraud operated, in substance, as
follows:

a. Defendant SARKISYAN submitted to JPMC an online
application for a PPP loan for Prime in which defendant
SARKISYAN falsely and fraudulently represented, among other
things, that Prime was an established business whose average
monthly payroll was $314,583 and that Prime had approximately 56
employees.

lon Defendant SARKISYAN fabricated and caused to be
fabricated and submitted to JPMC false Internal Revenue Service
Forms 941 (quarterly payroll tax returns) and false payroll
reports that purported to show that Prime had approximately 56
employees.

Cis In reliance on the false statements and
fabricated documents defendant SARKISYAN made and submitted,
JPMC approved a PPP loan for Prime and JPMC electronically
transferred the proceeds of that loan via interstate wire into a
Prime bank account controlled by defendant SARKISYAN and others
known and unknown to the Grand Jury.

d. Defendant SARKISYAN used the proceeds of the PPP
loan for Prime for personal and other impermissible uses under
PPP rules.

e. Defendant SARKISYAN submitted to SBA an online
application seeking forgiveness of the PPL loan for Prime in

which defendant SARKISYAN falsely and fraudulently represented,
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among other things, that Prime used the entirety of its PPP loan
proceeds of $786,457, disbursed on or about April 16, 2021, for
Prime’s business costs that were eligible for forgiveness.

Ci USE OF THE WIRES

23. On or about the following dates, in Los Angeles
County, within the Central District of California, and
elsewhere, defendant SARKISYAN, together with others known and

unknown to the Grand Jury, for the purpose of executing the

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Case 2:25-cr-00458-CV Document 155

above-described scheme to defraud,

Filed 06/10/25
#:354

Page 19 of 19 Page ID

transmitted and caused the

transmission of the following wire communications in interstate

commerce:

COUNT DATE

WIRING

THIRTY-FOUR 4/14/2021 | Online submission of PPP loan
application to JPMC on behalf of Prime

THIRTY-FIVE 6/30/2022 | Online submission of PPP Loan
Forgiveness Application to JPMC on
behalf of Prime

BILAL A. ESSAYLI
United States Attorney

CHRISTINA T. SHAY
Assistant United States Attorney
Chief, Criminal Division

KRISTEN A. WILLIAMS
Assistant United States Attorney
Chief, Major Frauds Section

MARK AVEIS

GREGG MARMARO

Assistant United States Attorneys
Major Frauds Section

19

A TRUE BILL

/S/

Foreperson


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