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Indictment — United States v. Arsen Terzyan, Central District of California (Document 64)

Summary

A grand jury indictment in United States v. Arsen Terzyan, aka "Steven Terzaki," CR 2:25-CR-00456-MWC, in the United States District Court for the Central District of California, filed June 10, 2025 as Document 64. Counts One through Seven charge wire fraud under 18 U.S.C. § 1343, alleging that from about January 2021 through about December 2021 Terzyan submitted EIDL and Restaurant Revitalization Fund applications for Grub House, Inc. that misstated its income and expenses and misused the proceeds. The listed wires include EIDL proceeds of $149,900 and RRF proceeds of $1,864,830 deposited to a Grub House account. Counts Eight through Eighteen charge transactional money laundering under 18 U.S.C. § 1957 for checks from that account, and forfeiture allegations follow.

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“Indictment — United States v. Arsen Terzyan, Central District of California (Document 64).” Original at ecf.cacd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-usa-v-terzyan-dkt-64-c-d-cal-994bc477e5/, SHA-256 e0c065a8323bf5a88e513bf1217bf3ce5966bef42157266214616ed235d306ac.

Full text

     Case 2:25-cr-00456-MWC   Document 64   Filed 06/10/25   Page 1 of 9 Page ID #:84



 1                                                                    6/10/2025
 2                                                                        MMC



 3

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 7

 8                            UNITED STATES DISTRICT COURT

 9                     FOR THE CENTRAL DISTRICT OF CALIFORNIA

10                              January 2025 Grand Jury

11   UNITED STATES OF AMERICA,                   CR   2:25-CR-00456-MWC

12              Plaintiff,                       I N D I C T M E N T

13              v.                               [18 U.S.C. § 1343: Wire Fraud; 18
                                                 U.S.C. § 1957: Transactional Money
14   ARSEN TERZYAN,                              Laundering; 18 U.S.C. §§ 981, 982,
       aka “Steven Terzaki,”                     28 U.S.C. § 2461(c): Criminal
15                                               Forfeiture]
                Defendant.
16

17

18         The Grand Jury charges:

19                              COUNTS ONE THROUGH SEVEN

20                               [18 U.S.C. §§ 1343, 2]

21   A.    INTRODUCTORY ALLEGATIONS

22         At times relevant to this Indictment:

23         1.    Defendant ARSEN TERZYAN, also known as “Steven Terzaki,”

24   was a resident of Granada Hills, California.

25         2.    Defendant TERZYAN wholly owned an entity called Grub House,

26   Inc., a purported restaurant or food service business.               Defendant

27   TERZYAN was the sole signer on a business account for Grub House at

28   JPMorgan Chase ending in 3502 (“JPMC 3502”).

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     Case 2:25-cr-00456-MWC   Document 64   Filed 06/10/25   Page 2 of 9 Page ID #:85



 1         3.    The Coronavirus Aid, Relief, and Economic Security

 2   (“CARES”) Act was a federal law enacted in or about March 2020 that

 3   was designed to provide emergency financial assistance to Americans

 4   suffering economic harm as a result of the COVID-19 pandemic.               The

 5   CARES Act authorized taxpayer funds under the Economic Injury

 6   Disaster Loan program (individually, an “EIDL,” or collectively,

 7   “EIDLs”).    The EIDL program provided low-interest funding to small

 8   businesses, renters, and homeowners affected by the COVID-19

 9   pandemic.

10         4.     In order to obtain an EIDL, a qualifying business was

11   required to submit an application to the United States Small Business

12   Administration (“SBA”), typically through an online portal, and

13   provide information about its operations, such as the nature of the

14   applicant’s business, e.g., “agriculture,” the number of employees,

15   and gross revenues for the 12-month period preceding the Covid-19
16   pandemic.    EIDL applicants were required to certify that all
17   information in the application as provided by the applicant or on
18   behalf of the applicant by their authorized representative was true
19   and correct.
20         5.     An EIDL “Loan Authorization and Agreement” (“LA&A”) was
21   executed by the applicant’s authorized representative as a condition
22   of receipt of EIDL proceeds that stated that.            The LA&A required that
23   the applicant use the EIDL proceeds only for purposes stated in EIDL
24   rules, such as for employee payroll expenses, employee sick leave,
25   and business obligations and expenses such as business debts, rent,
26   and mortgage payments.      EIDL funds could not be used other than for
27   those purposes, including that such funds could not be deposited or
28   held for future business operations, used to capitalize a new
                                             2
     Case 2:25-cr-00456-MWC   Document 64     Filed 06/10/25   Page 3 of 9 Page ID #:86



 1   business or for business start-up expenses, or used for purposes not

 2   associated with the operation of a going concern.

 3         6.     The amount of an EIDL was determined, in part, by the

 4   applicant’s representations in the EIDL application about the nature

 5   of the applicant’s business and the applicant’s statements about

 6   employees, and revenue.      Any funds paid under an EIDL were issued

 7   directly by the SBA from CARES Act appropriations by Congress.

 8         7.     EIDL applicants were also obligated to provide true and

 9   correct information in response to requests by the SBA as part of the

10   EIDL vetting process, such as requests to clarify business ownership

11   and requests to provide genuine payroll tax documents such as IRS

12   Forms 940, 941, or W3 “Transmittal of Wage and Tax Statements.”

13         8.    In March 2021, the American Rescue Plan Act became law and

14   established the Restaurant Revitalization Fund (“RRF”) for which

15   Congress appropriated $28.6 billion for the SBA to award emergency

16   assistance to qualifying businesses that served food or drink,

17   essentially restaurants.      Entitlement was substantially based on

18   pandemic-caused revenue loss.          The RRF was a conditional grant

19   program, meaning that RRF recipients were not required to repay the

20   funds so long as those funds were used for specific expenses and by a

21   certain deadline.

22         9.     RRF applicants submitted personal and business

23   information, typically through an online SBA portal, in support of

24   each RRF application.      Among other things, applicants were required

25   to list all owners of 20% or more of the business.               The listing for

26   each owner required the owner’s Employer Identification Number

27   (“EIN”), Social Security number, or “Individual Taxpayer

28   Identification Number.”
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     Case 2:25-cr-00456-MWC   Document 64   Filed 06/10/25   Page 4 of 9 Page ID #:87



 1         10.    The SBA prioritized RRF awards to small businesses at

 2   least 51% owned and controlled by women, veterans, and/or the

 3   socially and economically disadvantaged.

 4         11.    RRF recipients were required to certify that they would

 5   use RRF proceeds for normal business operations such as for payroll

 6   costs, health care, business mortgages or rent.            Recipients were then

 7   required to submit a “post-award report” in which they certified that

 8   their RRF proceeds were used in compliance with the program.

 9   B.    THE SCHEME TO DEFRAUD

10         12.    Beginning in or about January 2021 and continuing through
11   at least in or about December 2021, in Los Angeles County, within the
12   Central District of California, and elsewhere, defendant TERZYAN,
13   together with others unknown to the Grand Jury, each aiding and
14   abetting the other, knowingly and with the intent to defraud,
15   devised, participated in, and executed a scheme to defraud the SBA
16   and the United States Treasury as to material matters, and to obtain
17   money and property from SBA and the United States Treasury, namely,
18   EIDL and RRF benefits, by means of material false and fraudulent
19   pretenses, representations, and promises, and the concealment of
20   material facts.
21         13.    The fraudulent scheme operated, in substance, as follows:
22               a.    Defendant TERZYAN filed and caused to be filed EIDL
23   and RRF applications on Grub House’s behalf, including an application
24   to modify Grub House’s EIDL to request a larger amount, that falsely
25   and fraudulently stated Grub House’s income and expenses, and falsely
26   certified that Grub House would use the EIDL and RRF funds for
27   expenses and business purposes authorized under the EIDL and RRF
28
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     Case 2:25-cr-00456-MWC   Document 64   Filed 06/10/25   Page 5 of 9 Page ID #:88



 1   programs, knowing those statements were false and intending that the

 2   SBA would rely on those material false statements.

 3                 b.   In reliance on defendant TERZYAN’s material false

 4   statements, representations, and certifications, the SBA approved

 5   Grub House for an EIDL and RRF grant, and funded those loan and grant

 6   proceeds through electronic deposits into JPMC 3502.

 7                 c.   Defendant TERZYAN fraudulently misused those EIDL and

 8   RRF proceeds for personal and other uses impermissible under the

 9   terms of the EIDL and RRF programs for which Grub House applied.

10   C.    USE OF THE WIRES

11         14.     On or about the following dates, in Los Angeles County,
12   within the Central District of California, and elsewhere, defendant
13   TERZYAN, together with others known and unknown to the Grand Jury,
14   for the purpose of executing the above-described scheme to defraud,
15   caused the transmission of the following wire communications in
16   interstate commerce:
17         COUNT            DATE                       WIRING
           ONE           1/30/2021   Electronic submission of Grub House EIDL
18                                   application
19         TWO           3/4/2021    Electronic submission of federal income
                                     tax transcript for Grub House
20         THREE         3/29/2021   Electronic submission of Grub House LA&A

21         FOUR          4/2/2021    Wire transfer of Grub House EIDL proceeds
                                     of $149,900 to JPMC 3502
22         FIVE          4/7/2021    Telephone call from defendant TERZYAN to
                                     SBA requesting EIDL modification
23         SIX           5/11/2021   Electronic submission of application for
24                                   Grub House RRF
           SEVEN         5/28/201    Wire transfer of Grub House RRF proceeds
25                                   of $1,864,830 to JPMC 3502

26

27

28
                                             5
     Case 2:25-cr-00456-MWC   Document 64   Filed 06/10/25   Page 6 of 9 Page ID #:89



 1                            COUNTS EIGHT THROUGH EIGHTEEN

 2                              [18 U.S.C. §§ 1957(a), 2]

 3           15.   The Grand Jury realleges paragraphs 1 through 11 and 13 of

 4   this Indictment here.

 5           16.   On or about the dates set forth below, in Los Angeles

 6   County, within the Central District of California, and elsewhere,

 7   defendant TERZYAN, knowing that the funds involved represented the

 8   proceeds of some form of unlawful activity, engaged in and willfully

 9   caused others to engage in the following monetary transactions, in

10   and affecting interstate commerce, in criminally derived property of

11   a value greater than $10,000, which property, in fact, was derived

12   from specified unlawful activity, namely, wire fraud, committed in

13   violation of Title 18, United States Code, Section 1343, as charged

14   in Counts One through Seven, inclusive, of this Indictment:

15    COUNT          DATE         MONETARY TRANSACTION
16    EIGHT          4/6/2021     Check no. 1199 for $24,970 from JPMC 3502
                                  to Humboldt Wholesale
17    NINE           6/4/2021     Check no. 1198 for $32,597 from JPMC 3502
                                  to Humboldt Wholesale
18
      TEN            6/4/2021     Check no. 1197 for $27,433 from JPMC 3502
19                                to Humboldt Wholesale
      ELEVEN         7/6/2021     Check no. 1244 for $27,440 from JPMC 3502
20                                to M.L.J.
      TWELVE         7/7/2021     Check no. 1243 for $22,560 from JPMC 3502
21                                to M.L.J.
      THIRTEEN       7/12/2021    Check no. 1233 for $30,275 from JPMC 3502
22                                to Standard Home Lending
      FOURTEEN       7/13/2021    Check no. 1234 for $29,725 from JPMC 3502
23                                to Standard Home Lending
      FIFTEEN        7/14/2021    Check no. 1235 for $18,440 from JPMC 3502
24                                to Ikon Development Corp.
      SIXTEEN        7/15/2021    Check no. 1236 for $21,560 from JPMC 3502
25                                to Ikon Development Corp.
      SEVENTEEN      7/15/2021    Check no. 1249 for $22,700 from JPMC 3502
26                                to M.A.
27    EIGHTEEN       7/30/2021    Check no. 1269 for $42,330 from JPMC 3502
                                  to TT Trade Inc.
28
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     Case 2:25-cr-00456-MWC   Document 64   Filed 06/10/25   Page 7 of 9 Page ID #:90



 1                             FORFEITURE ALLEGATION ONE

 2               [18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c)]

 3         17.   Pursuant to Rule 32.2 of the Federal Rules of Criminal

 4   Procedure, notice is hereby given that the United States of America

 5   will seek forfeiture as part of any sentence, pursuant to Title 18,

 6   United States Code, Section 981(a)(1)(C) and Title 28, United States

 7   Code, Section 2461(c), in the event of the defendant’s conviction of

 8   the offenses set forth in any of Counts One through Seven of this

 9   Indictment.

10         18.   The defendant, if so convicted, shall forfeit to the United

11   States of America the following:

12               (a)   All right, title, and interest in any and all

13   property, real or personal, constituting, or derived from, any

14   proceeds traceable to the offenses; and

15               (b)   To the extent such property is not available for

16   forfeiture, a sum of money equal to the total value of the property

17   described in subparagraph (a).

18         19.   Pursuant to Title 21, United States Code, Section 853(p),

19   as incorporated by Title 28, United States Code, Section 2461(c), the

20   defendant, if so convicted, shall forfeit substitute property, up to

21   the value of the property described in the preceding paragraph if, as

22   the result of any act or omission of the defendant, the property

23   described in the preceding paragraph or any portion thereof (a)

24   cannot be located upon the exercise of due diligence; (b) has been

25   transferred, sold to, or deposited with a third party; (c) has been

26   placed beyond the jurisdiction of the court; (d) has been

27   substantially diminished in value; or (e) has been commingled with

28   other property that cannot be divided without difficulty.
                                             7
     Case 2:25-cr-00456-MWC   Document 64   Filed 06/10/25   Page 8 of 9 Page ID #:91



 1                             FORFEITURE ALLEGATION TWO

 2                             [18 U.S.C. § 982 (a)(1)]

 3         20.   Pursuant to Rule 32.2(a) of the Federal Rules of Criminal

 4   Procedure, notice is hereby given that the United States will seek

 5   forfeiture as part of any sentence, pursuant to Title 18, United

 6   States Code, Section 982(a)(1), in the event of the defendant’s

 7   conviction of the offenses set forth in any of Counts Eight through

 8   Eighteen of this Indictment.

 9         21.   The defendant, if so convicted, shall forfeit to the United

10   States of America the following:

11               (a)   Any property, real or personal, involved in such

12   offense, and any property traceable to such property; and

13               (b)   To the extent such property is not available for

14   forfeiture, a sum of money equal to the total value of the property

15   described in subparagraph (a).

16         22.   Pursuant to Title 21, United States Code, Section 853(p),

17   as incorporated by Title 18, United States Code, Section 982(b)(1),

18   and Title 18, United States Code, Section 982(b)(2), the defendant,

19   if so convicted, shall forfeit substitute property, if, by any act or

20   omission of the defendant, the property described in the preceding

21   paragraph, or any portion thereof: (a) cannot be located upon the

22   exercise of due diligence; (b) has been transferred, sold to, or

23   deposited with a third party; (c) has been placed beyond the

24   jurisdiction of the court; (d) has been substantially diminished in

25   value; or (e) has been commingled with other property that cannot be

26   divided without difficulty. Substitution of assets shall not be

27   ordered, however, where the convicted defendant acted merely as an

28   intermediary who handled but did not retain the property in the
                                             8
     Case 2:25-cr-00456-MWC   Document 64   Filed 06/10/25    Page 9 of 9 Page ID #:92



 1   course of the money laundering offense unless the defendant, in

 2   committing the offense or offenses giving rise to the forfeiture,

 3   conducted three or more separate transactions involving a total of

 4   $100,000.00 or more in any twelve-month period.

 5                                               A TRUE BILL
 6
                                                 /S/
 7                                               Foreperson
 8
      BILAL A. ESSAYLI
 9    United States Attorney
10

11
      CHRISTINA T. SHAY
12    Assistant United States Attorney
      Chief, Criminal Division
13
      KRISTEN A. WILLIAMS
14    Assistant United States Attorney
      Chief, Major Frauds Section
15
      MARK AVEIS
16    GREGG MARMARO
      Assistant United States Attorneys
17    Major Frauds Section
18

19

20

21

22

23

24

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26

27

28

                                             9


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