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
4
5
6
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”).
1
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.”
3
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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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
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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
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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
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/S/
7 Foreperson
8
BILAL A. ESSAYLI
9 United States Attorney
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CHRISTINA T. SHAY
12 Assistant United States Attorney
Chief, Criminal Division
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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
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