Information — United States v. Ashot Bejanyan, Central District of California (Document 153)

Summary

An Information filed June 9, 2025 as Document 153 in United States v. Ashot Bejanyan, also known as “Alex Benjamin,” Case 2:25-cr-00450-CV, in the Central District of California. Count One, under 18 U.S.C. § 1344(2), alleges that from no later than in or about May 2024 through at least in or about January 2025 the defendant executed a scheme to obtain property of First Citizens Bank and Trust Co. of North Carolina, including by seeking a PLP loan on behalf of Alex Titan Solutions, Inc. in the amount of $2.6 million. Count Two, under 18 U.S.C. § 1956(h), alleges a conspiracy beginning in or about October 2022 to conduct monetary transactions in criminally derived property of a value greater than $10,000, and lists overt acts involving a JPMorgan Chase account.

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“Information — United States v. Ashot Bejanyan, Central District of California (Document 153).” Original at ecf.cacd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-as-to-ashot-bejanyan-4-usa-v-bejanyan-dkt-153-c-d-cal-a13f10e99e/, SHA-256 e14410dd4031ba5bc2bc26c973f0cd2f6afbc53c7e951c44fbf05bb1e3c30347.

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Case 2:25-cr-00450-CV Document 153 Filed 06/09/25 Page 1 of 6 Page ID #:192

6/9/2025
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MMC

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8 UNITED STATES DISTRICT COURT

9 FOR THE CENTRAL DISTRICT OF CALIFORNIA
10 UNITED STATES OF AMERICA, ) No. CR 2:25-CR-00450-CV
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11 Plaintiff, ) I N F O R M A T I O N
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12 v. ) [18 U.S.C. § 1344(2): Bank
) Fraud; 18 U.S.C. § 1956(h):
13 ASHOT BEJANYAN, ) Conspiracy to Commit Money
aka “Alex Benjamin,” ) Laundering]
14 )
15 Defendant. )
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17 The United States Attorney charges:
18 COUNT ONE
19 [18 U.S.C. § 1344(2)]
20 A. INTRODUCTORY ALLEGATIONS
21 At times relevant to this Information:
22 1. Defendant ASHOT BEJANYAN, also known as “Alex
23 Benjamin,” was a resident of Los Angeles County, California.
24 2. First Citizens Bank and Trust Co. of North Carolina
25 (“First Citizens”) was a financial institution, the deposits of
26 which were insured by the Federal Deposit Insurance Corporation.
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Case 2:25-cr-00450-CV Document 153 Filed 06/09/25 Page 2 of 6 Page ID #:193

1 3. The United States Small Business Administration
2 (“SBA”) guaranteed certain loans vetted and originated by
3 financial institutions pursuant to the SBA’s “Preferred Lender
4 Program” (“PLP”). PLP loans were offered to small businesses or
5 individuals seeking to buy or improve small businesses and who
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might not be eligible for loans through normal lending channels.
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B. THE SCHEME TO DEFRAUD
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4. Beginning no later than in or about May 2024, and
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continuing through at least in or about January 2025, in Los
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Angeles County, within the Central District of California, and
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elsewhere, defendant BEJANYAN, knowingly and with intent to
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defraud, executed a scheme to obtain money, funds, credits,
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assets, and other property owned by and in the custody and
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control of First Citizens by means of material false and
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16 fraudulent pretenses, representations, and promises, and the

17 concealment of material facts.

18 5. The fraudulent scheme operated, in substance, as

19 follows:
20 a. Defendant BEJANYAN posed as the owner and
21 operator of Alex Titan Solutions, Inc., an entity that, as
22 defendant BEJANYAN well knew, was merely a shell company that
23 conducted no business activity.
24 b. Defendant BEJANYAN applied to First Citizens for
25 a PLP loan of $2.6 million on behalf of Alex Titan Solutions,
26 purportedly to fund Alex Titan Solutions’ purchase of another
27 shell company purportedly owned by a co-schemer. In that
28 application, defendant BEJANYAN and co-schemers made and caused
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Case 2:25-cr-00450-CV Document 153 Filed 06/09/25 Page 3 of 6 Page ID #:194

1 to be made materially false statements, and provided and caused
2 to be provided fabricated documents, to First Citizens to cause
3 it to believe that Alex Titan Solutions intended to purchase
4 that other company and to fraudulently induce it to approve the
5 PLP loan for Alex Titan Solutions. Such materially false
6 statements and fabricated documents included fraudulent
7 financial statements, fraudulent federal income tax returns, and
8 false lease documents.
9 C. EXECUTION OF THE SCHEME
10 6. On or about January 27, 2025, within the Central
11 District of California and elsewhere, defendant BEJANYAN,
12 together with others known and unknown to the United States
13 Attorney, executed and willfully caused others to execute and
14 attempt to execute the fraudulent scheme through the submission
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of a document entitled “Business Purchase Agreement and Joint
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Escrow Instructions” that fraudulently represented that Alex
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Titan Solutions was purchasing Titan Solutions, Inc. for
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approximately $3 million, in support of Alex Titan Solutions’
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PLP loan application to First Citizens.
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Case 2:25-cr-00450-CV Document 153 Filed 06/09/25 Page 4 of 6 Page ID #:195

1 COUNT TWO
2 [18 U.S.C. § 1956(h]
3 7. The United States Attorney realleges paragraphs 1
4 through 3 and 5 through 6 of this Information here.
5 A. OBJECT OF THE CONSPIRACY
6 8. Beginning in or about October 2022, and continuing to
7 at least in or about January 2025, in Los Angeles County, within
8 the Central District of California, and elsewhere, defendant
9 BEJANYAN conspired with others known and unknown to the United
10 States Attorney to knowingly and intentionally conduct monetary
11 transactions in criminally derived property of a value greater
12 than $10,000, knowing that the funds involved represented the
13 proceeds of some form of unlawful activity, and which funds
14 were, in fact, derived from specified unlawful activity, namely,
15 bank fraud, in violation of Title 18, United States Code,
16 Section 1344, in violation of Title 18, United States Code,
17 Section 1957.
18 B. MEANS AND MANNER OF THE CONSPIRACY
19 9. The object of the conspiracy was to be carried out,
20 and was carried out, in substance, as follows:
21 a. Defendant BEJANYAN, and others known and unknown
22 to the United States Attorney, would commit bank fraud, as
23 alleged in paragraphs 5 and 6 of this Information.
24 b. Defendant BEJANYAN, and coconspirators known and
25 unknown to the United States Attorney, would open bank accounts,
26 including JPMorgan Chase account ending in 1787 (“JPMC 1787”),
27 into which the proceeds of bank fraud would be deposited.
28 c. Defendant BEJANYAN, and coconspirators known and

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Case 2:25-cr-00450-CV Document 153 Filed 06/09/25 Page 5 of 6 Page ID #:196

1 unknown to the United States Attorney, would transfer and cause
2 the transfer of proceeds of bank fraud to other bank accounts,
3 or would withdraw or cause the withdrawal of proceeds of bank
4 fraud, for the personal benefit of defendant BEJANYAN and
5 coconspirators known and unknown to the United States Attorney.
6 C. OVERT ACTS
7 10. In furtherance of the conspiracy and accomplish its
8 object, defendant BEJANYAN, together with others known and
9 unknown to the United States Attorney, committed and willfully
10 caused others to commit the following overt acts, among others,
11 within the Central District of California, and elsewhere:
12 Overt Act 1: On October 24, 2022, defendant BEJANYAN
13 caused to be opened JPMC 1787 in the name of a shell entity
14 called Arms of Olympus LLC.
15 Overt Act 2: On November 22, 2022, defendant BEJANYAN
16 caused to be deposited into JPMC 1787 six checks payable to Arms
17 of Olympus LLC, including checks from shell entities Canmar
18 Promo Corp for $12,480.60; CM General Auto Electric Supplies for
19 $11,420.55; and Mass Exclusive LLC for $12,730.50; and from
20 individuals M.D. for $9,850.40 and V.M. for $9,820.75.
21 Overt Act 3: On December 15, 2022, defendant BEJANYAN
22 issued check no. 5001 drawn on JPMC 1787 for $12,590.85 payable
23 to shell entity Affordable Essential Business Solutions.
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Case 2:25-cr-00450-CV Document 153 Filed 06/09/25 Page 6 of 6 Page ID #:197

1 Overt Act 4: On December 15, 2022, defendant BEJANYAN
2 issued check no. 5006 drawn on JPMC 1787 for $11,470.55 payable
3 to shell entity Dynamic Delivery Install.
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BILAL A. ESSAYLI
5 United States Attorney
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CHRISTINA T. SHAY
8 Assistant United States Attorney
9 Chief, Criminal Division

10 KRISTEN A. WILLIAMS
Assistant United States Attorney
11 Chief, Major Frauds Section
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MARK AVEIS
13 GREGG MARMARO
Assistant United States Attorneys
14 Major Frauds Section
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