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CRM 2000 - 2500

2181. Jury Instruction -- Multiple Intents --18 U.S.C. § 1956

Count ____ charges the defendant with having engaged in a prohibited financial transaction in violation of [list statutory section]. The count charges that the defendant engaged in the financial transaction for multiple purposes. Or, as we say, with alternative intents. Specially, it is alleged that the defendant engaged in the financial transaction for the purpose of: [list all intents charged]. You may find that the government has met its burden of proof as to none, one or more, or all of the multiple intents charged in this count. To find the defendant guilty of the offense, however, you must agree unanimously as to which one or more of the intents charged, if any, were proved beyond a reasonable doubt.

Title 18 U.S.C. § 1956

Granted ____

Denied ____