2114

Jury Instruction—Elements of 18 U.S.C. §  1956(a)(1)(A)(ii)

There are four elements to Count __ of this indictment which the government must prove: FIRST, the defendant must knowingly conduct or attempt to conduct a financial transaction; SECOND, the defendant must know that the property involved in the financial transaction represents the proceeds of some form of unlawful activity; THIRD, the property involved in the financial transaction must, in fact, involve the proceeds of specified unlawful activity; and FOURTH, the defendant must engage in the financial transaction with the intent to engage in conduct constituting a violation of §§ 7201 or 7206 of the Internal Revenue Code of 1986. In this case, [add specific conduct alleged in indictment.][FN1] FN1. Practitioner's Note: Include a separate instruction on the elements of either § 7201 or § 7206 or what constitutes "intent to engage in conduct constituting a violation" of those sections. Title 18, U.S.C. § 1956(a)(1)(A)(ii) Granted Denied