On or about _________________, in the District of _____________, the defendants(s) did knowingly conduct and attempt to conduct a financial transaction affecting interstate and foreign commerce, to wit, (description of financial transaction), which involved the proceeds of a specified unlawful activity, that is (describe specified unlawful activity), with the intent to engage in conduct constituting a violation of [26 U.S.C. § 7201], [26 U.S.C. § 7206][FN1] to wit, (describe conduct) and that while conducting and attempting to conduct such financial transaction knew that the property involved in the financial transaction, that is [funds][FN2] [monetary instruments][FN3] in the amount of (dollar amount), represented the proceeds of some form of unlawful activity.
- FN1. Choose one or both. If both are used, set forth in the conjunctive.
FN2. Select one. Remember "monetary instrument" is a defined term in 1956(c)(5) whereas "funds" is undefined.
FN3. If the activity described in this paragraph is intended to cover more than one count this last phrase can be redrafted as follows: That is, [funds] [monetary instruments] in the amounts set forth below:
Count Approx. Dollar Amount
All in violation of Title 18, United States Code, Sections 1956 (a)(1)(A)(ii) and 2.