On or about___________________, in the District of ___________, defendant(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), knowing that the transaction was designed in whole and in part to avoid a transaction reporting requirement under [State] [Federal] law and that while conducting and attempting to conduct such financial transaction knew that the property involved in the financial transaction, that is [funds] [monetary instruments][FN1] in the amount of (dollar amount)[FN2] represented the proceeds of some form of unlawful activity.
- FN1. Select one. Remember "monetary instrument" is a defined term in 1956(c)(5) whereas "funds" is undefined.
FN2. 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:
CountDate Approx. Dollar Amount
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2.