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)