Count __ of the indictment charges the defendant with a violation of Title 18, U.S.C. § 1956(a)(1)(B)(ii). This statute provides in pertinent part:
- (a)(1) Whoever, knowing that the property involved in a financial transaction represents the proceeds of some form of unlawful activity, conducts or attempts to conduct such a financial transaction which in fact involves the proceeds of specified unlawful activity--
(B) knowing that the transaction is designed in whole or in part --
(ii) to avoid a transaction reporting requirement under state or federal law[FN1] is guilty of an offense against the United States.
FN1. Practitioner's Note: Cross reference the appropriate Title 31, 26, or other reporting instructions for the transaction reporting requirement alleged to have been avoided. Court may choose to give an overview of the reporting requirement at this time.
Title 18, U.S.C. § 1956(a)(1)(B)(ii)