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CRM 2000 - 2500

2127. Jury Instruction -- 8 U.S.C. 1956(a)(2)(B)(i) -- (Sting Provision) (Alternative)

On or about __________________, in the District of ____________, defendant(s), ___________________, did knowingly and intentionally [transport] [transmit] [transfer] and attempt to [transport] [transmit] [transfer] [monetary instruments] [funds] represented by a law enforcement officer to be the [proceeds of specified unlawful activity] [property used to [conduct] [facilitate] specified unlawful activity] from a place [in] [outside] the United States, to a place [in] [outside] the United States, believing[FN1] that the [monetary instrument(s)] [funds] involved in the transportation represented the proceeds of some form of unlawful activity and that such transportation was designed in whole or in part to [conceal] [disguise] the [nature] [location] [source] [ownership] or [control] of the proceeds of specified unlawful activity.

  1. FN1. "Believing" is inserted here instead of "knowing" because of the sting nature of the charges. As set forth in Section 1956(a)(2), the defendant's subsequent statements or actions are to be used to establish that the defendant believed such representations to be true.

This form is applicable only to "sting" offenses committed after November 29, 1990.

In violation of Title 18 United States Code, Section 1956(a)(2)(B)(i) and 2.