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CRM 2000 - 2500

2128. Jury Instruction -- 18 U.S.C. 1956(a)(2)(B)(ii)

On or about _________________, in the District of _____________, defendants(s), _________________, did knowingly and intentionally [transport] [transmit] [transfer][FN1] and attempt to [transport], [transmit], [transfer] [monetary instruments] [funds] that is (describe monetary instruments or funds), from a place [in] [outside] the United States, that is __________, [to] [through] a place [outside] [in] the United States, that is ________________, knowing that the [monetary instrument] [funds] involved in the transportation represented the proceeds of some form of unlawful activity and knowing that such transportation was designed in whole or in part to avoid a transaction reporting requirements under state or federal law.

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

FN1. Note "transmit" and "transfer" may only be alleged for offenses occurring after November 18, 1988