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CRM 2000 - 2500

2152. Jury Instruction -- 18 U.S.C. 1956(a)(3)(A)

On or about ___________________, the District of __________________, defendant(s), ___________________ with the intent to promote the carrying on of specified unlawful activity, did knowingly conduct and attempt to conduct a financial transaction affecting interstate or foreign commerce involving property represented[FN1] by a law enforcement officer, to be [proceeds of specified unlawful activity,] [property used to conduct or facilitate specified unlawful activity], to wit: ________________________.

  1. FN1. Remember the term "represented" as defined in section 1956(a)(3), means any representation made by either: "a law enforcement officer or by another person at the direction of a Federal official authorized to investigate or prosecute violations of this section." Thus, you should specify in the indictment who it was that made the representation if possible, except if a confidential informant is involved whose identity cannot yet be revealed.

In violation of Title 18, United States Code, Sections 1956(a)(3)(A) and 2.