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CRM 2000 - 2500

2154. Jury Instruction -- 18 U.S.C. 1956(a)(3)(C)

On or about _____________________, in the District of ____________, defendant(s), _________________________, with the intent to avoid a transaction reporting requirement under [State] [Federal] law, 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)(C) and 2.