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The United States Supreme Court has held that the depositing of "bad checks" in Federally insured banks is not proscribed by 18 U.S.C. § 1014. United States v. Williams, 458 U.S. 279 (1982). Accordingly, check kites cannot be prosecuted under this statute. These cases should be prosecuted under 18 U.S.C. § 1344 or, in appropriate cases, under 18 U.S.C. § 656.
[cited in JM 9-40.000]