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CRM 500-999

844. Sample Indictment—Money Laundering, 18 U.S.C. § 1956(a)(1)(B)(i)

NOTE: This count is based on the facts of the concealment listed above.

  1. On or about the _______day of _____ , in the________District of________,


    defendant herein, did knowingly conduct and cause to be conducted a financial transaction affecting interstate commerce, that being the expenditure of a $6,583.30 account receivable of the debtor in possession, Robert Roe Nursery, Inc., from Sun Gardens, Chicago, Illinois, by using the money in making a loan payment of $8,073.50 payable to the First State Bank, Wrens, Georgia on a debt owed by JOHN DOE .

  2. The $6,583,30 used to make part of this $8,073,50 loan payment involved the proceeds of a specified unlawful activity, that is bankruptcy fraud in violation of 18 U.S.C. § 152 as charged in count one of this indictment.

  3. The defendant did so knowing that the transaction was designed in whole or in part to conceal and disguise the ownership and control of the proceeds of the specified unlawful activity, namely bankruptcy fraud, and that the property involved the proceeds of some form of unlawful activity.

All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.

[cited in JM 9-41.001]