On or about ______________, in the District of ____________ defendant(s) ________________________ did knowingly conduct and attempt to conduct a financial transaction affecting interstate and foreign commerce, to wit (description of financial transaction), which involved the proceeds of a specified unlawful activity, that is (describe specified unlawful activity), with the intent to promote the carrying on of specified unlawful activity, to wit:
_______________ and that while conducting and attempting to conduct such financial transaction knew that the property involved in the financial transaction, that is [funds][FN1] [monetary instruments][FN2] represented the proceeds of some form of unlawful activity.
- FN1. Select one. Remember "monetary instrument" is a defined term in 1956(c)(5) whereas "funds" is undefined.
FN2. If the activity described in this paragraph is intended to cover more than one count this last phrase can be redrafted as follows: That is, [funds] [monetary instruments] in the amounts set forth below:
CountDate Approx. Dollar Amount
All in violation of Title 18, United States Code, Section 1956(a)(1)(A)(i) and 2.
[cited in Criminal Resource Manual 2101]