On or about ______________, in the District of ______ defendants _______________ 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
), knowing that the transaction was designed in whole and in part to [conceal] and [disguise], the [nature], [location], [source], [ownership], and [control][FN1] of the proceeds of said specified unlawful activity and that while conducting and attempting to conduct such financial transaction knew that the property involved in the financial transaction, that is [funds][monetary instruments][FN2] in the amount of (dollar amount
)[FN3] represented the proceeds of some form of unlawful activity.
- FN1. Can use all these in combination or select one or more as appropriate to the facts of the case.
FN2. Select one. Remember "monetary instrument" is a defined term in 1956(c)(5) whereas "funds" is undefined.
FN3. 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 Sections 1956(a)(1)(B)(i) and 2.