2135. Jury Instruction -- Elements Of 18 U.S.C. § 1956(a)(2)(B)(i) (Sting)

There are four elements to Count ___ of this indictment which the government must prove:

FIRST, the defendant must knowingly[FN1] transport, transmit, or transfer, or attempt to transport, transmit, or transfer [a] monetary instrument[s] or funds
  1. FN1. Practitioner's Note: See footnote on previous page regarding proof of knowledge for purposes of the sting provision. See also the knowledge sting instruction found in the general instructions section.

SECOND, from a place in the United States to or through a place outside the United States or to a place in the United States from or through a place outside the United States;

THIRD, the defendant must know[FN2] that the monetary instrument[s] or funds involved in the transportation, transmission, or transfer, or attempted transportation, transmission, or transfer, represent the proceeds of some form of unlawful activity;
  1. FN2. Practitioner's Note: See footnote on previous page regarding proof of knowledge for purposes of the sting provision. See also the knowledge sting instruction found in the general instructions section.
FOURTH, the defendant must know[FN3] that the transportation, transmission, or transfer, or attempted transportation, transmission, or transfer, is designed, in whole or in part, to conceal or disguise the nature, the location, the source, the ownership, or the control of the proceeds of specified unlawful activity.
  1. FN3. Practitioner's Note: See footnote on previous page regarding proof of knowledge for purposes of the sting provision. See also the knowledge sting instruction found in the general instructions section.
Title 18, U.S.C. § 1956(a)(2)(B)(i)

Granted ____

Denied ____

Updated September 19, 2018