2166. Jury Instruction -- Conspiracy To Commit Money Laundering

1. Beginning on or about _____________, and continuing through on or about __________________, within the __________ District of ________, and elsewhere, the Defendants,

_____________________,

______________,

__________________, did unlawfully, willfully and knowingly combine, conspire, confederate and agree together and with each other, and with others known and unknown to the Grand Jury, to commit certain offenses under Title 18, United States Code, Sections 1956 and 1957, as follows:

  1. to conduct and attempt to conduct a financial transaction affecting interstate commerce, which transaction involved the proceeds of specified unlawful activity, (that is, ), (1) with the intent to promote the carrying on of such specified unlawful activity and (2) with the intent to engage in conduct constituting a violation of [26 U.S.C. § 7201], [26 U.S.C. §  7206] to wit, (describe conduct), and (3) knowing that the transaction was designed in whole or in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of said specified unlawful activity, and (4) knowing that the transaction was designed in whole and in part to avoid a transaction reporting requirement under [State] [Federal] law, and that while conducting and attempting to conduct such financial transaction knew that the property involved in the financial transaction, represented the proceeds of some form of unlawful activity, in violation of 18 U.S.C. §  1956(a)(1); and
  2. knowingly to transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instrument and funds from a place in the United States to and through a place outside the United States with the intent to promote the carrying on of specified unlawful activity, in violation of 18 U.S.C. §1956(a)(2)(A); and
  3. knowing that the property involved in a financial transaction represented the proceeds of some form of unlawful activity, to transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instrument and funds from a place in the United States to and through a place inside the United States knowing that such transportation was designed in whole or in part to conceal and disguise the nature, the location, the source, the ownership and the control of the proceeds of specified unlawful activity, and to avoid a transaction reporting requirement under federal law, in violation of 18 U.S.C. §1956(a)(2)(B); and
  4. knowingly to engage, attempt to engage and cause and aid and abet others in engaging in monetary transactions in criminally derived property that was of a value greater than $10,000, in violation of 18 U.S.C. 1957;

MANNER AND MEANS

3.

OVERT ACTS

#. In furtherance of this conspiracy and to effect the objects thereof, the following overt acts, among others, were committed in the Western District of Texas:

LIST OVERT ACTS

All in violation of Title 18, United States Code, Section 1956(h).

Updated September 19, 2018