There are four elements to Count __ of this indictment which the government must prove:
FIRST, the defendant must knowingly conduct or attempt to conduct a financial transaction;
SECOND, the defendant must know that the property involved in the financial transaction represents the proceeds of some form of unlawful activity;
THIRD, the property involved in the financial transaction must, in fact, involve the proceeds of specified unlawful activity; andFOURTH, the defendant must engage in the financial transaction knowing that the transaction is designed in whole or in part to avoid a transaction reporting requirement under state or federal law, that is [specify reporting requirement alleged to have been violated].[FN1]
- FN1. Practitioner's Note: See footnote on previous page. Court could elect to give the reporting instruction at this point.