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2129. Jury Instruction -- 18 U.S.C. 1956(a)(2)(B)(ii) -- (Sting Provision) (Alternative)

On or about______________, in the District of ____________, defendant(s), __________________, did knowingly and intentionally [transport][transmit][transmit] and attempt to [transport] [transmit] [transfer] [monetary instruments] [funds] represented by a law enforcement officer to be [the proceeds of specified unlawful activity] [property used to [conduct] [facilitate] specified unlawful activity] from a place [in] [outside] the United States, to a place [in] [outside] the United States, believing[FN1] that such transportation was designed in whole or in part to avoid a transaction reporting requirement under [State] [Federal] law.
  1. FN1. Believing is inserted here instead of knowing because of the sting nature of the charges. As set forth in Section 1956(a)(2), the defendants's subsequent statements or actions are to be used to establish that the defendant believed such representation to be true.

    This form is applicable only to "sting" offenses committed on or after November 29, 1990.

In violation of Title 18, United States Code, Sections 1956(a)(2)(B)(ii) and 2.

Updated December 18, 2015