From the First Circuit Federal Defender Blog:
Torres-Velazquez
No clear error in six-level enhancement under USSG 2S1.1(b)(1) for knowledge that laundered funds were proceeds of drug offense where modus operandi of D and coDs was typical of drug organizations, D had two prior drug convictions, and there was large quantity (over $750,000) of cash. No plain error in applying two-level enhancement under USSG 2S1.1(b)(2)(B), even where section is inapplicable under note 3(c) if sole object of conspiracy is laundering funds under 18 USC 1957, since D plead guilty under 18 USC 1956 to conspiracy to launder funds knowing that the proceeds were derived from an unlawful activity.
3/28/07
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