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Naranjo: Sufficient Concealment for Money Laundering

By Tim Cone

In U.S. v. Naranjo, No. 08-13814 (March 2, 2011), the Court affirmed concealment money laundering convictions.The Court rejected the argument that the government failed to prove ?concealment.? The Court pointed out that while Naranjo signed the checks from his fraudulent companies, he tried to conceal his association with the bank accounts on which the checks were drawn. ?It is irrelevant that Naranjo left enough evidence to allow a novice investigator to trace these cash withdrawals to Naranjo . . . because the statute requires only that proceeds be concealed, not that they be concealed well.? The Court also noted that large cash withdrawals are more difficult to trace than funds transferred between accounts.The Court dismissed as ?at best, speculative? Naranjo?s claim that a state report on his companies was exculpatory and therefore should have been turned over as Brady material...continue to full post

Full post as published by Defense Newsletter Blog on March 03, 2011 (boomark / email).