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Defining "Proceeds" Under the Money-Laundering Statute: A Survey of Circuit Opinions
Efraim Santos received a 60-month sentence for operating an illegal gambling operation as well as a 210 month sentence for money-laundering. The latter was based on an interpretation of the undefined term “proceeds” under the money-laundering statute to include payments made to Santos’ employees and the gambling winners. This obviously created a wide-reaching effect of the statute, allowing prosecution to tack on money-laundering charges to almost any illegal enterprise. What follows is a brief overview of the various approaches taken by courts throughout the United States.


Going "Cocoanuts": Looking at Modern Mortgage Fraud
Groucho Marx meets mortgage fraud. A look at modern mortgage fraud, the law, a little of the law of unintended consequences, and, perhaps, a reminder that those who forget the past are doomed to repeat it.
Health Care Fraud Enforcement
Despite modest coverage by the media, a key element of this spring’s landmark health care reform legislation was increased support for cracking down on health care fraud.
Addressing Errors in Entering Appeal Waivers: Why Appeal Waivers Entered in Violation of the Due Process Clause or Rule 11 Should Be Severed from Otherwise Valid Plea Agreements
Most federal criminal cases are resolved by plea agreements, and many include appeal waivers. Although defendants rarely enter the appeal waiver in error, how the judiciary handles those cases is just as important to the criminal justice system as enforcing a correctly entered waiver.