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Defining "Proceeds" Under the Money-Laundering Statute: A Survey of Circuit Opinions

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.

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Health Care Fraud Enforcement

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.