text:
- 184.108.40.206 Overview
- 184.108.40.206 Money Laundering-Title 18 Violations
- 188.8.131.52 Title 31 Violations
Manual Transmittal
February 27, 2015
(1) This transmits revised IRM 9.5.5, Money Laundering and Currency Crimes.
Material Changes
(1) IRM Subsections 22.214.171.124.2(2) and 18.104.22.168.2(3) have been added to reflect structuring investigation policy changes. Subsequent paragraphs have been re-numbered. Criminal Investigation will not pursue the seizure and forfeiture of funds associated solely with "legal source" structuring cases unless there are exceptional circumstances justifying the seizure and forfeiture and the case has been approved at the Director, Field Operations (Criminal Investigation) level.
Effect on Other DocumentsThis IRM supersedes IRM 9.5.5 dated February 15, 2008. This IRM also incorporates procedure(s) implemented by the Director, Operations Policy and Support memorandum dated October 17, 2014, [Subject: IRS Structuring Investigation Policy Changes.]
Effective Date(02-27-2015)
Domenic A. McClinton for Richard Weber
Chief, Criminal Investigation
Money laundering is the process of disguising criminal proceeds and may include the movement of clean money through the United States with the intent to commit a crime in the future (e.g., terrorism). Common methods include disguising the source of the proceeds; changing the form of the proceeds; or moving the proceeds to a place where the proceeds are less likely to attract attention. The object of money laundering is ultimately to get the proceeds back to the individual who generated them. Money laundering is a necessary consequence of almost all profit generating crimes and can occur almost anywhere in the world. Money laundering is a threat to the United States tax system in that taxable illegal source proceeds go undetected along with some taxable legal source proceeds from tax evasion schemes. Both schemes use nominees, currency, multiple bank accounts, wire transfers, and international "tax havens" to avoid detection. This untaxed underground economy ultimately erodes public confidence in the tax system.
The National Money Laundering Strategy, established by the Secretary of the Treasury and the Attorney General, describes the goals, objectives and priorities for combating money laundering, terrorism and related financial crimes. Tax and money laundering violations are closely related and the Internal Revenue Service (IRS) has used the money laundering statutes to combat tax evasion.
The other operating divisions of the IRS coordinate to review data collected in compliance with the requirements of the money laundering statutes and Title 31 Bank Secrecy Act (BSA).
Criminal Investigation (CI) enforces the money laundering statutes relative to legal source income tax crimes (i.e., abusive trusts, offshore tax evasion schemes and corporate evasion schemes); large scale narcotics crimes (through the Organized Crime and Drug Enforcement Task Force (OCDETF) program); and non-narcotics illegal income tax crimes (i.e., illegal gambling and bankruptcy fraud). Criminal Investigation is also responsible for enforcing the BSA statutes under Title 31. Bank Secrecy Act information includes Currency Transaction Reports (CTR), and Suspicious Activity Reports (SAR), Reports of Cash Payments Over $10,000 Received in a Trade or Business (Form 8300), Reports of Foreign Bank and Financial Accounts (FBAR), Registration of Money Services Business (RMSB) and Report of International Transportation of Currency and Monetary Instrument (CMIR). The Internal Revenue Code (IRC) in Title 26 also contains reporting requirements on a Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business. Money laundering activity may violate 18 USC §1956, 18 USC §1957, 18 USC §1960, and provisions of Title 31, and 26 USC §6050I of the United States Code (USC). This section will discuss only those money laundering and currency violations under the jurisdiction of IRS, CI. These include:
Money Laundering - Title 18 Violations and lesser included offenses
Money Laundering/Currency Crimes - Title 31 Violations
Money Laundering - Form 8300 Violations
Definitions and Terms of Legal Applications
Forfeitures in Money Laundering Investigations
Money Laundering Expert Witness Cadre
Use of Money Laundering Posters
Money laundering statutes apply to transactions occurring after the completion of the underlying criminal offense. The same transaction cannot be both a money laundering offense and the underlying specified unlawful activity (SUA) that generated the funds being laundered. For example, the initial drug deal between buyer and seller is not a transaction involving SUA proceeds because money exchanged for drugs is not proceeds at the time the exchange took place (US v. Puig-Infante, 19 F.3d 929 (5th Cir. 1994)).
The applicable sections of IRM Part 9 and Law Enforcement Manual (LEM) 9 should be referred to for the authorization and use of undercover operations, consensual monitoring, informants, confidential and non-confidential expenditures, search warrants, and other investigative tools in money laundering investigations.
See IRM 9.4.13, Financial Investigative Task Force regarding the participation of the various task forces that conduct money laundering investigations.
Title 18 USC §1956 and 18 USC §1957, were brought into existence by the Money Laundering Control Act of 1986, which has since been expanded. In general, these statutes prohibit knowingly engaging in financial transactions using funds derived from a SUA. Title 18 USC §1956 investigations have no dollar amount limit, other than that found in the LEM, and no requirement that a financial institution be involved; 18 USC §1957 prohibits monetary transactions over $10,000 or an aggregate of money transactions over $10,000 of criminally derived funds obtained from a SUA while utilizing a financial institution.
Lesser-included offenses in money laundering investigations include:
18 USC §2 (aiding and abetting)
18 USC §371 or 18 USC §1956(h) (conspiracy)
18 USC §1001 (false statements)
18 USC §1510(b)(3)(B)(i) (obstruction of 18 USC §1956 or 18 USC §1957 or Title 31 investigations)
18 USC §1621 (perjury)
18 USC §1960 (illegal money transmitting business)
31 USC §5322 (Title 31 criminal penalties)
31 USC §5324 (structuring)
31 USC §5332 (bulk cash smuggling)
18 USC §1028 and 18 USC §1028A (identity theft)
Refer to LEM 9.14.1, Criminal Investigation Official Use Only Procedures for criteria relating to prosecution recommendations for violations of 18 USC §1956, 18 USC §1957 and Title 31.
The list of SUAs change periodically and special agents should consult 18 USC §1956(c)(7), for a definition of the term "specified unlawful activity" . For a complete list of offenses visit: http://assembler.law.cornell.edu/uscode/html/uscode18/usc_sec_18_00001956----000-.html. The government must prove that the transaction proceeds under 18 USC §1956(a)(1) were in fact derived from a SUA, or in the instance of 18 USC §1956(a)(3), represented money derived from SUA. Specified unlawful activities go far beyond narcotics related offenses and include, in part, bankruptcy fraud, health care fraud, and insurance fraud. Title 26 and Title 31 offenses are not SUAs. A SUA includes:
offenses listed as predicate acts under the Racketeer Influenced and Corrupt Organizations Act (RICO) statute of 18 USC §1961(1)
a separate list of non-RICO offenses set forth in 18 USC §1956(c)(7)
An August 1990 Memorandum of Understanding (MOU) between Department of the Treasury, the Postal Service, and Department of Justice (DOJ) requires that the IRS show Title 26 or Title 31 violations also exist in order to have jurisdiction over 18 USC §1956 or 18 USC §1957. The Title 26 or Title 31 activity requirement may be waived if no other agency objects or, if after positions are made known by each concerned agency, it is resolved to give the IRS jurisdiction.
A five year criminal statute of limitations applies to all money laundering violations of 18 USC §1956 and 18 USC §1957. The five year statute also applies to violations of 18 USC §1960 absent any other specific provision. The statute of limitations runs from the date on which the money laundering offense was completed.
Venue for money laundering offenses under 18 USC §1956 or 18 USC §1957 exist in:
any judicial district in which the financial or monetary transaction is conducted, or
any judicial district where a prosecution for the underlying SUA could be brought, if the defendant participated in the transfer of proceeds from the SUA from that judicial district to where the financial or monetary transaction is conducted
Title 18 USC §1956 is the basic Title 18 money laundering offense. It has three specific parts. They are:
18 USC §1956(a)(1), Domestic Financial Transactions
18 USC §1956(a)(2), International Transportation of Monetary Instruments or Funds
18 USC §1956(a)(3), Sting Operations
The criminal penalty for a violation of 18 USC §1956(a)(1) and (2) is a fine of up to $500,000 or twice the value of the monetary instruments involved, whichever is greater, or imprisonment of up to 20 years, or both; and for a violation of 18 USC §1956(a)(3) an undetermined fine, or imprisonment of up to 20 years, or both.
Title 18 USC §1956(b) provides that violators under 18 USC §1956(a)(1) or (2) are also liable for a civil penalty of not more than the greater of the value of the property, funds, or monetary instruments involved in the transaction, or $10,000. The civil penalty is intended to be imposed in addition to any criminal fine.
The Federal Deposit Insurance Act provides that individuals convicted of 18 USC §1956, or conspiracy to do so, shall be precluded from all affiliation with an Federal Deposit Insurance Company (FDIC) insured institution, including employment or ownership, for a minimum of 10 years from the date of conviction.
Title 18 USC §1956(h) and 18 USC §1957 do not carry corresponding civil penalties.
With respect to 18 USC §1956(a)(1), the government must show each of the following elements:
the defendant conducted or attempted to conduct
a financial transaction
knowing that the property involved in the transaction represented the proceeds of some form of unlawful activity
which in fact involved the proceeds of SUA with one of the following specific intents listed in paragraph (2).
Without proof of one of these four specific intents, there is no crime.
Title 18 USC §1956(a)(1)(A)(i) acting with the intent to promote the carrying on of SUA
Title 18 USC §1956(a)(1)(A)(ii) acting with the intent to engage in conduct which violates 26 USC §7201 or 26 USC §7206
Title 18 USC §1956(a)(1)(B)(i) acting with the knowledge that the transaction is designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the SUA
Title 18 USC §1956(a)(1)(B)(ii) acting with the knowledge that the transaction is designed in whole or in part to avoid a Federal or state transaction reporting requirement
Special agents are cautioned to avoid charging 18 USC §1956(a)(1)(B)(i) in instances when a subject makes a purchase with illegal proceeds and titles the asset in his/her own name, without any additional sign of intent to conceal or disguise.
With respect to 18 USC §1956(a)(2), the government must prove the elements that a defendant:
transports, transmits or transfers (or attempts to do so)
a monetary instrument or funds
from a place in the United States to or through a place outside the United States; or, to a place in the United States from or through a place outside the United States with one of the following intents listed in paragraph (2)
The specific intent is either:
Title 18 USC §1956(a)(2)(A) with the intent to promote a SUA
Title 18 USC §1956(a)(2)(B) with the knowledge that the funds involved in the transportation, transmission, or transfer represent the proceeds of some form of unlawful activity and knowing that such transportation, transmission, or transfer is designed in whole or in part to under (18 USC §1956(a)(2)(B)(i) conceal or disguise the nature, the location, the source, the ownership, or the control of the proceeds of the SUA); or to avoid a Federal or state transaction reporting requirement under 18 USC §1956(a)(2)(B)(ii)
Unlike the corresponding provision in 18 USC §1956(a)(1)(A)(i), there is no requirement in 18 USC §1956(a)(2) that the monetary instrument or funds be the product of unlawful activity. Title 18 USC §1956(a)(2)(B)(i) requires proof that the defendant knew that the monetary instruments or funds involved represented the proceeds of some form of unlawful activity. But this provision does not require the government to prove that the property was, in fact, the proceeds of an SUA. Therefore, offenses under 18 USC §1956(a)(2)(A) can involve legally derived funds used to promote an SUA.
Under this section, the movement of funds does not include tax evasion. Tax evasion is not an SUA and intent to evade tax is not an enumerated intent of the transportation offense.
Title 18 USC §1956(a)(3) is a sting provision that allows for undercover operations where the government, or a direct informant, represents funds as being derived from a SUA. This subsection was added to the statute expressly to permit prosecution where the defendant believes the proceeds were derived from a SUA because of a representation made by a law enforcement officer (LEO) or an informant working under the LEO's control. The elements include that a defendant conducts or attempts to conduct a financial transaction involving property represented by a LEO or another person at the LEO's direction, to be either:
proceeds of an SUA, or
property used to conduct or facilitate an SUA
The government must prove that the defendant's intent was to:
promote the carrying on of an SUA - Title 18 USC §1956(a)(3)(A);
conceal or disguise the nature, location, source, ownership, or control of property represented to be proceeds of the SUA - Title 18 USC §1956(a)(3)(B); or
avoid a Federal or state transaction reporting requirement - Title 18 USC §1956(a)(3)(C)
Under 18 USC §1956(a)(1), it is an offense to take known drug money and intentionally engage in a financial transaction. However, it is not a money laundering offense to engage in a financial transaction in a drug deal if the money was not the proceeds of an SUA before the transaction began. Therefore, an undercover agent or directed informant must represent that the money involved in a financial transaction is the proceeds of some past criminal activity (or property used to facilitate past criminal activity).
Criminal Investigation or the attorney for the government must decide how far to let a sting operation go to satisfy the financial transaction element. Circumstantial evidence will have to be used to show intent if an arrest is made before a defendant does anything with funds received from an undercover agent or a directed informant. In such instances, the delivery of funds must satisfy the definition of a financial transaction, the undercover agent or directed informant must properly represent the funds as being proceeds of a past SUA, and a defendant must accept the funds with one of the intents set forth in 18 USC §1956(a)(3)(A), (B) or (C).
Defenses in undercover operations include entrapment, i.e., government inducement or a lack of predisposition by a defendant to commit a crime, and outrageous government conduct whereby the government violates a defendant's constitutional rights. A review of predisposition must be made in any undercover operation, especially for a first-time offender with nothing criminal in his/her background.
The sting provision does not include conduct intended to evade tax.
Department of Justice has directed that conspiracy to violate 18 USC §1956 or 18 USC §1957 will be charged under 18 USC §1956(h), and not under 18 USC §371.
The following is intended to assist the special agent in identifying the elements of 18 USC §1956 violations. The statutory language has been interpreted by the government and the courts and may not be applicable in all investigations and in all jurisdictions. Special agents must work closely with the attorney for the government to ensure the local jurisdictional court rulings are applied to the facts and evidence of each investigation.
Proceeds is not statutorily defined. It has been interpreted to include more than the money derived from unlawful activity. It may include:
a line of credit
real property
uncashed checks
inventory acquired in a fraud scheme
assets concealed in bankruptcy fraud
Circumstantial evidence is sufficient to prove that a transaction involved proceeds of a SUA, e.g., evidence that a defendant traffics drugs, has large amounts of currency, and has no or little legitimate income is sufficient. Because this is a criminal matter, each element of the crime must be proved beyond a reasonable doubt, including any elements proved by circumstantial evidence.
It is critical to determine when property or funds become the proceeds of an underlying crime. Money in a consummated drug transaction becomes proceeds; any subsequent transaction could be charged as a money laundering offense, e.g., an automobile purchased with SUA funds qualifies as proceeds. The definition of when funds become SUA proceeds in transactions that involve a middleman is based on the party employing the middleman. If a victim in a fraud scheme sends an innocent party to deliver funds to a defendant, the funds become proceeds upon receipt by the defendant; whereas, if the defendant sends an innocent assistant to receive funds, the funds become proceeds upon receipt by the assistant.
Defendants often commingle SUA proceeds with legitimate funds. The government need not prove that all proceeds in a transaction were unlawfully derived, but must be able to trace some of the proceeds to a SUA. Criminally derived proceeds deposited with legal funds are considered to be withdrawn last unless the account/business is deemed to be permeated with fraud. This implies that the business operations are so intertwined with fraud that to segregate the legitimate operation and profits is impossible. Special agents should work closely with the attorney for the government when investigations involve commingled funds to ensure the elements of the crime are met.
The term knowing that the property involved in a financial transaction represents the proceeds of some form of unlawful activity means that the person knew the property involved in the transaction represented proceeds from some form, though not necessarily which form, of activity that constitutes a felony under state, Federal, or foreign law, regardless of whether or not such activity is specified in 18 USC §1956(c)(7).
Title 18 USC §1956(a)(1)(A)(i): intent to promote the carrying on of specified unlawful activity:
Circumstantial evidence is sufficient to show intent for this section. The government is not required to prove that a defendant intended to violate a specific statute, but did intend to promote or facilitate an activity that he/she knew to be illegal. A violation may occur even if the promoted SUA is never completed.
A defendant can engage in financial transactions that promote not only ongoing or future activity, but also prior activity, e.g., 18 USC §1956(a)(1)(A)(i) can be charged for the deposit of funds in a mail fraud scheme which issues IRS refund checks to fictitious employees.
Under 18 USC §1956(a)(1)(A)(i), the payment of proceeds to fraud victims to entice him/her to continue to invest in a fraudulent scheme, or to keep quiet about an ongoing scheme, could be promotion.
A prosecution recommendation for the simple deposit of criminal proceeds into one's bank account as money laundering promotion is generally not advisable.
The term conducts includes initiating, concluding, or participating in initiating, or concluding a transaction.
Title 18 USC §1956(a)(1)(B)(i): intent to conceal or disguise the nature, source, ownership, or control of proceeds of SUA.
Circumstantial evidence may be used to show intent that a transaction's purpose was to conceal or disguise under this section.
The government need only prove that a defendant knew a transaction was designed to conceal the nature, location, source, ownership or control of proceeds of some felonious activity, that were, in fact, from an SUA. The evidence can include using a third party's name or business account or commingling illegal funds with legitimate funds.
The government need only show that a defendant had knowledge a transaction was designed to conceal illegal activity proceeds and not that a defendant had the purpose of concealing illegal activity proceeds. This applies to individuals who are willfully blind. The majority of courts ruling in this area have held that converting proceeds into goods or services can violate 18 USC §1956(a)(1)(B)(i) if the expenditures demonstrate an ulterior design to conceal or disguise.
The US Sentencing Commission as said simple "receipt and deposit" of SUA proceeds causes little or no harm to society and simply constitutes the completion of an underlying offense. Courts have held there is no intent to conceal by the mere deposit of funds into an account. Therefore, prosecution of a receipt and deposit transaction should only be recommended for transactions that involve the movement or spending of funds subsequent to an initial deposit.
Title USC 18 §1956(a)(1)(A)(ii): intent to engage in conduct constituting a violation of 26 USC §7201 or 26 USC §7206.
Under this section, a defendant's objective is to engage in conduct constituting a violation of 26 USC §7201 or 26 USC §7206.
An individual may be prosecuted under 18 USC §1956(a)(1)(A)(ii) for engaging in a money laundering financial transaction with the intent to violate 26 USC §7201 even where the tax year has not yet concluded and the tax return has not yet been filed. However, there must be some proof that the person engaged in the financial transaction was aware the transaction related in some way to an intended violation of 26 USC §7201 or 26 USC §7206.
Title 18 USC §1956(a)(1)(A)(ii) does not limit the type of tax or the type of document submitted. Also, the tax involved need not be the tax of the person engaging in the financial transaction, i.e., the statute can apply to a person who intends to assist another person in violating the tax laws.
Absent exceptional circumstances, DOJ, Tax Division will not authorize a 18 USC §1956(a)(1)(A)(ii) charge in tax crimes involving mail, wire, or bank fraud when a tax return or other IRS form or document is the only mailing charged, or when the only wire transmission to the IRS involves a tax return or other IRS form, or the transmission of a refund check to a bank account by an electronic funds transfer, or when the mailing, wire transfer, or representation charged is incidental to the underlying violation of Internal Revenue laws.
By statute, the term transaction includes a purchase, sale, loan, pledge, gift, transfer, delivery, or other disposition, and with respect to a financial institution includes a deposit, withdrawal, transfer between accounts, exchange of currency, loan, extension of credit, purchase or sale of any stock, bond, certificate of deposit, or other monetary instrument, use of a safe deposit box, or any other payment, transfer, or delivery by, through, or to a financial institution, by whatever means effected.
The courts and the government have ruled or taken the following positions relating to the term transaction:
a) An exchange of cash between two drug dealers arguably is a transaction under the general definition, i.e., a transfer or other disposition (DOJ).
b) Mere transportation of funds within the United States or mere possession of supposed drug cash without a subsequent disposition ARE NOT transactions (Courts).
c) Each transaction involving dirty money is intended to be a separate offense, e.g., a drug dealer who divides $1 million in drug money into smaller lots and deposits it in 10 different banks has committed 10 violations, and two more violations if he/she withdraws some of the money and purchases a car and a boat (Congress).
The term financial transaction as defined by 18 USC §1956(c)(4) specifies that a transaction must meet one of four requirements to be a financial transaction:
Transactions involving the movement of funds by wire or other means that in any way affects interstate or foreign commerce. The courts have affirmed the following movement of funds to be financial transactions: giving a check in exchange for cash, sending cash through the mail, transfer of a box of currency from one person to another person, various transfers of currency from a defendant's house to vehicles parked outside and the movement of drug money from an undercover agent to another person who intended to carry the money in interstate travel.
Transactions involving the use of a monetary instrument that in any way affects interstate or foreign commerce. This includes a transfer of cash or any other monetary instrument from one person to another without involvement of a financial institution.
Transactions involving the transfer of title to any real property, vehicle, vessel, or aircraft (as of October 28, 1992) that in any way affects foreign or interstate commerce, e.g., a transfer of title of a vehicle from one person to another person.
Transactions involving a financial institution, as defined by 18 USC §1956(c)(6) and 31 USC §5312(a)(2) or 31 CFR 103.11, that is engaged in, or the activities of which affect interstate or foreign commerce. A court found a financial services company which received and invested funds to be a financial institution because it behaved like a bank. Car dealers, pawnbrokers, and precious metal dealers are also considered financial institutions.
The courts have affirmed Congress' determination that property derived from narcotics trafficking affects interstate commerce.
The courts have interpreted funds movement broadly, but they have ruled that mere possession of drug money in one's house and mere transportation of funds by car or airplane are not financial transactions.
The term monetary instrument is defined as:
coin or currency of the United States or of any other country
traveler's checks, personal checks, bank checks, and money orders, or
investment securities or negotiable instruments, in bearer form or otherwise in such form that title thereto passes upon delivery
The term financial institution is defined under 31 USC §5312(a)(2). The International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 amended the definition to include credit unions, commodities merchants, non-financial trades and businesses and informal money transfers systems which include underground banking systems, black market peso exchanges and hawalas.
Alternate remittance systems represent informal or unregulated means of transferring value between or among multiple locations. Often these systems are comprised of geographic networks and are described by a variety of specific terms depending on the region or community they serve.Hawala is the term often used to describe alternative remittance systems or services in the Middle East.
Legislative history has held the term avoid is synonymous with evade as it is used in 18 USC §1956(a)(1)(B)(ii) and 18 USC §1956(a)(2)(B)(ii), i.e., knowing that the transaction is designed in whole or in part to avoid a transaction reporting requirement under state or Federal law.
For example, if A gave his/her cocaine profits to B to launder through a network of smurfs, B could be charged with 18 USC §1956(a)(1)(B)(ii) even if he/she was unaware that the funds actually came from a SUA provided that it could be shown that B knew the funds came from some form of unlawful activity.
A smurf is an individual(s) who makes numerous same-day currency deposits of less than $10,000, usually at several different banks, to evade the filing of CTRs. The act of conducting such transactions is termed "smurfing" .
The term represented in this subsection means any representation made by either a law enforcement officer or by another person at the direction or approval of a Federal official who is authorized to investigate or prosecute 18 USC §1956(a)(3) violations. Explicit representations need not be made, but are preferred.
Title 18 USC §1956(a)(1) and18 USC §1956(a)(3) are parallel statutes, i.e., they address the same conduct and punish the same wrong. The requirement of subsection 18 USC §1956(a)(3) that the property be represented as either the proceeds of a SUA or as being used to facilitate or conduct criminal activity replaces the knowledge and proceeds requirements of 18 USC §1956(a)(1).
It is an offense if an undercover agent explicitly says, this is drug money, and a defendant uses (or attempts to use) the money to conduct a financial transaction to promote a future SUA (buying a vessel to ship drugs), or to conceal or disguise the ownership of money (wires to a fictitious corporate account), or to violate a currency reporting requirement (structured check purchases). It is also an offense if an undercover agent says, this airplane is used to smuggle drugs, and a defendant then engages in a financial transaction that involves the property with one of the specific intents.
In contrast, as an example of an implied representation, a jury could infer that a defendant knew certain funds were drug money by a veiled reference from an undercover agent to a co-conspirator that their currency exchange should charge higher commissions due to the dangers in dealing with drug dealers. The courts have held that it is enough for an undercover agent to make a defendant aware of circumstances from which a reasonable person would infer that certain property was criminal proceeds. Also, the government need not recite the alleged source of represented funds during each transaction in a sting operation.
Title 18 USC §1957 prohibits an actual or an attempted monetary transaction of over $10,000 in SUA proceeds.
To prove a violation of 18 USC §1957, the government must prove:
the defendant knowingly
engaged in, or attempted to engage in
a monetary transaction (i.e., a transaction by, through or to a financial institution)
in criminally derived property of a value in excess of $10,000 and the property is derived from SUA
The statute does not require that these funds be used for any additional criminal purpose or that the defendant engage in the transaction with any specific intent. Simply spending the proceeds violates this statute.
This statute applies not only of a person who engages in a monetary transaction with a financial institution knowing the cash is criminal proceeds, but also to a financial institution employee who accepts cash knowing it is criminal proceeds. An individual who initiates and then benefits from a transaction that was effected by another individual or entity, can be charged with the direct charge or as an aider and abettor, e.g., a person who uses nominees to purchase real estate.
Department of Justice Asset Forfeiture and Money Laundering Section must approve any prosecution of an attorney under 18 USC §1957 for the receipt and deposit of funds allegedly derived from a SUA.
Title 18 USC §1957 is the equivalent of a financial transaction offense under §1956(a)(1) except that the specific intent requirements are replaced by the requirement that the (monetary) transaction involve an amount over $10,000 and a financial institution as defined in 18 USC §1956. Title 18 USC §1956(a)(1) requires proof of a particular purpose or knowledge (e.g. intent to promote an SUA), whereas 18 USC §1957 does not.
The criminal penalty for a violation of 18 USC §1957 is a fine in accordance with 18 USC §3571 – 18 USC §3574 (or up to twice the amount of the criminally derived property involved in the transaction), up to 10 years imprisonment, or both.
Title 18 USC §1957 does not carry corresponding civil penalties.
The following is intended to assist the special agent in identifying the elements of 18 USC §1957 violations. The statutory language has been interpreted by the government and the courts and may not be applicable in all investigations and in all jurisdictions. Special agents must work closely with the attorney for the government to ensure the local jurisdictional court rulings are applied to the facts and evidence of each investigation.
The terms conducts, monetary instrument and financial institution have the same meaning under 18 USC §1957 as under 18 USC §1956. See subsections 188.8.131.52.1.5.4, 126.96.36.199.1.5.8 and 126.96.36.199.1.5.9, respectively.
The term monetary transaction is narrower than the term financial transaction as used in 18 USC §1956. In 18 USC §1957 violations, monetary transactions require that a financial institution and at least $10,000 be involved in the transaction.
The terms monetary transaction and financial institution mean:
the deposit, withdrawal, transfer, or exchange
in or affecting interstate or foreign commerce
of funds or a monetary instrument (as defined in 18 USC §1956(c)(5))
by, through, or to a financial institution (as defined in 18 USC §1956(c)(6))
including any transaction that would be a financial transaction under 18 USC §1956(c)(4)(B)
but such term does not include any transaction necessary to preserve a person's right to representation as guaranteed by the Sixth Amendment to the Constitution
The term criminally derived property means any property constituting, or derived from proceeds obtained from a criminal offense. See subsection 18.104.22.168.1.5.1, Definition of Proceeds of Specified Unlawful Activity.
The government must establish by direct or circumstantial proof that a defendant actually or constructively knew property involved in a financial transaction was the proceeds of some state, Federal, or foreign felonious activity and not the proceeds of a specific SUA.
Effective October 26, 2001, 18 USC §1960 was revised to relax the scienter requirement and broaden the scope of the statute to a " general intent" crime. It is now an offense for anyone to knowingly conduct any unlicensed money transmitting business, whether or not the defendant knew that the operation was required to be licensed or that operation without a license was a criminal offense. The proceeds of illegal money transmitting businesses are subject to both civil and criminal forfeiture to under 18 USC §981(a)(1)(A) and 18 USC §982(a)(1).
The criminal penalty for a violation of 18 USC §1960 is a fine in accordance with 18 USC §3571–18 USC §3574, up to five years imprisonment, or both.
A person who violates this offense knowingly conducts, controls, manages, supervises, directs or owns all or part of an unlicensed money transmitting business by:
operating without a state license, or
failing to comply with Federal money services business (MSB) registration requirements, or
transferring money knowing the funds transmitted were criminally derived or intended to promote or support some unlawful activity
The term "money transmitting" includes transferring funds on behalf of the public by any and all means including, but not limited to transfers within the country, or to locations abroad by wire, check, draft, facsimile, or courier.
The term "State" means by any state of the United States, and the District of Columbia, the Northern Mariana Islands, and any commonwealth, territory, or possession of the United States.
"Money transmitting businesses" and " money services businesses" are terms used by Title 31 and the regulations implementing the registration requirements, respectively. These terms should be understood to encompass the same array of businesses. There are five classes of financial institutions referred to as MSBs:
currency dealers or exchangers
check cashers
issuers of travelers checks or money orders
sellers or redeemers of travelers checks or money orders
money transmitters
The US Postal Service (USPS), a bank, or any other person registered with and regulated or examined by the Security and Exchange Commission (SEC) or the Commodity Futures Trading Commission are not considered money services businesses.
Title 18 USC §1960 (b)(2) defines "money transmitting " to include "transferring funds on behalf of the public by any and all means including but not limited to transfers within this or to locations abroad by wire, check, draft, facsimile or courier ...." It is not clear that check cashers and currency exchanges meet this definition for purposes of a prosecution under 18 USC §1960. The Department of Justice (DOJ), Asset Forfeiture and Money Laundering Section advises against prosecution of check cashers and currency exchanges under 18 USC §1960.
On August 20, 1999, the Department of the Treasury issued a final rule concerning application of the Bank Secrecy Act to MSBs. The rule (i) revises the definition of certain businesses for BSA purposes, and (ii) requires MSBs to register with the Department of the Treasury and maintain a list of its agents as required under 31 USC §5330. Under the final rule, MSBs must register with the Department of the Treasury by filing the form that FinCEN specifies with the IRS Detroit Computing Center (or such other location as the form may specify) and renew their registration every two years. The information required by 31 USC §5330(b) and any other information required by the form must be reported in the manner and to the extent required by the form.
Money services businesses must maintain a list of their agents, available to any appropriate law enforcement agency upon request, and update the list annually. The following information must be included on the list of agents:
the name, address, and telephone number of the agent
the type of service or services that the agent provides on behalf of the MSB maintaining the agent list
a listing of the months during the 12 months immediately preceding the date of the most recent agent list in which the agent's gross transaction amount exceeds $100,000 from the sale of products or services offered by the MSB maintaining the agent list
the name and address of the bank(s) at which the agent maintains transaction account(s) for all or part of the funds received from the sale of products or services offered by the MSB maintaining the agent list
the year in which the agent first became an agent of the MSB maintaining the agent list
the number of branches or subagents the agent has
Agents of MSBs are not required to register or keep a list of their own agents if they are MSBs solely because they serve as agents of other MSBs. Thus, a person that engages in MSB activities both on its own behalf and as an agent for others must register. For example, a supermarket corporation that acts as an agent for an issuer of money orders and performs no other services of a nature and value that would cause the corporation to be an MSB, is not required to register. However, registration would be required if the supermarket corporation, in addition to acting as an agent of an issuer of money orders, cashed checks or exchanged currencies (other than as an agent for another business) in an amount greater than $1,000 in currency or monetary or other instruments for any person on any day, in one or more transactions.
Any person failing to comply with the registration or agent list requirement may be subject to criminal prosecution and may be assessed a civil penalty of $5,000 for each violation. Each day during which a violation occurs constitutes a separate violation. In addition, the Secretary of the Treasury may bring a civil action to enjoin the continued violation.
On October 26, 2001, the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 created the requirement that all MSBs report suspicious activities detected as of January 1, 2002.
On October 1, 1998, the Identity Theft and Assumption Deterrence Act of 1998 went into effect. The Act amended 18 USC §1028 by, among other things, adding Section (a)(7) which establishes an offense for anyone who knowingly, transfers, possesses, or uses without lawful authority another person's means of identification with the intent to commit or aid or abet any unlawful activity that constitutes a violation of Federal law or a felony under any applicable state or local law.
Title 18 USC §1028, fraud and related activity in connection with identification documents and information, under Sections (a)(1)-(6) contain other provisions making it an offense to:
Knowingly and without lawful authority produce an identification document authentication feature or a false identification document.
Knowingly transfer an identification document authentication feature or a false identification document knowing such document was stolen or produced without lawful authority.
Knowingly possess with intent to use or transfer unlawfully, five or more identification documents authentication features or false identification documents.
Knowingly possess an identification document authentication feature, or a false authentication feature with the intent to use such document to defraud the United States.
Knowingly produce, transfer, or possess a document-making implement or authentication feature with the intent that it will be used to produce a false identification document.
Knowingly possess an identification document or authentication feature that is or appears to be of the United States which is stolen or produced without lawful authority, knowing such document was stolen or produced without lawful authority.
The term "means of identification" includes any name or number used alone or in conjunction with any other information to identify a specific individual.
Identity theft violations should only be utilized when it enhances the overall investigative strategy. It is not intended to be a stand-alone violation, but to assist in enhancing the investigation of Questionable Refund Program (QRP) and money laundering schemes. This violation can be charged in conjunction with money laundering violations or separately if there is insufficient evidence to support a money laundering charge. For example, during a money laundering investigation involving heath care fraud, evidence of 18 USC §1028 or 18 USC §1028A are developed. Both money laundering and identity fraud charges may be charged. If the money laundering evidence is insufficient, the identity theft charges may still be recommended against the supplier of the fraudulent identities when no financial nexus exists in the underlying fraud scheme.
Civil and criminal forfeiture provisions may be applicable in money laundering investigations involving 18 USC §1028 and 18 USC §1028A under 18 USC §981(a)(1)(C) and 18 USC §982(a)(2), respectively. However, no forfeiture provisions are applicable if the identity fraud violations are directly linked to the investigation of a substantive tax charge (absent extraordinary and compelling circumstances).
Special agents should consult with Criminal Tax (CT) Counsel, DOJ, Tax Division and the attorney for the government early in the investigation when contemplating recommendation of these violations. A recommendation of 18 USC §1028 and 18 USC §1028A directly linked to a substantive tax violation will be reviewed by DOJ, Tax Division.
See 18 USC §1028 and 18 USC §1028A for additional definitions of key terms relative to this statute and applicable fines and terms of imprisonment. The offense penalties vary depending on the intent and associated criminal activity.
Title 31, known as the Bank Secrecy Act (BSA), requires filing reports with the government and recordkeeping by financial institutions or individuals for domestic and foreign transactions involving currency, monetary instruments, and foreign accounts. It also sets forth punishments for the failure to make or falsify reports or records. Offenses investigated by CI are summarized in the following sections. Title 31, Federal Criminal Code, Chapter 53, Money and Finance, contains information regarding the purposes, specific offenses, definitions and penalties for use with this Title.
Under 18 USC §3282, the statute of limitations for violations of 31 USC §5322, 31 USC §5324, and 31 USC §5332 is five years.
Title 31 CFR 103.56(b)(8) gives the IRS Commissioner authority to examine all financial institutions for Title 31 compliance that are not currently examined by Federal bank supervisory agencies, except for brokers or dealers in securities. Title 31 CFR 103.56(c)(2) gives the IRS Commissioner the authority to investigate all criminal violations of Title 31 (except with respect to reports of transportation of currency or monetary instruments). Title 31 civil examinations of certain non-bank financial institutions are the responsibility of the IRS Small Business/Self-Employed (SB/SE) operating division.
In Delegation Order No. 143 (see IRM 1.2.2, Delegations of Authority (Delegation Order 25-5)), as revised, the IRS Commissioner delegated the authority to initiate criminal investigations of:
financial institutions that are not currently examined by Federal bank supervisory agencies, except for brokers or dealers in securities, to the Director and Deputy Director, Operations Policy and Support, CI:OPS, and the Special Agents in Charge (SAC), CI
banks, brokers and dealers in securities referenced in 31 CFR 103.18 through CFR 103.19 for possible criminal violations of 31 CFR Part 103 (except 31 CFR 103.23 and CFR 103.48). These must be authorized by the Chief, CI, pursuant to Treasury Order 150-10 and Directive 15-41.
The SAC may ask for or agree to participate in a grand jury investigation in accordance with the appropriate procedures (see IRM 9.5.2, Grand Jury Investigations). The authority to initiate a Title 31 investigation is not redelegated any lower than the SAC (see IRM 9.4.1, General, Primary and Subject Investigations.)
The historical emphasis of the IRS in Title 31 money laundering investigations has related to the failure to file or the false filing of Currency Transaction Reports (CTRs) (formerly Form 4789), FinCEN Form 104, i.e., the requirement that a financial institution file a CTR when a person conducts a currency transaction of more than $10,000 with the financial institution. IRS investigations have resulted in numerous convictions of individuals and financial institutions for the structuring of currency deposits via a network of smurfs (those who make numerous same-day currency deposits of less than $10,000, usually at several different banks, to evade the filing of CTRs). The smurfing of currency was and often still is a popular method of laundering drug profits.
The government has been successful in the prosecution of structuring violations under Title 31 by showing that a defendant knew that his/her structured deposits with a financial institution were designed to evade the filing of CTRs. However, in Ratzlaff v. United States, 114 S. Ct. 655 (1994), the US Supreme Court ruled that the willfulness requirement of 31 USC §5322, as it pertained to the structuring of currency transactions to evade the filing of CTRs under 31 USC §5324, meant that the government had to show that a defendant knew that the structuring of currency transactions to evade the filing of CTRs was in fact illegal.
The Money Laundering Suppression Act of 1994, Pub. L. 103–325 (September 23, 1994), included a legislative "fix" to the Supreme Court's decision in Ratzlaff. Title 31 USC §5324 was amended to exclude the willfulness requirement.
If an allegation of possible Title 31 violations committed by a financial institution is received, either by referral from the Department of the Treasury, by investigative development, or otherwise, the following procedures must be followed if the field office desires to obtain jurisdiction to conduct an investigation:
The attorney for the government will be given a written summary of the information developed concerning the potential violation, including the identity of all bank employees suspected of participating in the violation.
The commitment of the attorney for the government to investigate the alleged violation must be obtained.
A request for jurisdiction with the concurrence and signature of the Director, Field Operations will be sent to the Chief, CI, and must include the name of the attorney for the government who provided the commitment along with a summary of the facts of the allegation specifying the full name and address of the financial institution and whether the investigation covers a particular branch or the entire financial institution. Also included in the request must be the years under investigation and the request for copies of regulatory agency compliance reports for a specified period of time.
When authorization is approved, CI:OPS will notify the Assistant Director, Regulatory Policy and Programs Division of Financial Crimes Enforcement Network (FinCEN), and the regulatory agency that governs the financial institution involved.
The authorization to conduct the investigation will expire in 120 days. If, at the end of 120 days a primary investigation (PI) is not elevated to a subject criminal investigation (SCI), and CI wants to continue the investigation, the authorization must be renewed. If an SCI(s) is numbered, then the authorization will be in effect until the conclusion of the criminal investigation.
It is not necessary to number an investigation of a bank as a corporate entity in order to obtain jurisdiction. Jurisdiction is for the purpose of conducting a criminal investigation of possible Title 31 violations committed by the financial institution, or by any of its current or former officers. It is not necessary to make an additional request for jurisdiction of additional officers of the same financial institution if they are later identified as possible violators. However, a grand jury expansion request will be prepared and submitted.
When CI determines that civil penalties are warranted against a financial institution, a detailed report will be submitted to the Chief, CI, for compliance coordination with the Assistant Director, Regulatory Policy and Programs Division at FinCEN. The report will identify the financial institution and each partner, officer, director, or employee against whom the penalty recommendation is made (see IRM 9.5.13, Civil Considerations).
Recommendations for civil penalties can be made at any time, but should not jeopardize an ongoing criminal investigation. All recommendations will be sanitized of grand jury material, and must contain a statement that information contained in the recommendation does not include grand jury material. Tax information can only be released if a related statute call has been made, and should be communicated to FinCEN so that 26 USC §6103 are followed regarding subsequent use (see IRM 9.3.1, Disclosure.)
Reports for civil penalty recommendations will consist of the following information (IRM 9.5.14, Civil Activity at the Close of the Subject Criminal Investigation, subsection 188.8.131.52):
A brief summary of the evidence, including evidence of related violations, e.g., narcotics charges in which drug proceeds were laundered.
For Title 31 investigations resulting in an indictment, a summary of the charges in the indictment and the convicted charges.
The scope of the Title 31 crime including the amount of money laundered, the total dollar amount of unreported currency transactions in the indictment, the number of CTRs not properly filed, and the number of improperly reported transactions named in the indictment.
Copies of any public information such as a copy of the indictment, plea agreement, sentencing memorandum, affidavit for search warrants, arrest warrants, press releases and news articles.
The attorney for the government and the Assistant Director, Regulatory Policy and Programs Division at FinCEN may decide that the assessment of a civil penalty in a Title 31 investigation is appropriate in lieu of prosecution. Field offices will advise the Chief, CI, of the agreement as soon as an agreement is negotiated. If checks are received from a financial institution as payment for the civil penalties prior to assessment, the checks should be mailed to the Assistant Director, Regulatory Policy and Programs Division at FinCEN, Attn: FinCEN, PO Box 39, Vienna, Va., 22183-0039 with a copy of any court order with respect to the stipulation for settlement. The field should then follow up with a recommendation for civil assessment.
Under the authorization of the SAC, CI has jurisdiction to investigate allegations of violations of Title 31 USC §5324 structuring transactions to evade reporting requirements and Title 31 USC §5332, Bulk Cash Smuggling.
Regarding violations of 31 USC §5324, CI will not pursue the seizure and forfeiture of funds associated solely with "legal source" structuring cases unless there are exceptional circumstances justifying the seizure and forfeiture and the case has been approved at the Director, Field Operations (Criminal Investigation) level.
In cases where legal source income is involved in alleged structuring activity, consideration should be given to initiating a Title 26 criminal tax investigation. In certain circumstances, the structuring activity can be treated as an affirmative act of evasion under 26 USC §7201, evidence of willfulness, an overt act of conspiracy under 18 USC §371, or it may support Title 31 violations.
Title 31 USC §5324(a) prohibits a person from:
causing or attempting to cause a domestic financial institution to fail to file a CTR or fail to keep records for purchases of bank checks and drafts, cashier's checks, money orders, and traveler's checks over $3,000
causing or attempting to cause a domestic financial institution to fail to file a CTR, or keep records for purchases of bank checks and drafts, cashier's checks, money orders and traveler's checks over $3,000
structuring or assisting in structuring, or attempting to structure or assisting in structuring, any transaction with one or more domestic financial institutions
Title 31 USC §5324(b) prohibits a person from engaging in any of the following activity:
failing to file a Form 8300 as required by 31 USC §5331
attempting to cause a person to fail to file a Form 8300
filing or causing or attempting to cause a person to file a Form 8300 that contains a material omission or misstatement of fact
structuring or assisting in structuring, or attempting to structure or assist in structuring, any transaction with one or more non-financial trades or businesses
Title 31 USC §5324(c) prohibits a person from engaging in any of the following activity:
failing to file a CMIR
attempting to cause a person to fail to file a CMIR
to filing or causing or attempting to cause a person to file a CMIR that contains a material omission or misstatement of fact
structuring or assisting in structuring, or attempting to structure or assisting in structuring, any importation or exportation of monetary instruments.
CMIR violations are within the jurisdiction of the Bureau of Immigration and Customs Enforcement (ICE).
Currency Transaction Reports, CTRs by Casinos, Reports of Foreign Bank and Financial Accounts (FBAR), and Forms 8300 must be filed with the Detroit Computing Center or with the local IRS office. Hence, venue involving Title 26 or Title 31 investigations for falsification or omission of those forms is in the Eastern Judicial District of Michigan, in the judicial district where an IRS post-of-duty is located, or in the judicial district where the document was prepared.
Title 31 USC §5332, Bulk Cash Smuggling into or out of the United States, was created by the USA Patriot Act, effective October 26, 2001. Criminal Investigation's jurisdiction over this offense is limited to investigations where the underlying conduct falls under CI's jurisdiction in money laundering offenses (18 USC §1956 and 18 USC §1957), Title 26 or Title 31 only. The USA Patriot Act made the act of smuggling in cash or other monetary instruments over $10,000, a criminal offense and authorized forfeiture of the cash or instruments of the smuggling.
Failure to file and filing a false report are predicated on the existence of a transaction (or an aggregate of related transactions) which actually exceeds $10,000 thus triggering the duty to file; whereas acts of structuring may never trigger the reporting requirement because the individual transactions involved may never exceed the threshold amount. Transactions comprising an act of structuring constitute a single offense.
Undercover operations involving possible violations of Title 31 may precede or operate concurrently with a grand jury investigation. It is not necessary to request jurisdiction from the Chief, CI, solely for the purpose of conducting the undercover operation. To protect the existence and confidentiality of the undercover operation, Title 31 jurisdiction should not be requested until the field is ready to proceed to the grand jury stage.
Information in the subsections below discusses Title 31 requirements for specific reports, recordkeeping, and registration.
The following reports are required under Title 31.
Currency Transaction Report (CTR), (formerly Form 4789) FinCEN Form 104
Currency Transaction Report by Casinos (FinCEN Form 103)
Report of Foreign Bank and Financial Accounts (FBAR) (TD Form 90-22.1)
Report of International Transportation of Currency or Monetary Instruments (CMIR), (formerly Customs Form 4790), FinCEN Form 105
Suspicious Activity Report (SAR) Forms
Title 31 CFR 103.22 requires that each financial institution file a CTR on each deposit, withdrawal, exchange of currency or other payment or transfer, by, through, or to such financial institution that involves a transaction in currency of more than $10,000. Title 31 CFR 103.27 requires that the CTR must be filed by the 15th calendar day after the day of the transaction with the IRS Detroit Computing Center, Attn: CTR, PO Box 33604, Detroit, MI 48232-5604, or with the local IRS office. Casinos must file a report for each currency transaction involving either cash in or cash out of more than $10,000. There is an exception for the US Postal Service, who does not have to file CTRs, for payments or transfers made solely in connection with the purchase of postage or philatelic products.
Banks may exempt certain entities from CTR filings through the filing of a form TDF 90-22.53, Designation of Exempt Person, with the Detroit Computing Center. These designation forms are entered into the Currency Banking Retrieval System (CBRS) and can be queried by those with CBRS access. Banks also maintain a list of these exempt businesses. Further information relating to who qualifies for this designation is contained in Title 31 CFR 103.22.
Title 31 CFR 103.22(b)(2) requires each casino file a report of each transaction in currency, involving either cash in or cash out, of more than $10,000.
Title 31 CFR 103.11(n)(5)(i) defines a casino as an organization duly licensed to do business in the United States as a casino or gambling casino with gross annual gaming revenues in excess of $1 million. This includes the principal headquarters or any branch or other place of business.
Types of transactions in currency involving CASH-IN include but are not limited to (31 CFR 103.22(b)(2)(i)):
purchases of casino chips, tokens and other gaming instruments
deposit(s) (front money or safekeeping)
payments in any form of credit including markers and counter checks
bets of currency
currency received by the casino for transmittal of funds through wire transfer for a customer
purchases of casino checks
exchanges of currency for currency including foreign currency
bills inserted into electronic gaming devices
Types of transactions in currency involving CASH-OUT include but are not limited to (31 CFR 103.22(b)(2)(ii)):
redemption of casino chips, tokens, tickets, and other gaming instruments
withdrawal(s) of deposit (front money)
safekeeping withdrawals
advances on any form of credit, including markers and counter checks
payments on bets
payments by a casino to a customer based on receipt of funds through wire transfer
cashing of checks or other negotiable instruments
currency exchanges, including foreign currency
travel and complimentary expenses and gaming incentives
payment for tournament, contests, and other promotions
The report must be filed by the 15th day after the transaction date, with the IRS Detroit Computing Center, PO Box 32621, Detroit, MI 48232-5604 Attn: CTRC, or with the local IRS office.
Casinos with gross annual gaming revenues of less than $1 million are subject to the reporting requirements of 26 USC §6050I, Report of Cash Payments Over $10,000 Received in a Trade or Business, Form 8300. Casinos with non-casino businesses, e.g., shops, restaurants, and hotels, are subject to the reporting requirements of 26 USC §6050I, regardless of the amount of annual gaming revenues.
The Department of the Treasury allows Nevada casinos to file CTRs and related records with the Nevada Gaming Control Board, who in turn forwards the reports to the Detroit Computing Center. Effective July 1, 2007, Nevada casinos with gross annual gaming revenues of $10 million or more and "table games statistical win" of $2 million or more became subject to all applicable BSA requirements, including the requirement to file FinCEN Form 103, Currency Transaction Report by Casinos (CTRC). Currency Transaction Reports will no longer be filed with the Nevada Gaming Control Board.


text:
RAISE: Revolutionizing Asian American Immigrant Stories on the East Coast
RAISE (Revolutionizing Asian American Immigrant Stories on the East Coast) is a pan-Asian undocumented youth-led group on the East Coast. We aim to create safe spaces in our communities while advocating for humane immigration policies. Through political activism, leadership development, community education, and coalition building, we work to reclaim our dignity as pan-Asian undocumented peoples. RAISE organizes on the grassroots level to reimagine justice and demand liberation for immigrants in America.
* * *
About RAISE: Because every one of us has a story to tell...
"I can't get a job. I can't start a career."
"I can't totally relax. I have to be careful of what to say, and what not to say."
"I can't have my parents by my side."
"I can't sleep at night, because I'm worried about immigration agents breaking down my door."
Why We Rise is a compelling new documentary short featuring three brave young Asian New Yorkers who reveal what it's like to grow up without having legal immigration status. Their struggles and their strength are on full display as they come out of the shadows and into the light.
Why We Rise was filmed by Brian Redondo (be.net/brianredondo) and Corinne Manabat (corinnemanabat.com) with the support of the Asian American Legal Defense and Education Fund.
Why We Rise premiered May 20, 2013 in front of a packed audience at #UndocuAsians, a theater performance by RAISE at The Culture Project.
Join these RAISE members in their fight for change at raisenyc.tumblr.com.
If you are a member of the press and interested in finding out more about RAISE and talking to our members, please contact firstname.lastname@example.com.

subset: commoncrawl


text:
What's better for me? The new Ipad or Ps Vita?
I am a gamer of which I usually more prone to online games such as RoM (Runes of Magic), but I do have a semi-preference for Rachet and Clank type of games. I'd prefer something with an average or above camera as I have found my Ipod's camera isn't the most astounding thing in the world. Surfing the web at a reasonable speed is also a factor. I'd like a device with a reasonable battery life because I do use my electronics frequently. And last of all I'd like to store music and photographs that I can access on the go.
-Which in your opinion is more cost effective?
-If the Vita, is there any games you would recommend?
Earthangel x.
As a gamer, you will definitely feel at home with the Vita's controls. There are games on the iPad that make use of virtual touch screen controls, but those never really feel good.
On the types of games you mentioned: No word any Vita games available now that are for those tastes specifically, being that there isn't much yet, but the previous PSP library may help. There's definitely a lot of RPGs in the PSP's library that you can download off the PSN store to play on your Vita. And there was even a pretty good Ratchet & Clank game on the PSP, "Size Matters", but unfortunately it doesn't seem to be available on the PlayStation Store, last I checked.
I can't think of any Ratchet-and-Clank-ey games on the iPad, which there may be, but there's definitely several RPGs on Apple's app store. There's even a few actual MMOs on there. (side note: Vita appears to be capable of having full-on MMOs as well, but no games have been announced that actually are).
As for the 'essentials': The camera on the iPad, especially the latest one, is really great. No doubt about that; The quality from the rear camera is really nice. Unfortunately for the Vita: It's cameras are rather subpar. You may be better off taking photos from your smart phone (also, curious: What kind of phone do you have? Android, Windows Phone, BlackBerry, iPhone?) The Vita's cameras are nice for the likes of gameplay, like some Augmented Reality games (which seem a lot more accurate than iPad AR), but for actually sharing what you see, the iPad is the way to go between these two. For better or worse, though: You'll be seen holding up that big iPad just to record a video or take a picture...
Surfing the web on the Vita works, but not quite to the degree that you'll find on the iPad. Both devices will also store/play music and photos. Some may say that the iPad may be best for playing those types of media, but both seem alright to me.
As for battery life, you will unfortunately get about 3-5 hours of straight gameplay on the Vita. The iPad, however, can last you about 10 hours from a single charge. I haven't heard anything about the Vita's battery life drastically diminishing yet, but clearly for the iPad, that isn't too much of a worry.
Another thing to keep in mind: Price. For the base wifi model of a Vita is about $249. A memory card, which is essentially REQUIRED, yet not included with each Vita, can cost you from $19.99 for 4 GB up to $99.99 for 32 GB. Vita games will also run you about $9.99-$49.99.
A 16 GB wifi iPad will cost about $499, up to a 64 GB wifi iPad is $699. Many iOS apps are either free or $0.99 or a little higher.
While the iPad is a bit more costly, I feel that that may be best in the long run. You'll find more use with the iPad with it's apps. The Vita itself, however, can do similar things to what the iPad has to offer, like web browsing, music/video/photo playback, cameras, and several of it's own apps like Facebook, Twitter, Foursquare, Skype, Netflix, and Flickr. However, the iPad tends to do all of those a little better, except games for gamers. You won't get the same console-quality games on the iPad since there are no buttons and it's not a dedicated gaming system, although, there isn't that many games available on the Vita right now to probably warrant the purchase. But keep in mind that there will definitely be games on the system that you can't find anywhere else, like the inevitable Ratchet & Clank portable sequel.
In the end: It comes down to a pricey gaming-focused machine with some multimedia capabilities, or the even pricier do-it-all-device that, well, pretty much does everything except proper console-style games.
What would I do if I were in your shoes? Wait.
There's always rumors about another iPad coming in and/or a price cut from Apple, and E3 is just around the corner and Sony could very well announce a much-needed price cut of their own as well as some games and apps coming to the Vita that may make the system appear more worth it.
But if I were to just base my opinions just off of what's available now, I would have to lean towards the iPad.
Hope that helps and best of luck deciding on your next purchase!
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To me, it seems the iPad would be a better choice for you.
In terms of games, you can go from addictive games like Angry Birds and Jetpack Joyride to games with outstandingly beautiful graphics and gameplay like Infinity Blade II.
I believe the camera on the new iPad is quite good - 1080p and 5 MP. See examples here: https://secure.flickr.com/photos/johnkarakatsanis/...
I think the iPad is the best portable way to surf the web.
The battery life is 10 hours of constant use - certainly enough to last all day with normal usage levels.
iPad can store your music and photographs - in fact the new iPad's retina display is the best way to view digital photos.
I think you'd use an iPad more so it's well worth the higher price.
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If you are going to primarily be web surfing, listening to music or viewing pictures, go with the iPad. The vita's browser isn't bad but it does not compare to any competent tablet. As for music and pictures, Sony requires that you use an ap called Content Manger to move files to and from the Vita. While this ap is designed to prevent hacking of the Vita's OS, it is horrible to use. The antithesis of user friendly.
So, examine your priorities and make a decision based on what's important to you. At the end of the day, they are both pretty cool pieces of tech and you won't be disappointed either way you go.
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I own an iPad 2 and a Vita. Recently, due to the large number of games I have for iOS, I contemplated buying an iPod Touch as a portable gaming device. I was deterred when I realized that the deepest game on iOS couldn't hold a candle to the Vita exclusive Gravity Rush. Playing its demo made me realize how much more I enjoy having buttons and control sticks versus on-screen d-pads and virtual buttons.
Another possibility is getting a Vita and a more cost effective tablet. The Samsung Galaxy Tab 2 (7 inch) is available for $250. That with a $300 Vita (if you spring for the GSM version) is only $50 more than the cheapest iPad 3. That might yield the best of both worlds, especially if you can tether the tablet via your smartphone.
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text: Ems win 3 in a row with Renfroe, 8-0 against AquaSox Share this story email Share this story «Previous 9 of 35 Photos Next » Read the story « » Ems win 3 in a row with Renfroe 8-0 against AquaSox26 Marcus Davis (#24) looks at his hit to left field. The hit would earn Davis a double. (Matthew Leslie/Oregon News Lab)


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Straight Cutters
The most commonly used router bit is a straight cutter, and they're available in an astonishing number of sizes. Excellent uses for straight cutters include cutting dadoes and rabbets, making grooves, mortices, inlays, etc. These bits come in basic straight 2-flutes to bits with a downshear or spiral cut.
These router bits by Whiteside are 100% made in the USA, rated #1 by Fine Woodworking magazine, and guaranteed.


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San Francisco Giants v Oakland Athletics
Pitcher Grant Balfour of the Oakland Athletics reacts after striking... News PhotoAmerican League Baseball,Andres Torres,Baseball - Sport,Baseball Pitcher,California,Facial Expression,Grant Balfour,Match - Sport,National League Baseball,Oakland - California,Oakland Athletics,San Francisco Giants,Sport,Stadium,Strike Out,USA,Vertical,o.Co ColiseumPhotographer Thearon W. HendersonCollection: Getty Images Sport 2013 Getty ImagesOAKLAND, CA - MAY 28: Pitcher Grant Balfour #50 of the Oakland Athletics reacts after striking out Andres Torres #56 of the San Francisco Giants for the final out of the game at O.co Coliseum on May 28, 2013 in Oakland, California. The Athletics won the game 6-3. (Photo by Thearon W. Henderson/Getty Images)


text: Photo by Matt Cardy/Getty Images [ Amarillo VA Getting Greener By Turning To Solar Power By James G June 14, 2012 You may have noticed all the construction going on at the VA. It's like they want to save the planet or something. Read More|Comment Category: Amarillo News Tags: Amarillo, solar power, va Send to a friend! Share on Facebook Share on Twitter Pin it! Reddit This! Share on Tumblr!


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Annuities were included in many treaties, from the treaty of 1778 with the Delaware (Lenápe) through the end of the treaty period in 1871. The government had several reasons for including annuities in treaties. In the Report of Commissioner of Indian Affairs for November 1, 1875, Edward P. Smith stated, "The annuity in money or blankets, or bacon and beef, may have a tendency to draw the Indians within the reach of the Government, and prepare them for the beginning of a work of civilization, and also to render them disinclined to take up arms and go upon the war-path. But with any tribe a few years of this treatment is sufficient for the purpose, and after this end has been gained, a continuation of the feeding and clothing, without a reference to further improvement on the part of the Indians, is simply a waste of expenditure."
The distribution of annuities became one of the most important duties of agency personnel and was a complex process. Before distribution each year, the agent took a tribal census to calculate the amount of individual payments. The annuity goods were sent to the superintendent, who was responsible for them until signed payment vouchers were received from the tribe. The distribution was made by the superintendent, agent, and several witnesses to ensure accuracy and legitimacy.
The annuity system was faced with numerous problems, including inferior goods, transportation costs, and corruption. Reformers lobbied for the end of annuity payments, claiming that the annuities increased the dependence of Native peoples rather than aided their progress toward self-sufficiency.
Early annuities, in either cash or goods, were paid to the chiefs of a tribe. The chiefs then distributed the payment to the rest of the tribe according to their personal obligations and tribal customs. However, this did not result in the even distribution the government desired. In 1847, the federal government tried to diminish the power and influence of the chiefs by distributing annuity payments directly to heads of families.
Goods distributed in annuity payments included beef, flour, sugar, coffee, corn, pork, shoes, clothing, blankets, beads, mirrors, beds, plows, wagons, and other goods deemed necessary to propel Native peoples toward civilization. Individual portions of tribal annuities ranged from a few cents to more than $100. In many instances, cash annuities went directly to traders to pay for goods that had been bought on credit during the year.
The government often threatened to withhold annuity payments to influence the actions of Natives. The Trade and Intercourse Act of 1834 provided for the payment of depredation claims against a tribe from that tribe's annuity. Tribes could also lose their annuity payments if they returned to ceded land, fought with other tribes or white citizens, resisted allotment, or refused to send their children to school.
Tamara Levi
Further Reading
Priest, Loring Benson. Uncle Sam's Stepchildren: The Reformation of United States Indian Policy, 1865–1887. Lincoln: University of Nebraska Press, 1975; Prucha, Francis Paul. The Great Father: The United States Government and the American Indians. 2 vols. Lincoln: University of Nebraska Press, 1984; Washburn, Wilcomb E. The American Indian and the United States: A Documentary History. New York: Random House, 1973.


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Arkanius is a 2D Retro-Styled Fantasy MMORPG. It is currently in development, however, already has many features. There is a very interactive and deep quest system, a weather system, player housing, leveled and experience based skills including cooking, woodcutting, mining, tailoring, leatherworking, blacksmithing, fishing, harvesting, alchemy, crafting, carpentry and enchanting. The player can fight solo or in parties, participate in social events including last-man-standing PvP events on distant islands and much more. There is magic, projectile and melee weapons. The characters have their equipment paperdolled in harmony with each other, equipment including shoulder armour, cloaks, helmets, amulets, quivers, shields, armour, weapons, belts, gloves, boots and rings in which can all be worn without any cluttered look whatsoever. Characters can be personalized to the players own choice through many hairstyles and colours.
A small update to the game client's GUI. The player's portrait has been added to the left of the vital bars.
Posted by ArtisanCodesmith on Oct 27th, 2012
I've added a portrait (based on your character, just as the chat portrait works) to the left of the player's vitals (health, magic and experience). I feel it gives the impression that the vital bars are your characters vital bars. I didn't feel they gave that impression as much so without the portrait there. Any way, all feedback is welcome as always.


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Watch this video and think
Written by Escape The Illusion 4 Comments
Last Updated: March 10, 2010
Powerful video that is very thought provokingView Escape The Illusion's Profile Subscribe via RSS
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#1 procyon
March 11, 2010 pm31 6:13 am
…but they wouldn't do that to us. Why would canola and aspartame be allowed in our food if those additives caused cancer or leukemia. H1N1 is swine fever, the vaccine will save our lives…but Lee Harvey Oswald shot Kennedy not the guy driving the presidents car…but NASA wouldn't lie about there being no life on mars nor would they doctor and obfuscate photos from around the solar system…It's ridiculous saying there are people on mars and even more ridiculous saying the next false flag attack wii come from space.
Im your average american, and I'm comfortable in my bed sleeping, yet you try to wake me up to this fallacies. I'm rolling over and going back to sleep. Btw I will get up tomorrow to watch The Matrix again. Thats a good story…
#2 renee
March 12, 2010 pm31 2:42 am
please remember , this world and everything happening in it is just a test. they want your soul. do not give it to them. until the test is over, love one another
#3 pj
March 15, 2010 pm31 6:10 am
Government is good. Government cares about you. Government knows what is best for you. Government is the most efficient provider of all things. Nancy Pelosi loves you. President Obama cares about you. Everything evil is because of private companies. Everything vile is because of profit. The government wants to care for you. All wealth is created by the government. All goodness comes from the government. All pray for the government. All hail the government. All love the government. Love, peace, government, hot chocolate, government and warm puppies. Any criticism of the government is racist and hateful. We must love our government and our Dear Leader. Dedicate yourself to the government. Denounce deviation. Obama 2012. Obama 2012. Obama 2012.
#4 helen
February 22, 2011 pm31 12:45 am
PJ, you lost your mind, completely. It is very scary that there are too many morons like you…. wow….


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STEUBENVILLE, Ohio (WKYC) -- Ohio Attorney General Mike DeWine says two girls have been arrested for making threats social media threats against the victim in the recent emotional Steubenville rape trial.
"Let me be clear. Threatening a teenage rape victim will not be tolerated. If anyone makes a threat verbally or via the internet, we will take it seriously, we will find you, and we will arrest you," said DeWine.
Detectives with the Jefferson County Sheriff's Office alerted the Attorney General's Bureau of Criminal Investigation to the online threats soon after Sunday's sentencing hearing concluded.
The Steubenville girls, 15 and 16, were both taken to the Jefferson County Juvenile Detention Center upon arrest.


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Maximum Price Contracting
Is this a program that fits the needs of you or your business?
· Are you concerned about the potential of increasing fuel costs?
· Would it benefit you to know your fuel prices would not exceed a set price for six months?
· Would it benefit it you to know that if fuel prices dropped in that time period, you would receive the benefit of the lower pricing?
· Would knowing your fuel costs for the next six months assist you in budgeting for your business?
If you answered yes to any of the above questions it may be time for you to talk to your local AGRIS location or call 1-800-363-3385 to find out more about Maximum Price Contracts.
Answers to questions about Maximum Price Contracts
What is it?
A program designed to enable you to purchase a contract to establish a ceiling on your fuel prices for up to six months.
How does it work?
On the day you sign your Maximum Price Contract, your maximum price will be established at four cents above your current fuel price. For example, if today your price for clear diesel is $0.9099/litre; your maximum price would be set at $0.9499/litre for the term of your contract.
When does the contract expire?
The duration of the contract is six months or until you purchase the total of the litres booked in your Maximum Price Contract, whichever occurs first.
What if the market price for fuel drops during the term of my contract?
If fuel prices drop during the term of your contract, you will pay the lower price for your fuel. The Maximum Price Contract protects you against rising fuel prices, while offering the benefit of paying a lower price if the market prices decrease.
What products can I book?
You can book dyed diesel, clear diesel or furnace oil on a Maximum Price Contract.
What does it cost to buy a contract?
The cost to purchase a contract is 3.5 cents a litre for the number of litres you choose to book. For example if you choose to book 10,000 litres, your price to purchase the contract would be 10,000 x $.03.5= $350.00 + GST.
AGRIS Co-operative reserves the right to limit quantities booked.
You will be required to sign a contract to book the fuel.


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Sneak-a-Peek: Oakley Jupiter Carbon Sunglasses
The Oakley Jupiter Carbon Sunglasses are one of the newest releases to come out of Oakley Sunglasses HQ and they may look a little familiar…but don't let that fool you! Those of you who remember the Oakley Jupiter Factory Lite Sunglasses will be able to draw this comparison, however they are very different indeed; from the material that they are made of, right through to subtleties in design. First of all, lets discuss the similarities; they both have an almost identical shape and profile on your face, patented Plutonite lenses which are 100% UVA, UVB and UVC protective and both of their lenses feature Oakley's HD and XYZ Optics which completely cut out refraction of light and therefore the optical clarity is second to none! Oakley have over 600 patents to protect this technology so you can be sure that you won't find this kind of innovation elsewhere.
As with the Oakley Jupiter Factory Lite Sunglasses, the Oakley Jupiter Carbon Sunglasses feature lightweight carbon fibre arms which are attached with mono-shock hinges for a truly comfortable wear and the 'three-point fit' technology ensures that they will fit the vast majority of head sizes and shapes. Where the two frames differ is the actual frame itself; where the Factory Lites had a precision engineered aluminium centre frame, the Oakley Jupiter Carbon Sunglasses have an O Matter centre frame. O Matter is Oakley's patented polycarbonate compound which is incredibly flexible and durable and is impact resistant to the same level as industrial strength eyewear!
Although these amazing frames are not going to be available until the summer, you can register your interest on our site and we will let you know when they arrive. Make sure to follow us on Facebook and Twitter for daily updates and news…
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October 04, 2003 November 01, 2003
76 Grand Street, New York
Ryan McGinness is known for his labyrinths of flat imagery, but in
Worlds Within Worlds
he extended his vision into the viewers space and created a world where his iconic imagery filled the air and breathed a sense of life. These multiple environments suggest the existence of parallel universes that develop self-similar cultures independently of each other but that are occasionally and briefly informed of one anothers progress through repeated wormholes in the forms of plants, roots, and other tunnel-like shapes. McGinness expanded this labyrinth into the third dimension with a mirrored maze installation in which the viewer was interjected between infinitely reflected collapsing and expanding graphic worlds.
More information about:
Ryan McGinness
Select press
Surface Magazine, Profile
ARTnews, Worlds within Worlds
Select a project
Dream Garden
Art Basel Miami Beach 2004
Art Basel Miami Beach 2003
Art Basel Miami Beach 2002
alife Shop
Session the Bowl


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For aspiring actors, we recommend the following
online extras directories:
Whether you are an aspiring actor, or just want to be seen in your favourite movies or television shows and series, being an extra is the perfect start to get familiar with showbiz, and on top of that you often make some extra cash. So, what does it take and how do you become an extra?
extras get to rub elbows with the celebrities without having to memorize lines or attend acting classes
extras get to rub elbows with the celebrities without having to memorize lines or attend acting classes. If you are an aspiring actor, being a background artist can give you some much needed experience and maybe even a few networking opportunities.
Heard of Shirley Temple, Client Eastwood and Bruce Willis? Former extras
Ben Affleck, Matt Damon, Shirley Temple, Bruce Willis, Clint Eastwood, Dennis Hopper, Jeff Goldblum, Adam Brody, Jackie Chan, Sylvester Stallone, Heath Ledger, Cuba Gooding Jr. are just a few of the actors that started as extras.
Extras.co.uk is more than twice as popular as FilmExtras.co.uk! [Alexa Traffic Rank, Nov 2008]
How do you know which online extras directories are good and which ones are not? A good extras directory has a strong focus on extras; many and relevant members; a user-friendly Website frequently utilised by its members, production companies and casting directors (compared to similar sites in the same region); many and relevant ads, casting calls, production companies and casting directors; and a reasonably priced subscription.
Extras Home | How to Become an Extra? | Famous Extras | Directories of Extras | Film Resources | Glossary for Extras
Copyright © 2011 Extras . All rights reserved. Sitemap


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Red Wings Patrick Eaves, right, and Pavel Datsyuk celebrate a goal during scrimmage in September 2011. Eaves was hurt by a puck in November of last year.
- Filed Under
Eleven months after he was felled by a puck during a game, Red Wings forward Patrick Eaves remains bothered by postconcussion problems.
He can, at the very least, skate regularly with some of his locked-out teammates, something he wouldn't be able to do if the NHL wasn't mired in a labor dispute.
Eaves, 28, checks in regularly with a concussion specialist at the University of Michigan Hospital, but otherwise tries to lead as full a life as possible. He spent Sunday at Ford Field cheering on the Lions against Seattle, opting to watch the Tigers-Giants World Series game from home. ...


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Blood Cleanser, diuretic
Native to Europe, Dandelions are now found all over the world
- much to the chagrin of those who like a vast expanse of
green lawn. But not everyone reviles the humblest member of
the sunflower family.
are rich in vitamins A, B, C, D and G and minerals such a
potassium. Dandelion leaves can be tossed into salads, it's
flowers distilled into wine and spirits, its roots dried into
teas or roasted into a coffee-like beverage. The Chinese considered
the plant a "blood cleanser" and used Dandelion juice to clear
up infections as far back as the seventh century. Europeans
were using the plant medicinally by 1485. Folk medics used
the plant as a diuretic, a digestive aid and to cure warts
and blisters. Today, dandelions are widely believed to lower
cholesterol and benefit the liver. Modern research suggests
that dandelions do possess antibacterial, and possibly antiviral
properties. It is also a mild diuretic and laxative.
1990-2003 The Chedd-Angier Production Company, Inc. All rights reserved.


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"Megyn's still on maternity leave, isn't she? Boy, what a racket that is."
Fox News host Megyn Kelly defends Maternity Leave.
Easy to defend human rights when it's you. When it's someone else, not so feminist:
So close to redeeming herself after that whole "Did this lady beaten into a coma deserve it?" thing. And yet, still so far away. [Media Matters]
Still, awesome sauce:
MK: What a moronic thing to say.
MG: Well, I mean, let's— Are you going to disagree that's there a diff—
MK: Oh, you're standing by? Are you doubling down? No, no, no, no, no, are you not taking those remarks back? Is maternity leave, according to you, a racket?
MG: Well, do men get maternity leaves?
MK: Guess what honey? Yes, they do. It's called Family Medical Leave Act. If men would like to take three months off to take care of their newborn baby, they can.
MK: OK. Let me give you an explanation. I was drinking that day.
MK: Now you're more along the path I expected.
MK: Just in case you didn't know, Mike, I want you to know that the United States is the only country in the advanced world that doesn't require paid maternity leave. Now I happen to work for a nice employer that gave me paid leave. But the United States is the only advanced country that doesn't require paid leave. If anything, the United States is in the dark ages when it comes to maternity leave. And what is it about carrying a baby for nine months, that you don't think deserves a few months off so bonding and recovery can take place, hmm?
MG: I have a— I even think a— People on your staff— [bullshit about trying to call Megyn on the phone or something]
MK: You can't answer the question because there is no answer, my friend.
Incorrect source, offensive, or found a typo? Email us (please put title in subject bar of email so we'll be able to fix). Or do you want to write for Elephant?
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2 Responses to ""Megyn's still on maternity leave, isn't she? Boy, what a racket that is.""
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