Promotion Money Laundering
When property is involved in a conspiracy to commit promotion money laundering, the crime is charged under 18 U.S.C. § 1956(a)(1)(A)(i) and (h). Promotional money laundering has many of the same requirements for concealment laundering that include showing that the financial transactions knowing they were proceeds involved in some other form of unlawful activity. 18 U.S.C. § 1956(a)(1).
To meet its burden as to promotion money laundering, in particular, the United States has to show that conspirators conducted financial transactions “with the intent to promote the carrying on of specified unlawful activity,” which includes wire fraud in violation of 18 U.S.C. § 1343. 18 U.S.C. §§ 1956(a)(1)(A)(i), 1956(c)(7)(A), 1961(1).
The United States must also show that they knew that the property involved in those transactions “represent[ed] the proceeds of some form of unlawful activity.” 18 U.S.C. § 1956(a)(1).
Financial transactions include those that “in any way or degree affect[] interstate or foreign commerce . . . involving the movement of funds by wire or other means” (which include virtual currency) or that involve “the use of a financial institution which is engaged in, or the activities of which affect, interstate or foreign commerce in any way or degree.” Id. § 1956(c)(4).
Financial institutions include, among other things, foreign or domestic banks and currency exchanges. 18 U.S.C. § 1956(c)(6); 31 U.S.C. § 5312(a)(2).
In some cases, the promotion offense “is aimed . . . only at transactions which funnel ill-gotten gains directly back into the criminal venture.” United States v. Stoddard, 892 F.3d 1203, 1214, 436 U.S. App. D.C. 205 (D.C. Cir. 2018) (citation omitted).
The intent to promote the underlying illegal activity can generally be shown by facts showing conspirators benefited from, or had extensive knowledge about, the underlying illegal activity they were promoting. The distribution of funds to co-conspirators qualifies as such promotion.
In cryptocurrency cases, the conspirators in these cases might distribute funds to other participants in the conspiracy to compensate them and thereby promote their continued participation in subsequent hacking activities.
In other cases, the proceeds from the thefts are used to pay for infrastructure perpetuating the scheme, such as domain registration and virtual private networks.
Attorneys for Promotion Money Laundering in Tampa, FL
Contact an attorney at Sammis Law Firm if you were accused of promotion or concealment money laundering or being involved in a conspiracy to commit concealment money laundering.
We help clients fight such accusations in the federal courts throughout the Middle District of Florida and Tampa Division. We protect clients charged with promotion, concealment money laundering, or international concealment money laundering.
Call 813-250-0500.
International Promotion Money Laundering
When property is involved in a conspiracy to commit international promotion money laundering, the crime is charged under 18 U.S.C. § 1956(a)(2)(A) and (h).
The statute prohibits the movement of funds across the border of the United States “with the intent to promote the carrying on of specified unlawful activity.” 18 U.S.C. § 1956(a)(2)(A). Under this form of money laundering, specified unlawful activities include wire fraud. Id. §§ 1956(c)(7)(A), 1961(1).
The term “promote” means to make the underlying illegal scheme easier by funneling ill- gotten gains directly back into the criminal venture.
In cases involving cryptocurrency, the federal prosecutor might alleged that conspirators sent the virtual currency stolen from a U.S.-based exchange to to exchanges outside the United States or to unhosted wallets in foreign conspirators’ control. In these cases, federal prosecutor might allege the transactions were intended to promote the ongoing wire fraud scheme.
Federal charges under Section 1956(a)(2)(A) that penalize an overseas transfer with the intent to promote the carrying on of specified unlawful activity.
This article was last updated on Friday, October 3, 2025.
