Thursday, July 30, 2026

Conviction for Promotional Money Laundering Conspiracy Requires Proof of Agreement to Reinvest Funds

US v. Jones: Jones was involved in scheme where people would make straw purchases of firearms in West Virginia which he and others would resell in Pennsylvania. He was charged with (among other things) conspiracy to engage in promotional money laundering with others in Pennsylvania, but not with the straw purchasers in West Virginia. He was convicted on that count (and others) and sentenced to 300 months in prison.

On appeal, a divided Fourth Circuit vacated Jones’ conviction for conspiracy to commit promotional money laundering. Whereas regular money laundering is about “scrubbing” the taint of funds acquired from illegal activity, promotional money laundering is about using the proceeds of illegal activity to reinvest in that activity. Here, the court concluded, the Government had not shown that Jones and the Pennsylvania resellers he was alleged to have conspired with ever had such an agreement. That illicit funds were used to pay expenses of the scheme (and those in it) was not enough.

Judge Quattlebaum dissented as to the conviction, arguing that the majority “misapplies Supreme Court and Fourth Circuit precedent” in its opinion.

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