US v. Pierre Almonor
Split Score
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Case Summary
Disposition
Affirmed
The Fourth Circuit affirmed Pierre Yvelt Almonor’s conviction and sentence for conspiracy to commit money laundering. Rejecting eight appellate challenges, the court upheld rulings on Batson, venue, jury instructions, evidentiary issues, loss and restitution calculations, a money-laundering business enhancement, and supervised-release conditions.
Circuit Split Identified
Legal Issue
Whether 18 U.S.C. § 1956(i) requires that overt acts establishing venue in a money-laundering conspiracy be reasonably foreseeable to the defendant.
Circuit Positions
Venue for money-laundering conspiracy requires that overt acts in the district were reasonably foreseeable to the defendant.
Venue is proper in any district where any conspirator committed an act in furtherance of the conspiracy; no foreseeability requirement.
Conflict Summary
The Second Circuit holds that, for venue in a money-laundering conspiracy, overt acts performed in the venue district must have been reasonably foreseeable to the defendant, while the Fourth and Sixth Circuits read § 1956(i) to require no such foreseeability—venue is proper in any district where any conspirator committed an act in furtherance of the conspiracy.