The World in U.S. Courts: Fall 2013 - Criminal Law | September.18.2013
Defendant was charged with participating in a vast conspiracy to distribute cocaine and launder money. As part of the scheme, Defendant allegedly moved large quantities of drug proceeds from the U.S. to Colombia in a series of transfers. Among other arguments, Defendant claimed the money laundering statute could not be applied to his extraterritorial cash transactions from the U.S. to Colombia. However, the court of appeals disagreed, holding that because each cash transaction originated and was initiated in Miami the requirements for extraterritorial jurisdiction were met. Even if the shipments to Colombia were outside the government’s jurisdiction, the Court held, the transactions within Miami were punishable themselves under the money laundering statute.