## Facts

- A drug trafficker generated millions of dollars in illicit profits and used others to conduct transactions involving the cash proceeds.
- Basilio Rivera-Rodríguez and Oscar Trinidad-Rodríguez were tried jointly and convicted of conspiring to launder money, based on their participation in financial transactions tied to the trafficker’s proceeds.
- The government’s theory was that defendants handled transactions structured to reduce detection and conceal the source, ownership, or control of the funds, rather than participating in drug distribution.
- Trinidad, a speedboat racer, engaged in transactions with the trafficker related to speedboat purchases, including one in which he received $100,000 in cash taken from a concealed stash.
- For the speedboat purchase, the cash was converted into multiple smaller manager’s checks, purchased through associates at different banks, in amounts kept below common reporting thresholds.
- Rivera engaged in transactions involving the trafficker’s cash proceeds that used intermediaries and arrangements that obscured the trafficker’s ownership and the source of funds.
- At trial, the government relied heavily on testimony from the trafficker and circumstantial indicators (structuring, use of intermediaries, and unusual handling of large cash amounts) to show knowledge and concealment purpose.

## Issues

1. Whether the evidence was sufficient to prove beyond a reasonable doubt that each defendant knew the funds were proceeds of some unlawful activity and knew the transactions were designed, at least in part, to conceal or disguise the nature, source, ownership, location, or control of those proceeds, as required by 18 U.S.C. § 1956(a)(1)(B)(i) and § 1956(h).
2. Whether the jury could infer the required knowledge from circumstantial evidence, including a willful-blindness theory.
3. Whether alleged trial-management and evidentiary errors (including issues related to a joint trial) warranted reversal.

## Decision

- The First Circuit affirmed both defendants’ convictions for conspiracy to launder money.
- Applying the sufficiency standard, the court viewed the evidence in the light most favorable to the verdict and held a rational jury could find the statutory knowledge and concealment-design elements.
- The court concluded that the transactional patterns—large hidden cash, structuring into multiple smaller instruments, use of third-party purchasers, and methods obscuring ownership—supported findings of actual knowledge or willful blindness.
- The court rejected the remaining evidentiary and trial-related claims, finding no reversible error.

## Legal Principles

- To prove concealment money laundering under 18 U.S.C. § 1956(a)(1)(B)(i), the government must show (1) a financial transaction involving proceeds of unlawful activity, (2) the defendant’s knowledge that the property represents proceeds of some unlawful activity, and (3) the defendant’s knowledge that the transaction was designed, at least in part, to conceal or disguise the nature, source, ownership, location, or control of the proceeds; conspiracy liability is governed by § 1956(h).
- The government need not prove the defendant knew the specific underlying felony that generated the proceeds; knowledge that the funds came from some felonious activity is sufficient.
- Knowledge may be established through circumstantial evidence, including proof of willful blindness—deliberate avoidance of facts that are plainly indicated by the circumstances.
- Transaction features commonly associated with concealment—structuring payments into smaller instruments, using multiple banks or intermediaries, and atypical handling or storage of large cash sums—can support a jury inference of both illicit source awareness and concealment design.

## Conclusion

The court upheld the money-laundering conspiracy convictions because the evidence permitted a reasonable jury to find that each defendant knowingly handled felony-tainted funds through transactions structured to conceal the funds’ source or ownership, and any additional trial-related challenges did not justify reversal.


United States v. Rivera-Rodríguez, 318 F.3d 268 (1st Cir. 2003)