View PDF Version  No. 06-1005   In the Supreme Court of the
United States       Solicitor General Counsel of Record
Department of Justice Washington, D.C. 20530-0001 (202) 514-2217
In the Supreme Court of the United States  No. 06-1005
The Seventh Circuit has seriously misconstrued the prin cipal
federal money laundering statute, 18 U.S.C. 1956(a)(1), by
interpreting the term "proceeds" to mean "profits." As the
government's opening brief demonstrates, the statutory text,
background, and purposes make clear that "proceeds" instead
means "gross receipts." Respondents rely on secondary dic
tionary definitions, statements in the legislative history, and
a claimed need to employ a "profits" definition in order to
distinguish money laundering from the underlying crimes. But in
the end they are unable to support their contention that
Congress would have adopted the onerous and impracti cal
requirement that the government establish that a criminal
venture is profitable before a defendant may be held liable f