Background
Okorie was indicted for conspiracy to commit money laundering involving business email compromise and romance scams. He argued venue was improper, there was a material variance in the conspiracy charge, prior convictions were unfairly prejudicial, the deliberate ignorance instruction was erroneous, and his sentence was unreasonable.
The court’s reasoning
The court held that venue was proper where acts in furtherance of the conspiracy occurred. It found sufficient evidence of a single conspiracy rather than multiple ones. The admission of prior convictions was appropriate to prove intent, and the deliberate ignorance instruction was warranted by the evidence. The sentence was upheld as reasonable given Okorie’s history and the need for deterrence.
What it means going forward
The decision reinforces that venue for money laundering conspiracy can be established in any district where a co-conspirator acts, and that prior convictions are admissible to prove intent in fraud cases.