Background
Defendants Nafis Quaye and Sunna Sepetu operated business entities that received over three million dollars from a romance scam victim. Quaye directed friends and family to open accounts, while Sepetu, his romantic partner, registered one entity and facilitated transfers. Despite bank inquiries and law enforcement questioning, they continued to withdraw and spend funds on personal expenses without maintaining business records or knowing the victim.
The court’s reasoning
The court held that the evidence, viewed in the light most favorable to the government, was sufficient to support the jury’s verdict. The pattern of using multiple accounts, withdrawing large sums for personal use, and failing to maintain records or answer basic business questions supported a finding that the defendants were willfully blind to the illicit origins of the funds. The court also found no error in the jury instructions regarding willful blindness or the government’s arguments.
What it means going forward
Reinforces that willful blindness can be proven through circumstantial evidence of suspicious financial patterns and lack of business documentation, even without direct proof of knowledge of the specific fraud scheme.
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