1st Cir.

United States v. Quaye

May 15, 2026 ·24-1821 ·Panel Decision ·Dunlap · By James Taylor

The First Circuit affirmed convictions for money laundering conspiracy, finding sufficient circumstantial evidence of willful blindness regarding fraud proceeds.

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Background

Defendants Quaye and Sepetu operated business entities that received over three million dollars from a romance scam victim. They used these funds for personal expenses without maintaining records of legitimate business transactions, despite bank inquiries about the source of funds.

The court’s reasoning

The court held that circumstantial evidence was sufficient to prove the defendants had actual knowledge or were willfully blind to the unlawful origins of the proceeds. The defendants’ failure to keep records, their withdrawal of large cash sums for personal use, and their continued operations after bank inquiries supported the jury’s verdict.

What it means going forward

Reinforces that willful blindness can be established through circumstantial evidence in money laundering cases involving unexplained large transfers and lack of business documentation.

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