transmissions, and transfers represented the proceeds of some form of unlawful activity, and knowing that such transportation, transmissions, and transfers were designed in whole and in part to conceal and disguise the nature, the location, the source, the ownership, and the control of the proceeds of specified unlawful activity, to wit, identity theft, access device fraud, computer hacking, wire fraud, child pornography, and narcotics trafficking, in violation of Title 18, United States Code, sections 1023, 1029, 1030, 1343, and 2252, and Title 21, United States Code, section 541, respectively, in violation of Title 13, United States Code, section 1956(a)(2)(B)(i).
(Title 18, United States Code, section 1956(h).)
COUNT TWO
(conspiracy to operate Unlicensed Money Transmitting Business)
The Grand Jury further charges:
BACKGROUND
33. The allegations contained in paragraphs 1 through 29 of this Indictment are repeated and realleged as if fully set forth herein.
34. Title 1B, United states code, section 1950 makes it a crime to operate an unlicensed money transmitting business. The statute was enacted in 1992 in order "to combat the growing use of money transmitting businesses to transfer large amounts of the monetary proceeds of unlawful enterprises,"
