United States v. Ojedokun, No. 21-4127 (4th Cir. 2021)
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Ojedokun participated in a complex international operation designed to obscure the proceeds of a U.S.-based fraud scheme that involved contacting elderly victims on internet dating websites. In 2019, after relocating to this country from Nigeria, Ojedokun was questioned and arrested by the FBI at his Illinois home and was indicted. The grand jury returned a superseding indictment in August 2020, which Ojedokun unsuccessfully moved to dismiss as untimely. Ojedokun filed multiple unavailing suppression motions, was convicted of conspiracy to commit money laundering, 18 U.S.C. 1956(h), and was sentenced to 108 months' imprisonment.
The Fourth Circuit affirmed. Section 1956(f) overcomes the presumption against exterritorial jurisdiction not only as applied to the substantive money laundering offenses, but also with respect to conspiracy offenses under 1956(h). By making an agreement with at least one U.S. resident and engaging in a conspiracy extensively carried out in this country, Ojedokun participated in conduct relevant to the 1956(h) charge that transpired within the U.S., placing his actions within the confines of 1956(f)(1). The allegations in the Original Indictment afforded Ojedokun sufficient notice of what he was accused of in the Superseding Indictment, which related back to the date of the Original and was not barred by the statute of limitations. Ojedokun’s consent for the agents to enter his home was fully voluntary and the agents remained within the scope of that consent.
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