United States v. St. Michael's Credit Union

880 F.2d 579 (1989)

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United States v. St. Michael’s Credit Union

United States Court of Appeals for the First Circuit
880 F.2d 579 (1989)

Facts

Janice Sacharczyk (defendant) was the bookkeeper for St. Michael’s Credit Union (St. Michael’s) (defendant). After a Massachusetts banking-commission audit revealed that St. Michael’s had failed to file two currency-transaction reports (CTRs), the Internal Revenue Service (IRS) initiated an investigation. Sacharczyk showed IRS agents copies of two CTRs she claimed to have sent after the state audit and indicated that St. Michael’s had no official policy regarding CTRs and no CTR compliance officer. The investigation revealed many transactions for which no CTRs were filed. Sacharczyk and St. Michael’s were charged with felony violations of the CTR-reporting requirement. The indictment charged 50 different violations involving 25 different customers and five different forms of currency transfers. Sacharczyk and St. Michael’s were convicted. On appeal, Sacharczyk and St. Michael’s argued that the government (plaintiff) had failed to prove that the transactions alleged in the indictment formed a pattern of illegal activity.

Rule of Law

Issue

Holding and Reasoning (Bownes, J.)

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