Responding to a Money Laundering Civil Investigative Demand (CID)
So your probably sitting there with this Civil Investigative Demand about money laundering and your entire life is falling apart. Maybe your bank transactions got flagged. Maybe someone claimed you structured deposits. Or maybe your business dealings triggered there algorithms. Look, we get it. Your ABSOLUTELY TERRIFIED. And you should be! Because money laundering under 18 USC § 1956 carries 20 YEARS in federal prison and fines up to $500,000 or DOUBLE the transaction amount!
What Is Money Laundering and Why Am I Being Investigated?
Let me explain the nightmare your facing. The Money Laundering Control Act criminalizes virtually ANY financial transaction involving proceeds from illegal activity – even if you didn’t know it was illegal!
Here’s what’s really scary – “specified unlawful activity” includes over 200 different crimes! Got paid by someone who committed tax fraud? Money laundering! Deposited a check from someone who violated environmental laws? Money laundering! Received wire transfers from a business that bribed someone? MONEY LAUNDERING! You don’t need to know about the underlying crime to be guilty!
The government interprets money laundering so broadly that normal business transactions become federal felonies. Moving money between your own accounts? Could be concealment laundering. Paying business expenses? Promotional laundering. Breaking up deposits? Structuring! We’ve seen legitimate businesspeople imprisoned for completely innocent financial transactions!
How Devastating Are Money Laundering Penalties?
Sit down and hold onto something because these numbers will destroy everything you’ve worked for. Money laundering penalties are absolutely crushing:
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(212) 300-5196Section 1956: Up to 20 years in prison PER TRANSACTION plus fines up to $500,000 or twice the value involved – whichever is GREATER! Had $1 million pass through your accounts? That’s a $2 million fine! Section 1957: 10 years prison for transactions over $10,000. And every deposit, every wire, every check is a SEPARATE count!
Let me paint you a nightmare: You received 50 wire transfers of $20,000 each from a client who, unknown to you, committed fraud. That’s 50 counts of money laundering = 1,000 YEARS potential prison time + $100 MILLION in potential fines! Obviously nobody gets that, but prosecutors use it to force guilty pleas!
What’s the Difference Between 1956 and 1957?
Understanding this distinction is critical because they carry different penalties and requirements! Section 1956 requires intent to promote or conceal while Section 1957 is simpler but still devastating.
Todd Spodek
Lead Attorney & Founder
Featured on Netflix's "Inventing Anna," Todd Spodek brings decades of high-stakes criminal defense experience. His aggressive approach has secured dismissals and acquittals in cases others deemed unwinnable.
Section 1956 covers four types: Promotional (using proceeds to further crimes), Concealment (hiding the source), Structuring (avoiding reporting requirements), Tax evasion (evading taxes on criminal proceeds). Each type requires specific intent but prosecutors are experts at inferring intent from circumstances!
You received a Civil Investigative Demand from the DOJ's Money Laundering and Asset Recovery Section requesting five years of bank records, wire transfer details, and business financial statements. The CID references 18 USC § 1956 and gives you only 30 days to produce thousands of documents or face judicial enforcement.
Can I push back on the scope of this CID or am I legally required to hand over everything they're asking for?
A Civil Investigative Demand is not a grand jury subpoena, and you do have the right to negotiate its scope or file a petition to modify or set aside the CID under 18 USC § 1968(f) if compliance would be unreasonable or oppressive. Your attorney can challenge overbroad requests, assert applicable privileges including Fifth Amendment protections against self-incrimination, and negotiate a more manageable production timeline with the issuing office. However, ignoring the CID entirely is extremely dangerous — the government can seek a federal court order compelling compliance, and obstruction could escalate this from a civil inquiry into a criminal investigation. The key is responding strategically within the deadline while preserving every legal protection available to you.
This is general information only. Contact us for advice specific to your situation.
Section 1957 is the “spending statute” – it criminalizes ANY transaction over $10,000 involving criminal proceeds, even buying groceries! No intent required! Just spending or depositing tainted money is enough. We’ve seen wives imprisoned for depositing there husband’s paychecks because his employer committed fraud!
