US Court partially allows venue challenge in money laundering and sanctions evasion case
20 August 2025
A US District Court in the District of Colombia has partially allowed a proper venue challenge in a money laundering and sanctions evasion case.
The defendant, Guanghua Jin, is charged with 12 counts of participation in a bank-fraud, sanctions-evasion, and money-laundering conspiracy. Mr Jin challenged all 12 charges on the basis that the DC District Court was not the proper venue to hear the charges.
The Court found an adequate basis for venue in the conspiracies and substantive sanctions violations charges (charges 1-7) because the “essential conduct elements” of the alleged offences were completed outside the US and were thus within the scope of “high-seas” venue statute (section 3228).
However, the Court found that the substantive money-laundering charges (charges 8-12) should be dismissed for lack of adequate basis of venue. The Court observed that the institutions which Jin allegedly moved funds to, from, or through have headquarters in the US but not in DC. The essential element of the offending was therefore outside the scope of section 3228. Since the Government did not identify any other basis for venue for these counts, the substantive money-laundering charges were dismissed.
