(b) Example 2: A typical FECA crime: laundered
corporate contributions
Factual Scenario: A corporate CEO contributes $50,000
in corporate funds to a federal candidate in violation of 52
U.S.C. § 30118 by laundering the money through thirteen
conduits in violation of § 30122, twelve of whom gave
$4,000, and one of whom gave $2,000. The defendant’s
motive was to fulfill a pledge. The conduct results in one
§ 30118 felony violation under § 30109(d)(1)(A)(i) with
an aggregate value of $50,000, and one § 30122 felony
violation under § 30109(d)(1)(D)(i) involving the thirteen
conduit transactions. The combined aggregate value of the
defendant’s illegal conduct is $50,000. The conduct would
be charged in two counts: one violation of § 30118
charged under § 30109(d)(1)(A)(i), and thirteen
violations of § 30122 aggregated together as one offense
charged under § 30109(d)(1)(D)(i).
Total Offense Level: 14
Base Offense Level under § 2C1.8(a): 8
Enhancement for value between $40,000 and
$95,000 under § 2B1.1(b)(1)(D): 6
Enhancement for number of illegal transactions under
§ 2C1.8(b)(4) (fourteen violations – one
§ 30118 corporate contribution crime and
thirteen § 30122 conduit crimes): 0
187
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