The mere payment of the purchase price of drugs, by whatever means, does not constitute money laundering, and here the government showed nothing more. United States v. Harris, 666 F.3d 905 (5th Cir. 2012).
The Fifth Circuit reversed for insufficient evidence the defendant's convictions for money laundering and attempted money laundering (18 U.S.C. § 1956(a)(1)(B)(i)) and conspiracy to commit money laundering (§ 1956(h)). The court held that the government failed to prove that the transactions involved the proceeds of illegal activity. A transaction to pay for illegal drugs, alone, is not money laundering because the funds are not proceeds of an unlawful activity when the transaction occurs, but become so only after the transaction is completed.