United States v. Miguel Amaris-Caviedes, 701 F. App'x 84

DEA investigated Miguel Amaris-Caviedes for laundering drug proceeds through his Costa Rican business; he traveled to Philadelphia and agreed with cooperating sources to launder funds.
Agreed scheme: receive wire transfers into his Costa Rican business account, remit funds (minus a fee) to an account in Puerto Rico, and provide fictitious invoices to make transfers appear legitimate.
Transactions were structured to avoid detection (recommendation to split transfers into smaller amounts).
DEA sent undercover funds in November 2013; Amaris-Caviedes routed funds and produced fake invoices.
Indicted in May 2014 on two counts under 18 U.S.C. § 1956(a)(3)(B); pleaded guilty and was sentenced to 60 months.
On appeal, he challenged a two-level Sentencing Guidelines enhancement for "sophisticated laundering" under USSG § 2S1.1(b)(3).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the two-level "sophisticated laundering" enhancement under USSG § 2S1.1(b)(3) was improperly applied	Amaris-Caviedes: District Court applied the enhancement as if money laundering is per se sophisticated and relied on irrelevant conduct; the offshore account alone is insufficient	Government/District Court: Transactions used an offshore account and included layering, fake invoices, use of legitimate business, and structuring to avoid detection — all support enhancement	Affirmed: no clear error. Offshore account and other laundering tactics justified the sophistication enhancement

United States v. Fish, 731 F.3d 277 (3d Cir. 2013) (Application Note 5 factors are illustrative, not exhaustive; supports upholding sophistication finding)
United States v. Miles, 360 F.3d 472 (5th Cir. 2004) (presence of an offshore account can support sophisticated laundering enhancement)
United States v. Charon, 442 F.3d 881 (5th Cir. 2006) (district court may consider defendant's broader conduct in applying enhancement)