United States v. Mordchai Fish, 2013 U.S. App. LEXIS 20000

Fish, a Brooklyn rabbi, was investigated for public corruption and money laundering with Solomon Dwek.
Dwek arranged about twelve money laundering transactions from 2008–2009 totaling over $900,000.
Transactions involved checks to gemachs and rabbis in exchange for cash, with a ~10% commission.
Fish concealed activities through SIM cards, coded language, frequent changes of devices, and multiple couriers/locations.
In April 2011, Fish pled guilty to conspiracy to commit money laundering; the plea anticipated a total offense level of at least 21.
At sentencing, the district court applied a two-level enhancement for sophisticated money laundering, resulting in a 46-month sentence; Fish appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court properly applied the sophisticated money laundering enhancement.	Fish argues the scheme lacked complexity; AN5 factors not required.	U.S. asserts standard clear-error review and that the facts show sophistication.	Affirmed; district court’s finding supported by record.

United States v. Richards, 674 F.3d 215 (3d Cir. 2012) (review under clear-error standard for guideline application)
United States v. Pizano, 421 F.3d 707 (8th Cir. 2005) (de novo review used in some circuits)
United States v. Miles, 360 F.3d 472 (5th Cir. 2004) (affirming enhancement when two or more levels of transactions involved)
United States v. Fernandez, 559 F.3d 303 (5th Cir. 2009) (affirming application of enhancement based on misconduct like layering or shell entities)
United States v. Chon, 713 F.3d 812 (5th Cir. 2013) (approving sophistication finding beyond AN5 factors)