The National Law Review in the US on 1st October carried an article about a recent court case in Virginia – United States v. Millender. This involved a seemingly straightforward alleged fraud and money laundering scheme reminds us that money laundering charges still require the government to establish elements which can be difficult to prove, including, importantly, specific intent. The case involved an alleged investment fraud scheme charged against a husband and wife and their associate – Terry and Brenda Millender, the founder and pastor of the “First Lady” of the Victorious Life Church. Despite jury guilty verdicts, the court found at least as to some counts that there was insufficient evidence as a matter of law of knowledge and specific intent. The court overturned the wife’s conspiracy to commit wire fraud and money laundering because “the evidence was insufficient to establish that she knew the funds involved in the . . . transactions represented the proceeds from some form of unlawful activity”, hence lacking the mental intent (mens rea) for conviction.