On December 3rd, the Ninth Circuit addressed whether the U.S. Supreme Court's decision in U.S. v. Santos, which discussed money laundering under 18 U.S.C. § 1956, applies to a money laundering case brought under Section 1957. Defendant appealed his securities fraud related money laundering conviction under Section 1957, arguing that the government failed to prove that his money laundering transactions involved the profits of criminal activities, as required by U.S. v. Santos. Although the Ninth Circuit held that Santos applies to money laundering transactions under 18 U.S.C. § 1957, it nevertheless affirmed the conviction because defendant's money laundering and fraud offenses did not merge. U.S. v. Bush.