Publications

Money Judgments in Criminal Forfeiture

May 1, 2010
Business Crimes Bulletin

The Second Circuit has just become the latest Court of Appeals to uphold the imposition of money judgments in criminal forfeiture orders. The court sustained forfeiture money judgments of $10 million and $4.6 million against two indigent defendants, holding that the criminal forfeiture statutes permit "imposition of a money judgment on a defendant who possesses no assets at the time of sentencing." United States v. Awad, 598 F.3d 76, 78 (2d Cir. 2010). While Awad was a drug case, white-collar sentences also commonly include forfeiture money judgments.