The government’s in personam claim for civil money laundering penalties against
Howard Lederer is premised on allegations that (1) Lederer participated in FTP’s fraud against its players; and (2) FTP operated in violation of IGBA. The government has failed to sufficiently plead either of these allegations, and the in personam claims against Lederer must be dismissed. The government has similarly failed to plead its First and Fourth in rem claims for relief against Lederer’s bank accounts, and those claims too must be dismissed.
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